We recognize privacy is important to our users. This policy describes how and why Market Tactic Media Ltd., collects non-personally identifiable data (anonymous data) from users and website visitors, publishers and end-users of publisher sites to Market Tactic Media Ltd. (http://www.tomorrowinvestor.com), and how that data will be used. Market Tactic Media Ltd. is committed to respecting the privacy of non-personal identifiable data and anonymous user data gathered.
Information We Collect
Anonymous User Information (Data)
Non-personal information is any information that does not personally identify you. We obtain non-personal information about you from the information that you provide to us (anonymous information may be automatically provided to our Web servers by your computer). This information is collected when Publishers, advertisers, and ad networks use the Market Tactic Media Ltd. Platform.
Additionally, certain other information (such as cookies, described below) may be transmitted by our Web server to your computer. That information does not contain any personally identifiable information. Specific types of anonymous information are described below:
As part of our ad delivery and reporting, we log page views and collect information for the purpose of delivering ads or providing advertising-related services, including providing a specific advertisement based on a particular type of browser or time of day; statistical reporting in connection with the activity on a Web site; and tracking the number of ads served on a particular day to a particular Web site(tracking web analytics data). To do so, we collect information about the type of browser, referrer and operating system of Web site visitors, as well as the domain name, day and time of visit, and page(s) visited. We do so across multiple Web domains owned or operated by different entities (each, a “Site”).
Cookies and Log Files
If you are concerned about cookies, most browsers permit individuals to decline cookies.
In order to properly manage our website we may anonymously log information on our systems, and identify categories of visitors by items such as domains and browser types. These statistics are used to manage the operational efficiency of our systems.
How We Use Information Collected
Market Tactic Media Ltd. uses non-personally identifiable data collected from users and website visitors in order to:
- To improve the quality and functionality of the website, enhance your experience, create new services (including customized services), change/cancel existing content and services, or for other internal and statistical purposes.
- To present you relevant content, marketing materials and advertisements, by analyzing your interests from the web pages you visit and online services that you use.
- To provide you with support and handle inquires
- To comply with any applicable law and assist law enforcement agencies as required.
- To conduct surveys and market research.
We may also use anonymous, statistical or aggregated information about the website’s use and share, publish, post, disseminate, transmit or otherwise communicate or make available such information, to suppliers, business partners, sponsors, affiliates and any other third party, at our sole discretion
With respect to data collected via the Market Tactic Media Ltd.’s platform and websites, we may combine Non-Personal Information with data collected from other sources and disclose the Non-Personal Information and combined information to participating advertisers and ad networks so that they can determine whether to bid on ad inventory and in order to improve the relevance of the advertising presented to Users. Examples of such data include: (a) country, city, and other geo-location details based upon the IP address of the User; (b) category and keyword information based upon the Publisher website URL; and (c) other data from advertisers and data providers that would help in ad targeting (e.g., an advertiser that wants to advertise to users who have previously visited the advertiser’s website).
How we protect the Collected Information
Information that we collect is stored on servers that Market Tactic Media Ltd. solely manages, using standard security procedures and practices appropriate to the nature of the information in an effort to protect information from unauthorized access, destruction, use, modification, or disclosure. If we learn that we have unexpectedly stored personal information (e.g., if we become aware that a URL that we store contains personal information), we will use commercially reasonable efforts to anonymize or purge this information.
How we share the Collected Information
We share personal information with third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt-out of those sales. The categories of third parties to whom we disclose your personal information may include our subsidiaries and related companies, our service providers, business partners and channel partners, third party investors relations firms, marketing and business strategy partners and providers, ad networks and advertising partners, analytics providers, sweepstakes and contest providers, order fulfillment and payment providers and certain third parties where you have provided consent or where we are required by law.
Third Parties Providing Functionality:
We also work with third parties to provide certain functionalities on the Services and to improve the effectiveness of the Services and its content. Separate and distinct from information Market Tactic Media Ltd. shares with third parties, third party companies may also use Tracking Technologies to independently collect and store information about you and your usage of the Services and may combine this information with information they collect from other sources. Please note, we do not control Tracking Technologies used by third parties, and their use of such Tracking Technologies may be governed by their own privacy policies.
If you access the Services through a device or app, we may share your information with mobile carriers, operating systems, and platforms.
We may partner with third-party advertising networks and exchanges to display advertising on our websites or to manage and serve our advertising on other sites and may share your personal information with them for this purpose. We may also send out promotional emails to third-party offers and may share your personal information with them for this purpose. Please see more information in Your Choices / How to Opt-Out in the section below.
With Your Consent or at Your Direction. As directed by you or with your consent we may share your information with a third-party.
Your Choices / How To Opt-Out
- Surveys Sent by Email: You may elect not to receive surveys conducted by Market Tactic Media Ltd. that are sent by email by using the opt-out link contained in such emails.
Use of Push Notifications
We use push notifications to send you periodic alerts when we publish important and/or sponsor-related news items to the website. When you first enter our website, you choose to approve or deny receiving push notifications. If you no longer wish to receive these notifications, you may opt-out by turning them off at the browser or mobile device level. We collect certain information about your device, such as operating system and user identification information, to ensure you receive proper notifications, to administer the health of our website, and in reporting capacities to our sponsors.
Changes to Policy
The EU General Data Protection Regulation (GDPR)
As of May 25, 2018, a new data privacy law known as the EU General Data Protection Regulation (or the “GDPR”) will be in effect through the EEA countries and Switzerland. The GDPR requires TomorrowInvestor and those using our services to provide users with certain information about the processing of their “Personal Data. “Personal Data” is a term used in Europe that means, generally, data that identifies or can identify a particular unique user or device – for instance, names, addresses, cookie identifiers, mobile device, precise location data and biometric data.
To comply with the GDPR, we provide the below representations and information, which are specific to persons located in EEA countries or Switzerland (so don’t rely on the below, if you’re not).
a. Legal grounds for processing your Personal Data
The GDPR requires us to tell you about the legal basis we’re relying on to process any Personal Data about you. The legal basis for us processing your Personal Data for the purposes set out above will typically be because:
- You provided your consent. In order to store and gain access to information stored on your device, we rely on your consent. For this so-called “cookie consent” (which applies not only to “cookies” but also to mobile ad identifiers), we rely on our own compliance steps and our web and mobile partners’ compliance steps, designed to ensure that consent is collected and passed on to partners, and to ensure that we only facilitate the collection of legally obtained data. We do this to fulfill our obligations under the ePrivacy Directive. We may choose to obtain consent in other cases as well, in which case we will adhere to applicable laws relating to such consent and its withdrawal.
- The processing is in our legitimate interest. In some cases, we use legitimate interest as a legal basis for processing Personal Data, in order to provide our and/or other data controllers’ services. Such processing goes beyond the original collection of mobile ad identifiers. A legitimate interest we rely on, for instance, is the tailoring of promotional communications to users of web and mobile properties, which is beneficial to users and is an integral part of the ecosystem by which freely available content is funded through advertising revenue. This also sometimes includes providing analysis of and reporting about ad campaigns, as well.
- We also rely on legitimate interest when we use Personal Data to maintain the security of our Services, such as to detect fraud or to ensure that bugs are detected and fixed.
- Contractual Relationships. Sometimes, we process certain data as necessary under a contractual relationship we have (such as our customer records and contact information);
- Legal Obligations. Finally, some processing of data may be necessary for us to comply with our legal or regulatory obligations.
b. Transfers of Personal Data
As TomorrowInvestor works with global companies and technologies, we may need to transfer your Personal Data outside of the country from which it was originally provided. For instance, we may transfer your data to third parties that we work with who may be located in jurisdictions outside the EEA or Switzerland, and which have no data protection laws or laws that are less strict compared with those in Europe.
When we transfer Personal Data outside of the EEA or Switzerland, we take steps to make sure that appropriate safeguards are in place to protect your Personal Data. Feel free to contact us at the contact information below, for more information about the safeguards we have put in place to protect your Personal Data and privacy rights in these circumstances.
c. Personal Data Retention
As a general matter, we retain your Personal Data for as long as necessary to provide our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. We generally render our own identifiers (e.g., those we use to “sync” our customers data to online users) inactive after 13 months, provided that we may retain them if we have a legal or significant operational need to do so, such as for auditing, corporate record-keeping, compliance accounting or security and bug-prevention purposes.
d. Your Rights as a Data Subject
The GDPR provides you with certain rights in respect of Personal Data that data controllers hold about you, including certain rights to access Personal Data, to request correction of the Personal Data, to request to restrict or delete Personal Data, and to object to our processing of your Personal Data (including profiling for online ad targeting).
- Right To Access: If you wish to exercise your right to access Personal Data we process as a data controller, you may do so by requesting access through the e-mail address support AT TomorrowInvestor DOT com. When we receive your request, we will provide you with current, step-by-step instructions to follow in order to obtain access. As we are required to verify a requestor’s identity prior to providing Personal Data, we will assess requests to exercise certain data access rights on a case-by-case basis: in doing so, we consider (a) the difficulty of verifying whether data that we hold and data we have linked to it truly and solely belongs to the data subject making the request, along with (b) the potential adverse affects on disclosure of personal data to the wrong individual. Because such improper disclosure would likely adversely affect the privacy rights and freedoms of the data subject, we may limit the Personal Data we make available.
- Please note that we will only grant requests submitted via email for Personal Data for which we are a data controller, as explained further, below. Where we act as a processor for one of our customers, we will refer your request to that customer. Please identify the customer your request refers to (if possible), to simplify this process.
Right to Correct: If you wish to exercise your right to correct Personal Data, you may do so by contacting us at the contact information below.
We either collect these opt-out signals ourselves or receive them from the mobile apps we work with.
- Right to Erasure. You also have the right to obtain the erasure of Personal Data concerning you that we hold as a controller. The above opt-out process satisfies this right. When a user opts-out through our partners (or through mobile device settings), and we receive this signal, we no longer use Personal Data to provide our advertising services. We will also manually delete your Personal Data if prefer that we do so; please contact us at info AT TomorrowInvestor DOT com for further instructions if you wish to exercise this right manually. Please note, however, that we may retain copies of certain Personal Data on inactive or back-up files, for our own internal and necessary purposes, such as auditing, accounting and billing, legal or bug-detection. We will in most cases delete such data within 36 months, absent a compelling reason to retain it.
- Right to Lodge Complaints. You have the right to lodge a complaint with a supervisory authority. However, we hope that you will first consult with us, so that we may work with you to resolve any complaint or concern you might have.
e. TomorrowInvestor as a data controller and a data processor
EU data protection law makes a distinction between organisations that process Personal Data for their own purposes (known as “data controllers”) and organisations that process Personal Data on behalf of other organisations (known as “data processors”). As noted above, we are not always a data controller of the data in our possession, but are sometimes a data processor for other companies such as our customers. In such cases, we may direct your inquiry to the relevant data controller, since data controllers are the ones with primary responsibility for your Personal Data.
Enforcement, Questions, and Complaints