Medier Agency
Privacy Policy

Version 1.0
Last update: 21 August 2023


Background


Please read this Privacy Policy carefully and ensure that you understand it. This Privacy Policy is intended to give you a better understanding of the personal data we collect, the reason why we collect such data, the manner in which we process this data, the entities with whom we share the said personal data, your rights in relation to the collection, processing and sharing of such data and any other pertinent matter relating to privacy and security of your personal data.


We understand that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits our Website and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under national and international laws and regulations.


Under the applicable laws, we are required to comply with personal data protection and processing procedures to ensure that your data is at all times stored and processed securely and that your rights as a data subject are observed and protected. We take these obligations very seriously and have implemented adequate technical and organizational measures to ensure protection of your privacy.


All processing of your personal data performed by us as envisaged in this Privacy Policy shall be carried out in line with the following laws and regulations, as well all binding acts amending or implementing the same (hereafter be collectively referred to as the “Data Protection Laws”):


- the Cypriot Law providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data of 2018 (Law 125(I)/2018), as well as any other subsidiary legislation issued under the law, as may be amended from time to time; and
- Regulation (EU) 2016/679  of The European  Parliament And of The Council of 27 April 2016  On The Protection of Natural Persons With Regard to The Processing of Personal Data And On The Free Movement of Such Data, And Repealing Directive 95/46/EC (General Data Protection  Regulation).


Information About Us


Our Website is operated by Medier Limited, a Cypriot company with its registered address at 38 Agias Filaxeos, Nicolas Court, Floor 1, Suite/Office 101, Katholiki, 3025 Limassol, Cyprus.


Medier Limited determines the means and purposes of the processing of your personal data and therefore acts as the “Data Controller” in terms of the applicable Data Protection Laws.  


Our Data Protection Officer can be contacted by email at office@medieragency.comor by post to 38 Agias Filaxeos, Nicolas Court, Floor 1, Suite/Office 101, Katholiki, 3025 Limassol, Cyprus.


What Does This Policy Cover?


This Privacy Policy applies to the processing of your personal data by us, primarily in connection to your use of this Website. Our Website may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before any data is provided.


This Policy also applies to our processing of your personal data in connection to our communication with you, our processing of your queries and/or job applications, your use of our products and/or services, and any other relationship with you that is not covered by a separate privacy policy.


Legal Basis for Processing


We may process your personal data on several legal grounds. Please see the below section “Which Data We Process” for the legal grounds applicable to each category of your personal data that we process.

Legal Requirement


We may process your personal data as required under the European Union or a Member State law applicable to us.

Contractual Necessity


We may process your personal data as required to fulfill a legally binding contract between you and us.

Legitimate Interest


A legitimate interest exists when we have a business or commercial reason upon which personal data will be processed. Before relying on our legitimate interest, we balance it against your interests and ensure that our interest is compelling enough and that pursuing such legitimate interest will not cause any disproportional risks to your rights and interests.


In particular, our legitimate interests are listed in the “Which Data We Process” section below. You have the right to object against our processing of your personal data on the basis of legitimate interest by contacting us at office@medieragency.com. We will do our best to meet your request, but in certain cases were we will not be in a position to meet your request, you will be informed immediately. Note that we will always honour your objection with regards to any processing for marketing purposes.

Legal claims


We may process your personal data as required for the establishment or defense of legal claims.

Consent


We may process your personal data when you give us your consent to do so. We will only process your personal data on the basis of your consent, where we cannot or otherwise choose not to rely on any other legal grounds as previously mentioned.

Where we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time. Should you wish to withdraw your consent please contact us at office@medieragency.com. Any such withdrawal of your consent will not invalidate any processing operations carried out prior to you having withdrawn your consent.


Which Data We Process


The paragraphs below outline the categories of personal data which we process, the purpose for which we process such personal data as well as the corresponding legal basis used for such processing. Note that some categories of personal data may be processed on several legal grounds and/or for several purposes.

Category of personal data: Contact data - This type of data may include your full name, email address, telephone/mobile number, postal address, the company you represent and your title. We obtain this data from you when you contact us, either by submitting your CV, using the contact form on the Website or by other means.
Purpose of processing: a) To provide you with information on our offers, industry events and other news and products of ours and of our affiliates that may interest you; b) To answer your queries; c) To respond to your job applications and to update you on available vacancies from time to time.
Legal basis for processing: Legitimate Interest (Developing our business by keeping you updated regarding the latest developments and opportunities, responding to your questions and other communication, and employing qualified individuals).

Category of personal data: Identity data - This type of data may include your full name, your gender, the company you represent and your title. We obtain this data from you when you contact us, either by using the contact form on the Website or by other means.
Purpose of processing: a) To provide you with information on our offers, industry events and other news and products of ours and of our affiliates that may interest you; b) To answer your queries; c) To respond to your job applications and to update you on available vacancies from time to time.
Legal basis for processing: Legitimate Interest (Developing our business by keeping you updated regarding the latest developments and opportunities, responding to your questions and other communication, and employing qualified individuals).

Category of personal data: Other information you provide to us - This includes any other data you choose to share with us.
Purpose of processing: Depends on the nature of the data. If the data in question does not pertain to any purposes outlined in this Privacy Policy, it will be immediately deleted and not processed any further.
Legal basis for processing: Depends on the nature of the data. If the data in question does not pertain to any legal basis outlined in this Privacy Policy, it will be deleted and not processed any further.
The initial processing, necessary to evaluate such data, determine further purpose and legal grounds for processing or delete it, is done on the basis of our legitimate interest (To provide accessible contact channels to the general public).

Category of personal data: Activity data - This category includes your activity on the Website, the pages you visit, the links you click on, and other similar activities.
Purpose of processing: To evaluate the outreach and performance of our Website
Legal basis for processing: Legitimate Interest (Providing and developing innovative gaming and betting experiences to our users on a sustained basis)

Category of personal data: Technical data - This category includes traffic data, GeoIP location, information from your browser, computer or mobile device when you access or use our Website, device and network information.
Purpose of processing: a) To evaluate the outreach and performance of our Website; b) To prevent any fraudulent activity and to protect our Website from malicious actions.
Legal basis for processing: Legitimate Interest (Providing and developing innovative services and websites, ensuring Website stability)

We do not perform any automated decision making or profiling using your personal data.


Your Rights


As a data subject, you have the following rights under the GDPR, which this Privacy Policy and our use of personal data have been designed to uphold. Please contact us at office@medieragency.comfor more information, or to exercise these rights.
• You have the right to be informed about our processing and use of your personal data and the right to access your personal data we process;
• You have the right of rectification if any of your personal data we process is inaccurate or incomplete;
• You have the right to be forgotten – i.e. the right to ask us to delete your personal data we process;
• You have the right to restrict the processing of your personal data, and the right to object to us using your personal data for particular purposes, e.g. for marketing purposes;
• You have the right to data portability (obtaining a copy of your personal data to re-use with another service or organization). We will provide such copy free of charge unless the request is manifestly unfounded or excessive, where in such case a reasonable fee for administration costs may be charged;
• You have the right to lodge a complaint with any relevant Data Protection Supervisory Authority should you feel that any of your rights have been impinged by us. Without limiting this right, we kindly ask you to attempt to resolve any issues you may have with us directly, prior to lodging a complaint;
• You have certain rights with respect to automated decision making and profiling. You have the right to obtain human intervention in the process of automated decision making, to express your point of view and to contest the decision.


Personal Data Storage, Security and Retention


Our commitment to protect personal data is not merely through quality and high standards but also through the best and most efficient application of the law. Personal data processed by us is protected using the highest industry standard security processes and systems. We store your personal data within the European Union, on encrypted hard drives and/or with certified data centers. Both our storage environment and those of the data centers we employ are compliant with the “ISO/IEC 27001 - Information security management” standard. We use secured https protocol for communication between the Website and your browser. In addition, our secure servers protect all information information using advanced firewall technology.


Despite the best practices we employ, no party can warrant absolute security of your Internet connection. Any data sent via the Internet may be transmitted across international borders even where sender and receiver of information are located in the same country. We cannot be held responsible for anything done or omitted to be done with your personal data before such personal data reaches us.


We do not process your personal data for any longer than is necessary for the purposes of processing for which it was first collected. Your personal data will be retained for as long as we have a relationship with you (for example, evaluating employment opportunity or answering your queries) and up to one (1) year thereafter. With regards to your personal data used to provide you with information on our offers, industry events and other news and products of ours and of our affiliates that may be of interest, such data will be processed until you indicate that you no longer wish to receive such information from us.


Sharing your Personal Data


We may share your personal data with competent authorities having jurisdiction over us. Such disclosures will only be made when permitted or required pursuant to the Data Protection Laws and/or other legislation applicable to us.


We may share your personal data with other companies in our corporate group – our parent companies, subsidiaries, and sister companies. These companies, as our processors, will process your personal data on our behalf on the grounds and for the purposes listed in this Privacy Policy.


We may share your personal data with other selected third parties:


• IT and related services’ providers and their sub-processors, engaged in operating our Website, such as service providers contracted to store your personal data (Amazon Web Services);
• analytics, business intelligence partners and search engine providers and their sub-processors, such as listed in the “Our Use of Cookies” section below;
• our lawyers, advisors, auditors, consultants who we may engage from time to time to advise on any matter which requires them to gain access to personal data.


Your personal data will only be transferred outside of the EEA when such transfer meet the requirements of the Data Protection Laws. Your Personal Data will never be shared with third parties for their own marketing purposes (unless you give your consent thereto).


Contacting Us


If you have any questions about the Website or this Privacy Policy, please contact Our Data Protection Officer, by via the contact us form or by post at 38 Agias Filaxeos, Nicolas Court, Floor 1,Suite/Office 101, Katholiki, 3025 Limassol, Cyprus. Please ensure that your query is clear, particularly if it is a request for information about the data we process.


Cookie Policy


When you visit or access our websites or applications operated by us, or when you interact or engage with our content ("Services"), we use (and authorize third parties to use) cookies, pixel tags, beacons, local storage and similar technologies ("Tracking Technologies").


These allow us to automatically collect information about you, your device, and your online behavior (for example your computer or mobile device), in order to enhance your navigation on our Services, improve our Services' performance, perform analytics, customize your experience and offer you, for example, tailored content and advertisements that better correspond with your interests.


We also allow third parties to collect information about you though Tracking Technologies.


What are cookies?


Cookies are small text files (composed only of letters and numbers) that a web server places on your computer or mobile device when you visit a webpage. When used, the cookie can help make our Services more user-friendly, for example by remembering your language preferences and settings. You can find more information about cookies at www.allaboutcookies.org.


Cookies are widely used in order to make websites work in an efficient way. The use of cookies allows you to navigate between pages efficiently. Cookies remember your preferences, and make the interaction between you and the Services smoother and more efficient. Cookies are also used to help ensure that the advertisements you see online are relevant to you and your interests.


Storing Tracking Technologies


We store Tracking Technologies when you visit or access our Services (for example when you are visiting our Website or using our mobile applications) – these are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example our analytics service providers, business partners and advertisers) who run content on our Services – these are called "Third Party Tracking Technologies".


Both types of Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits.


What types of Tracking Technologies do we use?


When you use or access our Services, we use the following categories of Tracking Technologies:
Strictly Necessary Tracking Technologies – these Tracking Technologies are automatically placed on your computer or device when you access our Services. These Tracking Technologies are essential to enable you to navigate around and use the features of our Services. We do not need to obtain your consent in order to use these Tracking Technologies;
Functionality Tracking Technologies – these Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services;
Performance Tracking Technologies – these Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services), including behavioral data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).
Marketing or Advertising Tracking Technologies – these Tracking Technologies are used to deliver tailored offers and advertisements to you, based on your derived interests, as well as to perform email marketing campaigns. They can also be used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by our advertisers (for example advertising networks) and provide them insights about the people who see and interact with their ads, visit their websites or use their app.
Social media Tracking Technologies – Our website includes social media features, such as the Facebook "Like" or "Share" buttons. These features are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy statement of the company providing these features.

The following Tracking Technologies are used in connection with our Services.  For additional information about any of the Third Party Tracking Technologies, please visit the links of those companies provided.

Tracking   Technologies
Type
Purpose
ANALYTICS COOKIES
First party Tracking Technology
PERFORMANCE TRACKING TECHNOLOGIES

These Tracking Technologies are used to collect information regarding how you interact with the content on our Services, attribution purposes (for example, the referral URL), and to remember your language preferences and authentication (remember you are logged-in). We use the information to compile reports, calculate the revenues due to us, help us improve the Services and to offer personalized products and content.
MARKETING OR ADVERTISING TRACKING TECHNOLOGIES
First party Tracking Technology
MARKETING OR ADVERTISING TRACKING TECHNOLOGIES

These Tracking Technologies are used to deliver tailored offers and advertisements to you, based on your derived interests, as well as to perform email marketing campaigns. They can also be used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by our advertisers (for example advertising networks) and provide them insights about the people who see and interact with their ads, visit their websites or use their app.
FUNCTIONALITY COOKIES
First party Tracking Technology
FUNCTIONALITY TRACKING TECHNOLOGIES

These Tracking Technologies are used to remember your settings, language preferences and account status, to facilitate the completion of forms and other functionalities available on our websites (such as performing deposits or other actions), to manage our website’s content, to track media channels, to record previous messages you were presented with and to deliver promotions.
OTHER COOKIES
First and Third party Tracking Technology
STRICTLY NECESSARY TRACKING TECHNOLOGIES

These unlisted cookies might be in use on internal sections of the Services, in order to customize and simplify the user experience on the site by remembering choices you made and your log in credentials.

Cookies allow us to:


• Improve the use of the Service and to make the content more interesting and relevant to the wishes of users, like offering you more relevant promotional offers.
• Distinguish you from other users of our sites to grant a good user experience.
• Identify your settings and preferences regarding customized content or functionality.
• Your log-in details for the confirmation as a registered user for our Service.
• Collect statistical analysis on the use of our Service.


Managing Your Cookies


Most browsers accept cookies automatically. However, one can configure the browser in a way that no cookies are stored on its computer or a hint appears before a new cookie is created. Please see the particular operator’s advice for the deactivation of cookies. Other methods of managing your Tracking Technology preferences includes: changing your browser settings to send a "Do-Not-Track" signal. In such case, your browser will send us a special signal to stop tracking your activity.


Disabling cookies completely may lead to decreased functionality regarding certain features of the Company’s website.


To learn more about how can manageyour cookies, below is a list of useful links that can provide you with moreinformation on how to manage your cookies:

·       Google Chrome

·       Internet Explorer

·       Mozilla Firefox

·       Safari (Desktop)

·       Safari (Mobile)

·      Android Browser


Turning off third party advertising cookies: you can turn off certain third party cookies for advertising purposes by visiting the Network Advertising Initiative, located here:
Network Advertising Initiative or the DAA opt-out program, which are located here: https://www.aboutads.info/choices/, here (for EU/EEA citizens): https://www.youronlinechoices.eu/ and here (for mobile devices): https://www.aboutads.info/appchoices.


Changes to Our Privacy Policy


We may change this Privacy Policy from time to time. Changes will be immediately posted on the Website and will be deemed to have been accepted on your first use of the Website following the alterations in the Privacy Policy. We recommend that you check this page regularly to remain up to date with any changes. Where appropriate, we will also notify you by e-mail. In the event that you do not agree with any changes, you must stop using the Website.


Definitions


In this Policy, the following terms shall have the following meanings:  


“personal data” means any information that identifies you individually or relates to an identified or identifiable natural person which can also be defined as data subject;
“data controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by the European Union or Member State law;
“data processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
"processing" means 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, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
“GDPR” means EU Regulation 2016/679 – the General Data Protection Regulation;
“personal data” means any and all data that relates to you as an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us via the Website or that we collect via the Website. This definition shall, where applicable, incorporate the definitions provided in the GDPR;
“we/us/our” and similar means the company described in the “Information About Us” section above;
“Website” means this website www.medieragency.com;
“you/your” and similar means you, the individual using the Website.

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