Updated: March 23rd, 2022
Biga Bid Media Ltd. (“BigaBid“, “we“, “our” or “us“) develops and provides data-driven performance marketing solutions for the mobile advertising industry, which allow us to bid on, and engage with individuals on behalf of mobile advertisers (our “Clients”) with a view to specifically target end users (“End Users”) who are most likely to become high-value users of their mobile applications. In addition, BigaBid acts as a DMP (Data Management Platform), creating audience related insights for optimizing ad performance (collectively, the “Services”).
You are not legally required to provide us with any Personal Data (defined below), but without it we may not be able to provide you with the full range of Services or with the best user experience when using our Services. To learn more about the choices available to you, please read Section 8 below.
We collect Personal Data regarding our Clients and their representatives. This includes names and contact details, as well as transaction history.
We also collect Personal Data regarding Visitors. Such data is typically collected and generated through the Visitor’s interaction with our Services, through automatic means, directly from such Visitor, or from other third parties.
When we collect data about our Clients and their representatives, as well as data about our Visitors, we are the Controller of the Personal Data.
We collect Personal Data regarding End Users, as our systems consider and bid on the opportunity to engage with them and show them our Clients’ advertisements (“Bids”); and following successful Bids and engagements, as we monitor the performance of our Services on behalf of our Clients. When we collect data of End Users, we act as Data Controller, except in those instances where we collect and process End User data on behalf of our Clients, in which case those Clients are the Data Controllers of the End Users’ Personal Data.
Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, will be deemed as “Personal Data“):
We collect or generate such data either independently or with the help of third party services (as detailed in Section 4 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 5 below).
Such data mainly consists of connectivity, technical and aggregated usage data, such as IP addresses, unique advertising IDs (e.g. IDFA; you may reset such ID by following the instructions below), data regarding your device (such as type, screen resolution), operating system, app version, mobile carrier, in-app events and various apps usage statistics, browser version, locale and language settings used, visit history, search keywords, activities and actions on the website, general End User location (city, country, zip code), date and time stamp, types of advertisements viewed and click data, the pixels installed on such device, and the activity (clicks and other interactions) of Visitors and Clients in connection with our Services. Such data does not enable us to learn a person’s true identity or contact details. Nevertheless, it is possible that putting many of these data points together with additional outside data would enable someone to identify you. We therefore treat this data as Personal Data and take strong precautions to secure your data and ensure that outside actors cannot access it. We mainly use this data to gain a better understanding on how Visitors, Clients and End Users typically use and interact with our Services; how we could improve their user experience; to optimize our product; and to optimize the overall performance of our Services.
Clients may also provide us with Personal Data concerning their colleagues or employees, in order to register them to our Services. Such Data usually refers to first names/nicknames and work e-mails, however additional data may be provided at the Client’s discretion.
We use Personal Data as necessary for the performance of our Services; to comply with applicable law; subject to your explicit consent; or to support our legitimate interests in maintaining and improving our Services and offerings, optimizing our marketing and advertising services, customer service and support operations, and protecting and securing our Visitors, Clients, End Users, ourselves and our Services. With regards to the Personal Data of End Users, we use Personal Data to provide Services to our Clients who are the Controllers of such Personal Data.
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).
Specifically, we use Personal Data for the following purposes:
Data Location: We and our authorized Service Providers (defined below) maintain, store and process Personal Data in the United States, the European Union, Israel and other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
To the extent that we store or transfer the Personal Data of European residents outside of the EU or Israel, such transfers are subject to the European Commission’s Standard Contractual Clauses, and we ensure that the standards of GDPR are maintained when the data is transferred outside of the EU.
Data Retention: We retain Personal Data of Visitors and prospective Clients for as long as reasonably necessary in order to maintain and expand our relationship and to provide them with our Services.
We retain Personal Data of Clients as necessary for us to provide them with our Services, to comply with our legal and contractual obligations, and to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our data retention policy.
We retain Personal Data of End Users in accordance with the instructions of our Clients, as necessary for continuously optimizing the display and performance of our Clients’ ads, and to gain further insights based on the aggregation of data available to us. At the request of our Client, we will permanently delete or return to our Clients the Personal Data of End Users.
Please note that except as required by applicable law, we are not obligated to retain your Personal Data for any particular period, and we are free to securely delete or anonymize it for any reason and at any time, with or without notice to you.
If you have any questions about our data retention policy, please contact us by email at firstname.lastname@example.org.
Legal Compliance: We may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
One of our Service Providers in particular is Google, which provides a tool called “Google Analytics”, used by us to track and analyze the use of our Services, for internal purposes. To learn more about how Google uses data from our use of Google Analytics, we recommend you review Google’s policies located at: google.com/policies/privacy/partners. For additional information, please see Google Analytics’ opt-out web tool available at: https://tools.google.com/dlpage/gaoptout.
Sharing End User Personal Data with or on behalf of our Clients: We may share the Personal Data of End Users in accordance with the reasonable instructions of our Clients, each acting as the “Data Controller” of such data, as we act as the “Data Processor” and process such End User data on their behalf. For example, based on a Client’s instructions, we may share their End Users’ Personal Data with another service provider also processing such Personal Data on such Client’s behalf.
Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of BigaBid, any of our Clients or Visitors, End Users, or any members of the general public.
For the avoidance of doubt, BigaBid may share your Personal Data in additional manners, pursuant to your explicit consent, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.
Subject to your Explicit Consent on the first occasion that you use our Services, our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide, secure and improve our Services, personalize your experience and monitor the performance of our activities and campaigns.
While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser, most browsers allow you to control cookies, including whether or not to accept them and to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
If you wish to prevent the use of your mobile device’s advertising ID (e.g. for interest-based advertising), you may change your device settings to reset such advertising ID or to opt-out of such advertising (typically, this is available under the “Privacy” or “Ads” section in your device settings). You may also change your browser settings to reset or block cookies (typically, this is available under the “Settings” or “Help” section in your browser menu).
If you are an End User who lives in the USA, Canada or Europe, you can also opt-out from the collection of your data by our Clients who participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices (for US users), www.youradchoices.ca/choices (for Canadian users) or www.youronlinechoices.com (for European users).
Please note that if you reset your advertising ID or opt-out of interest-based advertising, you may still see advertisements served by BigaBid, or on any other channels, but those ads will not be targeted based on the above mentioned identifiers. For example, such ads may be instead based on context, such as your progress and actions in a certain app, or your language preferences. Please note that such actions may result in a less enjoyable user experience.
Service Communications: We may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, etc. We may also send you notifications, messages and other updates. Typically, you will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.
Notifications and Promotional Communications: Subject to your explicit consent, we may also send you notifications about new features, offerings, events and special opportunities or any other information we think our Visitors or Clients will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify BigaBid at any time by sending an email to email@example.com or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any Service Providers as described in Section 4 above.
Depending on your location, you may have certain rights in relation to your Personal Data, including the rights to access, or request modification or erasure of your Personal Data. If you wish to exercise your rights under any applicable law, including the EU General Data Protection Regulation (GDPR) or the California Privacy Act (CCPA) such as the right to request access to, and rectification or erasure of your Personal Data held with BigaBid, or to restrict or object to such Personal Data’s processing, or to port such Personal Data (each to the extent available to you under the laws which apply to you)– please contact us by email at firstname.lastname@example.org.
Please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.
If you are an End User, you should contact the relevant Client, acting as the Controller of your Personal Data (see Section 10 below for more details).
Our Services are not designed to attract children under the age of 16. We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that we collect data relating to a person under the age of 16, we will make all efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by email at email@example.com.
Certain data protection laws and regulations, such as the GDPR and CCPA, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller” (or under the CCPA, the “Business”) who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA, the “Service Provider”) , who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
If you would like to make any requests or queries regarding Personal Data we process on our Client’s behalf, please contact them directly. For example, if you wish to access, correct, or delete data processed by BigaBid on behalf of a Client, please direct your request to the relevant Client (who is the “Data Controller” of such data). Should we receive such requests directly, we will refer them to our Client.
MyEDPO has been designated as BigaBid’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. Inquiries regarding EU privacy practices may be sent to MyEDPO Ltd, Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork, Ireland, or by email to firstname.lastname@example.org. If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.