CitrusAd Privacy Policy
Definitions
In this Policy:
- Admin Console means the Website located at https://retailer.citrusad.com, or https://us.citrusad.co where Personal Information is collected from Advertisers and Customers.
- Advertiser means any person (and where a company, includes its officers, employees, agents and representatives) who We provide Services to as an advertiser.
- Customer means any person (and where a company, includes its officers, employees, agents and representatives) who We provide Services to as a customer.
- Our, Us and We refers to
- Australia: Citrus International Pty Ltd ACN 614 763 307 of Level 4, 116 Adelaide St, Brisbane, QLD, 4000, Australia
- United States: CitrusAd International Inc of 136 4th Street North STE 326 St. Petersburg, FL 33701
- United Kingdom: Citrus International Pty Ltd of Suite KC 33, Great Northern Road, Wyboston Lakes, Bedfordshire UK, MK44 3BA
- Personal Information means any information or an opinion that can identify an individual. It is still Personal Information whether or not it is true.
- Related Company has the same meaning as Section 50 of the Corporations Act 2001 (Cth).
- Services means services We provide to You.
- You and Your refers to Advertisers, Customers, and prospective advertisers and customers. It also generally refers to users of our Websites.
- Websites means all Websites used by Us through which the Services are provided.
Who does this Privacy Statement apply to?
This Privacy Statement (“this Statement”) applies to “CitrusAd” (“we” or “us”), which includes all of the entities it owns or controls. We want you to know that we are committed to protecting your privacy and handling your personal information in an open and transparent way.
What does this Privacy Statement cover?
This Statement explains how we collect, handle, store and protect personal information when:
- We provide professional services to you or our clients;
- You use “this Website”; or
- Perform any other activities that form part of the operation of our business.
- When we refer to “this Website” we are talking about websites associated with CitrusAd. This includes;
- Pages accessed using the www.citrusad.com URL
- Pages or communications that link directly to this privacy statement.
What are the methods and principles for collection?
Collection.
We collect personally identifiable information, such as your name, phone number, company name and email address, directly from you when you choose to enter it on our website, for instance when you complete the “Contact Us” form.
Use.
We use this information to respond to the request or inquiry you have submitted to us through the contact form or other entry field.
We also use this information for marketing purposes, such as to send you our newsletter or other promotional emails. You may choose to stop receiving our marketing emails by following the unsubscribe instructions included in these communications. With your consent, we may also post your name and a testimonial on our site.
Consent.
The collection of personal data based on your consent is done by using a consent form as for instance on our Contact Us page. Your consent is stored and documented in our systems. You may withdraw any consent to personal data processing at any time.
Contract.
We also use personal information for fulfilling our obligations related to contracts and agreements with customers, partners and suppliers.
Legitimate interest.
We may use your personal data if it is considered to be of legitimate interest, and if your privacy interests do not override this interest. Normally, to establish the legal basis for data collection, an assessment has been made during which a mutual interest between you and CitrusAd has been identified. This legal basis is primarily related to our sales and marketing purposes. We will always inform you about your privacy rights and the purpose for collecting your personal data. In such cases, you can always choose to object to the processing of your personal data.
Information Sharing.
We do not share your information with third parties for their promotional purposes. We may share your information with our subsidiaries, affiliated companies, and trusted third party service providers working under the instruction of CitrusAd, such as an email service provider, hosting provider or data center, exclusively for storage purposes. Such third parties who provide services on our behalf are authorized to use your personal information only as strictly necessary to provide these services to us.
We of course remain responsible for making sure they commit themselves to adhere to this privacy policy and applicable data protection legislation by signing a data processing agreement.
In this context, please note that CitrusAd may transfer your personal data outside the European Union as part of its processing. In such a case the organization receiving your personal data will have provided to CitrusAd adequate safeguards such as execution of the EU Standard Contractual Clauses for transfer to third countries, or another specifically stated lawful basis for the transfer of personal data to a third country.
Legal Disclaimer.
We reserve the right to disclose or transfer your personally identifiable information as required by law, as part of a merger, acquisition, dissolution or sale of assets, and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process. You will be notified via email and/or a prominent notice on our website of any change of ownership, uses of your personal information, and choices you may have regarding your personal information.
We may also disclose your personal information when we believe in good faith that disclosure is necessary to protect your safety or the safety of others, investigate fraud or respond to a government request. We may also disclose your personal information to any other third party with your prior consent.
Others’ Websites.
Our site includes links to other websites whose privacy practices may differ from ours. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.
Access.
Upon request, CitrusAd will provide you with information about whether we hold any of your personal information. You may update, access or request deletion of your personally identifiable information by contacting us at dpo@CitrusAd.com. We will respond to your request within a reasonable timeframe.
Rectification and erasure.
You may request CitrusAd the rectification of inaccurate personal data concerning you, as well as the completion of incomplete personal data. You may also request CitrusAd to erase without undue delay your personal data when it is no longer necessary for CitrusAd to retain such data.
Portability.
Upon request, CitrusAd will provide you with the personal data that you provided to us and, if possible, will communicate this information directly to another data controller of your choice in a portable format when the processing is based on consent or contract.
How do we collect and use your personal information?
Tracking Technologies.
CitrusAd uses cookies and similar technologies to analyze trends, administer the website, and track users’ movements around the website. We use cookies which are small text files stored on a user’s computer. The cookies store non-personally identifiable information related to your navigation on our website. Our website also uses web beacons, which are embedded invisibly on Web pages. Web beacons help us better manage content on our site by informing us what content is effective. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website.
Our cookies are placed for the following purposes:
Personalization of your navigation
These cookies enable us to recognize you and remember any information you have entered during your navigation on our website (such as language choice, country you are browsing from, or browser type). This makes your visit on our website easier as we don’t ask you the same information several times during your navigation.
Third parties cookies and web beacons
We use LogRocket, Google Analytics cookies, Intercom cookies and web beacons to collect information related to the web traffic and number of visitors. These are tools that enable us to measure the performance of the navigation on our website and provide feedback to our product team for enhancements.
For more information on the cookies used by these websites, you can refer to their specific privacy statements listed below:
- Google Analytics: https://tools.google.com/dlpage/gaoptout
- Intercom: https://www.intercom.com/legal/privacy
- LogRocket: https://logrocket.com/privacy/
Our website may also be embedded with videos from YouTube or Vimeo. When you watch these videos, Vimeo or YouTube may set cookies. We do not control the placement of these cookies, and for more information on these cookies and how to opt-out, please refer to YouTube or Vimeo specific privacy statements:
We use communication tools to share links with social networks. If you click on these features, such as social media widgets or “share” buttons, the company providing them may collect your IP address, which page you are visiting on our site and may place cookies when you are connected to their services. Your interactions with these features are governed by the privacy policy of the company providing it.
For more information on the cookies used by these websites, you can refer to their specific privacy statements listed below:
- Facebook: http://www.facebook.com/about/privacy/
- LinkedIn: https://www.linkedin.com/legal/privacy-policy
- Twitter: https://twitter.com/privacy
Search Engine Marketing.
We use Google AdWords service to advertise on the Google search result page. Google uses cookies to serve ads based on your past visits on our website. For more information on Google AdWords services and how to opt-out, please refer to Google specific privacy policy and settings for Google ads.
- Google AdWords: https://policies.google.com/technologies/ads?hl=en-US
We do not process any of this information, directly or indirectly, with the help of a third party or otherwise, to determine your identity.
Information about Epsilon’s CitrusAd services.
For information about CitrusAd’s privacy practices related to the processing of consumer personal data through services it provides to retailer and advertiser clients, please see the Epsilon global privacy policies (https://legal.epsilon.com/global-privacy-policies/)
Additionally if you are a consumer that would like to exercise your privacy rights related to the processing of your personal data by Epsilon’s CitrusAd Services, please visit Epsilon’s Privacy Choices site.
When will we disclose your personal information?
We will only disclose your personal information as set out below. Importantly, we will never sell your personal information to third parties for advertising purposes, or disclose it for any other secondary purpose without your authorisation.
We may disclose personal information to:
- Other entities in the CitrusAd group;
- Third parties that we engage to assist us in providing professional services to our clients or in the operation of our business (i.e. our subcontractors, advisors and suppliers). These entities and third parties may sometimes be located in other countries, in particular the United States, Europe, UK and India.
- Law enforcement, regulatory or government agencies, or to other third parties:
- To comply with legal or regulatory obligations or requests; or
- Where there is a legal or professional right or duty to disclose.
We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.
Blogs, forums, wikis, and other social media
This Website hosts various blogs, forums, wikis, and other social media applications or services that allow you to share content with other users (collectively ‘social media applications’). Importantly, any personal information that you contribute to these social media applications can be read, collected and used by other users of the application. We have little or no control over these other users and, therefore, we cannot guarantee that any information that you contribute to any social media applications will be handled in accordance with this Statement.
On what basis do we process personal information about you?
Certain data protection laws, such as the European GDPR, require us to have a ‘legal basis’ for processing personal information. Where those laws apply, we may process your personal information for the purposes outlined above because:
- You have consented to the processing of your personal information for those purposes;
- We have a legitimate interest in processing your personal information, which may be to:
- provide services to you and/or to the entity that has engaged us to provide the services;
- support the management of our client engagements;
- evaluate, develop or improve our services or products; or
- protect our business interests; or
- We are subject to legal, regulatory or professional obligations.
To the extent that we process any sensitive (special category) personal information about you for any of the purposes outlined above, we will do so because either:
- You have given us your explicit consent to process that information;
We are required by law to process that information, for example, in order to ensure we meet our ‘know your client’ and ‘anti-money laundering’ obligations; - The processing is necessary to carry out our obligations under employment, social security or social protection law; or
- The processing is necessary for the establishment, exercise or defence of legal claims.
How do we protect your information?
We hold personal information in hard copy and electronic formats. We use a range of physical, operational and technological security measures to protect this information.
These measures include:
- Staff education and training to ensure our staff are aware their privacy obligations when handling your personal information;
- Administrative and technical controls to restrict access to personal information to only those people who need access;
- Technological security measures, including fire walls, encryption and anti-virus software;
- Physical security measures, such as staff security passes to access CitrusAd premises
How can you access your personal information, or seek to have it corrected?
You may access your personal information, or seek to have that information corrected if you believe that it is incorrect, at any time.
To request access, or to correct your personal information, please contact the CitrusAd Data Privacy Officer at privacyofficer@citrusad.com. The privacy team will then get in contact with you (either by phone or via email) and will work with you to provide you with access to your information or to determine whether it requires correction.
Depending on the jurisdiction in which you are located, you may also have the right to:
- Ask that we delete personal information that we hold about you, or restrict the way in which we use your personal information;
- Withdraw consent to our processing of your personal information (to the extent our processing is based on your consent);
- Ask us to stop or start sending you marketing messages at any time;
- Obtain and/or move your personal information to another service provider; and/or
- Object to our processing of your personal information.
If you believe these rights apply to you and wish to exercise these rights, please contact the CitrusAd Data Privacy Officer at privacyofficer@citrusad.com.
Who can you contact if you have further questions or if you wish to make a complaint?
Who should you contact?
If you have any questions or concerns regarding your privacy, or if you would like to make a complaint, please contact the CitrusAd Data Privacy Officer at:
Data Privacy Officer
CitrusAd
Level 4, 116 Adelaide St
Brisbane City, QLD, 4000
Australia
privacyofficer@citrusad.com
If you believe that the Privacy Officer has not adequately handled your query or issue, you may complain to the Complaints Officer whose contact details are as follows:
Complaints Officer
CitrusAd
Level 4, 116 Adelaide St
Brisbane City, QLD, 4000
Australia
complaints@citrusad.com
How do we handle complaints that we receive?
We take all the privacy complaints we receive seriously.
We will acknowledge the receipt of a complaint immediately and will work with you to resolve it. If you would like more information about our process for handling complaints, please see our complaints handling policy.
What if you are not satisfied with how we have handled your complaint?
If you believe that CitrusAd has not adequately handled your privacy complaint, you may lodge a complaint to the official government or regulatory body in the region below.
Australia
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
1300 363 992
enquiries@oaic.gov.au
United States
State Consumer Protection
Office
https://www.usa.gov/state-consumer
Europe
European Data Protection Supervisor
https://edps.europa.eu/data-protection/our-role-supervisor/complaints_en
United Kingdom
Information Commissioner’s Office
https://ico.org.uk/make-a-complaint/your-personal-information-concerns/
New Zealand
Privacy Commissioner
https://www.govt.nz/browse/consumer-rights-and-complaints/how-to-complain/privacy-complaints
Canada
Office of the Privacy Commissioner
https://www.priv.gc.ca/en/report-a-concern/file-a-formal-privacy-complaint/
Changes to our privacy policy
Please note that we may update or change this privacy policy. If we revise our privacy policy, we will post those changes to this privacy statement, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make any material changes we will notify you by means of a notice on this site prior to the change becoming effective. Please check the CitrusAd website for the latest version of the privacy policy.