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Legal

Privacy Policy.

Contents

  1. Introduction
  2. Our Business
  3. Legal Basis
  4. Data Sources
  5. Transfer of data to third countries
  6. Retention period
  7. Data protection
  8. Cookies
  9. Opt-out
  10. Web analytics
  11. Third-party services
  12. Data subject rights
  13. Requirement or obligation to provide data
  14. Changes to the Privacy Policy
  15. Questions and concerns

Introduction

Waldenoy SA (“Lemmonet”, “we”, “us”, “our”) provides digital advertising services. This Privacy Statement is provided to help you understand how Lemmonet processes personal data on behalf of the clients who use our services. It does not set out the practices or policies of our clients, of the apps in which the ads are displayed, or of any other party. Lemmonet and our clients care about how personal data is collected, used and shared. We are a “data sub-processor” that collects and analyzes personal data at the specific request of our clients (data controllers), through third-party Mobile Measurement Platforms that act as “data processors”. Lemmonet also works with Programmatic Ad Exchanges that act as “data controllers”. In this scenario, we are “data processors” (and “joint data controllers” in some specific cases). This means that we securely collect and transmit data to be used for attribution to third-party Mobile Measurement Platforms. As set out in the Lemmonet Terms of Service, we work with approved social media platforms (for example, Facebook, Twitter, Instagram, TikTok, Snapchat, YouTube and Twitch). In this regard, Lemmonet fully complies with, and does not infringe, any of the terms of service and privacy policies of those approved social media platforms. Updated versions of the terms of service and privacy policies of the approved social media platforms can be found at the following URL links:

https://privacycenter.instagram.com/policy/

https://support.google.com/youtube/answer/7671399?hl=en&p=privacy_guidelines

https://www.tiktok.com/legal/page/row/privacy-policy/en

01 Our Business

Lemmonet technology powers the ads that may appear on websites and in apps on mobile phones or other devices connected to the mobile internet. It may interact directly with our servers (for example, when clicking on an ad) or indirectly through the mobile website or app that displays the ads.

02 Legal Basis

Your data is handled in accordance with the following legal provisions:

  • with regard to data provided in forms, etc., with your consent, Art. 6(1)(a) GDPR;
  • with regard to the services you use, for the performance of a contract, Art. 6(1)(b) GDPR;
  • otherwise, with particular attention to statistical data and online identifiers, based on legitimate interests, Art. 6(1)(f) GDPR (see below).

Legitimate Interests

When handling your data, we pursue the following legitimate interests:

  • Improving our service
  • Protecting against misuse
  • Statistics
  • Protection against advertising fraud

03 Data Sources

Unless otherwise specified, we receive data through third parties, collected through devices used by app users.

04 Transfer of data to third countries

To process and store the data we collect, this data is sometimes transferred to countries outside the European Union. This is done on the basis of contractual regulations stipulated by law that ensure adequate protection of your data and that are available for you to view upon request.

05 Retention period

We retain app users' data: if app users have consented to this, until they withdraw that consent; if we need the data to enter into an agreement, until the contractual relationship with the app user ends or the legal retention periods expire; if we use the data on the basis of a legitimate interest, until the overriding interest of the app user requires us to delete or anonymize it.

Purposes of use

Personal data will only be collected and processed by Lemmonet to the extent and for the purpose 1) for which it was provided by the Data Controller or, 2) in cases where we act as a “Joint Data Controller”, stated in written contracts with our partners, with the explicit consent of the Data Subject.

We use and store your personal data as part of our services for the following purposes, only if you have given us your express consent:

We use this information to help deliver more interesting and relevant ads to app users, and to provide our clients and partners with reports containing aggregated data (for example: the number of clicks on those ads, etc.). These reports are used to analyze trends and to perform fraud detection.

We use your personal information only in aggregated form and only within the company's systems, and we send it only to those companies that are involved in fulfilling the contracts entered into with you or are otherwise involved in providing the relevant service. Otherwise, your personal information will not be transferred to third parties, unless you have given your express consent to this or unless we are obliged to disclose it, for example, by order of a court or administrative authority.

We only transfer the following personal data to third parties: device identifier, IP address, user agent, location.

06 Data protection

We have taken extensive technical and organizational measures to protect your data against potential risks, such as unauthorized login or access, unauthorized reading, modification or distribution, as well as against loss, deletion or misuse.

To protect your personal data against unauthorized access by third parties during transmission, we secure data transmissions, where necessary, using SSL encryption.

This is a standard encryption procedure for online services, particularly for the internet.

07 Cookies

Cookies are small files that your browser stores on your PC in a directory designated specifically for this purpose. These cookies can be used, for example, to find out whether you have already visited a website. Most browsers accept cookies automatically.

However, you can change the settings in your browser so that cookies cannot be stored or so that your explicit agreement is required before cookies are stored. You can also delete previously set cookies at any time. Please note that disabling cookies may restrict your use of our website.

We use cookies only for the following purposes:

  • Tracking conversions and the performance of advertising campaigns. Cookies are set when the user clicks on the banners and not before.
  • Authentication and user tracking on "connect.lemmonet.com" and “contentcreators.lemmonet.com”.

08 Opt-out

If you wish to block these cookies, you will need to change the relevant settings on your mobile device. Some, but not all, mobile platforms allow you to manage settings specifically for the Lemmonet.com domain; on others you can only control cookies globally. The details on how to do this vary depending on your mobile device's operating system and browser, but common cases can be addressed as follows:

iOS

  1. From your device's home screen, select the “Settings” icon
  2. Select 'Safari' from the list
  3. To adjust the cookie settings, tap 'Accept cookies'
  4. Choose "Never", "From visited" or "Always"

Android

  1. Open the browser app
  2. Press the 'Menu' button
  3. From the options displayed, select the 'More' option
  4. Select the 'Settings' function from the browser's list of functions
  5. Scroll down to the 'Accept cookies' option. If the box is checked, uncheck it to disable cookies; if the box is not checked, select it to enable cookies.

09 Web analytics

Like almost all website operators, we use analytical tools in the form of tracking software to determine the number of users who use our website and how often they visit it.

To allow us to optimize our website and our service, we use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses what are known as “cookies”: text files stored on your computer and used to analyze your use of the website. The information generated by the cookie about your use of this website (including your IP address) will be sent to a Google server in the US and stored there. However, if IP anonymization is enabled on this website, within the member states of the European Union, or in other states that are party to the Agreement on the European Economic Area, Google will first truncate your IP address.

The full IP address will only be transmitted to one of Google's servers in the US in exceptional circumstances, where it will then be truncated. Google will use this information on behalf of the operator of our website to analyze your use of the website, to compile reports on website activity for the website operator, and to provide other services relating to website use and internet use. The IP address transmitted by your browser as part of Google Analytics will not be merged or combined with other data by Google. You can prevent cookies from being stored by applying the appropriate settings in your browser software; however, please note that in this case you may not be able to use all the functions of this website to their full extent.

You can also prevent Google from collecting data generated by the cookie in relation to your use of the website (including your IP address) and from processing this data by downloading and installing the browser add-on available at the following link https://tools.google.com/dlpage/gaoptout?hl=en.

As an alternative to the browser add-on, or within browsers on mobile devices, click this link to prevent Google Analytics from collecting data on this website in the future (the opt-out only works in this browser and only for this domain). This stores an opt-out cookie on your device. If you delete your cookies in this browser, you will need to click this link again. More information is available at https://tools.google.com/dlpage/gaoptout?hl=en or at www.google.com/intl/en/analytics/privacyoverview.html (general information on Google Analytics and data protection).

10 Third-party services

We use third-party services for various functions on our website.

If you complete the contact form on this website, the data you enter (name, work email, company and message) is sent through Web3Forms (web3forms.com), a third-party service that processes it in order to deliver it to Lemmonet by email. We use this data only to respond to your inquiry.

11 Data subject rights

Right of access, rectification, objection, complaint, deletion and blocking.

You have the right to request information about whether and what personal data our company processes about you. You also have the right to require that your personal data be rectified or modified.

In certain circumstances, you have the right to request that your personal data be deleted.

In certain circumstances, you have the right to require that the processing of your personal data be restricted.

You may withdraw your consent to the processing and use of your data, in whole or in part, at any time with future effect.

You have the right to obtain your personal data in a common, structured and machine-readable format.

If you have any questions, comments, complaints or requests relating to our data protection statement and the processing of your personal data, you may also contact our data protection officer using the details provided.

You also have the right to lodge a complaint with the competent supervisory authority if you believe that the processing of your personal data violates the law.

12 Requirement or obligation to provide data

Unless expressly stated otherwise, when data is collected, providing that data is neither required nor mandatory.

13 Changes to the Privacy Policy

Lemmonet is committed to continuously reviewing and revising its privacy practices, and may make changes to its Privacy Policy. If significant changes are made, the Privacy Policy on this website will be updated.

14 Questions and concerns

If you have any questions or concerns about our privacy practices, you can contact us:

Waldenoy SA

Costa Rica 1685, Uruguay CP 11500

Email: privacypolicy@lemmonet.com

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