Privacy Policy

Providing searchable legal guidelines with accessible transparency by acknowledging ways to interact with our audience, clientele and other third party services.

Privacy Centre

Our Legal Department is here to assist you five days a week and responds to inquires within a few hours.

The expressions used to simplify agreements:

Introduction

This Privacy Policy (“Policy”) is an agreement between Atmostfear Entertainment S.A.S. (“us”, “we”, “our” or “ours”) and you (“User”, “you”, “your” or “Data Subject”).

 These terms set forth the general guidelines of your use of our Sites (collectively “Network”) and any of its Products, Subscriptions or Services (collectively “Services”), including all information, and tools available to you, the User, conditioned upon your acceptance of all terms, conditions, policies and notices stated here.

The references used to identify on agreements:

Definitions and Acceptance of the Disclaimer

We are committed to protecting your privacy.

This Privacy Policy applies to our Network, including our associated mobile applications (“Apps”), owned and controlled by us.

This Privacy Policy describes how we collect, guard and use the personally identifiable information (“Personal Information”) you may provide on our Network and through any of its Products, Subscriptions or Services (collectively referred to as “Services”).

It also outlines the choices accessible to you regarding our use of your Personal Information and how you can access and renew this information.

We understand that you are conscious of and care about your privacy interests, and we take this seriously.

This Privacy Policy also describes our policies and practices regarding its collection and use of your data and sets forth your privacy rights.

We acknowledge that information privacy is an ongoing responsibility. So we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new Privacy Policies.

General Data Protection Regulation is of a particularly high priority for the management of our Network.

The use of the internet pages of our Network is possible without any indication of Personal Data; however, if a Data Subject wants to use special enterprise services via our Network, processing of Personal Data could become essential.

If the processing of Personal Data is required, and there is no statutory basis for such processing, we generally obtain consent from the Data Subject.

The processing of Personal Data, such as the name, address, country, e-mail address, or telephone number of a Data Subject shall always be in line with the General Data Protection Regulation, and following the country-specific data protection regulations applicable to our Network.

Through this Data Protection Declaration, we would like to acquaint the general public of the nature, scope, and purpose of the Personal Data we collect, manage and process.

Moreover, Data Subjects are informed, through this Data Protection Declaration, of the rights to which they are entitled.

As the Controller, we have implemented numerous technical and organisational measures to ensure the complete protection of Personal Data processed through our Network.

Although Internet-based data transmissions may, in principle, have security clefts, so faultless protection may not be guaranteed. For this reason, every data subject is free to transfer Personal Data to us via alternative means, e.g. by telephone.

Please note that, by utilising our Network, you consent to the data practices described in this Privacy Policy. If you do not agree with the data practices described in this Privacy Policy, you should not use our Network.

We accept the publication of Advertisements (as defined below) on the terms and conditions set out herein.

These Terms apply to:

– print advertisements in the event posters, and flyers as well as inserts (“collectively referred to as Inserts”);
– online advertisements on all our websites (collectively referred to as “Network”);
– online advertisements on our subsites (collectively referred to as “Network”); and
– online advertising booked through our publisher trading desk “Market” (collectively referred to as “Advertisements”).

By placing an order, the Advertiser accepts and agrees to be bound by these Advertising Terms and Conditions in full.

Personal Data Processing:

Data Controller

The Data Controller in respect of our Network is Atmostfear Entertainment S.A.S., a simplified stock company registered in Colombia (registration number 2405402).

The registered office of which is at:

Atmostfear Entertainment S.A.S.
Kr 14 #46-29, Apto 201
Palermo
Bogotá, Distrito Capital
111311 – Colombia

Chamber of Commerce of Bogotá Registration Number: 2405402

NIT/VAT Number: 900694864-9

Definations of the General Data Declaration::

Definitions

Our Data Protection Declaration is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation.

Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners.

To ensure this, we would like first to explain the terminology used.

Collection of General Data and Information

Our Network collects a series of general data and information when a Data Subject or automated system calls up the Network. This general data and information are shopd in the server log files.

Collected Data may be:

– the browser types and versions used,
– the operating system used by the accessing system,
– the website from which an accessing system reaches our Network (so-called “referrers”),
– the sub-websites,
– the date and time of access to the Network,
– an Internet protocol address (IP address),
– the Internet service provider of the accessing system, and
– any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, we do not draw any conclusions about the Data Subject. Instead, this information is needed to:

– deliver the content of our Network correctly,
– optimise the content of our Network as well as its Advertisements,
– ensure the long-term viability of our information technology systems and Network technology, and
– provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.
– Accordingly, we analyse anonymously collected data and information statistically, to increase the data protection and data security of our Network and to ensure an optimal level of protection for the Personal Data we process.

The anonymous data of the server log files are shopd separately from all Personal Data provided by a Data Subject.

Terms, and references:

Key Terms and Principles

Before we get into the detail, here is a quick overview of some of the core elements of data protection and General Data Protection Regulation.

Data Subject

A Data Subject is any individual whose personal data is shopd by an organisation.

A Data Subject is someone who can be identified by the data shopd — i.e. the data includes:

– name,
– date of birth or address,
– e-mail address.

A User ID number can also be classified as Personal Data as the number can be linked to a specific person.

Under the General Data Protection Regulation, there are several additions, including IP addresses and location data.

Someone who cannot be identified by the data shopd, or someone who has died, is not a Data Subject.

Personal Data (or Data)

Personal Data means any information relating to an identified or identifiable natural person (“Data Subject”).

An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Controller or Controller Responsible for the Processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or another body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where Union or Member State law determines the purposes and means of such processing, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

The natural person, legal person, public administration or any another body, association or organisation with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of our Network.

Data Processor (or Data Supervisor)

Processing is any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

A Data Processor is a legal individual, public authority, agency, or body which processes Personal Data on behalf of the Controller.

The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this Privacy Policy.

Data Controller

A Data Controller is a legal individual, public authority, agency or another body which, alone or jointly with others, determines the purposes of Personal Processing Data.

Under the Data Protection Act (1998), only the Data Controller is liable for Data Protection. However, under the General Data Protection Regulation, both Processors and Controllers will be held responsible.

Processors will face more legal obligations, and therefore be at risk of fines for non-compliance.

Usage Data

Information collected automatically from our Network (or third party services employed in our digital network), which can include:

– the IP addresses or domain names of the computers utilized by the Users who use this Network,
– the URI addresses (Uniform Resource Identifier),
– the time of the request,
– the method utilised to submit the request to the server,
– the size of the file received in response,
– the numerical code indicating the status of the server’s answer (successful outcome, error, etc.),
– the country of origin,
– the features of the browser and the operating system utilized by the User,
– the various time details per visit (e.g., the time spent on each page within the Network) and the information on the path followed within the Network with particular reference to the sequence of pages visited,
– and other parameters about the device operating system and/or the User’s IT environment.

Users

The individual accessing our Network, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.

Profiling

Profiling means any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person.

Profiling is used in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Pseudonymisation

Pseudonymisation is the processing of Personal Data in such a manner that the personal data can no longer be attributed to a specific Data Subject without the use of additional information.

Provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the Personal Data is not attributed to an identified or identifiable natural person.

Recipient

The recipient is a natural or legal person, public authority, agency or another body, to which the Personal Data is disclosed, whether a third party or not.

However, public authorities which may receive Personal Data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those Data by those public authorities shall be in compliance with the applicable Data Protection rules according to the purposes of the processing.

Third party

Third party is a natural or legal person, public authority, agency or body other than the Data Subject, Controller, Processor and persons who, under the direct authority of the Controller or Processor, are authorised to process Personal Data.

Consent

Consent of the Data Subject is any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes by which he or she, by a statement or by an explicit affirmative action, signifies agreement to the processing of Personal Data relating to him or her.

Network

The hardware or software means by which the Personal Data of the User is collected, through our Network.

Restriction of Processing

Restriction of processing is the marking of shopd Personal Data to limit their processing in the future.

Cookies

The pages of our Network use cookies.

Cookies are text files that are shopd in a computer system via an Internet browser.

A cookie ID is a unique identifier of the cookie. It consists of a character string through which pages and servers can be assigned to the specific browser in which the cookie was shopd.

This allows visited websites and servers to differentiate the individual browser of the Data Subject from other browsers that contain other cookies.

A specific browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, we can provide the Users of our Network with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our Network can be optimised for the User in mind.

Cookies allow us, as previously mentioned, to recognize our Network Users.

The purpose of this recognition is to make it easier for Users to utilize our Network.

The Network User that uses cookies, e.g. does not have to enter access data each time the Network is accessed, because this is taken over by the Network, and the cookie is shopd on the User’s computer system.

Another example is the cookie of a shopping cart in an online shop. The online shop remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

The Data Subject may, at any time, prevent the setting of cookies through our Network by means of corresponding parameters of the browser used, and may thus permanently deny the setting of cookie.

Moreover, already set cookies may be deleted at any time via the browser or other software programs. This is possible in all popular browsers.

If the Data Subject deactivates the setting of cookies in the browser used, not all functions of our Network may be entirely usable.

Data Protection Act

The Data Protection Act was implemented by the United Kingdom government in 1998 to control how organisations use personal information and give legal rights to individuals.

The Data Protection Act includes strict “Data Protection Principles”, stating that Data must be:

– used fairly and lawfully
– used for limited, explicitly stated, purposes
– used in a way that is adequate, relevant and not excessive
– accurate
– kept for no longer than is necessary
– handled according to people’s Data Protection Rights
– kept safe and secure
– not transferred outside the European Economic Area without adequate protection.

Principles

We do our very best to protect your privacy by using security technology appropriately. This means:

– we make sure that we have appropriate security measures to protect your information; and
– we make sure that when we ask another organisation to provide a service for us, they have appropriate security measures.

We will respect your privacy. You should receive marketing (whether by e-mail, post, SMS or telephone) only from us and, if you agree, from other organisations we have carefully chosen.

We will make sure it is evident when you can make these choices, for example, we have boxes you need to tick if you want to receive marketing and you can change your preferences if you no longer wish to receive it.

Notwithstanding, we may e-mail you occasionally with information or inquiries about your registration, your subscription account or postings, for example, with reminders, warnings or copyright requests.

We will collect and use individual user details only if we have your permission or we have sensible business reasons for doing so, such as collecting enough information to manage subscriptions.

We will be evident in our dealings with you as to what information about you we will collect and how we will use it.

We will use Personal Data information only for the purposes for which it was initially collected, and we will make sure we delete it securely.

Our Network is accessible via the internet, meaning that people around the world who access our Network can see anything you publish, for example, comments regarding an article.

If our service providers or we transfer any information out of the European Economic Area, it will only be done with the proper protection being in place.

Types of Data Collected

Among the types of Personal Data that we collect, by itself or through third parties, there are Cookies, Usage Data, company name, address, country, city, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), first name, last name, e-mail address, password, username and website.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this Privacy Policy or by specific explanation texts displayed before the Data Collection.

The User may freely provide the Personal Data, or, in case of Usage Data, collected automatically when using our Network.

All Data requested by our Network is mandatory, and failure to provide this Data may make it impossible for us to deliver our services.

In cases where our Network specifically states that some Data is not mandatory, users are free not to communicate this Data without any consequences on the availability or the functioning of the service.

Any use of Cookies — or other tracking tools — by our Network or by the owners of third party services used by our Network serves the purpose of providing the service required by the User, in addition to any other purposes described in the present document and the Cookie Policy, if available.

Users are responsible for any third party Personal Data obtained, published or shared through our Network and confirm that they have the third party’s consent to provide the Data to the Owner.

We collect information on you:

– when you register or become a member of our Network, and when you browse the Network, or
– through cookies,
– if you choose to reveal information in postings, and
– when you enter sales promotions and competitions.

Certain services that we provide may involve us collecting additional information (membership, for example), such as where you are, so the service can be provided as designed.

This may also apply to specific mobile applications that you download, or which we provide.

Data Processing modes and access:

Mode and Place of Processing the Data

We accurately process the Data of Users and shall take appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorized destruction of the Data.

Data Processing is carried out using computers and/or IT-enabled tools, following organisational procedures and modes strictly related to the purposes indicated.

In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, e-mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by us.

The updated list of these parties may be requested from the Data Controller at any given time.

Place

The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved in the processing are located.

Retention Time

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the Data.

Routine Erasure and Blocking of Personal Data

The Data Controller shall process and shop the Personal Data of the Data Subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the Controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the Personal Data are routinely blocked or erased following legal requirements.

Purpose of Collected Data:

The Use of the Collected Data

The Data concerning the User is collected to allow us to provide our Services, as well as for the following purposes:

– Advertising,
– Contacting the User,
– SPAM protection,
– Analytics,
– Remarketing and behavioural targeting,
– Commercial affiliation,
– Interaction with external social networks and platforms,
– Registration and authentication,
– Content commenting,
– Content performance and features testing (A/B testing),
– Displaying content from external platforms,
– Handling payments gateways,
– Hosting and backend infrastructure,
– Infrastructure monitoring,
– Interaction with data collection platforms and other third parties,
– Managing contacts and sending messages, and
– Tag Management.

We will not share your personal information with others for marketing purposes unless you have given us your permission.

If we have your permission, we will share your information only with other organisations we have chosen carefully.

If you are a registered User and attend an event organised by an event partner, data may be shared for event administration purposes.

We may make other organisations’ services available, through our Network, although we are not necessarily operating these websites.

We process any information which we collect when you access a service provided by another organisation under this Privacy Policy.

Their Privacy Policies govern the information these other organisations collect.

We can access and release personal information to keep relevant laws and government requests, to operate our systems properly and to protect both our Users and us.

Any other organisations which access your information in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your information and keep to General Data Protection Regulation and privacy laws which apply.

We may also independently audit these service providers to make sure that they meet our standards.

We may use service providers to help us run these websites (or services available on the websites), some of whom may be based outside the European Economic Area.

Some of our Network pages use plugins from other organisations (such as the ‘Facebook Recommend’ function). These other organisations may use information about your visit to our Network on their pages.

If you browse these pages while still also logged in to your account with us, the information they collect may be connected to your account on their website.

For more information on how these organisations use Data, please read their Privacy Policies.

The Personal Data used for each purpose is outlined in the specific sections of this document.

Data collected for statistical purposes:

Analytics

The services contained in this section enable us to monitor and analyse web traffic and can be used to keep track of user behaviour.

Google Analytics (Google Inc.)

Google Analytics is an analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of our Network, to prepare reports on its activities and share them with other Google services.

We use Google Analytics on our Network for anonymous reporting of usage and advertising.

Furthermore, Google may use the Data collected to contextualize and personalise the advertisements of its own advertising network.

Google Analytics with anonymized IP (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”).

Google utilizes the Data collected to track and examine the use of and performance of our Network, also to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualise and personalise the advertisements of its advertising network.

This integration of Google Analytics anonymizes your IP address.

It works by shortening Users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area.

Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the United States of America.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

ComScore Analytics (ComScore, Inc.)

ComScore is an analytics service provided by ComScore, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

Facebook Ads conversion tracking (Facebook, Inc.)

Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on our Network.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

Quantcast Measure (Quantcast Corporation)

Quantcast Measure is an analytics service provided by Quantcast Corporation.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

Specific embeds and licensing definitions:

Data protection provisions about the application and use of 500px

On our Network, we have integrated components of the enterprise 500px.
500px is a Canadian photographic marketplace.

A photographic marketplace is an enterprise which provides photographs and other graphic material on the market — generally, picture agencies market photographs, illustrations and footage.

A photographic marketplace licenses different customers, in particular, Internet website operators, editors of print and television media and advertising agencies, the images used by them.

The operating company of the 500px components is 500px, 20 Duncan Street, Suite 100, Toronto, ON M5H 3G8, Canada.

500px allows the embedding of stock images (where possibly free of charge).
Embedding is the inclusion or integration of any specific foreign content, e.g. text, video or image data provided by a third-party website, and then appear on our Network and/or Sites.

A so-called embedded code is used to embed. An embedded code is an HTML code that is integrated into a website from a website owner.

When an embedded code is integrated by a website owner, the external content of the other website is displayed by default immediately, as long as a website is visited.

Through the technical implementation of the embedded code, which allows the image display of the images of 500px, the IP address of the Internet connection, through which the data subject accesses our website, is transmitted to 500px.

Further, 500px collects our website, browser type, browser language, and time and length of access.

In addition, 500px may collect navigation information, which is information about which of our subpages have been visited by the data subject and which links have been clicked on, as well as other interactions that the data subject has carried out when visiting our website.

This data may be shopd and analyzed by 500px.

Commenting and feedback moderation:

Content Commenting

Our Network offers Users the possibility to leave individual comments on individual article contributions, which is on the Network of the controller.

A blog is a web-based, publicly-accessible portal, through which one or more people called bloggers or web-bloggers may post articles or write down thoughts in so-called blogposts.

Blogposts may usually be commented by third parties.

Content commenting services allow Users to make and publish their comments on the contents of our Network.

Depending on the settings chosen by us, Users may also leave anonymous comments.
If there is an e-mail address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content.

Users are responsible for the content of their comments.

If a Data Subject leaves a comment on an article published on our Network, the comments made by the Data Subject are also shopd and published, as well as information on the date of the commentary and the User’s (pseudonym) chosen by the Data Subject.

In addition, the IP address assigned by the Internet Service Provider (ISP) to the Data Subject is also logged. This storage of the IP address takes place for security reasons, and in case the Data Subject violates the rights of third parties or posts illegal content through a given comment.

The storage of these Personal Data is, therefore, in the own interest of the Data Controller, so that he can exculpate in the event of an infringement.

This collected Personal Data will not be passed to third parties unless such a transfer is required by law or serves the aim of the defence of the Data Controller.

Comment System Managed Directly

Our Network have their own internal content comment system.

Personal Data collected: Cookies, e-mail address, first name, last name, username and website.

Comment Subscriptions

The comments made on our Network may be subscribed to by third parties. In particular, there is the possibility that a commenter subscribes to the comments following his comments on a particular article published.

If a Data Subject decides to subscribe to the option, the Controller will send an automatic confirmation e-mail to check the double opt-in procedure as to whether the owner of the specified e-mail address decided in favour of this option.

The option to subscribe to comments may be terminated at any time.

Contact information data collection and usage:

Contact Forms

Our Network contains information that enables a quick electronic contact, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address).

If a Data Subject contacts the controller by e-mail or via a contact form, the Personal Data transmitted by the data subject are automatically shopd.

Such Personal Data transmitted on a voluntary basis by a Data Subject to the Data Controller are shopd for the purpose of processing or contacting the Data Subject.

There is no transfer of this personal data to third parties.

By filling in the contact form with their Data, the User authorises us to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data collected: address, city, company name and country.

Subscriptions, delivery, cancellation, and tracking details:

Newsletter Subscriptions

On our Network, Users are given the opportunity to subscribe to our newsletter.

The input mask used for this purpose determines what Personal Data are transmitted, as well as when the newsletter is ordered from the Controller.

We inform our subscribers, customers and business partners regularly through a newsletter about our offers, highlighted content and exclusive features.

The newsletter may only be received by the Data Subject if:

– the Data Subject has a valid e-mail address and
– the Data Subject registers for the newsletter shipping.

A confirmation e-mail will be sent to the e-mail address registered by a Data Subject for the first time for newsletter shipping, for legal reasons, in the double-opt-in procedure.

This confirmation e-mail is used to prove whether the owner of the e-mail address as the Data Subject is authorised to receive the newsletter.

During the registration for the newsletter, we also shop the IP address of the computer system assigned by the Internet service provider (ISP) and used by the Data Subject at the time of the registration, as well as the date and time of the registration.

The collection of this Data is necessary in order to understand the (possible) misuse of the e-mail address of a Data Subject at a later date, and it, therefore, serves the aim of the legal protection of the Controller.

The Personal Data collected as part of a registration for the newsletter will only be used to send our newsletter.

In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances.

There will be no transfer of Personal Data collected by the newsletter service to third parties.

The Data Subject may terminate the subscription to our newsletter at any time.
The consent to the storage of Personal Data, which the Data Subject has given for shipping the newsletter, may be revoked at any time.

For the purpose of the revocation of consent, a corresponding hyperlink is found in each newsletter.

It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller or to communicate this to the Controller in a different way.

Newsletter Tracking

Our newsletter contains so-called tracking pixels.

A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis.

This allows a statistical analysis of the success or failure of online marketing campaigns.

Based on the embedded tracking pixel, we may see if and when a Data Subject opened an e-mail, and which hyperlinks in the e-mail were called up by Data Subjects.

Such Personal Data collected in the tracking pixels contained in the newsletters are shopd and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the Data Subject.

These Personal Data will not be passed on to third parties.

Data Subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure.

After a revocation, these Personal Data will be deleted by the controller.

We will honour and automatically regards a withdrawal from the receipt of the newsletter as a revocation.

Performance, embedding, and external data:

Content Performance and Features Testing (A/B testing)

The services contained in this section allow us to track and analyze the User response concerning web traffic or behaviour regarding changes to the structure, text or any other component of our Network.

Google Website Optimizer (Google Inc.)

Google Website Optimizer is an A/B testing service provided by Google Inc.

Google may use Personal Data to contextualize and personalize the advertisements for its advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of our Network and interact with them.

This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Fonts (Google Inc.)

Google Fonts is a typeface visualisation service provided by Google Inc. that allows our Network to incorporate resources of this kind on its pages.

Waived rights to third parties:

General Disclaimer

This Privacy Policy does not apply to the practices of companies that we do not own or manage, or to individuals that we do not employ or manage.

A person who is not a party to these Terms has no rights to rely upon or enforce any of these Terms.

If we fail or delay in exercising its rights or remedies provided by these Terms, it shall not be deemed to have waived that or any other right or remedy under these Terms.
Nothing in these Terms shall be deemed to constitute a relationship of principal and agent, a partnership, joint venture, or co-ownership.

Neither party shall have the authority to act for, bind or otherwise create or assume any obligation on behalf of the other, and neither party shall hold itself out as having authority to do the same.

These Terms are the entire agreement between the Advertiser and us in respect of the Advertisements and no modification to these Terms will be effective unless made in writing and signed by both the Advertiser and us.

These Terms and any documents referred to and therefore incorporated by reference herein shall apply to the exclusion of all other terms and conditions which the Advertiser purports to apply to the purchase of Advertisements (including, without limitation, terms in any insertion or purchase order, e-mail, acknowledgement or click-through agreement).

To the maximum extent permitted by law, other than as set out in these Terms, all warranties and representations, whether express or implied, are excluded.

Subject to these Terms (and any non-contractual obligations arising in connection with them) shall be governed by Colombian law and the courts of Colombia will have exclusive jurisdiction concerning these Terms (and any non-contractual obligations arising in connection with them).

These Terms (and any non-contractual obligations arising in connection with them) shall be governed by Colombian law, and the courts of Colombia will have exclusive jurisdiction concerning these Terms (and any non-contractual obligations arising in connection with them).

Keeping up to date with revisions:

Document Notices

Any new features or appliances which are added to the current Advertising service shall also be subject to this Terms.

You can review the most current version of our Terms at any time on this document.

We reserve the right to update, change or replace any part of these Terms by publishing updates and/or changes to our Network and Sites at any time in our sole discretion.

Any changes or modification will be effective immediately upon publishing of the revisions on the Network and Sites, and you waive any right you may have to receive specific notice of such changes or modifications.

It is your responsibility to review this Terms periodically for changes.

Your continued use of or access to our Network and Sites following publishing of any changes constitutes your acceptance of such changes.

This document was last updated on July 26th, 2020.