Privacy Policy

NewMedia SA., together with its affiliates (“NewMedia”, “we”, “us”, or “our”) recognizes the importance of privacy and is committed to providing transparency and control over the use of the data in online advertising. This privacy policy details NewMedia data practices on how we collect, use, process and share the data we may collect through our advertising services (collectively, the “Services”) as well as the ways in which individuals may exercise control over the use of information collected by us.

This privacy policy does not describe NewMedia data practices relating to information NewMedia collects through its website www.newmedia.az, and only pertains to NewMedia Services. Your use of the Services is also governed by the Terms of Use. As used herein, “personal data” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular NewMedia customer or consumer or his or her household.

The Privacy Policy focuses on specific regulations such as GDPR in Europe and CCPA in California (USA). However, NewMedia is committed to offering you the best privacy protection. Therefore opt-out mechanisms provided herein are accessible to any data subject that intends to benefit from these mechanisms. Please note that we may update or change this privacy policy. If we make any material changes we will notify you by means of a notice on our website prior to the change becoming effective.

We do not collect or process information related to (i) name, user address, place of work, date of birth, email address, or phone number, (ii) hardware-based identifiers such as UDID or MAC Address or (iii) sensitive targeting categories as defined by the European Interactive Digital Advertising Alliance (EDAA) in the European Economic Area (EEA) and under other applicable law (e.g. religion, political opinion, health). In order to deliver personalized ads as well as non-personalized ads, NewMedia uses the following 3 methods to identify users depending on the device they use, whether they access our Services on web or mobile, and operating system:

A. Cookie-based identification

NewMedia drops a cookie on the user web and/or mobile browser. Cookies are alphanumeric identifiers that are created on your device through your web browser for record-keeping purposes. Cookies are used to identify a user and store a randomly generated identifier to identify his or her browser across visits.

B. Cookie-less environments

NewMedia drops a cookie on the user web and/or mobile browser. Cookies are alphanumeric identifiers that are created on your device through your web browser for record-keeping purposes. Cookies are used to identify a user and store a randomly generated identifier to identify his or her browser across visits.

C. Advertising ID

NewMedia uses its software development kit (“SDK”) technology to identify your advertising ID for mobile applications. For the Google Android operating system, we use the Google Advertising ID and for Apple iOS the IDFA.

We do not collect information about you directly, but we collect data through our web tags on publisher web pages, or through our SDK within publisher mobile apps. We also automatically collect the information listed below about your use of our Services through tracking technologies such as cookies, pixel tags, beacons, and embedded scripts. These tools help us collect and measure session information, time spent on certain pages, and page interaction information.

Automatically collected information

Identifiers: Cookies ID, IP address, advertising ID for in-app.

Internet or other electronic network activity information:

• Page URL
• Browser information (e.g. browser name and version)
• Device information (e.g. device type, OS)
• Network carrier information (e.g. Wi-Fi, 4G or wired connection)
• Mobile application information (e.g. application name or IDFA)
• User interactions with NewMedia ads

Geological information:

• Non-precise geolocation data: On web and web mobile, we collect non-precise location information at the country and/or city level that is derived from the user IP address.
• Precise geolocation data: On mobile apps, when a user opts-in for geo location on the publisher's app, precise user geolocation (latitude / longitude) might be transferred to NewMedia SDK by the mobile app, but this data is neither stored nor used by NewMedia.

Information we infer

We may derive information or draw inferences from you based on the information we or our partners collect. For example, we may use data drawn from trusted providers in order to infer general users' interests (e.g. socio-demographic, brand affinity) and improve advertising relevance for users.

We use the information we collect for various business and commercial purposes, including those described below:

• Target advertising: We use the data to filter ad delivery according to the user profile, such as their interests, location, device used or page content;
• User frequency capping: We use data to prevent displaying the same ad to the same user too many times;
• Analyzing traffic and user interactions: We use data for monitoring and reporting the campaign delivery for advertisers and publishers and for internal business analysis;
• Delivering ads: We may transmit part of the user profile to programmatic buyers so that they can deliver their advertising campaigns;
• Providing, maintaining, and improving our Services: We use data to improve our Services and technology, including training our ad delivery algorithms;
• Cross device experience: We use data to provide a consolidated experience through a user's different device or browser environments, and we may link the NewMedia identifiers on the different browsers and environments the user is using;
• Providing customer service: We may use data to resolve disputes, feedback, or other issues related to our Services;
• Debugging, identifying, and repairing errors: We may use data to fix issues that impair the functionality of our Services;
• Protecting the rights and property of NewMedia and complying with law: We may use data to protect our rights and property and comply with our legal obligations, including to detect, investigate, and prevent fraud and other illegal activities and to enforce our agreements;
• Carry out certain short-term activities: We may use data for other short-term, reasonable internal purposes related to our Services or your ongoing relationship with us;
• Insights: We may use the data to deliver aggregated insights, at advertising campaign or market levels.

Data shared with third parties

In order to provide the Services, we need to share data (including personal information) with third party vendors, service providers, contractors or agents who perform functions on our behalf, including the ones listed below. Our service providers are authorized to use the information we provide only as necessary to provide these services to us.

• Programmatic buyers. We may send part of the user profile to programmatic buyers using demand side platforms who buy our ad placements through programmatic ad auctions. Those companies are responsible as independent controllers of the data used to deliver their ads on the NewMedia network.
• Viewability measurement. We transmit data to companies specialized in campaign measurement such as MOAT or IAS in order to verify that our ads are viewable.
• Fraud detection. We transmit data to companies such as DoubleVerify in order to prevent delivering our ads on fraudulent traffic, such as non-human traffic.
• Geo-location. We transmit the IP address of the user to buy-side partners that may use it to derive non-precise geolocation.
• Analytics and audience measurement. We transmit data to companies such as Nielsen, ComScore or Mediametrie in order to validate the accuracy of our targeting or measure the demographic reach of our network.
• Affiliates. We may disclose the information we collect through the Services to our affiliates or subsidiaries for the purposes described in this privacy policy; however, if we do so, their use and disclosure of your personal information will be subject to this privacy policy.
• Hosting. We utilize third party hosting and data-center providers to store data.
• Compliance with Google API Services User Data Policy. Our application's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Other disclosures

We also may disclose information in the following circumstances.

• Business transfers. If we are or may be acquired by or merged with another company, if any of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
• In response to legal process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal processes, such as in response to a court order or a subpoena.
• To protect us and others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which NewMedia is involved.
• Aggregate and de-identified information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.

Legal basis for processing

When we process your personal data, we will do so, e.g., in the following situations:

• We have obtained your valid consent prior to placing cookies and/or processing personal data.
• We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the products or services you have requested).
• We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to our products and Services, and to provide, secure, and improve our products and Services.
• We find such processing is necessary to comply with our legal obligations.

Data subject requests

You have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us as indicated below.

• We retain the data linked to a user up to 12 months from the date of collection.
• We may also store aggregated and non-personal data for a longer period than 12 months for financial and statistical reasons.
• For security reasons, the user's IP address is stored in a private security log for a period of 4 months.
• The NewMedia cookie is kept up to 365 days after the last user interaction with our services.
• NewMedia uses generally accepted industry security standards to protect data.

Your personal information will be retained in accordance with our data retention policy which is designed to retain data for as long as needed for us to comply with our contractual obligations, employment obligations, and other business purposes, including global legal obligations to retain data. We may retain some information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze or troubleshoot programs, enforce our Terms of Use, or take other actions permitted by law.

We have implemented reasonable security measures to protect the information we collect from unauthorized access, exfiltration, theft, loss, misuse, disclosure, alteration, or destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

NewMedia is based in the United States and we process and store information throughout the United States, Europe and Asia. NewMedia ensures it uses an appropriate safeguard mechanism when required.

This privacy policy only addresses the use and disclosure of information and data by NewMedia. Publishers, advertisers and other websites that may be accessible through our Services have their own privacy policies and practices that govern the collection, use, and disclosure of your personal information when you interact with their services and use their products. We encourage you to familiarize yourself with the privacy policies provided by all third parties prior to giving them information or taking advantage of an offer or promotion.

You may request that NewMedia delete the personal information it has collected and/or maintained about you. To do so, please email us at [email protected]. Note, we may need to retain certain personal information as permitted by law, such as to complete the transaction for which the personal information was collected, provide a requested good or service, detect security incidents, protect against malicious, deceptive, fraudulent or illegal activities, comply with legal obligations or to enable solely internal uses that are reasonably aligned with your expectations or lawful within the context in which you provided the information.

Verification

Please note, we will take steps to verify your identity before fulfilling any consumer request. If you maintain an account with us, we will verify your identity through existing authentication practices for the account (e.g., login and password). If you are not a registered member, we will verify your identity by matching two or three data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification (e.g., browser and device ID).

Authorized agents

You can use an authorized agent to make such requests on your behalf. But we may require the agent to provide a written permission and verify his/her identity or demonstrate that he or she has power of attorney.

Anti-discrimination right

You have the right to be free from discrimination in product quality, goods or services if you choose to exercise your privacy rights under the CCPA.

Do Not Track signals

Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we stop running targeted advertising when we receive a “do not track” signal. For information about Do Not Track, visit www.allaboutdnt.org.

If you do not want us to show you personalized ads (based on your inferred interests) please follow the below instructions:

To opt-out from your web browser on any device

If you opt-out, you will still see ads, including contextually tailored ads (i.e., ads tailored to the current website or app you are viewing) and ads based on your current location; they just may not be relevant to your interests.

The opt-out mechanism will only opt you out of personalized advertising delivered by NewMedia in this browser or in mobile applications on this device (e.g., phones, tablets). It will not opt you out on other devices or in other browsers you use.

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. Opt-out information is stored in a cookie for 5 years. If you delete your cookies, this information will also be deleted, and you will need to renew your opt-out choices.

For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.youronlinechoices.com, www.aboutads.info/choices, and other similar sites.

To opt-out from an in-app environment

If you opt-out, you will still see ads, including contextually tailored ads (i.e., ads tailored to the current website or app you are viewing) and ads based on your current location, they just may not be relevant to your interests.

If you want to disable NewMedia personalized ads, please refer to your operating system settings.

Mobile device system software provides mechanisms that allow users to opt-out of the use of information about their usage of mobile apps to deliver targeted ads to their mobile device. For more information, or to opt-out using these mechanisms, consult your device settings (e.g. “Opt-out of Interest-Based Ads” on Android devices and “Limit Ad Tracking” on iOS devices).

Please note that this is a device setting which will disable personalized ads from all providers, and not just for NewMedia. If your device's advertising identifier is reset, you will need to renew your opt-out choice for that device.

Our Services are not directed to children under the age of sixteen (16) in the United States or children under the age of legal majority in jurisdictions outside the United States, nor do we market products or services to such children.

For any questions about this privacy policy or our data practices, you can contact NewMedia:

• By email: [email protected]
• Address: Bayil Plaza, Qurban Abbasov 29, Baku, Azerbaijan, AZ1003