Privacy Policy

Last updated: October 18, 2021

GDMServices, Inc. d/b/a Bidmind is committed to respecting and protecting the privacy of personal information of identifiable individuals. This Privacy Policy explains how we (“Bidmind”, “we”, “us” or “our”) collect, use, protect, disclose personal information of individuals who visit the website bidmind.com (the “Site”) and use the services available or offered thereon (the “Services”).

 

We respect your privacy and are committed to protecting it through our compliance with this policy. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.

 

We are committed to maintaining the privacy of your information when you visit Self-Service Demand Side Platform Bidmind at Site, and when we provide products that optimize the mobile and CTV marketplace inclusive of ads and app download environments, on behalf of our mobile and CTV application provider clients ("Clients").

 

If you do not agree with our policies and practices, do not use the Site. With, accessing, or using the Site, you agree to this Privacy Policy. This policy may change from time to time. Your continued use of or access to the Site after we make changes is deemed to be acceptance of those changes, so please check this page periodically for updates.

OUR PRINCIPLES REGARDING PRIVACY AND DATA PROTECTION

WHAT INFORMATION DO WE COLLECT AND PROCESS

INFORMATION YOU PROVIDE TO US

INFORMATION COLLECTED AUTOMATICALLY

COOKIES, INFORMATION COLLECTION AND TRACKING TECHNOLOGIES

AGGREGATED DATA

DISCLOSURE OF YOUR PERSONAL DATA

HOW DO WE USE YOUR INFORMATION

HOW DO WE PROTECT YOUR INFORMATION

DATA WE COLLECT FROM OUR PARTNERS

THIRD-PARTIES

DATA TRANSFERS AND INTERNATIONAL DATA TRANSFERS

AGE OF CONSENT AND CHILDREN'S PRIVACY

YOUR RIGHTS AND OPTIONS

WHAT DATA PROTECTION RIGHTS YOU HAVE UNDER GENERAL DATA PROTECTION REGULATION (GDPR)

CALIFORNIA ONLINE PRIVACY PROTECTION ACT COMPLIANCE

PERSONAL INFORMATION COLLECTED AND PROCESSED    
REQUESTS TO EXERCISE YOUR RIGHTS    
DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE    
SALE OF PERSONAL INFORMATION    

EU-U.S. AND SWISS-U.S. PRIVACY SHIELD STATEMENT

DO NOT TRACK NOTICE

BIDMIND AS DATA PROCESSOR

DATA RETENTION

CHANGES TO THE POLICY

TERMS OF SERVICE

YOUR CONSENT

CONTACT US

 

 

 

 

OUR PRINCIPLES REGARDING PRIVACY AND DATA PROTECTION

  • Lawfulness, transparency and fairness;

  • Purpose Limitation;

  • Data Minimization;

  • Accuracy;

  • Storage limitation;

  • Confidentiality and integrity.

Your privacy and security are of the utmost importance to us. We will always follow these principles.

Adherence by Bidmind to these privacy principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

 

WHAT INFORMATION DO WE COLLECT AND PROCESS

When you use certain features of our Site or visit our Site, or register and log in to our Services we may collect certain information from you:

  • Your email address;

  • Full name (First and Last name);

  • Phone number;

  • Company name and address;

  • Device info including the device model and IP address;

  • UI activity events (e.g. clicked on active buttons/ elements of the Site): information about your interactions with the Site such as your search queries (including the date and time of any requests you make). 

  • Inferences drawn about your interests and preferences based on your usage of the Site:

  • Certain technical data, which may include:

  • URL information;

  • online identifiers including cookie data and IP addresses;

  • information about the types of devices you are using such as unique device IDs, network and device performance, browser type, language, information enabling digital rights management, operating system;

  • your non-precise location, which may be derived or inferred from certain technical data (e.g., your IP address, language setting of your device).

Except as specifically set forth in this Privacy Policy, we will not share your personally identifiable information outside of Bidmind.

 

INFORMATION YOU PROVIDE TO US

When you are filling out forms via the Site, we may ask you to provide information (a) by which you may be personally identified, such as name, company name, email address, or any other personal or personally identifiable information under applicable law (“personal information“), and/or (b) that is about you but individually does not identify you.

This information includes:

  • Information that you provide by filling in forms on the Site. This includes information provided at the time of registering to use or access the Site. We may also ask you for information when you interact with us (such as when responding to notices and announcements from us) or otherwise correspond with us. 

  • Records and copies of your correspondence (including email addresses), if you contact us;

  • Your responses to surveys that we might ask you to complete for research purposes.

 

INFORMATION COLLECTED AUTOMATICALLY

While using our Site, we may collect certain personally identifiable information that can be used to contact or identify you which also includes: IP Address, Cookies, Usage Data. This personal information is necessary to manage our Site, communicate with you about the Site, and for other purposes set out in this Privacy Policy.

You voluntarily consent to the collection, use and disclosure of such personal information by providing personal information to us and by continuing to use the Site. Without limiting the aforesaid, if appropriate, you may be asked to provide your consent when we collect, use, or disclose your personal information in particular circumstances. Take into account, occasionally, your consent will be implicit through your conduct with us in the case the purpose of the collection, use or disclosure is clear and voluntarily provided by you.

 

COOKIES, INFORMATION COLLECTION AND TRACKING TECHNOLOGIES 

We may use cookies and log files to track user information. Cookies are small amounts of data that are transferred to your web browser by a web server and are stored on your computer’s hard drive. We use cookies to track which page variant a visitor has seen, to track if a visitor has clicked on a page variant, to monitor traffic patterns and to assess popularity of services options. We will use this information to deliver relevant content and services to you. This also allows us to make sure that visitors see the landing page they expect to see if they return to the same web URL and it allows us to tell you how many people click on your landing pages. You can disable cookies in your settings, but some parts of the Site may then not function properly. Specific information about how we use Cookies and how you can refuse certain cookies is set Bidmind Cookie Policy. You can refuse certain cookies  here.

Web Beacons. Parts of the Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related Site statistics (for example, recording the popularity of certain Site content, features, functionality, and services, and verifying system and server integrity).

Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our sites. 

We automatically collect certain information when you visit, use or navigate the Site. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Site and other technical information.  This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.

Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device, if you access the Site from a mobile device.

Additionally, we may use third-party software to serve ads on the Site, implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies or similar tracking technology to help manage and optimize your online experience with us.

Note: that certain cookies are necessary to enable the Site to operate and refusing or disabling some or all cookies may limit your ability to make use of the Site.

AGGREGATED DATA

From time to time we may use your personal information to generate Aggregated Data for internal use and for sharing with others on a selective basis. “Aggregated Data” means records which have been stripped of information potentially identifying customers, landing pages or end-users, and which have been manipulated or combined to provide generalized, anonymous information. Note: that any such aggregated data will not include any personal information, and we will never make it available to third parties to use for their own purposes.

 

DISCLOSURE OF YOUR PERSONAL DATA

We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

 

Furthermore, we do not share, distribute, sell, trade, rent or otherwise transfer to outside parties your personally identifiable information without first receiving your permission or as permitted in this Privacy Policy. We will only share your information with third parties in accordance with your instructions or as necessary to provide you with a specific service or to trusted third parties who assist us in operating our Site, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.

Under certain circumstances, Bidmind may be required to disclose your personal information if required to do so by law, or in response to valid requests by public authorities (e.g. a court or a government agency).

 

The following personal data will only be shared with the categories of recipients outlined in the table below if:

  • you choose to make use of a specific Site feature where sharing of particular personal data is required for the proper use of the Site feature; or

  • you grant us your permission to share the personal data, e.g. by selecting the appropriate setting in the Services or authorizing Bidmind through a presented consent mechanism.

 

In addition, we may disclose personal information that we collect or you provide:

 

In addition, we may disclose personal information for the following categories of recipients and for the following reasons:

Service providers

We work with service providers that work on our behalf which may need access to certain personal data in order to provide their services to us. These companies include those we've hired to provide customer service support, operate the technical infrastructure that we need to provide the Services, assist in protecting and securing our systems and services, and help market own products and services as well as partner products, services, events, and co-branded promotions in which we involved. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity

Advertising partners

We work with advertising partners to enable us to customize the advertising content you may receive on our Services. These partners help us deliver more relevant ads and promotional messages to you, which may include interest-based advertising (also known as online behavioral advertising), contextual advertising, and generic advertising on the Site. We and our advertising partners may process certain personal data to help Bidmind understand your interests or preferences so that we can deliver advertisements that are more relevant to you.

Our partners

Depending on how you access the Site (e.g. through a third-party service or a mobile provider), we may share your information as necessary. We may also share personal data with that third party about your use of the Site.

Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us

Law enforcement and data protection authorities

We may share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. We also may share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security? to a lawful request by public authorities (including to meet national security) or law enforcement requirements, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.

Business Transfers

We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Bidmind, our customers, users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

 

HOW DO WE USE YOUR INFORMATION

 

Bidmind buys web, mobile and CTV/OTT advertising space on behalf of our Clients which are generally product owners or mobile/CTV application providers and companies looking to advertise via web, mobile/CTV applications or OTT content. When you click on a Client ad or application link delivered by Bidmind, Bidmind servers may receive and store an advertising identifier ("Advertising ID") or device identifier ("Device ID"), either of them is a pseudonymous number that is associated with your mobile or CTV device. Bidmind cannot use the Advertising/Device ID to identify you personally, but it does enable us to deliver relevant advertising to each mobile or CTV device. In addition to the Advertising/Device ID, we collect information about the kind of mobile/CTV device you use (e.g., iPhone, Samsung, Roku etc.), the operating system for your mobile device (e.g., Android, iOS, Fire OS etc.), IP address, websites you may be visiting, content that you may be watching through video streaming CTV/OTT applications, the applications you download from Clients of Bidmind, when, how, and how often you use those applications.

Bidmind will gather and manipulate only non-sensitive data signals. Personal information will be pseudonymized and encrypted to ensure the user privacy. The collected information will be handled for standard cases of web / mobile / CTV advertising use: brand targeting; campaign operations; brand measurement; performance attribution and optimization on the Demand Side Platform.

We use your device's Advertising/Device ID and other information about Client applications you download to help our Clients understand which ads are most effective at generating downloads of our Client's applications or at achieving other goals defined by Client. We also use your Advertising/Device ID and the information associated with your device Advertising/Device ID over time (e.g., the applications you download, when and how you use those applications, and any publisher-provided demographic data) to enhance our services and to select Bidmind' Client ads that are most likely to be of interest to you.

Bidmind may use agents and contractors in order to provide our services to Clients. If such agents and contractors have access to your Advertising/Device ID and/or the information associated with your Advertising/Device ID, they are required to protect this information in a manner that is consistent with this Privacy Policy by, for example, not using the information for any purpose other than to carry out the services they are performing for Bidmind.

We may aggregate your data with other customers' data in non-personally identifiable, aggregated, and de-identified form to better optimize marketing campaigns and to improve our Site or service. We may also share this de-identified aggregate data publicly, for example in order to provide analytical summaries.

We may periodically communicate with you via email address you provide for us regarding to your transactions, orders, our products, services, updates, news, events, etc. We may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails or you can communicate with us and tell us not to communicate this information to you. We will process your request within a reasonable time after receipt.

 

Note: that you will continue to receive transaction-related emails regarding the Site you have requested, including information specific to your account, planned Services suspensions and outages, updates to our Terms or this Policy. We will attempt to minimize this type of communication to you. 

 

We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

 

HOW DO WE PROTECT YOUR INFORMATION

We aim to protect your personal information through a system of organizational and technical security measures. 

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process which included: 

  • using secure shell protocol (SSH);

  • multi-factor authentication;

  • access control (physical and technical);

  • link encryption.

The protection of your personal information is important to us. We maintain appropriate safeguards and current security standards to protect your personal information from unauthorized access, disclosure, or misuse, such as using Secure Socket Layer (SSL) encryption for all supplied sensitive/credit information. However, no system can be completely secure, and we cannot ensure or warrant the security of any information you provide to us. While we take meaningful steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure. We do not accept liability for unintentional disclosure.

 

However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

 

We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites. 

 

The Site may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Sites. You should review the policies of such third parties and contact them directly to respond to your questions.

 

Personal information will be pseudonymised and encrypted to ensure the user privacy. The collected information will be handled for standard cases of use described in this Privacy Policy.

 

If you have any questions about these security practices, please email dpo@bidmind.com.

LINKS TO OTHER CONTENT

We frequently make content or services from other websites available to you from links located on our Website. These other websites are not subject to this Privacy Policy, and Bidmind has no control over how such websites may use the personally identifiable information collected on those sites. We recommend that you review the privacy policy at each such website to determine how that site protects your privacy.

DATA WE COLLECT FROM OUR PARTNERS

We also collect the following data from our partners:

  • location data (such as to determine the coarse location of your IP address);

  • data for analytics purposes, so we can provide you with better services.

We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

 

THIRD-PARTIES

When you use or access Site or its/their content, certain third parties may use automatic information collection technologies to collect information about you or your device, or you may otherwise be accessing and using third-party platforms, software, and applications.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about a third party’s processing of your information, you should contact the responsible provider directly. You acknowledge and agree that your access and use of such third party tools may be subject to their respective terms of use and privacy policies.

We may also partner with selected third-party vendors (subprocessors) to allow tracking technologies and remarketing services on the Site through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site, determine the popularity of certain content and better understand online activity. By accessing the Site, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. 

Full list of third-party you can find here: "Disclosure of Your Personal Data".

DATA TRANSFERS AND INTERNATIONAL DATA TRANSFERS

We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations. 

 

We only share and disclose your information in the following situations:

Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.  

Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer services and marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time.  This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. 

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Sites. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you. See our Cookie Policy for further information. 

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

Business Partners. We may share your information with our business partners to offer you certain products, services or promotions. 

With your Consent. We may disclose your personal information for any other purpose with your consent.

 

Our servers are located in the USA. If you are accessing our Site from outside the USA, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information in other countries. In such instances Bidmind shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures are in place.

 

Bidmind, the Site, and the services are global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than the United States (or your own country, if you are using the Site outside the United States, despite the geographic restrictions provided in the Terms), we take steps to ensure adequate safeguards are in place to protect your data as explained in this privacy policy. 

Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission.

When we transfer personal data from the European Economic Area to other countries, we use appropriate legal mechanisms to help ensure all applicable laws, rights and regulations continue to protect your data.

Such measures implementing the European Commission's Standard Contractual Clauses for transfers of personal information between us and our third-party providers, which require all such recipients to protect personal information that they process from the EEA in accordance with European data protection laws. Our Standard Contractual Clauses are available here. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

AGE OF CONSENT AND CHILDREN'S PRIVACY

We do not knowingly collect, maintain, or use personal information from individuals under the age of consent (18 years of age). If you have reason to believe that anyone under the age of consent has provided us with personal information, you may contact us immediately. If we become aware that we have collected any personal information from individuals under the age of consent we will promptly take steps to remove and permanently delete such information.

Bidmind adheres to the Children's Online Privacy Protection Act. We do not create nor use any behavioral advertising segments of children under 16 as part of our Services. Our Site is not directed at children under the age of 16. If we are made aware that we have received personally identifiable information from someone under 16, we will use reasonable efforts to remove that information from our records.

 

YOUR RIGHTS AND OPTIONS

You have the right to opt-out of marketing emails and other direct marketing (if any);

Access the personal data we hold about you. If you request, we will provide you a copy of your personal data in an electronic format; and

You also have the right to correct your data, have your data deleted, object to how we use or share your data, and restrict how we use or share your data. You can withdraw your consent, for example by turning off cookies in your browser settings. We will respond to all requests within a reasonable timeframe. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please let us know. You may also contact your local data protection authority within the European Economic Area for unresolved complaints.

All these rights may be fulfilled by you simply emailing us with the relevant request to  dpo@bidmind.com 

 

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws.  These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use our Data Protection Officer - dpo@bidmind.com. We will consider and act upon any request in accordance with applicable data protection laws.  

 

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

 

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here.

 

WHAT DATA PROTECTION RIGHTS YOU HAVE UNDER GENERAL DATA PROTECTION REGULATION (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Bidmind aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal information.

The General Data Protection Regulation or "GDPR" gives certain rights to individuals in relation to their personal data. Accordingly, we are happy to offer transparency and access controls to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:

 

  • Right of access - the right to be informed of, and request access to, the personal data we process about you;

  • Right to rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;

  • Right to erasure - the right to request that we delete your personal data;

  • Right to restrict - the right to request that we temporarily or permanently stop processing all or some of your personal data;

  • Right to object - the right, at any time, to object to us processing your personal data on grounds relating to your particular situation; the right to object to your personal data being processed for direct marketing purposes;

  • Right to data portability - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and

  • Right not to be subject to automated decision-making - the right to not be subject to a decision based solely on automated decision-making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

 

We will process your requests to us within 30 days. We will also notify a relevant supervisory authority within 72 hours from a breach related to your personal information that we hold.

Furthermore, we have assigned a Data Protection Officer (DPO) who may be reached via dpo@bidmind.com 

 

However, you can also contact and have the right to lodge a complaint with your local Data Protection Authority.

 

Our EU Representative – according to Art. 27 GDPR: ePrivacy GmbH represented by Prof. Dr. Christoph BauerGroße Bleichen 2120354 Hamburg Germany https://www.eprivacy.eu  

 

Additional privacy rights under the California Consumer Privacy Act (CCPA) can be found in California Online Privacy Protection Act Compliance section, which contains supplemental disclosures relating to the processing of your personal data.

 

CALIFORNIA ONLINE PRIVACY PROTECTION ACT COMPLIANCE

The California Code of Regulations defines a "resident" as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."

 

Beginning January 1, 2020, the California Consumer Privacy Act ("CCPA”) gives California residents certain rights with respect to the processing of personal data (known as “personal information” under the CCPA).

 

This supplement provides additional privacy disclosures and details additional rights and should be read in conjunction with our Privacy Policy.

 

If you are a resident of California, you are granted specific rights regarding access to your personal information. 

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal data.

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under Disclosure of Your Personal Data section.

If you are a California resident and would like to make such a request, please submit your request in writing to us via dpo@bidmind.com

If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

 

PERSONAL INFORMATION COLLECTED AND PROCESSED

Our Privacy Policy sets forth the categories of personal information that We collect and processes about you, a description of each category, and the sources from which we obtain each category.

 

REQUESTS TO EXERCISE YOUR RIGHTS

RIGHT TO KNOW REQUEST - Under the CCPA, you have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and ask that we provide you with the following information:

  • Categories of and specific pieces of personal information we have collected about you;

  • Categories of sources from which we collect personal information;

  • Purposes for collecting personal information;

  • Categories of third parties with which we share personal information;

  • Categories of personal information disclosed about you for a business purpose.

If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.

 

To make a verifiable request for information about the personal information we have collected about you, please to make a request by using the dpo@bidmind.com

 

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

 

RIGHT TO DELETE REQUEST - You also have a right to request that we delete personal information, subject to certain exceptions. You may exercise your right to delete emailing to  dpo@bidmind.com

 

HOUSEHOLD REQUESTS - We currently do not collect household data. If all the members of a household make a Right to Know or Right to Delete request, we will respond as if the requests are individual requests.

 

REQUESTS, GENERALLY - Please note, if you have not filled our Site’s forms we will not have enough information about you to verify your Right to Know and Right to Delete requests, as we do not keep sufficient information necessary to reidentify and link you to a prior visit to the user services where data may have been collected. As such, we will be unable to verify and honor your requests. You may make a verifiable consumer request related to your personal information twice per 12-month period. We will not discriminate against you for exercising any of your rights under the CCPA.

 

REQUESTS MADE THROUGH AGENTS - You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

 

DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE

In the preceding 12 months, We have disclosed certain data from the following categories of personal information to the categories of recipients listed in Section “Disclosure of Your Personal Data” of our Privacy Policy for one or more business purposes:

  • None

 

SALE OF PERSONAL INFORMATION

We do not sell personal information. We have taken substantial steps to identify and remediate any data sharing arrangements that could constitute a “sale” under the CCPA.

 

While we do not sell any personal information, we do provide Usage Data to advertising partners to enable us to provide you with interest-based advertising. For more information on interest-based advertising, please see our Cookies Policy.

 

We will continue to update our business practices as regulatory guidance becomes available and provides clarity on what constitutes a sale transaction, particularly in the advertising ecosystem.

 

To exercise these rights, you can contact us by email at dpo@bidmind.com. If you have a complaint about how we handle your data, we would like to hear from you.

EU-U.S. AND SWISS-U.S. PRIVACY SHIELD STATEMENT

GDMServices, Inc. d/b/a Bidmind ("Bidmind") complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Bidmind has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Shield Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/ 

 

We have adopted and subscribed to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, “Privacy Shield”) to establish and maintain an adequate level of Personal Data privacy protection.  We adhere to the Privacy Shield Principles including the Supplemental Principles, (collectively, the “Privacy Shield Principles”) for Personal Data received from entities in the European Economic Area (the “EEA”), the United Kingdom (“UK”) and Switzerland.

 

This Policy applies to the processing of Personal Data that Avangate obtains from Customers located in the European Union and Switzerland.

 

We have further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit  https://bbbprograms.org/privacy-shield-complaints  for more information and to file a complaint.

 

In compliance with the Privacy Shield Principles, GDMServices, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact GDMServices, Inc. at: dpo@bidmind.com.

 

GDMServices, Inc. has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/  for more information and to file a complaint. This service is provided free of charge to you.  

 

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.  

 

As a last resort and in limited circumstances, EU and/or Swiss individuals with unresolved privacy complaints may invoke a binding arbitration option before a Privacy Shield Panel.

 

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, GDMServices, Inc. is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”). 

 

DO NOT TRACK NOTICE

We don’t currently respond to Do Not Track and similar signals.  Please go to All About Do Not Track for more information or use this page.

The World Wide Web Consortium (W3C) has been attempting to develop a Do Not Track (DNT) standard, but it has not been finished. Currently, the standards regarding the DNT signals and appropriate responses are not well defined. Accordingly, we do not assign a meaning to DNT signals. If you'd like to opt-out from Bidmind, please click here. By opting out of Bidmind, you will continue to see advertising, although it will not be tailored to your interests by data provided by Bidmind.

 

The World Wide Web Consortium (W3C) has been attempting to develop a Do Not Track (DNT) standard, but it has not been finished. Currently, the standards regarding the DNT signals and appropriate responses are not well defined. Accordingly, we do not assign a meaning to DNT signals. If you'd like to opt-out from Bidmind, please click here. By opting out of Bidmind, you will continue to see advertising, although it will not be tailored to your interests by data provided by Bidmind.

 

BIDMIND AS DATA PROCESSOR

Bidmind`s customers, and not Bidmind, may determine the purpose and means of processing Personal Data provided to Bidmind by or at the direction of such customers (“Data Controllers”). In such event Bidmind (“Data Processor”) is a “data processor” under the EU General Data Protection Regulation (“GDPR”) and a “service provider” under the California Consumer Privacy Act (“CCPA”). Bidmind performs such processing services on behalf of its customers in accordance with this Privacy Policy and/or the terms of the agreement between Bidmind and the particular customer.  To the extent that Bidmind’s agreement with a customer conflicts with the terms of this Privacy Policy, the terms of such agreement will govern.  

 

As Data Controllers, Bidmind’s customers are responsible for disclosing the rights of individuals with respect to their Personal Data, and terms for the collection and use of that Personal Data, in accordance with the GDPR, CCPA, and other laws requiring such disclosures.  

 

Bidmind’s customers (not Bidmind), determine the purpose and means of processing Personal Data of EU persons provided to Bidmind as a Data Processor by or at the direction of such customers.  Bidmind performs such processing in accordance with this Privacy Policy and the terms of data processing agreements executed by Bidmind with such customers.  Bidmind customers are responsible for disclosing the rights and terms for processing of Personal Data in accordance with the EU General Data Protection Regulation.


 

DATA RETENTION

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

Note that if you ask us to remove your personal data, we may retain your data as necessary to comply with our legal obligations.

We process and for about 6 months store the pseudonymized data on the cloud servers with all necessary means and measures of data protection, let alone special requirement provided by GDPR (fraud, legal claim, etc.). Other than that, all personal data is deleted once the 6-month period is over.

 

If you request, we will delete or anonymize your personal data so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal data, including situations such as the following:

  • Where we need to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,

  • Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.

 

CHANGES TO THE POLICY

This Policy may be updated by us from time to time. Amendments to this Privacy Policy will be posted to the Site and/or Services and will be effective when posted. Your continued use of the Services following the posting of any amendment to the Privacy Policy shall constitute your acceptance of such amendment.

 

The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting this privacy policy to check for any changes.

 

TERMS OF SERVICE

Please also visit our Terms of Use which state the terms, disclaimers, and limitations of liability governing your use of the Site and Services.

 

YOUR CONSENT

By using our Site, you consent to our Privacy Policy.

 

CONTACT US

If you have any questions or suggestions regarding our Privacy Policy, please contact us at dpo@bidmind.com.

If you have any requests for resolving issues (other than issues related to data protection) we encourage you to contact us through  dpo@bidmind.com

If you are a resident in the European Economic Area, the "data controller" of your personal information is GDMServices, Inc. d/b/a Bidmind, with the address at 3500, South DuPont Highway, Dover, Delaware, 19901