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Privacy Policy for ARYU Advertising

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At ARYU Advertising, we respect your privacy and are committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data when you visit our website (regardless of where you visit it) and tell you about your privacy rights and how the law protects you.

Important Information & Who We Are

Purpose of this Privacy Policy

This privacy policy aims to give you information on how ARYU Advertising collects and processes your personal data through your use of this website, including any data you may provide through this site when you sign up for our newsletter, purchase a product or service, or take part in a survey.

Compliance with GDPR

ARYU Advertising’s website and its services are not intended for individuals within the European Union (EU), and we do not specifically target or market to EU residents. As such, our website and services are not compliant with the General Data Protection Regulation (GDPR). If you are an EU resident and choose to access or use our website and services, you acknowledge and agree that you are doing so on your own initiative and are solely responsible for compliance with local laws to the extent you are subject to such laws. 

Controller

ARYU Advertising is the controller and responsible for your personal data (collectively referred to as “ARYU Advertising”, “we”, “us” or “our” in this privacy policy).

Contact Details

Our full details are: 

Full Name of Legal Entity: ARYU Advertising 

Email Address: hello@aryuadvertising.com 

Postal Address: PO BOX 201733 Arlington, TX 76006 

Telephone Number: 214-396-8151 

You have the right to make a complaint at any time to the national supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the authority so please contact us in the first instance.

The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, title, photos, or other images. 
  • Contact Data includes billing address, delivery address, email address, and telephone numbers. 
  • Financial Data includes bank account and payment card details. 
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. 
  • Technical Data includes internet protocol (IP) address, your login data, browser type, and version, time zone setting, and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. 
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses. 
  • Usage Data includes information about how you use our website, products, and services. 
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

How is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you: 
  • apply for our products or services; 
  • create an account on our website; 
  • subscribe to our service or publications; 
  • request marketing to be sent to you; 
  • enter a competition, promotion, or survey; or 
  • give us feedback or contact us. 
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. 
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below: 
  • Technical Data from the following parties: 
  • analytics providers such as Google based outside the EU; 
  • advertising networks; and 
  • search information providers. 
  • Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services. 
  • Identity and Contact Data from data brokers or aggregators. 
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 

  • Where do we need to perform the contract we are about to enter into or have entered into with you? 
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 
  • Where we need to comply with a legal obligation. 
     

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Disclosures of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. 

  • Internal Third Parties as set out in the Glossary. 
  • External Third Parties as set out in the Glossary. 
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

International Transfers 

ARYU Advertising operates on a global scale, and as a result, your personal data may be transferred to and processed in countries different from your own. These countries may have laws regarding data protection that differ from those in your country. To ensure the continued protection of your personal data, we have implemented safeguards in accordance with this privacy policy. 

Transfer Mechanisms: 

  • Data Protection Standards: We transfer personal data to other countries only with data protection standards in place to safeguard your personal information. 
  • Contractual Obligations: When transferring data to third parties or affiliates in other countries, we employ contractual obligations to ensure the protection and confidentiality of your data. 
  • Corporate Policies: For transfers within our corporate group, we adhere to strict internal data protection policies that maintain high standards of data privacy, irrespective of the location.

Consent: 

Informed Consent: In situations where we transfer your data to countries with different data protection standards, we will seek your informed consent. This consent will be distinct and separate from other consents, and you will be fully informed about the nature of the transfer and the protection measures in place. 
 

Data Protection: 

  • Security Measures: Regardless of where your data is processed, we take appropriate measures to ensure its security and to treat it in accordance with this privacy policy and applicable laws. 
  • Monitoring and Compliance: We regularly monitor the effectiveness of our data transfer and protection strategies to ensure compliance with our high standards of data privacy. 

Rights and Remedies: 

  • Transparency: We are committed to maintaining transparency about the international transfer of your data and the measures in place to protect it. 
  • Resolution of Concerns: If you have any concerns about how your data is handled in the context of international transfers, you are encouraged to contact us. We are committed to addressing and resolving any issues in accordance with our internal policies and applicable laws. 

Data Security

ARYU Advertising takes the security of your personal data very seriously. We have implemented various measures to prevent your personal data from being accidentally lost, used, accessed, altered, or disclosed in an unauthorized way. These measures include: 

Technical Measures: 

  • Encryption: We use encryption technologies to protect data during transit and when storing sensitive information, such as financial details. 
  • Secure Servers: Our data is hosted on secure servers, with protections against unauthorized access and data breaches. 
  • Firewalls and Access Controls: We employ firewalls and advanced access controls to prevent unauthorized access to our systems and data. 
  • Regular Security Audits: We conduct regular security audits and risk assessments to identify and address potential vulnerabilities in our systems. 
     

Organizational Measures: 

  • Data Protection Training: Our staff receives regular training on data protection and information security best practices. 
  • Access Restrictions: Access to personal data is restricted to employees and third parties who need access for specific, authorized purposes. They are subject to confidentiality obligations. 
  • Policy Enforcement: We have policies and procedures in place to manage data security, including procedures for dealing with suspected data breaches. 
     

In Case of a Data Breach: 

  • Notification Procedures: In the event of a data breach, we have procedures in place to promptly notify affected individuals and relevant authorities, as required by law. 
  • Incident Response Plan: We have an incident response plan to swiftly respond to and mitigate the impact of any data breach. 
     

Continuous Improvement: 

  • Regular Updates and Patches: We regularly update our security software and systems to address new security threats. 
  • Feedback and Review: We continually review and improve our security practices based on feedback and new developments in technology and threats. 

Data Retention

Purpose of Data Retention 

ARYU Advertising is committed to retaining personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

Retention Duration 

  • General Retention Period: Personal data will be retained for a period of two years after your last interaction with us, or as long as required to fulfill our contractual obligations and resolve disputes. 
  • Specific Retention Periods: In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

Criteria for Determining Retention Periods 

The retention period for personal data is determined by: 

  • The amount, nature, and sensitivity of the personal data. 
  • The potential risk of harm from unauthorized use or disclosure of your personal data. 
  • The purposes for which we process your personal data and whether we can achieve those purposes through other means. 
  • Applicable legal, regulatory, tax, accounting, or other requirements. 

Deletion of Data 

Upon the expiration of the retention period, personal data shall be securely deleted or destroyed. Additionally, if we are requested to delete personal data by a data subject and there are no legal grounds for retaining it, we will comply with this request. 

Review and Adjustment of Retention Periods 

We regularly review our data retention policies and adjust them as necessary to align with legal requirements and operational needs. 

Your Legal Rights 

Under certain circumstances, you have rights under data protection laws in relation to your personal data including the right to request access, correction, erasure, restriction, transfer, object to processing, portability of data, and (where the lawful ground of processing is consent) to withdraw consent. 

  • Access to Information. You can request to see the personal data we hold about you. This is known as a “data subject access request.” It allows you to obtain a copy of the personal data in our possession and to verify our lawful processing of it. 
  • Correction of Information. If any personal data we have about you is incomplete or incorrect, you have the right to ask us to update or amend it. 
  • Deletion of Information. You may request the deletion of your personal data under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or if you withdraw consent and no other legal basis for processing exists. 
  • Objection to Processing. If we are processing your personal data based on legitimate interests or those of a third party, you have the right to object. This is especially relevant if you feel this processing impacts your fundamental rights and freedoms. 
  • Restriction of Processing. You have the option to request that we temporarily halt the processing of your personal data. This right is exercised in specific situations, such as when you contest the accuracy of your personal data, or you have objected to our processing, and we are considering whether our legitimate grounds override your rights. 
  • Data Portability. You have the right to request the transfer of your personal data to you or to a third party in a structured, commonly used, and machine-readable format, but only in situations where our processing of your data is based on your consent or a contract and is carried out by automated means. 

Please note that we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. 

Glossary

  • Personal Data 
    Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 
  • Processing 
    Processing includes any operation or set of operations that are performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction. 
  • Controller 
    The controller is the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data. 
  • Data Subject 
    A data subject is any living individual who is using our service and is the subject of Personal Data. 
  • Cookies 
    Cookies are small pieces of data stored on a user’s device by the web browser while browsing a website. Cookies are used to remember your preferences, to understand how you interact with the site, and to improve your user experience. 
  • GDPR 
    The General Data Protection Regulation is a regulation in EU law on data protection and privacy in the European Union and the European Economic Area. It also addresses the transfer of personal data outside the EU and EEA areas. 

Changes to the Privacy Policy and Your Duty to Inform us of Changes 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. 

We keep our privacy policy under regular review. This version was last updated on November 27, 2023. Historic versions can be obtained by contacting us.