We are committed to protecting and respecting user privacy. This Privacy Policy outlines the privacy practices of FIRST CLICK MEDIA GROUP PTE. LTD. (“FIRST CLICK MEDIA”, “we”, “our”, or “us”) in connection with your (“you” or “your”) access to or use of our websites where this Privacy Policy is linked and our services (collectively, the “Service”). Please review this Privacy Policy carefully as it contains important information regarding the use and disclosure of information collected through the Service. By accessing or using our Service, you acknowledge that you have read, understood, and agree to be bound to these privacy practices; if you do not agree to these terms, you may not use the Service.

Use of our Website and Services

Although certain areas of our website can be accessed by visitors generally, access to our services is not provided to the general public. Only persons or entities that are eligible to enter into further agreement(s) with us, such as advertisers and publishers (collectively, our “Clients”) may, with our permission, access non-public areas or our website.

What does this Privacy Policy cover?

This Privacy Policy outlines how we collect, use, and disclose information of users, both online and offline. Unless otherwise expressly stated, this Privacy Policy does not apply to any third-party practices, websites, or services, whether or not referenced in our Service. Each third party will have its own privacy practices and policies, which you should review before using them.

What information do we collect and how do we collect it?

“Information,” as used in this Privacy Policy means personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular user.

We may collect the below categories of information:

• Information You Provide to Us. We collect information from you when you voluntarily register with FIRST CLICK MEDIA and/or submit your information to us over the Service or through a written Agreement. Such information may include an individual or company’s name, email address, telephone number(s), fax number(s), mailing address, and website URLs.
• Payment Information. If you enroll as a Client, we may gather payment information from you. Such information may include your credit card number, debit card number, and expiration date.
• Internet, Device, and Network Activity Information. When you use the Service, we automatically gather information made available by your web browser, internet service provider, and the device you use (depending on your settings for each). For example, we may collect your IP address, domain server, devise information, and information about when you access the Website. Additionally, we may automatically gather information about your browsing history, search history, and information regarding your interaction with the Website.
• Geolocation Information. We may collect information about where you are located, both generally and at the time you access the Service. For example, we may ascertain your approximate location from your IP address.
• Other Information. FIRST CLICK MEDIA may supplement the information you provide with additional information gathered from public sources or from third parties (e.g., performance metrics) who may lawfully provide such information to FIRST CLICK MEDIA.

FIRST CLICK MEDIA may collect information about you, including the categories outlined above, in different instances, including:

• When you enter or upload information to the Service. We collect information you provide, including when you apply to enroll as an advertiser or publisher or purchase our services.
• When you provide information outside of the Service. This Privacy Policy specifically applies to information collected from you through the Service; however, there are circumstances when you provide information outside of the Service, including:
• When you enter into a written agreement with FIRST CLICK MEDIA, such as a Client agreement (“Agreement”);
• When you meet us at a trade show or other event and give us your contact information or sign up to receive emails or other promotional correspondence;
• When you interact with us through off-website social media or instant messaging
  platforms; and
• When you reach out to us or visit our offices as an existing or prospective client.

FIRST CLICK MEDIA makes no effort to segregate information collected on the Service from information collected elsewhere. Accordingly, information collected on the Service may be combined with information collected through other avenues.

• When you communicate with us. We collect information from your communications, such as when you email us, contact our customer service, or communicate via social media.
• From third parties. FIRST CLICK MEDIA may use third party services for advertising and analytics for the pages that we host. These third parties may place cookies on your device, use web beacons, gather IP addresses, and log data to collect traffic and activity data in order to deliver relevant metrics, content, and advertising.
• Through cookies, tracking tools, and other automated technologies. When you access the Website, your web browser automatically sends us device and internet connection information as well as certain internet activity information as described above. “Cookies” are text files that are placed on your computer by websites that you visit or certain emails that you open. A cookie acts as a string of information that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the website. The purpose of a cookie is to identify the user as a unique user of the website.

FIRST CLICK MEDIA uses functional cookies, some of which may be placed by third parties, to customize your experience on the Service. Cookies allow us to:

• Authenticate and identify you on our Service so we can provide you the services you request;
• Keep track of information you have provided;
• Store your preferences; and/or
• Measure your use of our web pages so that we can improve them and tailor our Service to your interests.

We may also use Google cookies and tools, such as Google Analytics, on our Service to collect usage data and analyze how users use the Service. For more information about how to opt out of this practice, visit the Google Analytics Opt-Out Add On page. You can change your cookie settings in your internet browser and use preferences or settings on your device to manage your privacy controls. However, if you disable cookies or other tools, some of the features of the Service may not function correctly. For more information, see https://www.allaboutcookies.org/; and to learn more about targeted advertising, including how to revoke consent and disable tools and how to opt out of third- party cookies and collection of mobile device IDs, see below and the links here and here.

How do we use the information we collect?

We may use the information identified above for certain “business purposes” that are necessary to provide the Service. We may also use your information for “commercial purposes,” meaning the use advances our business interests, such as marketing the Service.

The following are business and commercial purposes for which we may use your information:

• To secure the Service and related purposes, such as by detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and identifying and prosecuting those responsible for that activity.
• To fulfill our Agreements with you.
• To improve the Service and the services we offer, including by considering analytics, demographics, and user feedback to improve or repair the Service.
• To improve your experience on the Service, such as by using cookies to allow you to set personal preferences when using the Service, and to make it so you don’t have to re-enter the same information when you visit the Service several times in a short timeframe.
• To communicate with you, such as by responding to your emails and notifying you of updates to our Privacy Policy.
• To advertise public content to others, such as by sharing your reviews about us.

When do we disclose information?

As part of our business, we disclose information as follows and for the outlined purposes, which include business purposes to provide and improve the Service and comply with legal and contractual obligations, as well as commercial purposes, such as to market our business.

• Disclosure Pursuant to Agreement. If you enter into an Agreement with us, we may share your information with other clients as authorized in the Agreement or as reasonably necessary for us to perform our share of the services under the Agreement. For example, if you are an advertiser, we may disclose your name and offer details to our affiliates. 
• Company Parties; Merger or Sale. We may share information with affiliated companies that are related to us under a common ownership where they comply with this Privacy Policy. Such disclosure is for our business purposes, including to provide and improve our offers. Further, we may share information as part of a sale, merger, acquisition, or other change in control or entity status, either in whole or in part. We reserve the right to transfer or assign your information as part of any such transaction or investigation. 
• Service Providers and Contractors. We share information with service providers that allows us to provide and improve the Service. Service providers only use your information for a contracted-business purpose. Such disclosure is for our business purposes, in particular to provide you with the Service. We may likewise share information with “contractors” that are not service providers but to whom we disclose information for a business purpose. Such disclosure is for business purposes of providing you with products and services that you have requested or considered.
• Cookies/Device Data. For more information about our use of cookies and other technologies, see further below. Such disclosure is for our business purposes, in particular to provide you with the Service, as well as commercial purposes, such as to market to consumers that may be interested in our Service or related offers. FIRST CLICK MEDIA may also contract with third-party advertising companies to serve ads on our behalf. These companies may use cookies or other measures to collect non-identifier information.
• Legal Process and Protection. We may disclose information as necessary to comply with our legal obligations, such as to respond to government requests, law enforcement inquiries, legal processes, subpoenas, and court orders. We may disclose information when we believe it is necessary to investigate, prevent, or respond to illegal, fraudulent, or injurious actions or security incidents that may cause harm to us, the Service, or others. We may also disclose information in good faith where necessary to investigate or enforce a violation of this Privacy Policy, our terms, or any legal rights.
• We may disclose information as requested or consented to by you. Such disclosure may be for any business or commercial purpose as described to you.
• Unpaid Accounts. If you fail to pay any balance owed in consideration of services, FIRST CLICK MEDIA may, as permitted by law, report your information, including without limitation your unpaid balance, to consumer credit reporting services, collection agencies and others.

Do we sell or share information?

No, we do not sell personal information gathered through the Service.

How do we protect and transfer information?

 Consistent with others in our industry, we take efforts to employ technical, administrative, and physical security measures for personal information, taking into account reasonable security procedures and accessible technology. However, no system can be completely secure; and we cannot promise, and you should not expect, that your personal information will always remain secure. Your provision of personal information is at your own risk. The safety and security of your information also depends on you. Take steps to safeguard your passwords and other data, and notify us as soon as possible if you believe your account security has been breached.

Your data (including personally identifiable information) may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Currently, we use servers located within the United States and Canada. By using the Service, you authorize and specifically consent to the transfer of personal data to the United States and Canada and its storage and use as specified in this Privacy Policy.

How long do we retain information?

We retain personal information for the length of time necessary to fulfill the purposes outlined in this Privacy Policy, unless a different retention period is requested by you or required or permitted by law. For example, we will retain your personal information for as long as it is needed to provide you with the Service or fulfill a legal or contractual obligation. We may also aggregate, deidentify, or anonymize personal information as applicable for use in analytics, such as to analyze trends over periods of time without specifically identifying you.

We use the following criteria to determine how long we retain personal information: (a) our relationship with you, such as if there is an open contract or account or a pending transaction or request, (b) legal obligations to retain personal information for certain purposes, such as to maintain transaction records, and (c) other obligations or considerations relating to the retention of data, such as contract requirements, litigation holds, investigations, or statutes of limitation.

What are your privacy rights?

We value consumer privacy rights and strive to provide flexibility with how your personal data is used and shared. If you want to make a privacy request or have any questions, please contact us through our Contact Us form or email finance@firstclickmediagroup.com with your name and email address or other identifier used in connection with our Service so that we can verify your request. If an authorized agent is making a request on your behalf, the agent should provide its name and contact information, such as an email address, in addition to your information. There may be situations where we cannot grant your request, for example if you make a request and we cannot verify your identity, or if you request deletion of data but we have a legal obligation to keep your personal information. Where we deny your request in whole or in part, we will take steps to inform you of the denial and provide an explanation of our actions and the reasons for the denial.

Applicable privacy laws have different requirements and depend various factors, such as where you live and how much revenue or data is at issue. Generally, we adhere to the following set of privacy rights to the extent applicable and subject to any limitations authorized by law.

• You can access and obtain your data and ask us for certain information, including the categories of personal information collected and used, the categories of the sources of data, the business or commercial purposes for collecting, selling, or sharing data, the categories of third parties to whom data is disclosed, and the specific pieces of personal information collected. You also have a similar right to data portability.
• Amend. You can amend, correct, or rectify your data if it is inaccurate.
• Delete. You can have your data deleted subject to certain legal limitations.
• You can limit the processing of your data, in particular any sensitive data, and limit use of automated decision making, such as profiling.
• Opt Out. You have the right to opt-out of certain data practices. For example, you can unsubscribe from marketing communications by following the opt-out instructions in each message or by contacting us as outlined in this Privacy Policy (please note that we may still send non-marketing messages, and that consent to receiving marketing communications is not a condition of using the Service). You may also opt out of the “sale” or “sharing” or your personal information to the extent applicable.
• You have the right to make certain complaints, including for privacy concerns. We value your feedback and seek the opportunity to work with you on any issues. You have the right to no discrimination for asserting your privacy rights.
• Specific State Laws. Several states have enacted privacy laws that may apply to you, depending on the circumstances. For example, the California Consumer Privacy Act (“CCPA”), updated by the California Privacy Rights Act (“CPRA”), governs certain California-related conduct. Under California’s “Shine the Light” law, California residents may also request certain information regarding disclosure of personal information to third parties for their direct marketing purposes. Further, if you are a California resident under the age of 18, California Business & Professions Code Section 22581 permits you to request and obtain removal of content you have publicly posted. Please note that such a request does not ensure complete or comprehensive removal of public content.
• European Laws. Generally, residents of the European Economic Area (“EEA”) have the right to access information we hold about you and to ask that your information be corrected, updated, or erased, and the right to object to, or request that we restrict, certain processing of your information. Our legal basis for collecting and using your personal data is your consent, performance of a contract, or where the collection and use is in our legitimate interests and not overridden by your data protection interests or fundamental rights. You may withdraw your consent to our collection and use of your personal data. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your information used in reliance on lawful processing grounds other than consent. 
• Other Laws. If certain other privacy laws apply to you that afford you with additional rights, please contact us to make a request, as we strive to comply with all privacy rights.

Do we collect information about children?

No, we do not knowingly collect any personal information about children under the age of 13. If we obtain actual knowledge that we have collected such information, we will delete it from our database. We have no such information to use or to disclose to third parties or to otherwise report, including under the Children’s Online Privacy Protection Act (“COPPA”). We do not have actual knowledge of selling or sharing the personal information of consumers under the age of 16.

How do we use or disclose sensitive information?

We do not generally use or disclose “sensitive” personal information, nor do we use sensitive information for purposes other than those specified in the CPRA, which provides for the following uses without additional disclosures where the information is reasonably necessary and proportionate to the use: (a) to perform certain services, such as verifying information or for analytics, (b) to verify or maintain the quality or safety of our Service, (c) to perform services or provide goods reasonably expected, (d) for short-term, transient use where there is no disclosure or profiling, and (e) to resist malicious, fraudulent, or illegal actions or to ensure physical safety.

Do we offer financial incentives for your data?

No, we do not currently offer any financial incentives for your data.

Do we respond to Do Not Track (DNT) Signals?

No, our Service does not currently respond to DNT requests. DNT is a feature that, when enabled, sends a signal to websites to request that your browsing is not tracked.

How do we update this Privacy Policy?

We will update this Privacy Policy when our privacy practices change or as otherwise required or permitted by law. Each time you use the Service, the current version of this Privacy Policy will apply. Unless we receive your express consent, any revised Privacy Policy will apply only to information collected after the effective date of such revised Privacy Policy.

How can you contact us?

Please contact us with any questions or concerns! We can be reached at:
FIRST CLICK MEDIA GROUP PTE. LTD.
Corner of Charalambou Fteroudi & Tiranoktonon, Agios Athanasios 4104, Limassol, Cyprus

finance@firstclickmediagroup.com
Contact Us

Last Updated: June 12, 2023