PRIVACY POLICY

ENGKOR

 

Gazet Factory (the “Company,” “we,” “us,” “our”), in the business of providing of online advertisements to our users (“you,” “your”), complies with the Korean Act on Protection of Information and Communications Network Utilization and Information Protection, etc., Personal Information Protection Act, Protection of Communications Secrets Act, EU General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), Directive on Privacy and Electronic Communications (E-Privacy Directive), and other privacy related regulations applied to information and communication service providers.  We enact this Privacy Policy in accordance with applicable laws and exercise our best efforts to protect your privacy rights and interests.


This Privacy Policy includes the following

1. Who We Are

2. General Data Protection Regulation (GDPR)

3. Types of Information We Collect and Do Not Collect; Categorization of Information

4. How We Collect Information

5. How We Use This Information

6. Sharing and Transferring of Information

7. International Information Transfers

8. Processing Information in Aggregate

9. Retaining Information and Retention Period

10. Your Privacy Rights and Ways to Exercise Your Rights

11. California Consumer Privacy Act (CCPA)

12. Information Security

13. Children’s Online Privacy Protection Act (COPPA)

14. Automatic Data Collection and Opt-out Procedure

15. Contact our Data Protection Officer

16. Third Party Websites/Applications

17. Duty to Notification

1.  Who We Are


Gazet Factory is an advertising technology company that provides personalized advertisement services by processing certain information related to your online activity (visited websites, products of interest, etc.).  We provide personalized services to relieve the inconvenience of the users from exposures to unassociated advertisements.


2.  General Data Protection Regulation (GDPR)


The GDPR is a data and privacy security regulation developed to protect the privacy rights of EU residents with regard to the processing of their personal data by stipulating certain requirements the entities providing the services should make, implementing use of technical safeguards such as pseudonymization and encryption and higher legal thresholds in handling the user’s personal data, etc.  The GDPR applies to entities that engage in business transaction with EU residents.


The GDPR keeps EU residents informed of how businesses collect, use, share, secure, and process their personal data and, under the GDPR, users have the following rights.


A. The right to be informed; the right to be informed of what personal data is being processed, why, and whom the data may be passed to.


B. The right of access; the right to see what data is being held.


C. The right to rectification; the right to have your data amended if is incorrect.


D. The right to erasure; the right to have your personal data deleted.


E. The right to restrict processing; the right to request cessation of processing personal data.


F. The right to data portability; the right to ask for the provided personal data in a structured, commonly used format.


G. The right to object; the right to object further processing personal data which is inconsistent with the primary purpose of the processing.


H. Rights in relation to automated decision making and profiling; the right not to be subject to a decision based solely on automated processing.


In case where the GDPR applies to our services, we assure compliance with all the requirements established by this regulation.


3.  Types of Information We Collect and Do Not Collect; Categorization of Information


We collect certain information related to your online activity and your device to serve personalized advertisements to you.  Some of this information may be considered as personal data in some jurisdictions, such as the European Union.


The following are some types of information that we may collect:

-  IP address;

device identifiers including cookies and unique device identifiers;

browser type, internet service provider, operating system, mobile carrier;

advertisement impressions and interactions, data concerning the displaying of the advertising, such as date/time/frequency of viewing, and the website or application where the advertisement was displayed;

certain data concerning your activities and actions on the advertiser sites, and

 geolocation (including city, region, country, zip code, etc.).

Date / Time stamp


We do not collect data that might be regarded as sensitive under Article 9 of the GDPR, which includes the user’s race, sexual orientation, political affiliation, religious beliefs, etc. 


The collected personal information can be categorized as follows.


A. Information related to your browsing activity on advertisers’ websites or applications — it helps us understand what sorts of products and services you are interested in and, consequently, determine which advertisements should be displayed to you to match your interests.


B. Information that you are currently entering a publisher’s website or applications, where we may display an advertisement to you — we process this information for the purposes of displaying advertisements, advertisement measurement, product development, and fraud detection.


C. Information regarding the delivery of our advertisements, i.e., impressions of an advertisement (e.g., whether we displayed an advertisement to you and, if so, which advertisement we selected) and your interactions with an advertisement (e.g., whether you clicked on it).  We process this information as a data controller for the purposes of displaying advertisements (in particular for frequency capping and advertisement rotation), advertisement measurement, and product development.


4. How We Collect Personal Information


We use ‘cookies’ stored in your web browser and ‘advertising IDs’ on your mobile device.  Cookies are text files placed on your computer hard drive when you first visit the website and they are used to improve your web browsing experience.  Advertising IDs are device identifiers used on mobile OS to provide personalized information and advertisements.  We can also use other standard web technologies such as ‘tags and pixels,’ ‘software development kits,’ etc. to collect personal information. 


In addition, we may obtain personal information from other sources, including third party online advertising supply chain such as real time bidding markets.



5. How We Use This Information


We use the personal information mentioned above to serve personalized advertisements to you, which we believe will be of particular interest to you. 


The potential processing of information can be divided into three different categories:


A.    Buying advertising slots and managing campaigns

We can deliver advertisements specifically to your mobile phone by using device identifiers and contextual data such as geolocation, visited websites, and time and date of visits.  Managing advertising campaigns means that we use your personal information for ancillary activities, such as enabling standard advertising control or investigating and protecting you from fraudulent or illegal activities.


B.    Monitoring campaign performance

We can track whether the users that click on or simply see the advertisement we manage actually visit our clients’ website and purchase or subscribe to the goods or services provided. 


C.    Retargeting and segmenting

Upon request from our clients, we can create a list of devices which we intend to target in our marketing campaigns.  Since these devices have previously carried out certain activities, such as accessing our client’s website, we can create a list.  In this process, we segment users into different audiences that can be targeted separately.  In such operations, we do not act as a data controller, but as a data processor.


Within the scope of processing personal information, we conduct activities that may be deemed “profiling” of your personal information only to a very limited extent (i.e., analysis of data regarding ad impressions and your interactions with our advertisements for advertisement measurement purposes).


We do, however, conduct profiling with respect to the data related to your browsing activity on advertisers’ websites or applications (i.e., data we process on behalf of advertisers, as a data processor). We analyze it in order to display to you an advertisement that we believe you will be most interested in.


In any case, the profiling does not produce any legal effects toward users or similarly significantly affects them.  In particular, it does not result in price discrimination among the users based on their behavioral profile..



6. Sharing and Transferring of Information


The Company can share the data with other companies in the online advertising industry to carry out the campaign management, performance monitoring, and retargeting and segmenting functioned outlined above.


In particular, we can enter into data processing agreement with the following data recipients:

real time bidding platforms: for the purpose of managing advertisement campaigns;

our clients (i.e. advertising agencies and advertising networks), for the purposes of retargeting and segmenting; and

data trackers, data management platforms, and technology suppliers, for the purpose of performance monitoring, and in order to carry out retargeting and segmenting. 


We do not exceed our limits of permitted use of personal information by overusing the information but only use it in providing personalized advertisement or expose your personal information to outside entity without your consent. 



7. International Information Transfers


All personal information processed by us may be transferred, processed, and stored anywhere in the world, which may have information protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.



8. Processing Information in Aggregate


We process your information in aggregate, anonymous, and non-individual level, to (1) operate and improve technology, (2) conduct research and development, (3) report on campaign performance with our clients, and (4) carry out campaign forecasting.


Data processed in aggregate is not regarded as personal data, as it does not relate to any particular identified or identifiable person.



9. Retaining Information and Retention Period


We may store the information collected, such as IP address and other data described above, for up to 90 days before we aggregate that information into summary reports.


The Company may store the aggregated summary information (which for example, does not include IP address or other information that may be tied to a particular browser or device) for longer than 90 days.



10. Your Privacy Rights and Ways to Exercise Your Rights


You have the right to access your personal information we hold and to ask for correction, update, deletion of your personal information.  You also have the right to withdraw any consent given. 


Since most of the information we store can only identify a particular browser or device, and cannot identify the individual end user, we may require you to provide some additional information to ensure that we provide you with accurate information.


11. California Consumer Privacy Act (CCPA)


This section applies to our processing of personal information that is subject to the California Consumer Privacy Act (“CCPA”).  California residents are protected as “consumers” by the CCPA.


In accordance with the CCPA, you have the following privacy rights.


A.    Right to know


You have the right to know the specific pieces of personal information we have about you; the personal information we have collected about you in the preceding 12 months; the sources from which that personal information was collected; the personal information that we sold or disclosed in the last 12 months; and the purpose for collecting and selling your personal information.


B.    Right to deletion


You have the right to request that we delete the personal information that we have collected or maintain about you.  However, there may be circumstances when we will not be able to delete your personal information.  For instance, when we need to comply with legal obligations or complete a transaction for which your personal information was collected.  If we are unable to comply with your request for deletion, we will let you know the reason why. 


C.    Right to opt-out


You have the right to opt-out of the sale of your personal information.  If you do not affirmatively opt-out, and you are not a minor, your personal information may be sold as disclosed in this Privacy Policy.


D.    Right to equal service


If you choose to exercise any of these rights, we will not discriminate against you in anyway.  If you exercise certain rights, understand that you may be unable to use or access certain features of our websites or services. 


To submit a request to exercise the above rights, please contact us at privacy@gazetfactory.com. 


Once a request is submitted, we will take necessary measures to verify your and/or your authorized agent’s identity, depending on the person who made such request.  This may include requesting information to match with information we already have about you.



12. Information Security


We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice.  Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us.  To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.


By using the services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the services.  If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the services, by mail or by sending an email to you.


13. Children’s Online Privacy Protection Act (COPPA)


We do not purposefully collect, use, disclose personal information of children under 13 years of age or provide our services directed to children.  We comply with the Children’s Online Privacy Protection Act, and in case children’s personal information is provided to us without a consent from a parent, please contact our Data Protection Officer and said information will be deleted. 



14. Automatic Data Collection and Opt-out Procedure


You may opt-out of receiving personalized marketing communications or other services provided by us from the below platforms.


- Web browsers: Internet Explorer, Chrome, Firefox, Safari, Naver Whale, MS Edge, etc.

- Any devices supporting iOS, Android OS


Since the services are provided based on based on the browser cookie and mobile device settings, once opted-out the settings are reverted to default setting.

In addition, given that cookies are stored in a particular browser, the personalized advertisement may appear if you use another browser or device.


Standard advertisement can be displayed even after opting-out from receiving personalized advertisements.



15. Data Protection Officer


We designate Data Protection Officer who collects feedback and assists you with handling possible complaints.  Our Data Protection Officer can be contacted as below. 


Data Protection Officer

Name: Jonathan Lee

E-Mail: privacy@gazetfactory.com

Address: 06619 410, 4F, Platinum Tower, 398 Seocho-daero, Seocho-gu, Seoul, Republic of Korea


You may make a complaint regarding the processing of your personal information in connection with receiving our services to the Data Protection Officer or other appropriate department in charge.  We will quickly respond to your reports and complaints. 

If you need to file a report or receive consultation, please contact the below institutions.


KISA Personal Information Infringement Center

Supreme Prosecutor’s Office Cybercrimes Department

Korean National Police Agency Cyber Bureau



16. Third Party Websites/Applications


This Privacy Policy does not apply to other websites/applications which may be linked in our services provided by us.  These third party services are not controlled by us.  We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications.



17. Duty to Report


Any change to this Privacy Policy will be notified on the ‘Notification’ page.





Last Updated : 21st of Jan, 2021




ADDRESS  5F Platinum Tower, 398 Seocho-daero, Seocho-Gu, Seoul, Republic Of Korea, 06619

CONTACT  Email : team@gazetfactory.com


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