1. Introduction
Digital Media Services FZ-LLC, (referred to herein as “DMS”, “we”, “our”, or “us”), respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights.
By sharing your personal information, you agree that we can use your personal information in accordance with this Privacy Notice.
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.
2. Definitions
Affiliate(s) means any entity that controls, is controlled by, or is under common control of a company or an individual. As used herein, “Control” means the possession, directly or indirectly. of the power to direct or cause the direction of the management and policies of such entity, whether through the ownership or other interests, by contract or otherwise.
Brand Partner means the advertiser benefitting from the Campaign (as defined below) on DMS’ publishers, and its Affiliates.
Campaign means the Brand Partner’s campaign on DMS (as defined below) publishers enabling it to target specific audiences.
DMS means Digital Media Services FZ-LLC and its Affiliates.
User(s) means, like you, any individual who meets the conditions set out by the Campaign by duly filling the overlay and has been chosen to be targeted by the Brand Partner.
Website means the DMS website found on the URL www.dms-cg.com
3. What personal information does DMS collect and why?
- 3.1. Information that you provide voluntarily.
- 3.1.1. Certain parts of our Website or our publishers’ websites may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details (detailed under sub-section 3.2 below) to register you with us, or to subscribe to marketing communications from us, and/or to send you offers or suggestions of other campaigns with us.
- 3.1.2. The types of personal information collected may include but are not limited to your full name, email address, date of birth, telephone number, home or office address, photographic identification of yourself.
- 3.1.3. The information you provide us is used for such purposes as:
- 3.1.3.1. Fraud prevention;
- 3.1.3.2. Monitoring any claims and complaints that shall be transmitted to our Brand Partner; and / or
- 3.1.3.3. Communicating with you about news and other information in accordance with your communication preferences and to respond to any correspondence you send us.
- 3.2. Information that we collect automatically.
- 3.2.1. When you visit our Website or our publishers’ websites, we may collect certain information automatically from your device. In some countries, this information may be considered personal information under applicable data protection laws.
- 3.2.2. Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (such as city-level location) and other technical information.
- 3.2.3. Collecting this information enables us to better understand the visitors who are interested in the Campaign and where they come from. We use this information for our internal analytics purposes, and to share it with our Brand Partners, as well as to improve the quality and relevance of our publishers’ websites and the advertising campaigns therein to the visitors, and to improve the quality and efficiency of our services.
4. Who does DMS share your personal information with?
We may disclose your personal information to the following categories of recipients:
- 4.1. To our Brand Partners to carry out the relevant Campaign to the fullest extent, to register you on their mailing list and newsletters and for marketing purposes. Our Brand Partner's privacy policy can be found via the link provided on the consent form made available to you.
- 4.2. To our Affiliates, third party service providers, sub-contractors and Brand Partners to provide data processing services to us, , to provide functionality on and help enhance the security of our Website, to process personal information for purposes that are described in this policy or notified to you from time to time when we collect your personal information.
- 4.3. To any competent law enforcement body, governmental agency, or court of law where we believe disclosure is necessary as a matter of law or to exercise, establish or defend our legal rights or to protect vital interests or those of any other person.
- 4.4. To any other person with your consent to the disclosure.
5. Legal basis for processing personal information:
- 5.1. Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to contact you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.
- 5.2. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
- 5.3. If we ask you to provide personal information to comply with a legal requirement or to perform the Services, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
- 5.4. Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
- 5.5. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us on legal@choueirigroup.com
6. How does DMS keep your personal information secure?
- 6.1. We use appropriate technical and organizational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include encrypting your personal information or the training of our staff around proper data handling practices.
7. International data transfers
- 7.1. Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
- 7.2. Specifically, our Website servers are located in the United States, and our third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.
- 7.3. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this privacy policy and in compliance with applicable laws.
- 7.4. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.
8. Data Retention:
- 8.1. We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with additional services or for the provision future similar services or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
9. Your data protection rights:
- 9.1. You have the following data protection rights: If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using at legal@choueirigroup.com
- 9.2. In addition, you can object to processing your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us at legal@choueirigroup.com.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. If you are a registered customer, you can manage your subscriptions on your account page under the privacy section.
- 9.3. Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- 9.4. You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
10. Updates on this Privacy Policy:
- 10.1. We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
- 10.2. You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.