Legal

BigaBid Privacy Policy and Notice

Updated: February 13th, 2024

Biga Bid Media Ltd. (“BigaBid“, “we“, “our” or “us“) develops and provides data-driven performance marketing solutions for the mobile advertising industry, which allow us to bid on, and engage with individuals on behalf of mobile advertisers (our “Clients”) with a view to specifically target end users (“End Users”) who are most likely to become high-value users of their mobile applications. In addition, BigaBid acts as a DMP (Data Management Platform), creating audience related insights for optimizing ad performance (collectively, the “Services”).

We respect the privacy of visitors to our website (“Visitors”), our Clients and their representatives, the End Users, our employees and employment candidates (collectively, as applicable – “Data Subjects”, or “you”), and are committed to making our practices regarding their Personal Data transparent and fair. This Privacy Policy and Notice (“Policy”) describes how we collect, store, use, disclose and otherwise process personal data, and our role as “Data Controller” or “Data Processor” with respect to each of our data processing activities.

Specifically, this Privacy Policy describes our practices regarding:

Please read this Privacy Policy carefully and make sure that you fully understand and agree to it. If you do not agree to this Privacy Policy, please discontinue, and avoid using our Services.

You are not legally required to provide us with any Personal Data (defined below), but without it we may not be able to provide you with the full range of Services or with the best user experience when using our Services. To learn more about the choices available to you, please read Section ‎8 below.

Data Collection

We collect Personal Data regarding our Clients and their representatives. This includes names and contact details, as well as transaction history.

We also collect Personal Data regarding Visitors. Such data is typically collected and generated through the Visitor’s interaction with our Services, through automatic means, directly from such Visitor, or from other third parties.

When we collect data about our Clients and their representatives, as well as data about our Visitors, we are the Controller of the Personal Data. We are also the Controller of the Personal Data we collect about our employees and employment candidates.

We collect Personal Data regarding End Users, as our systems consider and bid on the opportunity to engage with them and show them our Clients’ advertisements (“Bids”); and following successful Bids and engagements, as we monitor the performance of our Services on behalf of our Clients. When we collect data of End Users for a particular Client, that Client is the Data Controller and we act as a Data Processor on behalf of our Client. When we collect End Users’ data in order to improve the Services to all our Clients, we act as Data Controller.

Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, will be deemed as “Personal Data“):

1. Data automatically collected or generated: When you visit, interact with or use our Services, or when we engage in Bids (and following successful Bids and engagements with you), we may collect or generate certain technical data about you. We collect or generate such data either independently or with the help of third party services (as detailed in Section 4 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 5 below). Such data mainly consists of connectivity, technical and aggregated usage data, such as IP addresses, unique advertising IDs (e.g. IDFA; you may reset such ID by following the instructions below), data regarding your device (such as type, screen resolution), operating system, app version, mobile carrier, in-app events and various apps usage statistics, browser version, locale and language settings used, visit history, search keywords, activities and actions on the website, general End User location (city, country, zip code), date and time stamp, types of advertisements viewed and click data, the pixels installed on such device, and the activity (clicks and other interactions) of Visitors and Clients in connection with our Services. Such data does not enable us to learn a person’s true identity or contact details. Nevertheless, it is possible that putting many of these data points together with additional outside data would enable someone to identify you. We therefore treat this data as Personal Data and take strong precautions to secure your data and ensure that outside actors cannot access it. We mainly use this data to gain a better understanding on how Visitors, Clients and End Users typically use and interact with our Services; how we could improve their user experience; to optimize our product; and to optimize the overall performance of our Services.
2. Data received from our Clients: Clients and their representatives may provide us with Personal Data such as their first and last name, address and email (collectively, “Account Data“), as well as any other data they choose to provide when contacting us. Clients may provide us additional Account Data such as their billing details, business needs and preferences. To the extent that such data concerns a non-human entity (e.g. the bank account of a company or business), we will not regard it as “Personal Data” and this Privacy Policy shall not apply to it. Clients may also provide us with Personal Data concerning their colleagues or employees, in order to register them to our Services. Such Data usually refers to first names/nicknames and work e-mails, however additional data may be provided at the Client’s discretion.
3. Client Data received from third parties: we may receive your Personal Data from other sources. For example, if you participate in an event or webinar that we sponsor or participate in, we may receive your Personal Data from the event organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our business partners or services providers, and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn.
4. End User Data received from third parties: we receive Personal Data relating to End Users from Ad Exchange networks, DMPs, Clients and mobile app publishers who share their users’ data with us (whether directly or via the Ad Exchanges).
5. Careers: If you wish to apply for a job with us, we will collect the Personal Information you choose to provide on your resume, such as your education and employment experience. You may also apply through a third-party platform, such as LinkedIn or Comeet. If you do so, we will collect the Personal Information you make available via those third-party platforms. We may also obtain information from third parties such as referees. If you apply for a job with us and are unsuccessful, we will retain your data for a period of 6 months in the event that another opportunity arises and we wish to contact you again. If you are an employee, the sort of information we hold includes your application form and references, your contract of employment, correspondence with or about you, information needed for payroll, benefits and expenses purposes, contact and emergency contact details, records of holiday, sickness and other absence, medical notes and reports, information needed for equal opportunities monitoring, records relating to your career history, such as training records, appraisals, and, where appropriate, disciplinary and grievance records. We also sometimes hold clocking-in/out data. In addition. you will inevitably be referred to in many company documents and records that are produced by you and your colleagues in the course of carrying out your duties and the business of the company. Where necessary, we may keep information relating to your health, which could include reasons for absence and doctors’ reports and notes. We need this data to administer and manage sick pay, and insurance. Your personal data will be stored for the duration of your employment, and for a period of seven years following the termination of your employment, unless it must be held longer for legal, regulatory, compliance or contractual reasons.

Data Uses

We use Personal Data as necessary for the performance of a contract to which you are party or with a view to enter into a contract with you; to comply with applicable law; subject to your explicit consent; or to support our legitimate interests in maintaining and improving our Services and offerings, optimizing our marketing and advertising services, customer service and support operations, and protecting and securing our Visitors, Clients, End Users, ourselves and our Services. With regards to the Personal Data of End Users when we act as Processor, we use Personal Data to provide Services to our Clients who are the Controllers of such Personal Data.

We do not sell or share your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).

Specifically, we use Personal Data for the following purposes:

Processing which is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract:

carrying out our obligations arising from any contracts entered into between you or your employer and Bigabid and to provide you with the information, and Services that you request from Bigabid;
carrying out our obligations arising from your employment contract with us;
administering your account with Bigabid including to identify and authenticate you;
verifying and carrying out financial transactions in relation to payments you make in connection with the Services;

Processing which is necessary for the purposes of the legitimate interests pursued by Bigabid or by a third party of providing efficient and wide-ranging Services to our Clients:

notifying you about changes to our Services;
contacting you for the purpose of providing you with technical assistance and other related information about the Services;
replying to your queries, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity;
contacting you to give you commercial and marketing information about promotions or services offered by Bigabid which may be of interest to you;
soliciting feedback in connection with your use of the Services;
processing to manage and deliver Bids and advertisements more effectively, including contextual, behavioral and interests-based advertising based on End User activity, preferences or other data available to us or to our business partners, including for re-targeting purposes;
processing to further develop, customize and improve the Services, based on common or personal preferences, experiences and difficulties;
processing carried out to pursue our legitimate interests of running our business in an efficient manner, when those interests are not overridden by your fundamental rights.

Processing which is necessary for compliance with a legal obligation to which Bigabid is subject:

compliance and audit purposes, such as meeting our reporting obligations in our various jurisdictions, and for crime prevention and prosecution in so far as it relates to our staff, customers, facilities etc;
processing which is necessary to comply with our employment-related legal obligations;
if necessary, we will use Personal Data to enforce our terms, policies and legal agreements, to comply with court orders and warrants and assist law enforcement agencies as required by law, to collect debts, to prevent fraud, infringements, identity thefts and any other service misuse, and to take any action in any legal dispute and proceeding;

Processing which is based on your consent

Sending you promotional materials by email if you have signed up to receive our newsletter. You may withdraw your consent at any time by clicking unsubscribe at the bottom of the email or by sending an email to privacy@bigabid.com.

Data Location & Retention

Data Location: We and our authorized Service Providers (defined below) maintain, store and process Personal Data in the United States, the European Union, Israel and other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.

Biga Bid Media Ltd. is headquartered in Israel, a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents. While privacy laws may vary between jurisdictions, BigaBid and its affiliates and Service Providers are each committed to protect Personal Data in accordance with this Privacy Policy, with the standards of GDPR, with customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.

To the extent that we store or transfer the Personal Data of European residents outside of the EU or Israel, such transfers are subject to the European Commission’s Standard Contractual Clauses, and we ensure that the standards of GDPR are maintained when the data is transferred outside of the EU.

Data Retention: We retain Personal Data of Visitors and prospective Clients for as long as reasonably necessary in order to maintain and expand our relationship and to provide them with our Services.

We retain Personal Data of Clients as necessary for us to provide them with our Services, to comply with our legal and contractual obligations, and to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our data retention policy.

We retain Personal Data of End Users in accordance with the instructions of our Clients, as necessary for continuously optimizing the display and performance of our Clients’ ads, and to gain further insights based on the aggregation of data available to us. At the request of our Client, we will permanently delete or return to our Clients the Personal Data of End Users.

Please note that except as required by applicable law, we are not obligated to retain your Personal Data for any particular period, and we are free to securely delete or anonymize it for any reason and at any time, with or without notice to you.

If you have any questions about our data retention policy, please contact us by email at privacy@bigabid.com.

Data Sharing

Legal Compliance: We may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own (e.g. hosting services, data analytics services, marketing and advertising services, data and cyber security services, payment processing services, e-mail distribution and monitoring services, HR and Payroll services, and our business, legal and financial advisors) (collectively, “Service Providers“). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes. Whenever we use Service Providers, we will ensure that we enter into an agreement with them and that they commit to protecting your Personal Data in accordance with GDPR, any other applicable data protection laws and with this Privacy Policy.

One of our Service Providers in particular is Google, which provides a tool called “Google Analytics”, used by us to track and analyze the use of our Services, for internal purposes. To learn more about how Google uses data from our use of Google Analytics, we recommend you review Google’s policies located at: google.com/policies/privacy/partners. For additional information, please see Google Analytics’ opt-out web tool available at: https://tools.google.com/dlpage/gaoptout.

Sharing End User Personal Data with or on behalf of our Clients: We may share the Personal Data of End Users in accordance with the reasonable instructions of our Clients, each acting as the “Data Controller” of such data, as we act as the “Data Processor” and process such End User data on their behalf. For example, based on a Client’s instructions, we may share their End Users’ Personal Data with another service provider also processing such Personal Data on such Client’s behalf.

Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of BigaBid, any of our Clients or Visitors, End Users, or any members of the general public.

BigaBid Subsidiaries and Affiliated Companies: We may share Personal Data internally within our group for the purposes described in this Privacy Policy. In addition, should BigaBid or any of its subsidiaries or affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.

For the avoidance of doubt, BigaBid may share your Personal Data in additional manners, pursuant to your explicit consent, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.

Cookies and Tracking Technologies

Subject to your Explicit Consent on the first occasion that you use our Services, our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide, secure and improve our Services, personalize your experience and monitor the performance of our activities and campaigns.

A “cookie” is a small text file that is used, for example, to collect data about activity on our Services. Some cookies and other technologies serve to recall Personal Data, such as an IP address, previously indicated by the Visitor, Client or End User. We recommend the use of cookies for an optimal user experience of our Services.

While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser, most browsers allow you to control cookies, including whether or not to accept them and to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

If you wish to prevent the use of your mobile device’s advertising ID (e.g. for interest-based advertising), you may change your device settings to reset such advertising ID or to opt-out of such advertising (typically, this is available under the “Privacy” or “Ads” section in your device settings). You may also change your browser settings to reset or block cookies (typically, this is available under the “Settings” or “Help” section in your browser menu).

If you are an End User who lives in the USA, Canada or Europe, you can also opt-out from the collection of your data by our Clients who participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices (for US users), www.youradchoices.ca/choices (for Canadian users) or www.youronlinechoices.com (for European users).

Please note that if you reset your advertising ID or opt-out of interest-based advertising, you may still see advertisements served by BigaBid, or on any other channels, but those ads will not be targeted based on the above mentioned identifiers. For example, such ads may be instead based on context, such as your progress and actions in a certain app, or your language preferences. Please note that such actions may result in a less enjoyable user experience.

Communications

Service Communications: We may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, etc. We may also send you notifications, messages and other updates. Typically, you will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.

Notifications and Promotional Communications: Subject to your explicit consent, we may also send you notifications about new features, offerings, events and special opportunities or any other information we think our Visitors or Clients will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.

If you do not wish to receive such promotional communications, you may notify BigaBid at any time by sending an email to privacy@bigabid.com or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.

Data Security

In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any Service Providers as described in Section 4 above.

Data Subject Rights

Depending on your location, you may have certain rights in relation to your Personal Data, including the rights to access, or request modification or erasure of your Personal Data. If you wish to exercise your rights under any applicable law, including the EU General Data Protection Regulation (GDPR) or the California Privacy Act (CCPA) such as the right to request access to, and rectification or erasure of your Personal Data held with BigaBid, or to restrict or object to such Personal Data’s processing, or to port such Personal Data (each to the extent available to you under the laws which apply to you)– please contact us by email at privacy@bigabid.com.

Please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.

If you are an End User, you should contact the relevant Client, acting as the Controller of your Personal Data (see Section 10 below for more details).

Children’s Privacy

Our Services are not designed to attract children under the age of 16. We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that we collect data relating to a person under the age of 16, we will make all efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by email at privacy@bigabid.com.

Data Controller/Processor

Certain data protection laws and regulations, such as the GDPR and CCPA, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller” (or under the CCPA, the “Business”) who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA, the “Service Provider”) , who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.

BigaBid is the “Data Controller” of its Visitors’ and Clients’ Personal Data, and with respect to which, assumes the responsibilities of Data Controller (solely to the extent applicable under law), as set forth in this Privacy Policy. BigaBid is also a Controller of the data of its employees and employment candidates.

When Bigabid processes the Personal Data of End Users to provide the Services to a Client, Bigabid acts as a “Data Processor” on behalf of its Client who is the “Data Controller”. Such data may be shared with the Client in accordance with this Privacy Policy and in accordance with their reasonable instructions and our agreements with them. The Client will be responsible for meeting any legal requirements applicable to Data Controllers such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control). We also process End Users’ data in order to improve the Services we offer to all our clients. When we are not acting on behalf of a particular Client, we process End Users’ data as a Data Controller in accordance with this Privacy Policy.

If you would like to make any requests or queries regarding Personal Data we process on our Client’s behalf, please contact them directly. For example, if you wish to access, correct, or delete data processed by BigaBid on behalf of a Client, please direct your request to the relevant Client (who is the “Data Controller” of such data). Should we receive such requests directly, we will refer them to our Client.

Additional Notices

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Website. The amended version will be effective as of the date it is so published. We will provide a 10-day prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.

External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services for the website or application of such third parties and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Services.

Questions, Concerns or Complaints: If you have any comments or questions about this Privacy Policy or if you have any concerns regarding your Personal Data, please contact our data protection team by email at privacy@bigabid.com.

MyEDPO has been designated as BigaBid’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. Inquiries regarding EU privacy practices may be sent to MyEDPO Ltd, Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork, Ireland, or by email to privacy@bigabid.com. If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.