Pubgalaxy Website Privacy Notice

We at Azerion Technology B.V. (“Pubgalaxy”, “we”, “us” or “our”) respect your privacy and recognise the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. your personal data. “Personal data” is any information that relates – directly or indirectly – to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data.

The purpose of this privacy notice (“Privacy Notice”) is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you, “Personal Data”) when you use our website including our platform (“Website”) which helps our clients to monetize their advertising spaces. This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing.

This Privacy Notice applies whenever you create an account on our Website or use any of our other services, all of which together we refer to as “Services”.

GENERAL INFORMATION

In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you use our Services. For specific information with more details about our processing activities, please see the service specific information below.

Who is responsible for the processing of your Personal Data

Azerion Technology B.V. Boeing Avenue 30, 1119PE Schiphol-Rijk, the Netherlands, is responsible (“the data controller”) for the processing of your Personal Data related to the use of our Services by you.

What types of Personal Data do we process and how do we collect it?

When you use our Services, as further explained below, we collect, use, store and transfer different kinds of Personal Data. As a general principle, we do not collect and do not ask you to provide any “special categories of Personal Data”, which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation.

The information we collect depends on which of our Services you use and how you use them. We process the following types of your Personal Data:

2.1 Personal Data provided by you

When you use our Platform as Publisher, you provide or be asked to give us certain information, including:

Account information: When you create and use an account, we collect your log-in data (your name, your email address, username, password, phone number, date of birth, address)
Your Company Information: When you choose to create an account, we collect information about your company name and position
Your Billing Information: We collect your (if you are a Publisher) billing information payment type, currency, depositor detail (company name, your name and surname if you are private person), street and house number street name and house number, postal code, city and country), bank details (bank name, account number/IBAN, swift code, bank address) in order to make you payment, VAT number
Information provided in relation to our customer service: When you contact support via our Website through the email addresses provided on the contact us page we collect information about your request (subject and content of your request) and your name and contact details.

2.2 Personal Data we receive or generate from your use of our Services

In certain scenarios, we will also obtain your Personal Data from third parties, in strict compliance with applicable data protection laws and regulations. Your Personal Data be provided by the following third parties:

Your Consent String: When you visit our Website, we will process your consent string via our consent management platform which shall provide us your preferences on our processing activity.
Technical information: We collect information about your device/device settings you use for the purposes described below. The information we obtain from your devices includes the type of your browser or device, online identifiers (your IP address), and/or imprecise location as derived from IP address), browser settings, screen resolution and other technical information.
Content information: We collect information about activity on Digital Property visited, such as pages loaded, or links clicked.
Cookie data: As further described in our Cookie Notice (“Cookie Notice”), we use cookies and similar technology such as pixels, or local storage and allow third parties to use cookies and similar technology for the purposes described below. The exact process of placing cookies, and the scope of the data that may subsequently be processed is set out in our Cookie Notice.
Your revenue share information: As further explained, we also have access to your revenue share information, generated from the ad monetization activities operated by us.

Do we collect data from minors?

We do not intentionally collect and/or categorize personal information from children. In the event that we learn that we have collected personal data from a user under 16 years of age within the scope of the Services explained in this Privacy Notice, we will delete that data as quickly as possible. If you believe that a user might be under the age of 16, please contact our support team.

For what purpose do we process your data?

Depending on which Services you are using and which privacy settings you have selected, we process your Personal Data for the following purposes:

Provision and improvement of our Services

to allow you to use our Services
to allow Publishers to use our Services and to integrate with third parties (e.g., SSPs)
to gain insights into the popularity of our Services
to assess the quality of our Services
to analyze the performance of our Services
to pay our business partners for the promotion of our Services
to provide customer support based on your questions, requests, or complaints

Marketing and analytics

to understand usage of our Services across all our group companies to support strategy and growth
to share newsletter, marketing materials, surveys

Compliance with our legal or regulatory obligations

to determine the legal requirements for processing of your Personal Data (based on your location such as your country)
to respond to your requests related to your data subject rights
to comply with our legal obligations (e.g., tax and accounting obligations)
to inform you about any changes to this Privacy Notice

Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data.

On which legal basis do we process your Personal Data?

We process your Personal Data for the purposes described in this Privacy Notice, based on the following legal grounds:

Your consent: We process your Personal Data if you have provided your consent for a specific purpose. For example, when you visit Digital Properties of Publishers using our technology or use our Services, your consent is asked for the data processing in the context of web analytics. You have the right to withdraw your consent at any time, for example by changing your privacy settings. Please note that this will not affect any processing carried out before you withdraw your consent.
Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations. for example, for tax and accounting purposes or legal disputes.

Performance of a contract: We process your Personal Data for the performance of a contract to which you are a party, for example, in the context of customer service or to make a payment or to provide reports.
Legitimate interests: We also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we process your Personal Data for the purpose of hosting of our Website which serves for our legitimate interest to provide information about our services on the web.

Please see for additional information the section with service specific information below.

With whom do we share your Personal Data?

We will not disclose your Personal Data to any party who is not authorised to process them. To manage our services, we will share your Personal Data internally with members of our responsible departments and technical support involved in the gaming process and in each case only if access to your Personal Data is necessary for the performance of their roles.

Moreover, and only when necessary to fulfil the purposes mentioned above, we disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our Services:

External service providers: We share your Personal Data with external service providers who perform services on our behalf, like IT services, hosting and content delivery services, analytics and video hosting service. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.
Law enforcement, government authorities or courts: We disclose your Personal Data in response to lawful requests to public authorities, including law enforcement, government authorities, or courts.
Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).

Please see the section with service specific information below for more information about the third parties we may share your data with. Furthermore, you can find the third parties your Personal Data may be shared with by clicking on the following link:

[Pubgalaxy Third Party Partners List]

Where will my Personal Data be processed?

In general, if you are accessing our Services from the European Union (EU) / the European Economic Area (EEA) your data is stored on servers within the EU / EEA. However, with regard to certain activities described in this Privacy Notice, your data may also be shared outside the EU / EEA. We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission’s standard data protection clauses (also known as Model Clauses) to provide safeguards for your Personal Data.

How do we protect your Personal Data

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.

How long do we store your Personal Data?

We will not retain your Personal Data longer than necessary to fulfil the purposes for which the data was collected or to fulfil our legal obligations or necessary for the establishment, exercise of defence of legal claims or resolving disputes. Afterwards, we will delete or anonymize your Personal Data. Please see <а href=”#service_specific_info”>below for information about how long we will retain your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available here.

What are your rights in respect of your Personal Data?

To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:

Access the Personal Data we hold about you, including information such as the source and categories of data, the processing purposes, the recipients (or categories thereof), and the respective retention period.
Request an update or correction of your Personal Data so that it is always accurate.
Receive your Personal Data in a structured, commonly used and machine-readable format, including the right to transfer your Personal Data to another data controller.
Request the deletion of your Personal Data if you believe that retention is no longer necessary for the purposes indicated above.
Restrict the processing of your Personal Data, for example, if you have contested the accuracy of your Personal Data, and for a period of time that is sufficient to allow us to verify its accuracy.
Withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the lawfulness of data processing based on consent granted prior to its withdrawal.
Object to the processing on specific grounds relating to your particular situation, in the event and to the extent that we process your Personal Data based on our legitimate interests. In such cases we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. You also have the right to object where we are processing your Personal Data for direct marketing purposes (including profiling). In such a case, we will stop processing your Personal Data for marketing purposes.

You can exercise these rights by sending a request to the contact details set out below, providing your name, your email address as well as a description of your request. If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example, the Autoriteit Persoonsgegevens in the Netherlands.

How can you contact us?

If you have any queries about this Privacy Notice or how we use your Personal Data, please contact us via our Website or our Data Protection Officer via e-mail to dpo@azerion.com.

How often do we update this Privacy Notice?

We regularly review and update this Privacy Notice. When there is an important change that will have a relevant impact on the processing of your Personal Data, we will inform you by email if we have your email address. If we do not have your email address, for example because you did not create an account, we will inform you with a banner on our Website.

This Privacy Notice was last updated on: 26/05/2023

Additional Information for California Residents

This section for California residents supplements the information provided in this Privacy Notice and applies solely to players, and others who reside in the State of California. We provide this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and the regulations issued under it; accordingly, this section addresses the specific requirements of the CCPA and should be read together with this Privacy Notice.

We do not sell your Personal Data. However, we may share or provide access to each of the categories of Personal Data we collect as necessary for our business purposes. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, we have collected the following categories of personal information (envisaged by the CCPA) from consumers within the last twelve (12) months:

Category A – Identifiers (such as your device identifier, demographic information -such as your country, your username, email address, any information you may choose to provide -such as your age or your language-)

Category B- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Category D – Commercial information (such as purchase history)

Category F – Internet or other similar network activity (such as your interaction with our ads, your IP address)

Category G – Geolocation data

Category H – Audio, electronic, visual, thermal, olfactory, or similar information.

The CCPA provides consumers (California residents) with specific rights regarding their personal information.

You have the right to access specific information i.e. you may request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.

You have the right to know. Under the CCPA you have the right to request that we disclose to you what Personal Data we process about you.

You have the right to deletion which means that you may request that we delete any of your personal information we collected from you and retained, subject to certain exceptions.

Under the CCPA, you have the right to opt out of any sale of your personal data. Please note that your right to opt out does not apply to our sharing of personal data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal data only for that function.

Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.

You can exercise these rights by sending a request to the contact details set out above, providing your name, your email address as well as a description of your request.

Additional Information for Brazil Residents

Under the Brazilian General Data Protection Law (the “LGPD”), you have the right to access, rectify, port, erase, and confirm that we process your data. If you have given consent about processing your data, you have the right to withdraw consent anytime.

SERVICE SPECIFIC INFORMATION

In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed. For general information about data processes that apply, please see above.

Creation/Administration of your account

In order to use our Services, you have to create an account. We store your account data (log-in credentials, first-last name, email address and password (encrypted)) to allow you to log in on different devices, based on the performance of a contract. Your account data will be stored for as long as your account exists. You can delete your account at any time by submitting a deletion request to our support team or by contacting our Data Protection Officer.

Hosting

Pubgalaxy is hosted and uses Amazon Web Services to provide its Services to its clients. All the above mentioned data is being stored in Amazon Web Services. We process this data on the basis of our legitimate interest, to provide and improve our service and ensure its functionality.

Customer service

If you contact us for customer support by using our email address, we will process your email address, and the content of your request in order to provide you with support. The request history helps us to solve a newer request and is stored to defend possible future legal claims. We process this data on the basis of performance of contract to provide you with customer support and store this data on the basis of our legitimate interest, to improve our services, and to be able to defend possible future legal claims.

Payments (billing and invoicing)

We process your billing and invoicing information in order to make you payments of your revenue share from our monetization services. We process this data on the basis of performance of contract to provide you our Services.