WELL DONE! YOU CARE ABOUT YOUR PRIVACY!

We don’t use your personal data for any other purposes not described in this policy.

We are delighted that you have shown an interest in Vuukle’s privacy practices. We are committed to safeguarding the privacy of our website visitors, service users, customers, and partners.

We ("Vuukle") are the “controller” in relation to your data ("Publishers data") and “joint controllers” in accordance with Article 26 GDPR for the joint processing in relation to your “end users data”, accordingly the terms of this “Privacy Notice” and our “Terms and Conditions of Use”.

Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, you should not use our website or our services, or otherwise provide us with your personal data. By using and/or accessing our website and the services or otherwise providing us with your personal data, you acknowledge that you have read, understood, and agreed to this “Privacy Notice” and our “Terms and Conditions of Use”.

GDPR and CCPA a rationalised approach.

We do business on a global scale, and as a such, we are required to meet the demands of privacy regulations and laws of many countries. At a high level, most data privacy legislation imposes many of the same types of obligations on organisations, and much of this regulation requires organisations to offer similar types of rights to individuals.

With that in mind, our data governance program and as a result this “privacy notice” adopts a rationalized approach that applies the strictest standards to meet the requirements of different privacy regulations around the world when seeking a solution to a privacy issue, or providing data subject rights, provided it does not violate any data privacy laws.

Services

Vuukle is an audience engagement and ad revenue monetization platform that provides web-based social widgets to users on third-party websites coupled with real-time analytics and engagement monetisation. The solutions that we provide are:

● Comments System

● Social Share Bar

● Real-Time Analytics

● Reactions Functionality

● Engagement Monetisation

Data we collect

From Publishers: We process data enabling us to get in touch with you "contact data". The contact data may include your name, email address, product or service that you are interested in, and any comments that you would like to refer to us. The source of the contact data is you.

We process your Vuukle’s website user "account data". The account data may include your account identifier, password, name, email address, business name, account creation and modification dates, website settings, and marketing preferences. The primary source of the account data is you, although as an option, and with your explicit consent, some elements of the account data may be collected by social login single sign-on system, accessing existing data from your social networking service.

We 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.

We process information relating to financial transactions that you enter into with us through our website "transaction data". The transaction data may include your name, your contact details, vat ID, payment details, and transaction details. The source of the transaction data is you or our payment service providers.

We process data about your use of our website and services "usage data" including by embedding our code on your websites to analyze the usage of your websites. The usage data may include your IP address, geographical location, browser type, and version, operating system, referral source, length of visit, page views, and website navigation paths, as well as information about the timing, frequency, and pattern of your service use. The source of the usage data is you.

From non-authenticated end-users: When a user opens a page powered by Vuukle technologies we collect "usage data" about “end-users” use of the publisher's website. The “usage data” may include IP address, geographical location, browser type, and version, operating system, referral source, length of visit, page views, and unique internal session ID, website navigation paths, as well as information about the timing, frequency, and pattern of your service use.

From authenticated end-users: When a user opens a page powered by Vuukle technologies and engages in the comment section to express his/her view for which a user has to login we collect "usage data" and “contact data” about “end-users” use of the publisher's website. The “usage data” may include IP address, geographical location, browser type, and version, operating system, referral source, length of visit, page views, and unique internal session ID, website navigation paths, as well as information about the timing, frequency, and pattern of your service use. The “contact data” may include name, profile photo and hashed email addresses. The source of the data is the Publisher end-users.

Purposes of processing & Legal basis

Services - We process your end-users “usage data”, and “contact data” to provide our audience engagement and ad revenue monetization services, as described in the “Services we provide” clause in this privacy notice. The legal basis for this processing is our business “legitimate interest”.

Operations - We process your “contact data”, “transaction data”, “usage data”, and “communication data” to operate our website, providing our services, generating invoices, bills, and other payment-related documentation. The legal basis for this processing is our business legitimate interests.

Communications & Marketing - We use “contact data”, and “communication data” to manage our relationships, communicate with you, and promote our business. The legal basis for this processing is our business legitimate interests.

Analytics - We use “usage data” to understand the use of our website and services, as well as the interactions with our business. The legal basis for this processing is your consent.

Data Disclosure

Third-party vendors and processors

Your data held in our platform will be stored on the servers of our third-party vendor infra-structure service providers. The vendor does not use or have access to your personal information for any purpose other than cloud computing, storage, and retrieval.

We may disclose personal data to our suppliers or subcontractors processors that provide “sufficient guarantees”, and “appropriate technical and organizational security measures” as reasonably necessary for website and services operational reasons, customer support services, and financial transactions relating to our services.

Advertising Partners

We use third-party advertising networks that can provide “appropriate technical and organizational security measures”, that collect and use "usage data'' to display ads based on the use of our services. The third-party ad network partners use tracking technologies like cookies and SDKs to collect data.

Advanced Matching Partners

We enable the collection of non-sensitive hashed data by our Advanced Matching Partners network that can provide “appropriate technical and organizational security measures” to provide their services. Our partners may use tracking technologies like Cookies, Mobile Advertising IDs or MAIDs, Statistical IDs, Web Beacons, Pixel Tags, JavaScript, HTML5 Local Storage, or similar technologies, along with other information described in their Privacy Statement.

Other companies’ use of their tracking technologies is subject to their privacy policies, not this one. To view the purposes they have a legitimate interest for, review their privacy practices you can request our ad partners, third-party processor, or advanced matching partners list at privacy@vuukle.com.

Some of our ad partners and advanced matching providers are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You can visit here (optout.networkadvertising.org), or here (optout.aboutads.info) to learn more about targeted advertising and how to opt-out of the use of your personal data.

LiveRamp

When you use our Platform, we share information that we collect from you, such as your email (in hashed form), IP address or information about your browser or operating system, with our identity partners/service providers, including LiveRamp Inc.

LiveRamp returns an online identification code that we may store in our first-party cookie for our use in online, in-app, and cross-channel advertising and it may be shared with advertising companies to enable interest-based and targeted advertising. To opt out of this use, please click here.

International transfers

We may transfer your data to the third parties mentioned above that are based in countries located outside of the European Economic Area which are not subject to an adequacy decision by the European Commission. In these cases, we ensure that both ourselves and our partners take adequate and appropriate technical, physical, and organisational security measures to protect your data. We also ensure a level of data protection at least equivalent to the one prevailing in the European Union by having an appropriate cross-border data safeguard in place with these third parties.

Data Retention

Personal data that we process for any purpose shall not be kept for longer than is necessary for that. We will retain your data according to our Data Retention Privacy Policy & Procedures. The user data stored by Vuukle exists with Vuukle for as long as the user has their profiles maintained with us. The data will be deleted whenever a user decides to delete his/her profile over which the user has complete control.

Security

Vuukle takes every reasonable measure and precaution to protect and secure the personal data that we process. We are implementing a robust set of data security policies and procedures as a part of our data governance program to protect personal information from unauthorized access, data incidents or breaches, or unintentional disclosure, disposal, or deletion.

Your rights

When we process personal data for purposes that are in our legitimate interests, we have carried out a Legitimate Interest Assessment to confirm what these interests are, to consider what effect the processing has on individuals, and to check if our interests in processing could be outweighed by individuals’ interests.

Additionally, data subjects located in the EU have certain rights under the General Data Protection Regulation (GDPR). Those rights include, for example, the right to access the personal data we hold about you; the right to rectify inaccurate data; the right to erasure if you want all your data deleted from our systems; and the right to withdraw consent when you have provided it to us.

Data subjects who are US California residents have specific rights under the California Consumer Privacy Act (CCPA). Apart from the rights already mentioned above we must enable and comply with a consumers request to opt-out of the sale of personal information to third parties.

We have a Do Not Sell My Personal Information link in a clear and conspicuous location on Vuukle’s website and we will not request reauthorization to sell a personal information for at least 12 months after the person opts out.

There are some exceptions to these rights, however.

For example, it will not be possible for us to delete your data if we are required by law to keep it. Similarly, access to your data may be refused if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information.

If you have a concern about the way we handle your data you have the right to complain to the data protection authority in the country where you live, work, or where you believe a breach has occurred.

You can exercise those rights by written notice to privacy@vuukle.com.

Cookies

We use “cookies” to collect information about you and your activity across our site and services. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified. Please refer to our Cookie Policy for more information.

For Individuals Based in California

This section provides additional specific information for consumers based in California as required by the California Consumer Privacy Act of 2018 (“CCPA”).

Collection and Use of Personal Information

In the last 12 months, we have collected the following categories of personal information:

Identifiers, such as your name, mailing address, email address, zip code, telephone number or other similar identifiers
California Customer Records (Cal. Civ. Code § 1798.80(e)), such as username and password, company name, job title, business email address and department
Internet/network information, such as your browsing history, log and analytics data, information about the device(s) used to access the services and information regarding your interaction with our websites or services and other usage data
Geolocation data, such as information about your location (at country and city level) collected from your IP address
Sensory Information, the content, audio and video recordings of conference calls between you and us that we record where permitted by you and/or the law
Profession/employment information that you send to us when applying for a position included in your CV and cover letter
Other personal information, such as personal information you provide to us in relation to a survey, comment, question, request, article download or inquiry and any other information you upload to our application

We collect personal information directly from you, from your browser or device when you visit our websites, from third parties that you permit to share your information or from third parties that share public information about you, as stated above.

See the section above, “How We Use Personal Information,” to understand how we use the personal information collected from California consumers.

Recipients of Personal Information

We share personal information with third parties for business purposes. The categories of third parties to whom we disclose your personal information may include: (i) our service providers and advisors, (ii) marketing and strategic partners; (iii) ad networks and advertising partners; (iv) analytics providers; and (v) social networks.

Please see the “How We Share Information” section of the Privacy Policy above for more information.

California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):

The right to know any or all of the following information relating to your personal information that we have collected and disclosed in the last 12 months (upon verification of your identity):
The specific pieces of personal information we have collected about you
The categories of personal information we have collected about you
The categories of sources of the personal information
The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed
The categories of personal information we have sold and the categories of third parties to whom the information was sold, and
The business or commercial purposes for collecting or selling the personal information.
The right to request deletion of personal information we have collected from you, subject to certain exceptions.
The right to opt-out of personal information sales to third parties now or in the future. However, we do not sell your personal information.

You also have the right to be free of discrimination for exercising these rights.

Please note that if exercising these rights limits our ability to process personal information (such as a deletion request), we may no longer be able to provide you with our products and services or engage with you in the same manner.

How to Exercise Your California Consumer Rights

To exercise your right to know and/or your right to deletion, please submit a request by contacting us at privacy@vuukle.com.

We will need to verify your identity before processing your request.

In order to verify your identity, we will generally require sufficient information from you so that we can match it to the information we maintain about you in our systems. Sometimes we may need additional personal information from you to be able to identify you. We will notify you.

We may decline a request to exercise the right to know and/or right to deletion, particularly where we cannot verify your identity or locate your information in our systems or as permitted by law.

You may choose to designate an authorized agent to make a request under the CCPA on your behalf. No information will be disclosed until the authorized agent’s authority has been reviewed and verified. Once an authorized agent has submitted a request, we may require additional information (i.e., written authorization from you) to confirm the authorized agent’s authority.

If you are an employee/former employee of a Vuukle DMCC client that uses our application and services, please direct your requests and/or questions directly to your employer/former employer.

If you are a third party (auditor, business associate, etc.), who was given access to the Vuukle DMCC application by a Vuukle DMCC client, please direct your requests and/or questions directly to the Vuukle DMCC client that gave you access.

Minors Under Age 16

Our application and services are intended for business use, and we do not expect them to be of any interest to minors. We do not intentionally collect any personal information of consumers below the age of 16. We do not sell the personal information of California consumers.

Changes to Privacy Policy

We may, in its sole discretion, modify or update this Privacy Policy from time to time, and so you should review this page periodically. Your continued use of our services following the posting of any changes to this policy means you accept such changes.

Our details

Vuukle DMCC

Unit 2980, DMCC Business Centre, Level 1

Dubai - UAE

privacy@vuukle.com

Last update: 22 of April 2022

﻿WELL DONE! YOU CARE ABOUT YOUR PRIVACY!