1.1 Arsus Technologies Ltd ("ReklamUp", "we", "us" or "our") is a Google MCM (Multiple Customer Management) partner operating under the brand ReklamUp that provides monetization services to websites and mobile apps. We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 In addition, ReklamUp operates a Supply-Side Platform (SSP) accessible at reklamup.com or exchange.reklamup.com, which intermediates between publishers and multiple demand sources (Demand-Side Platforms, ad networks and direct buyers) through programmatic real-time bidding (RTB) and similar auction mechanisms. The underlying SSP technology is provided by TeqBlaze under a white-label arrangement.
2.1 In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data. The definition of personal data depends on the laws where you are located and can be broadly defined in the European Economic Area, the United Kingdom and Brazil. In these regions, personal data would include pseudonymous identifiers such as your IP address, Google Advertising ID or Apple Identifier for Advertisers.
2.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. Please see the privacy policy of your social media account provider for more information about how your personal data is processed in such cases. The source of the contact data is you and/or your employer.
2.3 We may process your website user account data ("account data"). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings, bank account details and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by our website.
2.4 When we provide Google MCM services, we may process your Google account data ("Google account data"), namely your Google Ad Manager Network ID and Google Ad Manager email address. In such case, Google acts as the data controller. Please see Google's privacy policy (https://policies.google.com/privacy) for more information about how your personal data is processed in such case. The source of the contact data is you and/or your employer.
2.5 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The source of the contact data is you and/or your employer.
2.6 We may process data about your use of our website and services ("usage data"). The usage data may include your Internet Protocol (IP) address, traffic routing data, system configuration information, and other information about traffic to and from our websites and/or platform. The source of the usage data is our website security system, CloudFlare (https://www.cloudflare.com).
2.7 We do not knowingly process personal data of children under the age of 13. If we are made aware that we have received personal data from someone under the age of 13, we will use our reasonable efforts to remove that information from our records. Where applicable law raises the age of children higher than 13, we will do the same.
2.8 We do not knowingly collect and process sensitive data, that is, personal data related to racial or ethnic origin, politic opinions, religious or philosophical belief, trade union membership as well as genetic data, biometric data, data concerning health, sex life or sexual orientation. If we are made aware that we have received sensitive personal data from someone, we will use our reasonable efforts to remove that information from our records.
2.9 When we provide advertising monetisation services to publishers, whether in our capacity as a Google MCM partner ad network or as a Supply-Side Platform (SSP) operating at reklamup.com or exchange.reklamup.com on white-label technology provided by TeqBlaze, our advertising tags, software development kit (SDK) and SSP infrastructure may process limited categories of personal data relating to end users of those publisher properties ("advertising data"). The advertising data may include:
(a) IP addresses, truncated where feasible;
(b) mobile device identifiers, namely the Google Advertising ID (GAID), the Apple Identifier for Advertisers (IDFA), the App Set ID and the Identifier for Vendors (IDFV);
(c) web advertising identifiers, including browser cookie identifiers, pseudonymous user identifiers generated by our SSP platform, identifiers obtained through user-synchronisation with demand partners, and partner-provided or universal advertising identifiers (such as those passed in the user.id, user.buyeruid and user.ext.eids fields of OpenRTB bid requests), where lawfully available and where the user's consent or applicable legitimate interest permits their use;
(d) device characteristics, including device model, operating system and version, browser type and version, language, screen size and time zone;
(e) ad-event data, including bid requests and responses, ad impression and click events, viewability data, ad placement identifiers, referring URL and timestamps;
(f) non-precise location data, namely country and region derived from the IP address; and
(g) privacy signals, namely the IAB Transparency and Consent (TC) string, the IAB Global Privacy Platform (GPP) string and the Additional Consent (AC) string.
The source of the advertising data is the end user's device and the publisher's property. We do not process precise geolocation (GPS) data, authentication-derived identifiers or special categories of personal data through our advertising services.
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Operations - We may process your personal data for the purposes of operating our website, the processing and fulfillment of orders, providing our services, supplying our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.3 Access to our services - We may process your account data to enable you to access our extended services on our website/platform. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.4 Relationships and communications - We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, social media direct messages, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.
3.5 Direct marketing - We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, social media direct messages, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent OR if you are already a customer, our legitimate interests, namely promoting our business and communicating marketing messages and offers to you. You can opt-out at any moment from our direct marketing messages.
3.6 Research and analysis - We may process usage data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is consent OR our legitimate interests when it comes to monitoring, supporting, improving the security of our website, services and business generally.
3.7 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.8 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.8 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.10 Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.9 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person.
3.11 Advertising services - We may process advertising data (as described in clause 2.9) for the purposes and on the legal bases set out in the following table, in accordance with the IAB Europe Transparency and Consent Framework (TCF v2.3):
| Purpose | Description | Legal basis |
|---|---|---|
| Purpose 1: Store and/or access information on a device | Reading and writing cookies, mobile advertising identifiers and limited local storage on the user's device to deliver advertising and respect privacy choices. | Consent (Article 6(1)(a) GDPR and Article 5(3) of the ePrivacy Directive). |
| Purpose 2: Use limited data to select advertising | Selecting contextual (non-personalised) advertising based on the content of the page or application, approximate location and device type, and conducting programmatic auctions in our SSP capacity. | Consent (Article 6(1)(a) GDPR) or legitimate interest (Article 6(1)(f) GDPR). |
| Purpose 7: Measure advertising performance | Counting impressions, clicks, win rates and viewability, and reconciling reporting with publishers and demand partners. | Consent (Article 6(1)(a) GDPR) or legitimate interest (Article 6(1)(f) GDPR). |
| Purpose 9: Understand audiences through statistics | Producing aggregated, non-identifying audience reports for publishers and for internal analysis. | Consent (Article 6(1)(a) GDPR) or legitimate interest (Article 6(1)(f) GDPR). |
| Purpose 10: Develop and improve services | Debugging, optimising yield and auction logic, A/B testing of ad layouts and improving the ReklamUp SDK, platform and SSP configuration. | Consent (Article 6(1)(a) GDPR) or legitimate interest (Article 6(1)(f) GDPR). |
| Special Purpose 1: Ensure security, prevent and detect fraud, and fix errors | Detecting invalid traffic, bot traffic, click fraud, bid-stream abuse and platform manipulation, and investigating incidents. | Legitimate interest (Article 6(1)(f) GDPR). |
| Special Purpose 2: Deliver and present advertising and content | Rendering the advertisement in the placement, completing the auction, formatting and applying frequency capping. | Legitimate interest (Article 6(1)(f) GDPR). |
| Special Purpose 3: Save and communicate privacy choices | Reading and transmitting consent and preference signals through the advertising chain so that user choices are respected. | Legitimate interest (Article 6(1)(f) GDPR). |
3.12 We do not rely on TCF Purposes 3, 4, 5, 6, 8 or 11. We do not build user profiles for personalised advertising, do not personalise content and do not measure content performance. Where the legal basis for our processing of advertising data is legitimate interest, the balancing of interests required by Article 6(1)(f) GDPR is set out in our Legitimate Interest Assessment, available at https://reklamup.com/legitimate-interest.html. End users may exercise their right to object to such processing in accordance with Article 21 GDPR.
3.13 IAB Europe Transparency and Consent Framework - Arsus Technologies Ltd, trading as ReklamUp, participates in the IAB Europe Transparency and Consent Framework (TCF v2.3) and complies with its Policies and Specifications. ReklamUp's identification number within the Framework is [Vendor ID to be inserted upon registration].
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
4.2 Your personal data held in our website database will be stored on the servers of our hosting services provider, namely Hertzner Online GmbH (https://www.hetzner.com/legal/legal-notice), which are located in Germany.
4.3 To ensure the security of our website we use a website security system named CloudFlare. In accordance with section 3.8 of this policy, we may disclose log files including traffic routing data, system configuration information, and other information about traffic to and from our website to Cloudflare, Inc. identified at https://www.cloudflare.com/privacypolicy/ insofar as reasonably necessary for the security of our website. The servers used to process your personal data will depend on your location. The complete list of the servers' locations can be obtained from https://www.cloudflare.com/network/.
4.4 We use Google Workspace (https://workspace.google.com/intl/en_uk/business/) for the operation of our administration, in particular Google Forms, Google Sheets, Gmail and Google Calendar. As such, your personal data will processed by Google and will be stored on Google servers primarily in Europe and possibly in countries outside of the European Economic Area. For more information about Google's data centers for Google Workspace, please visit https://www.google.com/about/datacenters/locations/. You can also find information about Google's privacy policy and practices at https://policies.google.com/privacy.
4.5 Financial transactions relating to our services will be handled by our bank, Türkiye İş Bankası. We will share transaction data with our banks only to the extent necessary for the purposes of processing your payments, invoices, and credit notes, refunding any payments, and dealing with complaints and queries relating to such payments and refunds. You can find information about the banks' privacy policies and practices at https://www.isbank.com.tr/en/privacy-policy.
4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.7 Advertising data (as described in clause 2.9) may be disclosed to demand partners, advertising intermediaries and supply-chain participants to the extent necessary to deliver and measure advertising in accordance with the user's consent or, where applicable, legitimate interest. In our capacity as a Google MCM partner, our principal demand source is Google LLC. In our capacity as an SSP operating at reklamup.com or exchange.reklamup.com, bid requests are transmitted to multiple Demand-Side Platforms (DSPs), ad networks and direct buyers connected to our exchange. Each recipient processes advertising data under its own contractual safeguards and applicable data protection laws.
4.8 SSP technology provider - We use TeqBlaze as the technology provider for the operation of our Supply-Side Platform infrastructure (accessible at reklamup.com or exchange.reklamup.com), including auction processing, bidstream routing, user-synchronisation, reporting and related technical functions. To the extent TeqBlaze processes advertising data on our behalf or otherwise receives advertising data in connection with the operation of our SSP, such processing is governed by a written data-processing agreement and the contractual safeguards required by applicable data-protection law. Information about TeqBlaze is available at https://teqblaze.com.
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a country different from the country where you are located.
5.2 We may process your personal data from any country where we operate and may permit our suppliers and subcontractors to do so from the countries where they operate. Please see the following sections for more details. Except if you are located in the European Economic Area or in the UK, by providing us with your personal data, you consent to the transfer of your personal data to the countries where we and our suppliers and subcontractors operate, in accordance with this Privacy Policy.
5.3 The hosting facilities for our website and platform are situated in Germany. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of Germany.
5.4 The hosting of our Cloudflare, Inc. website security services is situated in the United States of America. Transfers to this country is protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities and incorporated in the Data Processing Addendum that we have entered into with Cloudflare, Inc., a copy of which can be obtained from https://www.cloudflare.com/en-gb/cloudflare-customer-dpa.
5.5 The hosting of Google Workspace is situated in Europe and in the United States of America (see https://www.google.com/about/datacenters/locations/). Transfers to countries outside of the European Economic Area and the UK is protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities and incorporated in the Data Processing Addendum that we have entered into with Google, a copy of which can be obtained from https://cloud.google.com/terms/data-processing-addendum.
5.6 The hosting of your personal data processed by our banks is primarily in Turkey. Since the banks act as data controllers, you can find more information on the way your personal data is processed by our banks on the following links: https://www.isbank.com.tr/en/privacy-policy
5.7 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5.8 Our SSP technology provider, TeqBlaze, operates infrastructure that may process advertising data outside the European Economic Area and the United Kingdom. Transfers to such countries are protected by appropriate safeguards, namely standard contractual clauses adopted or approved by the competent data protection authorities and incorporated in the data-processing agreement we have entered into with TeqBlaze, together with supplementary measures where necessary. A copy of the relevant safeguards may be requested at [email protected].
6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) contact data will be retained for a minimum period of 1 year following the date of the most recent contact between you and us and for a maximum period of 3 years following that date;
(b) account data will be retained for a minimum period of 1 year following the date of closure of the relevant account and for a maximum period of 1 year following that date;
(c) communication data will be retained for a minimum period of 3 years following the date of the communication in question and for a maximum period of 3 years following that date;
(d) usage data will be retained for a maximum period of 2 years following the date of collection;
(e) advertising data (as described in clause 2.9) will be retained for a maximum period of 14 days following the date of collection, after which it will be irreversibly deleted or aggregated to a level at which no individual user can be identified. Aggregated and fully anonymised statistics that contain no personal data may be retained for longer periods for business reporting purposes.
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, for the establishment, exercise or defence of legal claims or in order to protect your vital interests or the vital interests of another natural person.
6.5 Cookies, mobile identifiers and device storage. In order to deliver our advertising services on websites, we may set or read first-party and third-party cookies and use limited local storage on the user's device. In mobile applications, we access mobile advertising identifiers (GAID, IDFA) and similar resettable identifiers made available by the operating system. A complete and machine-readable list of the cookies, local storage keys and mobile identifiers used by ReklamUp, including their purpose and maximum age, is published in our Device Storage Disclosure at https://reklamup.com/device-storage-disclosure.json, in accordance with the IAB Europe TCF Technical Specifications. Cookies and similar technologies are only set or read where the user's consent has been validly obtained, typically through a Consent Management Platform operated by the publisher. Users may withdraw consent at any time through that platform, and may additionally use the controls provided by their operating system or browser, including resetting the device advertising identifier or enabling "limit ad tracking".
7.1 In this Section 7, we have listed the rights that you have under data protection laws and specifically under European Economic Area, Switzerland, UK and Brazil data protection laws. If you are a data subject from California, please see section 7.6.
7.2 Your principal rights under data protection laws are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
7.3 These rights are subject to certain limitations and exceptions.
7.4 You may exercise any of your rights in relation to your personal data by emailing us on [email protected]. Depending on the type of request and in accordance with applicable law, we may take up to 30 days to respond to you. Please also note that, in accordance with applicable law, we may proceed to a verification of your identity before fulfilling your request, this, as a measure of security.
7.5 If you are a publisher or a customer with an account, you can access your personal data at any time, update, rectify, delete it as well as change your communication preferences by logging into your account or by emailing [email protected].
7.6 If you are located in California, you have the following rights:
(a) The right to access the personal data we hold about you;
(b) The right to know what personal data we collect from you before the point of collection
(c) The right to opt in or out of marketing, analytics, and other similar activities;
(d) The right to equal services without discrimination;
(d) The right to request deletion of personal data.
7.7 Because we do not directly identify end users by name and operate only on pseudonymous identifiers in the context of our advertising services, requests in relation to advertising data must include the relevant identifier (such as the Google Advertising ID, the Apple Identifier for Advertisers, the TC string or a cookie identifier) to enable us to locate the data. Where we are unable to identify a data subject from the information provided, the limitations set out in Article 11 of the GDPR apply and we will inform you accordingly. End users may also exercise their choices directly through the Consent Management Platform of the website or mobile application they are using.
8.1 This website is owned and operated by Arsus Technologies Ltd.
8.2 We are registered in Turkey under registration number SL.610 - 085001851 and our registered offices are respectively at Serbest Liman ve Bolge PK 598 Gazimagusa Kktc Mersin 10 Turkey
8.3 Our principal place of business is at Serbest Liman ve Bolge PK 588 Gazimagusa Kktc Mersin 10 Turkey.
8.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website; or
(d) by email, using [email protected].
8.5 EU and UK representatives. To the extent required by Article 27 of the EU GDPR and Article 27 of the UK GDPR, ReklamUp will appoint a representative in the European Union and, where applicable, in the United Kingdom. Once appointed, the representative's name and contact details will be published in this section and may be used by data subjects and supervisory authorities alongside the contact channels set out in clause 8.4. [EU representative and UK representative details to be inserted upon appointment].
9.1 We may update this policy from time to time by publishing a new version on our website.
9.2 You should check this page occasionally to ensure you are happy with any changes to this policy.