Privacy Policy

Introduction

Mediam Bangladesh Limited (hereinafter also “Mediam”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below:

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED?
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE

This privacy policy aims to give you information on how Mediam Bangladesh Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, use our services or sign up for one of our events or webinars.

This website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy policy so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

1.1 CONTROLLER

This privacy policy is issued on behalf of the Mediam Bangladesh Limited so when we mention »Mediam«, »we«, »us«, or »our« in this privacy policy, we are referring to Mediam. Mediam is the controller and responsible for this website.

1.2 CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, including any requests to exercise your legal rights, please contact us in the following way: Email address: privacy@alephholding.com.

You have the right to make a complaint at any time to your country's supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so, please contact us in the first instance.

1.3 CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated on June 24 2022. Historic versions can be obtained by contacting us. It is the visitor's responsibility to periodically review the content of this Privacy Policy on our webpage where the changes made will be published together with the data of the last update.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.4 THIRD PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. For example we may use Mailchimp for the contact forms on the website, Google's Blog, Skillshop and we might link to content on our partner's websites or other similar sites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

2.1 Personal data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  1. On our websites: We collect personal data when you submit web forms to us (for example, when you register for a webinar) or interact with our sites (for example cookies). We may ask for your email address, first and last name, whether you are an agency or advertiser, country, and other such business information. You can freely browse our website without having to provide personal data.

  2. Special events: When you register for our Mediam webinars or special events, we collect information such as your name, address, telephone number and email address. We may use this information to contact you and, in some cases, assist you with registration.

  3. Client Onboarding information: the personal data which you provide to us through the Onboarding questionnaire.

  4. Customer Testimonials: We post comments and testimonials on our websites and these may contain personal data. We obtain the consent of each client by email or through other agreements with us before publishing their name and testimonial.

  5. Linking with Google: If you use linking from Gmail or your Google account to link your Google Ads account, you will be asked to give us access to information from your Google Ads or Google account. The use and transfer to any other application of information that Mediam receives from Google APIs adheres to the Google API Services User Data Policy, including limited use requirements.

  6. Integration with Google Ads: For the connection with Google Ads to work correctly, Mediam will be able to see the main KPIS of your campaigns, upload and download them, and store their content and titles. Mediam uses these permissions to activate the features of our Impression Share and recommendations platform, which will allow it to show you relevant information and recommendations to improve your campaigns. The use and transfer to any other application of information that Mediam receives from Google APIs adhere to the Google API Service User Data Policy, including limited use requirements.

We also collect, use and share Aggregated Data, such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.2 IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Personal Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you;
    • Apply for our products or services;
    • Subscribe to our service or publications;
    • Request marketing to be sent to you;
    • Enter a competition, promotion or survey; or
    • Give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

    Technical Data from the following parties:

    1. Analytics providers
    2. Advertising networks
    3. Search information providers
    4. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
    5. Identity and Contact Data from data brokers or aggregators
    6. Identity and Contact Data from publicly available sources
    7. Social media interactions with any of our channels

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

4.1 PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

4.1.1 We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out.

Mostly we process your personal data for the following purposes:

  • Comply with Mediam´s legal obligations.
  • Implement commercial, organisational and marketing strategies.
  • Carry out any activity necessary for the effective fulfilment of the commercial obligations that Mediam has with suppliers and/or clients.
  • Offer new products or services.
  • Market studies.
  • Administer sweepstakes, promotions or surveys.
  • Provide customer service.
  • Send promotional communications.
  • Monitoring of the client's experience.
  • Offer promotions and access to services or products to the client.

We use the information you provide to Mediam to promote our products, services and events. For example, we use your email or postal address to send you information or content from Google Ads that we think you might be interested in and marketing communications related to our company. We also use this data to promote the use of our services and share promotional and informational content with you in accordance with your communication preferences.

In addition, we may contact you by phone to discuss other Mediam products or services that may be of interest to you. If you have a scheduled call with a Mediam representative, we may record and transcribe the call. We will notify you of this beforehand, so that you can cancel it if you wish.

To communicate with you about the services we use the data you provide to Mediam when you register. We also send you updates related to our Terms of Service for customers and other legal agreements, and we may contact you by email or with a notification in Mediam to report security incidents.

Finally, we use your information to provide support, for example to solve technical problems and analyse failures and interruptions in the service.

4.1.2 For use of Mediam GPS

  • We use your account information and customer data to provide you with our products and services. For example, we use the email address you provide us when you sign up to create your user account.
  • We collect data about how our products and services are used by monitoring and tracking our users. We use this data to develop and improve our products and services. For example, usage data allows us to evaluate trends and product usage to help us determine what new features or integrations our users might be interested in. We may share Usage Data externally, but only after it is anonymized and/or aggregated to create or improve features.
  • We use anonymized customer information for machine learning that is used in certain features and functionality of products within the subscription service. For example, machine learning is used to improve the business card scanning tool when you use our mobile apps and makes it easier to import information into your Mediam account. You can request that your data not be used for the latter purpose by sending an email to us.

To protect Mediam users:

  • We use your account information to investigate and prevent security incidents. We may also use this information to comply with legal requirements.

For research and development purposes

  • We may provide statistical information to Google about our users, although such information will not be used to identify any individual person and will only be shared in an aggregated, de-identified manner; for example, we might post blog posts about trends and product interaction data.

Other activities we can do with your consent

  • We will share your data with third parties after you give us your permission to do so.

4.2 MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

4.3 PROMOTIONAL OFFERS FROM US

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

4.4 THIRD PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

4.5 OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service experience or other transactions.

4.6 COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

4.7 CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.

  • Internal Third Parties [see Glossary].
  • External Third Parties [see Glossary].
  • Specific Third Parties, such as our Partners, for example Google, for the purpose of direct communications or quality assessments. We obtain the consent of each client by email or through other means before sharing your personal data with Google.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We may share your personal data within the Aleph Group Inc. which is the holding company of different legal entities, details of which can be found here: LINK.

The client expressly authorises Mediam to store their data in the way it deems most appropriate and comply with the security required for the protection of the client's data.

6.1 TRANSFERRING DATA OF EU VISITORS

In some specific cases we will have to transfer personal data of an EU visitor also outside the EU.

Also some of our external third parties are based outside the EU so their processing of your personal data will involve a transfer of data outside the EU.

Whenever we transfer your personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • Where we use certain service providers, we may use specific contracts approved for use in the EU which give personal data the same protection it has in the EU.
  • Using also Standard Contractual Clauses.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EU.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

8.1 HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

You can request details of retention periods for different aspects of your personal data by contacting us.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact us at: privacy@alephholding.com.

9.1 HOW TO FILE YOUR REQUEST

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

9.2 HOW AND WHEN WE WILL RESPOND TO YOUR REQUEST

We will strive to promptly respond to your requests.

In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so. In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.

You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.

In the latter case, we’ll respond within 30 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.

9.3 NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

9.4 WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9.5 TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

YOU EXPRESSLY ACKNOWLEDGE THAT YOU HAVE READ THIS PRIVACY POLICY AND YOU UNDERSTAND THE RIGHTS, OBLIGATIONS, TERMS AND CONDITIONS SET FORTH HEREIN AND BY USING OUR WEBSITE YOU EXPRESSLY CONSENT TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND GRANT US THE RIGHTS SET FORTH HEREIN.

10. GLOSSARY

GOOGLE: means Google Asia Pacific Pte Ltd and if applicable its affiliates.

LAWFUL BASIS

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

INTERNAL THIRD PARTIES

Other affiliated companies acting as processors and who are based in EU and non-EU countries and provide services, such as IT and Legal internal support.

EXTERNAL THIRD PARTIES

  • Service providers acting as processors who provide IT and system administration services.
  • Professional advisers acting as processor or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restrictions of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data´s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Mediam (Cambodia) Co. Ltd. (“Mediam”) respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you about how we use your personal data when you visit our website (“Website”) and use our services and tell you about your rights and how the law protects you.

This Privacy Policy is provided in a layered format. You can click through to the specific areas below:

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. FOR RESIDENTS IN CAMBODIA
  3. FOR RESIDENTS IN THE EU/EEA, UK AND SWITZERLAND
    1. PERSONAL DATA WE COLLECT ABOUT YOU
    2. HOW WE COLLECT YOUR PERSONAL DATA
    3. HOW WE USE YOUR PERSONAL DATA
    4. YOUR RIGHTS
    5. COOKIES
    6. SHARING YOUR PERSONAL DATA WITH THIRD PARTIES
    7. INTERNATIONAL TRANSFERS
    8. DATA SECURITY
    9. HOW LONG WE KEEP YOUR PERSONAL DATA FOR
    10. GLOSSARY

I. IMPORTANT INFORMATION AND WHO WE ARE

This Privacy Policy aims at providing you with information on how Mediam collects and processes your personal data when you use our Website such as when you sign up to our newsletter and sign up for one of our events or webinars.

This Website is not intended for children, and we do not knowingly collect data relating to children. It is important that you read this privacy policy so that you are fully aware of how and why we are using your data.

i. CONTROLLER

Aleph Group Inc. is the holding company of different legal entities, including Mediam (Cambodia) Co. Ltd., which is the provider of this Website. When we use “Mediam”, “we”, “us”, or “our” in this Privacy Policy, we are referring to the relevant company, member of the Aleph Group, providing you services which is considered to be the Data Controller of your personal data.

We have appointed a Group Data Protection Officer who is responsible for overseeing compliance with applicable data protection legislation and will respond to your questions about this Privacy Policy. If you have any questions about this Privacy Policy, including requests to exercise any of your rights, please contact our Group Data Protection Officer using the details below

ii. CONTACT DETAILS

If you have any questions about this privacy policy or our personal data processing practices,, please contact us at:
Email address: privacy@alephholding.com and privacy@httpool.com

iii. CHANGES TO THE PRIVACY POLICY

We keep our Privacy Policy under regular review. This version was last updated on June 24th, 2023. You can obtain historic versions by contacting us via email.

It is important that the personal data we hold about you is accurate and current. Please keCAMBODIAep us informed if your personal data changes at any time.

iv. THIRD PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. For example we may use Mailchimp for the contact forms on the website, Google's Blog, Skillshop and we might link to content on our partner's websites or other similar sites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

II. FOR RESIDENTS IN CAMBODIA

If you reside Cambodia, we will process your personal data according to section III. below. You might have certain rights under applicable e-commerce laws in Cambodia, such as the right to access your personal information, the right to be informed about how we use your personal data, the right to correct inaccurate or incorrect personal data and the right to opt-out from receiving marketing communications (see section “Your rights” below). You can contact us to inquire further information or exercise your rights. If you try to exercise a right not granted to you under your country’s applicable legislation, we will let you know as soon as possible. In all other instances, we will respond to your request within the deadline set in the applicable legislation (if any).

The applicable data protection and e-commerce laws of your country require us to provide you with detailed information about how and why we process your personal data so please refer to the information provided in the section “For residents in the EU/EEA, UK and Switzerland” .

III. FOR RESIDENTS IN THE EU/EEA, UK AND SWITZERLAND

i. PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together below:

  1. On our websites: We collect personal data when you fill out and submit forms (for example, when you register for a webinar) or interact with our sites (for example cookies). We may collect your email address, full name and IP address. We may also ask whether you are an agency or advertiser, what country you come from, and other relevant business information. You can freely browse our website without having to provide personal data.
  2. Special events: When you register for our Mediam webinars or special events, we collect information such as your full name, address, telephone number and email address. We may use this information to contact you and, in some cases, assist you with registration.
  3. Client Onboarding information: the personal data you provide to us when you fill out the Onboarding questionnaire for our services.
  4. Customer Testimonials: We post comments and testimonials on our websites and these may contain personal data. We obtain consent from each client by email or through other agreements with us before publishing their name and testimonial.
  5. Linking with Google: If you use linking from Gmail or your Google account to link your Google Ads account, you will be asked to give us access to information from your Google Ads or Google account. The use and transfer to any other application of information that Mediam receives from Google APIs adheres to the Google API Services User Data Policy, including limited use requirements.
  6. Integration with Google Ads: For the connection with Google Ads to work correctly, Mediam will be able to see the main KPIS of your campaigns, upload and download them, and store their content and titles. Mediam uses these permissions to activate the features of our Impression Share and recommendations platform, which will allow it to show you relevant information and recommendations to improve your campaigns. The use and transfer to any other application of information that Mediam receives from Google APIs adhere to the Google API Service User Data Policy, including limited use requirements.

We also collect, use and share Aggregated Data, such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy

We do not collect any Special Categories of Personal Data about you (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data under applicable law, or under the terms of our contract, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to discontinue our services to you, but we will notify you before that happens

ii. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data about you.

  • Direct interactions. You may provide to us your personal data by filling in forms or by corresponding with us by post, over the phone or via email. This includes personal data you provide when you;
    • Apply for our products or services;
    • Subscribe to our service or publications;
    • Request marketing to be sent to you;
    • Enter a competition, promotion or survey; or
    • Give us feedback or contact us.
  • Automated technologies or interactions. We may collect this information directly from you, from your organization, and from third parties who own or operate applications available in the Service. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for more information.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

    Technical Data from the following parties:

    1. Analytics providers
    2. Advertising networks
    3. Search information providers
    4. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
    5. Identity and Contact Data from data brokers or aggregators
    6. Identity and Contact Data from publicly available sources
    7. Social media interactions with any of our channels

iii. HOW WE USE YOUR PERSONAL DATA

Below you can find the details of how we use your personal data and the legal bases we rely on to do so. Please note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. You can contact us if you need more details.

What we use your personal data for Our legal basis for processing
  1. Consider your application to receive services from us;
  2. Investigate any complaints or issues you may have and offer resolution;
  3. Exercise our rights under the contract between you and Mediam, such as managing invoices or recovering money you owe us;
  4. Provide our services in line with our Terms and Conditions;
  5. Send you emails or other communications about your account or services you use when you contact us.
 We need to use your personal data for a contract we have with you or to enter into a contract with you
  1. To meet our legal obligations when we need to respond to a request coming from you to exercise your rights under data protection law or when we have to notify you about changes to our Privacy Policy.
  2. To share it with other organisations (for example, government authorities, law enforcement authorities or tax authorities)
 Legal obligation
  1. We use your personal data to help us develop and improve our current services. This allows us to continue to provide services that our customers want to use;
  2. Security and business management
 When it’s in our legitimate interest
  1. To record any issues you want us to be aware of so we can best support you (if this information is sensitive, we are required to have a second legal basis);
  2. To tell you about our partners, products and services via email if we believe they are of interest to you. If you do not wish to receive such communications, you may unsubscribe using the link in each email you receive from us;
  3. Share your personal data with our suppliers when we need your permission;
 We will ask for your consent
We may share information about you externally (generally with law enforcement in an emergency), if it's necessary to protect your or another person's life and you cannot consent. It’s necessary to protect your, or another person’s, vital interests.

We use the information you provide to Mediam to promote our products, services and events. For example, we use your email or postal address to send you information or content from Google Ads that we think you might be interested in and marketing communications related to our company. We also use this data to promote the use of our services and share promotional and informational content with you in accordance with your communication preferences. In addition, we may contact you by phone to discuss other Mediam products or services that may be of interest to you. If you have a scheduled call with a Mediam representative, we may record and transcribe the call. We will notify you of this beforehand, so that you can cancel it if you wish.

For use of Mediam GPS

  • We use your account information and customer data to provide you with our products and services. For example, we use the email address you provide us when you sign up to create your user account.
  • We collect data about how our products and services are used by monitoring and tracking our users. We use this data to develop and improve our products and services. For example, usage data allows us to evaluate trends and product usage to help us determine what new features or integrations our users might be interested in. We may share Usage Data externally, but only after it is anonymized and/or aggregated to create or improve features.
  • We use anonymized customer information for machine learning that is used in certain features and functionality of products within the subscription service. For example, machine learning is used to improve the business card scanning tool when you use our mobile apps and makes it easier to import information into your Mediam account. You can request that your data not be used for the latter purpose by sending an email to us.

To protect Mediam users:

  • We use your account information to investigate and prevent security incidents. We may also use this information to comply with legal requirements.

For research and development purposes:

  • We may provide statistical information to Google about our users, although such information will not be used to identify any individual person and will only be shared in an aggregated, deidentified manner; for example, we might post blog posts about trends and product interaction data.

Other activities we can do with your consent.

There may be cases where Mediam discloses your information for purposes not listed above. Mediam will take steps to provide notice to you prior to these unforeseen disclosure

We will share your data with third parties after you give us your permission to do so.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising

PROMOTIONAL OFFERS

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

iv. YOUR RIGHTS

In short: Under data protection legislation in the UK, EU/EEA and Switzerland you may have certain rights, including but not limited to the right to access or manage your personal data, to delete or update it, and restrict its use.

  1. Right to be informed: you have the right to be informed about how we collect and use your personal data. We provide you with this information in this Privacy Policy and by answering any privacy-related questions you address to us.
  2. Right to access your data: you have the right to request a copy of the personal data we hold about you.
  3. Right to rectification: you have the right to have inaccurate or incomplete personal data rectified.
  4. Right to erasure: under certain circumstances, you may have the right to have your personal data deleted. Examples of when this request may be granted include when:
    • it is no longer necessary to process your data for the purpose it was collected
    • you have withdrawn your consent for consent-based data processing,
    • we have used your personal data unlawfully, or
    • we have a legal obligation to remove your data.
  5. Right to restrict or object to the processing of your personal data: in certain circumstances, we may agree to restrict or suppress the processing of your personal data. Examples of when we may agree to this include:
    • you have asked us to verify the accuracy of your data,
    • we have processed your data unlawfully, but you do not wish your data to be deleted,
    • we no longer need your personal data, but you do not wish your data to be deleted in order to establish, exercise, or defend a legal claim, or
    • you objected to us using your personal data, but your objection was outweighed by our legitimate interests.
  6. Right to challenge an automated decision: you have the right to request us to manually review an automated decision made about you if that decision has a legal or similarly significant effect on you.
  7. Right to withdraw consent: if the legal basis we use for the processing of your personal data is consent, you can withdraw your consent at any time.
  8. Right to opt-out of commercial communication: you have the right to opt-out of any future commercial communication through the unsubscribe link provided with each commercial email. You further have the right to not be contacted by phone regarding any commercial offering. Please note that your country may offer a telemarketing do-not-calllist.

If you wish to exercise any of the rights set out above, please contact us at: privacy@httpool.com or privacy@alephholding.com.

HOW TO EXERCISE YOUR RIGHTS

If you wish to exercise any of your rights, please use the information provided under Contact Details above.

HOW TO LODGE A COMPLAINT

You have the right to lodge a complaint with your national data protection authority if you are not satisfied with how we use your personal data. A list of all competent authorities in the EU can be found here. In the UK, you can refer the issue to the Information Commissioner’s Office (“ICO”), the UK’s supervisory data protection authority. If you reside in Switzerland, you can contact the Federal Data Protection and Information Commissioner (“FDPIC”).

v. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see COOKIE POLICY.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

vi. SHARING YOUR PERSONAL DATA WITH THIRD PARTIES

  1. Aleph group companies

    We share your personal data within the Aleph group of companies to:

    1. provide you with the best service;
    2. send you information about Aleph products and services we think you’ll be interested in hearing about.

  2. Suppliers

    Here we have included companies that help Aleph Express provide the services you use, and need to process details about you for this reason. We always share as little information as we can and encrypt and/or make it impossible for the recipient to identify you where possible. These are:

    • payment processing partners;
    • analytical and cyber security service providers that help us with fraud and security checks;
    • cloud computing power, storage and software providers;
    • our business intelligence and analytics platform provider;
    • companies that help us with functional analytics (to help us solve technical problems with the app, for example);
    • companies that help us with marketing (we won't share identifiable personal data with third parties for their own direct marketing unless you give us permission, and you can opt out any time);
    • software companies that we use to email you, or for processing and storing emails with you;
    • companies that help us with customer support, surveys, and developers.

  3. Partners who help to provide our services

    We may share your personal data with our partners to provide you with certain requested services. We‘ll only share your personal data in this way if you have asked for the relevant service. From time to time, we may work with other partners to offer co-branded services or promotional offers, and we will share some of your personal data with those partners. We will always make sure you understand how we and our partners process your personal data for these purposes.

    For example, we will share your personal data with Google, for the purpose of direct communications or quality assessments. We obtain the consent of each client by email or through other means before sharing your personal data with Google.

  4. For legal reasons

    We also share your personal data with government authorities, law enforcement authorities, tax authorities or courts:

    • if we have to do so under any law or regulation;
    • if we sell our business;
    • in connection with suspected or actual criminal or fraud investigations;
    • to enforce our rights (and those of our customers or others);
    • in connection with legal claims.

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

vii. INTERNATIONAL TRANSFERS

We may share your personal data within the Aleph Group Inc.
Mediam will store your personal data in accordance with your local regulations and will provide the security required to protect it

TRANSFERRING DATA OF EU/EEA, UK AND SWISS RESIDENTS

Is my personal data transferred internationally?

In short: We may transfer, store, and process your information in countries other than your own. We provide an international service which, in some instances, may require transferring, storing, and processing of your personal data in a country outside the UK, EU/EEA and Switzerland. To do so, we have taken all necessary steps to ensure that your data is afforded a level of protection that is essentially equivalent to that guaranteed within the EU/EEA, the UK and Switzerland. For that reason, we will only transfer your data to a third country:

  • if the European Commission has adopted a decision confirming that a third country provides adequate protection (or the competent authority in Switzerland) has done so for transfers outside these territories; or
  • if we’ve agreed to Standard Contractual Clauses (“SCCs”) approved by the European Commission (for EEA), to SCCs via the ICO’s UK Addendum (for the UK) or an equivalent mechanism (for Switzerland) with a third party.

viii. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

ix. HOW LONG WE KEEP YOUR PERSONAL DATA FOR

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

You can request details of retention periods when we process your personal data by contacting us.

In certain cases, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

HOW AND WHEN WE WILL RESPOND TO YOUR REQUEST

We strive to promptly respond to your requests. In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the reasons that prevent us from complying with your requests. In cases where we are not processing your personal information, we will indicate to you the natural or legal person to whom you should address your requests, if we are in the position to do so.

We try to respond to all requests as soon as possible and at least within one (1) month of receiving the request. However, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.

You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.

In the latter case, we’ll respond as soon as possible, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.

WHAT WE MAY NEED FROM YOU

We may need additional information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure we need to have so that personal data is not disclosed to any person who is not authorized to receive it . We may also contact you to ask you for further information in relation to your request to speed up our response.

YOU EXPRESSLY ACKNOWLEDGE THAT YOU HAVE READ THIS PRIVACY POLICY AND YOU UNDERSTAND THE RIGHTS, OBLIGATIONS, TERMS AND CONDITIONS SET FORTH HEREIN.

x. Glossary

GOOGLE: means Google EMEA HQ, Dublin 4 Ireland and its affiliates. LAWFUL BASIS
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Mediam Nepal Pvt Ltd (“Mediam”) respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you about how we use your personal data when you visit our website (“Website”) and use our services and tell you about your rights and how the law protects you.

This Privacy Policy is provided in a layered format. You can click through to the specific areas below:

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. FOR RESIDENTS IN NEPAL
  3. FOR RESIDENTS IN THE EU/EEA, UK AND SWITZERLAND
    1. PERSONAL DATA WE COLLECT ABOUT YOU
    2. HOW WE COLLECT YOUR PERSONAL DATA
    3. HOW WE USE YOUR PERSONAL DATA
    4. YOUR RIGHTS
    5. COOKIES
    6. SHARING YOUR PERSONAL DATA WITH THIRD PARTIES
    7. INTERNATIONAL TRANSFERS
    8. DATA SECURITY
    9. HOW LONG WE KEEP YOUR PERSONAL DATA FOR
    10. GLOSSARY

I. IMPORTANT INFORMATION AND WHO WE ARE

This Privacy Policy aims at providing you with information on how Mediam collects and processes your personal data when you use our Website such as when you sign up to our newsletter and sign up for one of our events or webinars.
This Website is not intended for children, and we do not knowingly collect data relating to children. It is important that you read this Privacy Policy so that you are fully aware of how and why we are using your personal data.

i. CONTROLLER

Aleph Group Inc. is the holding company of different legal entities, including Mediam Nepal Pvt Ltd,, which is the provider of this Website. When we use “Mediam”, “we”, “us”, or “our” in this Privacy Policy, we are referring to the relevant company, member of the Aleph Group, providing you services which is considered to be the Data Controller of your personal data.

We have appointed a Group Data Protection Officer who is responsible for overseeing compliance with applicable data protection legislation and will respond to your questions about this Privacy Policy. If you have any questions about this Privacy Policy, including requests to exercise any of your rights, please contact our Group Data Protection Officer using the details below

ii. CONTACT DETAILS

If you have any questions about this privacy policy or our personal data processing practices,, please contact us at:
Email address: privacy@alephholding.com and privacy@httpool.com

iii. CHANGES TO THE PRIVACY POLICY

We keep our Privacy Policy under regular review. This version was last updated on June 24th, 2023. You can obtain historic versions by contacting us via email.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes at any time.

iv. THIRD PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. For example we may use Mailchimp for the contact forms on the website, Google's Blog, Skillshop and we might link to content on our partner's websites or other similar sites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

II. FOR RESIDENTS IN NEPAL

If you reside in Nepal, you might have certain rights under applicable data protection laws, such as the right to access your personal information, the right to be informed about how we use your personal data and the right to correct inaccurate or incorrect personal data (see section “Your rights” below). You can contact us to inquire further information or exercise your rights. If you try to exercise a right not granted to you under Nepal’s applicable legislation, we will let you know as soon as possible. In all other instances, we will respond to your request within the deadline set in the applicable legislation (if any).

The applicable data protection laws of your country require us to provide you with detailed information about the personal data we collect about you and how we protect it so please refer to the information provided in the section “For residents in the EU/EEA, UK and Switzerland” . Please note that section III will only apply to you to the extent that local legislation allows Mediam to process your personal data in such a manner, e.g. rely on a specific legal basis for processing.

III. FOR RESIDENTS IN THE EU/EEA, UK AND SWITZERLAND

i. PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together below:

  1. On our websites: We collect personal data when you fill out and submit forms (for example, when you register for a webinar) or interact with our sites (for example cookies). We may collect your email address, full name and IP address. We may also ask whether you are an agency or advertiser, what country you come from, and other relevant business information. You can freely browse our website without having to provide personal data.
  2. Special events: When you register for our Mediam webinars or special events, we collect information such as your full name, address, telephone number and email address. We may use this information to contact you and, in some cases, assist you with registration.
  3. Client Onboarding information: the personal data you provide to us when you fill out the Onboarding questionnaire for our services.
  4. Customer Testimonials: We post comments and testimonials on our websites and these may contain personal data. We obtain consent from each client by email or through other agreements with us before publishing their name and testimonial.
  5. Linking with Google: If you use linking from Gmail or your Google account to link your Google Ads account, you will be asked to give us access to information from your Google Ads or Google account. The use and transfer to any other application of information that Mediam receives from Google APIs adheres to the Google API Services User Data Policy, including limited use requirements.
  6. Integration with Google Ads: For the connection with Google Ads to work correctly, Mediam will be able to see the main KPIS of your campaigns, upload and download them, and store their content and titles. Mediam uses these permissions to activate the features of our Impression Share and recommendations platform, which will allow it to show you relevant information and recommendations to improve your campaigns. The use and transfer to any other application of information that Mediam receives from Google APIs adhere to the Google API Service User Data Policy, including limited use requirements.

We also collect, use and share Aggregated Data, such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy

We do not collect any Special Categories of Personal Data about you (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data under applicable law, or under the terms of our contract, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to discontinue our services to you, but we will notify you before that happens

ii. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data about you.

  • Direct interactions. You may provide to us your personal data by filling in forms or by corresponding with us by post, over the phone or via email. This includes personal data you provide when you;
    • Apply for our products or services;
    • Subscribe to our service or publications;
    • Request marketing to be sent to you;
    • Enter a competition, promotion or survey; or
    • Give us feedback or contact us.
  • Automated technologies or interactions. We may collect this information directly from you, from your organization, and from third parties who own or operate applications available in the Service. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for more information.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

    Technical Data from the following parties:

    1. Analytics providers
    2. Advertising networks
    3. Search information providers
    4. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
    5. Identity and Contact Data from data brokers or aggregators
    6. Identity and Contact Data from publicly available sources
    7. Social media interactions with any of our channels

iii. HOW WE USE YOUR PERSONAL DATA

Below you can find the details of how we use your personal data and the legal bases we rely on to do so. Please note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. You can contact us if you need more details.

What we use your personal data for Our legal basis for processing
  1. Consider your application to receive services from us;
  2. Investigate any complaints or issues you may have and offer resolution;
  3. Exercise our rights under the contract between you and Mediam, such as managing invoices or recovering money you owe us;
  4. Provide our services in line with our Terms and Conditions;
  5. Send you emails or other communications about your account or services you use when you contact us.
 We need to use your personal data for a contract we have with you or to enter into a contract with you
  1. To meet our legal obligations when we need to respond to a request coming from you to exercise your rights under data protection law or when we have to notify you about changes to our Privacy Policy.
  2. To share it with other organisations (for example, government authorities, law enforcement authorities or tax authorities)
 Legal obligation
  1. We use your personal data to help us develop and improve our current services. This allows us to continue to provide services that our customers want to use;
  2. Security and business management
 When it’s in our legitimate interest
  1. To record any issues you want us to be aware of so we can best support you (if this information is sensitive, we are required to have a second legal basis);
  2. To tell you about our partners, products and services via email if we believe they are of interest to you. If you do not wish to receive such communications, you may unsubscribe using the link in each email you receive from us;
  3. Share your personal data with our suppliers when we need your permission;
 We will ask for your consent
We may share information about you externally (generally with law enforcement in an emergency), if it's necessary to protect your or another person's life and you cannot consent. It’s necessary to protect your, or another person’s, vital interests.

We use the information you provide to Mediam to promote our products, services and events. For example, we use your email or postal address to send you information or content from Google Ads that we think you might be interested in and marketing communications related to our company. We also use this data to promote the use of our services and share promotional and informational content with you in accordance with your communication preferences. In addition, we may contact you by phone to discuss other Mediam products or services that may be of interest to you. If you have a scheduled call with a Mediam representative, we may record and transcribe the call. We will notify you of this beforehand, so that you can cancel it if you wish.

For use of Mediam GPS

  • We use your account information and customer data to provide you with our products and services. For example, we use the email address you provide us when you sign up to create your user account.
  • We collect data about how our products and services are used by monitoring and tracking our users. We use this data to develop and improve our products and services. For example, usage data allows us to evaluate trends and product usage to help us determine what new features or integrations our users might be interested in. We may share Usage Data externally, but only after it is anonymized and/or aggregated to create or improve features.
  • We use anonymized customer information for machine learning that is used in certain features and functionality of products within the subscription service. For example, machine learning is used to improve the business card scanning tool when you use our mobile apps and makes it easier to import information into your Mediam account. You can request that your data not be used for the latter purpose by sending an email to us.

To protect Mediam users:

  • We use your account information to investigate and prevent security incidents. We may also use this information to comply with legal requirements.

For research and development purposes:

  • We may provide statistical information to Google about our users, although such information will not be used to identify any individual person and will only be shared in an aggregated, deidentified manner; for example, we might post blog posts about trends and product interaction data.

Other activities we can do with your consent.

There may be cases where Mediam discloses your information for purposes not listed above. Mediam will take steps to provide notice to you prior to these unforeseen disclosure

We will share your data with third parties after you give us your permission to do so.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising

PROMOTIONAL OFFERS

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

iv. YOUR RIGHTS

In short: Under data protection legislation in the UK, EU/EEA and Switzerland you may have certain rights, including but not limited to the right to access or manage your personal data, to delete or update it, and restrict its use.

  1. Right to be informed: you have the right to be informed about how we collect and use your personal data. We provide you with this information in this Privacy Policy and by answering any privacy-related questions you address to us.
  2. Right to access your data: you have the right to request a copy of the personal data we hold about you.
  3. Right to rectification: you have the right to have inaccurate or incomplete personal data rectified.
  4. Right to erasure: under certain circumstances, you may have the right to have your personal data deleted. Examples of when this request may be granted include when:
    • it is no longer necessary to process your data for the purpose it was collected
    • you have withdrawn your consent for consent-based data processing,
    • we have used your personal data unlawfully, or
    • we have a legal obligation to remove your data.
  5. Right to restrict or object to the processing of your personal data: in certain circumstances, we may agree to restrict or suppress the processing of your personal data. Examples of when we may agree to this include:
    • you have asked us to verify the accuracy of your data,
    • we have processed your data unlawfully, but you do not wish your data to be deleted,
    • we no longer need your personal data, but you do not wish your data to be deleted in order to establish, exercise, or defend a legal claim, or
    • you objected to us using your personal data, but your objection was outweighed by our legitimate interests.
  6. Right to challenge an automated decision: you have the right to request us to manually review an automated decision made about you if that decision has a legal or similarly significant effect on you.
  7. Right to withdraw consent: if the legal basis we use for the processing of your personal data is consent, you can withdraw your consent at any time.
  8. Right to opt-out of commercial communication: you have the right to opt-out of any future commercial communication through the unsubscribe link provided with each commercial email. You further have the right to not be contacted by phone regarding any commercial offering. Please note that your country may offer a telemarketing do-not-calllist.

If you wish to exercise any of the rights set out above, please contact us at: privacy@httpool.com or privacy@alephholding.com.

HOW TO EXERCISE YOUR RIGHTS

If you wish to exercise any of your rights, please use the information provided under Contact Details above.

HOW TO LODGE A COMPLAINT

You have the right to lodge a complaint with your national data protection authority if you are not satisfied with how we use your personal data. A list of all competent authorities in the EU can be found here. In the UK, you can refer the issue to the Information Commissioner’s Office (“ICO”), the UK’s supervisory data protection authority. If you reside in Switzerland, you can contact the Federal Data Protection and Information Commissioner (“FDPIC”).

v. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see COOKIE POLICY.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

vi. SHARING YOUR PERSONAL DATA WITH THIRD PARTIES

  1. Aleph group companies

    We share your personal data within the Aleph group of companies to:

    1. provide you with the best service;
    2. send you information about Aleph products and services we think you’ll be interested in hearing about.

  2. Suppliers

    Here we have included companies that help Aleph Express provide the services you use, and need to process details about you for this reason. We always share as little information as we can and encrypt and/or make it impossible for the recipient to identify you where possible. These are:

    • payment processing partners;
    • analytical and cyber security service providers that help us with fraud and security checks;
    • cloud computing power, storage and software providers;
    • our business intelligence and analytics platform provider;
    • companies that help us with functional analytics (to help us solve technical problems with the app, for example);
    • companies that help us with marketing (we won't share identifiable personal data with third parties for their own direct marketing unless you give us permission, and you can opt out any time);
    • software companies that we use to email you, or for processing and storing emails with you;
    • companies that help us with customer support, surveys, and developers.

  3. Partners who help to provide our services

    We may share your personal data with our partners to provide you with certain requested services. We‘ll only share your personal data in this way if you have asked for the relevant service. From time to time, we may work with other partners to offer co-branded services or promotional offers, and we will share some of your personal data with those partners. We will always make sure you understand how we and our partners process your personal data for these purposes.

    For example, we will share your personal data with Google, for the purpose of direct communications or quality assessments. We obtain the consent of each client by email or through other means before sharing your personal data with Google.

  4. For legal reasons

    We also share your personal data with government authorities, law enforcement authorities, tax authorities or courts:

    • if we have to do so under any law or regulation;
    • if we sell our business;
    • in connection with suspected or actual criminal or fraud investigations;
    • to enforce our rights (and those of our customers or others);
    • in connection with legal claims.

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

vii. INTERNATIONAL TRANSFERS

We may share your personal data within the Aleph Group Inc.
Mediam will store your personal data in accordance with your local regulations and will provide the security required to protect it

TRANSFERRING DATA OF EU/EEA, UK AND SWISS RESIDENTS

Is my personal data transferred internationally?

In short: We may transfer, store, and process your information in countries other than your own. We provide an international service which, in some instances, may require transferring, storing, and processing of your personal data in a country outside the UK, EU/EEA and Switzerland. To do so, we have taken all necessary steps to ensure that your data is afforded a level of protection that is essentially equivalent to that guaranteed within the EU/EEA, the UK and Switzerland. For that reason, we will only transfer your data to a third country:

  • if the European Commission has adopted a decision confirming that a third country provides adequate protection (or the competent authority in Switzerland) has done so for transfers outside these territories; or
  • if we’ve agreed to Standard Contractual Clauses (“SCCs”) approved by the European Commission (for EEA), to SCCs via the ICO’s UK Addendum (for the UK) or an equivalent mechanism (for Switzerland) with a third party.

viii. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

ix. HOW LONG WE KEEP YOUR PERSONAL DATA FOR

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

You can request details of retention periods when we process your personal data by contacting us.

In certain cases, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

HOW AND WHEN WE WILL RESPOND TO YOUR REQUEST

We strive to promptly respond to your requests. In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the reasons that prevent us from complying with your requests. In cases where we are not processing your personal information, we will indicate to you the natural or legal person to whom you should address your requests, if we are in the position to do so.

We try to respond to all requests as soon as possible and at least within one (1) month of receiving the request. However, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.

You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.

In the latter case, we’ll respond as soon as possible, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.

WHAT WE MAY NEED FROM YOU

We may need additional information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure we need to have so that personal data is not disclosed to any person who is not authorized to receive it . We may also contact you to ask you for further information in relation to your request to speed up our response.

YOU EXPRESSLY ACKNOWLEDGE THAT YOU HAVE READ THIS PRIVACY POLICY AND YOU UNDERSTAND THE RIGHTS, OBLIGATIONS, TERMS AND CONDITIONS SET FORTH HEREIN.

x. Glossary

GOOGLE: means Google EMEA HQ, Dublin 4 Ireland and its affiliates. LAWFUL BASIS
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.