Privacy Policy

Theorenji.com and its subsidiaries (“we”, “us”, “our”) view privacy and the protection of personal data as an important element of the services we provide. We have prepared this Privacy Statement so that you can become familiar with how we collect, use and share information we receive and collect about you. We receive such information on you especially through our services and websites (collectively “Services”).

We may receive and process information about you as a customer of our Services, or as an end-user, when you visit our clients’ websites, mobile applications, media players or other properties. In so far as we process your personal data, European Union data protection law is applicable and Theorenji.com shall comply with requirements arising from this. We may change this Privacy Statement from time to time. Please check the Privacy Statement regularly for updates. For more information, please see “Nature of and Changes to the Privacy Statement” below.

What data we process on you:

1. Personal Data

With “personal data” we mean any information that may identify you or make you identifiable as an individual.

2. Personal Data on Clients and Website Visitors

The personal data we process may include, among others, the following information on our clients and (incidental) website visitors:

  • Company name;
  • Name;
  • Contact details (such as e-mail address, telephone number and address);
    Payment information (such as bank details);
  • Correspondence (such as emails);
  • Online-identifiers (such as cookie-ID’s); and
  • Other information on you relating to, or derived from the use and provision of the Services, and/or your customer relationship or other business with us.

We collect or receive personal data through, among others, Theorenji.com, our other websites, our analytics dashboard for publisher clients, our software applications, social pages, as well as email and other communication channels.

Additionally, we may receive personal data through our advertising Services and technologies used by our publisher clients and other third parties on their websites and other digital properties across the Internet. We may also update and supplement personal data with information provided by third parties in order to improve the Services.

3. Personal Data on Individuals who visit our Clients’ Properties

What is said above of processing personal data on our clients and website visitors may in some situations apply also to individuals who are shown advertising as a result of our technology when these end-users visit our clients’ websites, mobile applications, media players or other properties. We may process the following information on the end-user which, in a particular context, may be considered as personal data:

  • your IP-address;
  • a unique user ID;
  • browser type;
  • visited URL;
  • session ID; and
  • timestamp.

4. Usage Data

We may collect and process technical and log data such as information sent by your browser when you are visiting our websites or those of our clients. Although technical data does not necessarily aim to recognize you, due to its contents, in practice, you can sometimes be recognized from it. In such situations, these data can also be seen as personal data.

When you use or access our Services or third-party sites, or properties using the Services, we may collect, among others, the following data: the URL of the site from which you came, the pages visited, the site to which you are going, Internet protocol (IP) address of the device you use, the device type, time of webpage visit, webpages visited, time spent on each webpage of the website, and the type of operating system used in the devices used to access the Services, type and version of your browser, date and time an ad was served, clicks on ads, and other traffic data.

We may collect this information in a variety of ways including through your browser or device, mobile advertiser identifier and your IP address. We may also use cookies and other tools, such as pixel tags, web beacons, and other local shared objects, for automatic data collection. To improve readability all these identifying techniques will hereinafter be called ‘cookies’.

We may use third-party service providers, such as Google Analytics, to collect and process technical data on our behalf.

5. Cookies

Cookies are pieces of information stored directly on the computer that you are using. Although cookies are a commonly used technology, they vary significantly by features and use. You may control the use of cookies by changing your browser settings and the setting of other programs that use cookies (e.g. the settings of your Adobe Flash Player). For more information about cookies generally, including how to see what cookies have been set on your device and how to control and delete them, visit www.allaboutcookies.org  and www.youronlinechoices.eu.

When you visit our website for the first time, a banner will pop up in which we explain why we use cookies. By clicking on ‘Agree’ you will consent with the use of cookies as described in this Privacy Statement. We use the following cookies:

Technical Or Analytical Cookies
We use cookies to gain insight into the use of our website, and to improve it on the basis of these insights and thereby increase the user-friendliness. The analytical cookies that we use for this purpose are:

  • Google Analytics
  • Google Tag Manager

Advertisement and Social Media Cookies
In addition we use advertising cookies to show personalized advertisements and content on our website, to give us insight into our campaign performance and to integrate with different social media platforms:

  • Doubleclick

6. Location Data

Theorenji.com may collect and process location data which may identify your current or past location. Such data is processed in order to provide and develop location-based Services and may include information such as your IP-based location or device-based location data. Such device-based data may rely on, for example, the location of Wi-Fi networks, GPS signals, or similar technologies.

When processing location data, Theorenji.com, or a company acting on our behalf, will always ask for your necessary consent and abide by it. It is possible to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

7. Why we Process Data About You

When it comes to the data we process about website visitors, we process data about you to get in touch with you, remember your website preferences and other purposes of cookies as stated above.

When it comes to the privacy data we process about clients, we process personal data especially in order to host, provide, maintain, develop and improve current and future Services and your customer relationship, as necessary from time to time. Such actions may include sending and directing marketing and other communication to you, and carrying out market research.

When it comes to the privacy data we process about end-users who visit our clients’ properties, we process data to be able to deliver our Services to our clients and to calculate payments for this and to monitor and improve the effectiveness of these Services (e.g. by keeping track of what advertisements are shown to a particular user).

Data processing may also be necessary to prevent and investigate fraud and other misuses.

In limited situations, we may process personal data about you for other purposes as well. Such processing may be necessary, for example, due to a legal obligation or public authority request; in order to protect our rights; or to allow us to pursue available remedies or limit sustainable damages or to provide you your requests.

The legal bases for data processing are your consent and in some cases necessary for the performance of a contract. We keep data only as long as necessary for us to fulfill the purposes described in this Privacy Statement. Once information is no longer necessary, we delete it as soon as possible unless there is a legal obligation to further retain certain data.

8. How We Disclose and Transfer Data About You

We may regularly disclose personal data about you among our subsidiaries and affiliates for the purposes described in this Privacy Statement. In such situations, Theorenji.com is the party responsible for the management of the personal information that we use jointly with our affiliates.

Theorenji.com may also disclose data to other third parties in limited situations. We do not disclose data to other third parties without careful consideration, and not without you being informed by us or a company acting on our behalf.

In addition to disclosing personal data, we may disclose pseudonymous data, and aggregated or other anonymous data to third parties, especially in the following situations:

  • To our publisher partners to allow them to analyze the effectiveness and performance of our Services and to offer targeted ad inventory to our advertiser clients; and
  • To our advertiser clients to allow them to make decisions regarding buying advertising inventory on our publisher clients’ websites and applications, and to analyze the effectiveness and performance of their advertising campaigns via our Services.

We may store and process your personal data in any country where we have facilities, employees, and/or service providers. Such countries may include the United States and other countries outside the European Union. We will ensure that any transfers of personal data to countries outside the European Union are subject to safeguards to ensure an adequate level of protection as required under European law.

9. Your Rights

As a data subject, you have the right to receive information on how we process data about you. Such information is provided in this Privacy Statement. In addition, you have the right to:

  • Right of Access: You can learn what personally identifiable data we hold about you. You may ask to learn about the followings, but not limited to the information as, recipients of data, including international data transfers, categories of personal data processed, locations where the personal data is being processed, retention periods, the source of personal data, whether there is use of automated decision making or profiling in place and the purpose of the processing, etc.
  • Right to Rectification: You can request from us to correct (rectify) or update, incomplete, incorrect, outdated, or unnecessary personal data. To do that, we may need information from you to identify you and complete your request.
  • Right to Data Portability: This is a new right provided by the General Data Protection Regulation (“GDPR”). This right allows you to obtain and reuse your data for your own purposes and across different services and can be used when there are certain cumulative conditions are in place.
  • Right to Erasure: You may request your personal data to be erased and therefore no longer processed when certain conditions are met.
  •  Right to Restriction: This right allows you to ask for storing your personal data without being further processed. This right provides an alternative route to the right to erasure in such circumstances where storing personal data is legally required.
  • Right to Object: You can object to the processing of personal data at any time for direct marketing or for statistical purposes.
  • Automated Processing: You can request not to be subject to a decision based solely on automated processing, including profiling unless there is an exception in place.

If you would like to use one of these rights, for example access or correct data on you, please contact us via the contact details below. You can also opt-out of marketing communications that you may receive from us, such as e-mail messages and SMS-messages, by using the unsubscribe function included in all of our marketing messages.

Please note that we will need sufficient information from you to establish your identity Usuallyexercising aforementioned rights are free of charge but if less than a year has passed since your last inquiry relating to accessing personal data we hold about you or if you ask for additional copies or ask for too detailed information that requires high level of analyzing on our end, we may charge you with reasonable administrative fee.

10. Opting Out of Behavioral Advertising of Our Clients

Theorenji.com and our clients may use behavioral elements in our Services, such as behavioral advertising to end-users, in order to provide more relevant services and content to you. Such customized content may be tailored to you based on information that is generated on you by combining previously collected data. To the extent this is done through the use of tracking cookies Theorenji.com or a company acting on its behalf will first ask your consent.

Some of our publisher clients have their own mechanisms to opt-out or withdraw your consent that is linked to their sites or their online-posted privacy policies. You should review the privacy policies of those companies for these opt-out links if you no longer wish to receive targeted advertising from a particular company or multiple companies.

11. Data Security

The security of personal data is important to us. We seek to use reasonable organizational, technical and administrative measures to protect your personal data within our organization and secure your personal data against unauthorized access, accidental or unlawful destruction, manipulation, disclosure and transfer, and other unlawful processing.

12. Third-Party Activities

This Privacy Statement applies only to personal data processing carried out by Theorenji. The Privacy Statement does not address and we are not responsible for, the privacy, data or other practices of any third parties, including our clients, advertisers, demand or supply-side providers, vendors or any other third party operating any site or service that you may encounter in connection to the Services.

We encourage you to carefully familiarize yourself with privacy policies applicable to any third party operated websites and/or services, including any third-party website containing our Services. If our Services (or a link to our Services) are included on a third party website it does not mean that we have given an endorsement of such site or service. Theorenji.com adheres to the IAB Europe Transparency & Consent Framework (and is an accredited Vendor with ID: 62).

13. Users from California, U.S.

The California Consumer Privacy Act (“CCPA”) will come into force as of January 1st, 2020. In general, the CCPA allows California residents to have the following rights;

  • Right to Know About Personal Information: You have the right to request from theorenji.com to disclose what personal information we collect, use, disclose and sell. We will provide you the categories of personal data we have about you and the source, purpose, name of the third parties whom we share the data with if any.
  • Right to Request Deletion of Personal Information: You have the right to request the deletion of your personal information collected or maintained by theorenji.com.com.
  • Right to Opt-Out of the Sale of Personal Information: You have the right to opt-out of the sale of your personal information by theorenji.com.
  • Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights: You have the right not to receive discriminatory treatment by theorenji.com for the exercise of the privacy rights conferred by CCPA.

We may ask some questions for verification purposes such as age and nationality. As a part of this process, government identification may be required.

You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government-issued identification.

14. Nature of and changes to the Privacy Statement

From time to time we may change this Privacy Statement. You can tell when changes have been made to the Privacy Statement by referring to the Last Updated legend on top of this page. Any changes to this Privacy Statement will become effective when we post the revised Privacy Statement on the Services.

15. Questions or Concerns

If you have any questions regarding this Privacy Statement or theorenji.com privacy practices, please contact us via the contact details below. If you have any complaints, please contact us as well. You also have the right to register a complaint with a supervisory authority. You can contact the Dutch supervisory authority.

Contact details

If you want to get in touch with us, please contact us via e-mail at [email protected]