Last Updated: December 15, 2019

Engageya is an online advertising company, operated by Trackonomics Ltd. (“we”, “us” or “Engageya”). Engageya that provides a content engagement engine and service, greatly values its end users’ privacy and therefore has designed this Privacy Policy (“Privacy Policy”) to explain to you about our data collection and protection practices when you access, use, interact or engage with our website(s) (available at: www.engageya.com), any of our widgets and any respective content, analytics tools, engines, technologies and/or services that we make available to different type of customers (respectively, the “Site”, the “Platform” and jointly, the “Services”).

Note that this Privacy Policy is an integral part of our Terms and Conditions available at: www.engageya.com/terms), (the “Terms”), whether you are an end consumer who interacts with the Services through one or more of our partners’ websites, or a business partner who engages with us and integrates the Services into your business and online properties.

If you do not agree to this Privacy Policy and to the data collection practices described herein, we will not be able to provide you with our Services. In some cases, however, if you are an end user, you will be able to opt out from having our Services using your personal data, as described below under the Choices and Opt-out section.

Please make sure you read this Privacy Policy carefully, understand it and consent to its terms. If you have any questions about it, please reach out to us at privacy@engageya.com or Esentepe Mahallesi, Talatpaşa Cd. No:5, 34394 Şişli/İstanbul, Turkey, +44-20-80895641.


We may, from time to time, modify, add or delete provisions of this Privacy Policy. Your use of the Site or Services following the effective date of any such modification means your consent and acceptance to the modified Privacy Policy. In cases of material changes, we will make sure to provide you with a more prominent notice, for example, posting a note on the Site, through Services or similar method.

This Privacy Policy includes the following:

  1. Application of this Privacy Policy
  2. If you are a business partner (a “Customer”)
    • Information we Collect About Customers
    • The purposes for collecting and processing Customer information and respective legal basis
    • Sharing of Customer information
    • Customers’ choices about their information
  3. If you are a visitor of a website in which the Services are displayed (an “End User”)
    • Information we collect about End Users
    • How we collect End User Information
    • The purposes for collecting and processing End Users information and respective legal basis
    • Sharing End User information
    • End User’s choices and opt-out
    • End User’s rights
    • Links to third-party websites
    • Data & Information security
    • Data retention and Destruction
    • Cross-border data transmission
    • Children’s privacy
    • Comments and questions


    This Privacy Policy explains Engageya’s data collection practices that apply toward (i) our Customers, whether they are publishers, advertisers or any other type of business partners and (ii) visitors of the Site and our (publishers) Customers’ websites and/or other online products. Customers and End Users will be jointly referred to as “Users”.

    Lastly, the Privacy Policy outlines general provisions, which are applicable to any type of User. Capitalized terms will have the meaning given in the Engageya Terms or herein. When we use the term Personal Information we mean information that may be used, either alone or in combination with other information, to personally identify an individual (natural person), such as a first and last name, email address, phone number, a home or other physical address, and other contact information. In some jurisdictions and given the specific use we make with the information,additional types of data may be considered as Personal Information, such as the IP address that your Internet service provider allocates for your devicecookies ID and other web tracking technologies and tags. We do not make any use of such data to personally identify you, and we make sure to safeguard any data to prevent such use. Additionally, in such cases we will treat the information as personal in all handling and safeguarding aspects.


    If you are a Customer of the Services, in addition to the User Information we collect and described below, we may collect Personal Information that you are required to submit when you open an account with us, for the purpose of engaging with us in a business relationship or otherwise integrating our Services into your own sites, products, software and services. In such cases our data collection practices will be as follows:


      In addition to theinformation we may collect about End Users, (as detailed below), if you are a Customer and you choose to open an account and sign up, you will be asked to submit to an online formcertain Personally Identifiable Information, such as first and last name, email address of the entity on whose behalf you are engaging with us, a password for accessing your account and information about your website that you wish to register with us. We will also collect other Information that Customers choose to provide to us, such as communications a Customer submits to us through our Services (collectively, “Customer Information”).


      We use Customer information in order to (i) render our Services and contact Customers who express their will to communicate with us and/or engage with the Services; (ii) communicate with Customers and respond to any inquiry or any other form of communications from Customers; (iii) provide Customers with newsletters, promotions, updates, and other information Customer may find useful, including via email.

      The legal basis to the purposes of using and processing this information is contract based. When a Customer engaged in a business partnership with us they agree to our business terms and conditions and sign a contract with us for exchange of services.


      Apart from the following circumstances, we do not share our Customers information: We may disclose or share Customer Information to a present or future (i) affiliated, parent company and/or subsidiaries that help us with facilitating the Services or operating the Sites; (ii)processors, service providers, contractors, vendors and any other individual or entity which requires access to Customer Information in order to perform their functions; (iii) other Customers, to the extent required to render the Services and consented to by Customer.


      As a Customer you have certain rights concerning your Customer Information, including to edit, correct, verify, update or delete it. If you wish to exercise any of those rights, you may do so by contacting us directly at: privacy@engageya.com, or requesting your business contact at Engageya to do so. In addition, any email communication we send you and includes general or marketing information will include an opt-out / unsubscribe option that you can directly exercise via the email communication. Please note that if you choose to unsubscribe from email communication, we may still hold your account information and Customer Information and may contact you for updates regarding your use of the Services or any other relevant account information.


    If you are an End User of the Services, the following data privacy practices are relevant for you:


      When you visit the Site or access or interact with the Services, we may collect some information about such use depending on the Service (and respective technology) in question. Such information includes the following categories: device information (such as type, operating system type, browser’s type, version and language, all of which extracted from your ‘user agent’), the domain or URL of the website you browse in which the Services are integrated, and on which you consume the Services. We also get access to the IP address of the device that accessed the Services for purposes of user validation bot or real End User validation and fraud detection, in which case such data is retained separately from other data items with no ability to correlate an IP address with other data (jointly, ("User Information")). We also use the IP address to extract non identifiable information, such as the country and region of the End Users and to facilitate content serving in the language of and relevancy for the End User. User Information and Customer Information will be jointly referred to as the "Information".


      Similarly to most online services, we also use Cookies (also known as web beacons), pixel tags and similar web technologies to collect User Information. We briefly explain herein about how cookie collection work, and designed a Cookie Policy to further explain about the type of cookies we use, how and why.

      • Cookies

        A cookie is a small text file that is placed on the browser of the hard drive of your computer (or similar device) by websites that you visit. Most websites and online services use cookies. Cookies are typically used together with web beacons in order to make websites or web services function, or function more efficiently, as well as to provide information to the operator of the particular website or service. Cookies make your use of the Services easier to use and improve their functionality. In some of the Platforms or Serviceswe operate, Cookies are essential for the proper functionality of that Platform or Services. Most browsers are automatically set to accept cookies, but you can usually modify your browser settings to disable cookies or to remove them. If you choose to disable cookies though you will still be able to access the Website and use the Services, but some features and services may not properly function.

      • Web Beacons

        We and our advertising partners may use standard Internet technology such as web beacons (or clear gifs), tracking pixels, and similar technologies to gather analytics and anonymous, non- identifiable information about End Users that interact with the Services or content therein. This is usually used to better understand Users’ likes and dislikes to better improve a content service engines and technologies.

      • Log Files

        Technical information from your browser is automatically collected into a log file whenever you visit our Site or interact with any of the Services. This information includes your device’s IP address, browser type, operating system, access times, the content of any undeleted cookies that the End User’s browser previously accepted from us, and the referring website address. For more information about cookies and our use of them on the Site and inthe course of our Services, refer to our Cookie Policy


      Please note that we use User Information for purposes of providing the Services, purposes of constantly improving them and improving our Platform. Most of our data processing activities are based on our legitimate interest, as it is essential for our ability to operate, maintain and improve the Services and the Platform. Other data processing activities are used to improve and personalize our content suggestion (i.e. End User experience), and is based on you consent, which is given to us either directly or indirectly.

      The following is a list of data processing activities, their purposes, and their respective legal basis:

      • Based on our legitimate interest, we process Personal Information for purposes of (a) operating and further developing and improving the Services, the Platform and the underlying technology, including our ability to make a content selection, filtering, vetting and monitoring; (b) we processes certain IP addresses for anti-fraud purposes, and to validate if an interacting End User is a human or machine/bot; (c) analytics and statistics of visits, interactions and engagement with content we serve.

      • Based on your consent, given by you to the websites in which we are embedded, we process Personal Information for purposes of (a) enhancing the Services by serving customized and personalized content and ads based on End User’s interests; (b) processing certain web browsing activity for purposes of retargeting.

      • In other cases we may process Personal Information for a specific ad-hoc purposes, such as (a) for responding to your communication, in case you of a form submission or any other contact you made with us. If you provided us with your email address, and contacted us for an inquiry or request, for example, we will use your contact details and inquiry content to process it and respond and other communications with you. (b) if you are a business Customer, for purposes of identifying or authenticating your access and use of your account; (c) For any legally permissible purpose in our sole discretion or law enforcement requirements.


      We do not share Personal Information about you with Third Parties, except for the following circumstances:

      • Anti-fraud purposes where a third-party monitoring tool or entity or certifier of such is required to maintain and audit a blacklist of IP addresses;

      • Data Storage, Data Centers and Security Platforms ("Processors");We use third-party cloud, data centers and data storage services to store and retain your Information. That means that we send or otherwise share your Information with third party entities that are based in the EU or outside of the EU (US and Israel), for the purpose of storing and safeguarding such information on our behalf or for other processing needs. Such entities include Amazon Web Services (which privacy policy available at: (https://aws.amazon.com/privacy/)and EvoSwitch (which privacy policy available at: https://evoswitch.com/disclaimer/). Our Processors may be based (and their servers may be located) outside of the EU or EEA. In such case, we require each such Processors to maintain a strict privacy protection and data security policies, and strict compliance with applicable data protection laws. Please note that all Processors’ data protection practices are fully governed by their own privacy policies and the jurisdictions in which they are based.

      • Enforcement. We may share your Information with any third party if we believe that disclosure of such information is helpful or reasonably necessary to: (a) comply with an applicable law, regulation, legal process, or governmental request; (b) enforce our terms and conditions, including investigations of potential violations thereof; (c) detect, prevent, or otherwise address fraud or security issues; and/or (d) protect against harm to the rights, property or safety of our Services, system network or technology, our affiliated entities, our users, yourself, and/or the public.

      • Third Party Partners. Under the legal basis of legitimate interest, we submit an anonymous cookie-based datato advertisers and content providers for the purpose of providing them with activity reportsand market research and general trends and interests of different types of End Users (“Content Selection Purpose”). In cases where we get indication for your consent from our publisher partner, we may additionally provide data such as content consumption preferences, to better serve you with content that is relevant and interesting for you, or for users with similar interests. Such data is not being submitted or shared where you chose to opt-out from personalized content or, in cases where you did not provide your consent to do so, when you first browse the website in which our Services are embedded.

      • Merger, Sale or Bankruptcy. In the event that we or one of our affiliated entities is acquired by, or merged with, a third party entity, or otherwise sells all or part of our/its assets, we may (and hereby reserve the right to) transfer or assign Personal Information and other information we have collected or received. In such case, we will require the acquiring entity to post its data practices and provide you with any of your rights as per the jurisdiction of your residency.

      • Other Third Parties. As per need and based on legitimate interest and your hereby consent, we may send or otherwise share End User Information to/with various third parties that help us with our business operations that help us, products and Services improvement or technical developments. These third parties may have their own privacy policies which we require them to (1) keep fully compliant with applicable laws and regulations; and (2) make available whenever their services are provided. We recommend you visit such privacy policies when those third parties render their services directly to you. These third parties may be based (and their servers may be located) anywhere in the world.


      We believe in keeping the choice in our Customers’ and End Users’ hands, so we let you choose whether you want to engage and interact with our Services subject to this Privacy Policy’s terms. Some Information is collected because it is essential and necessary to providing you with the Services. In other cases, you can exercise the following rights with respect to your Information, based on the jurisdiction of your residency. For example (where applicable and relevant):

      • Newsletters, Surveys and Promotions; You may choose not to receive future promotional, advertising, or other similar emails from us by selecting the unsubscribe link at the bottom of each email that we send. Please note that even if you opt out of receiving such emails, we may still send you administrative emails to facilitate your use of the Site or Services, unless you request to completely delete your contact information.

      • Cookies and web tracking technologies. you may set your browser to refuse and/or block any cookies from us or third -party services, or periodically remove and delete any existing cookie installed. Be aware that in such cases some of the Services’ functionality would not be available or would not function properly.

      • Opt-out from personalized content. If you do not wish Personal Information to be processed , sharedor used for personalized content purposes, you may opt out from this use by clicking your choices below. Please select your preferred recommendation settings below.

      • Before Opting Out (disabling EngageYa's cookies), please consider thatthis action may affect your user experience on the websites you visit; for example, you may receive repeated advertisements or general content despite having already clicked and read them in the past and you will probably receive content and advertisements that are generic rather than customized to your interests.

        End Users may also opt-out from the processing and use of Personal Information mobile applications by adjusting their device settings as follows:

      • iOS Devices: Settings > Privacy > Advertising > Limit Ad Tracking;

      • Android Devices: Settings > Google > Ads > Opt Out of Interest-based Advertising;

      • Please note, that opting out does not mean you will no longer see content from us on websites and mobile applications in which our Services are embedded. It means you will no longer see personalized content from us, or our advertising partners until you opt-in..

      • California Privacy Rights. California Civil Code Section 1798.83 permits our Customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are an End User, we do not collect any Personal Information that may identify you – so there would be nothing to request. If you are a Customer and have questions please contact us at privacy@engageya.com.

      • EU Data Subject Rights. Any Personal Information that we may collect under this Privacy Policy is treated in compliance with the EU general data protection regulation(GDPR).

      • Canada. If you are a resident of Canada, you are permitted to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes, where applicable. To make such a request, or if you have any questions about your Personal Information, please contact our compliance team at privacy@engageya.com.

  • You have the right to submit us a request to provide you access to a Personal Information we hold about you, correct your Personal Information, delete your personal Information, and cease or restrict processing of your Personal Information.

    To make any such request, please contact privacy@engageya.com and specify your request.

  • Some of our Services include a third-party content, feature, element and services that are not necessarily provided by us (“Third-Party Content”). Third Party Content may include articles, text, graphics, animation, video, ads, offers, links, buttons or any similar feature with which you are likely to interact or engage. Any interaction you make with such Third-Party Content is governed by its own provider’s policies, terms and conditions. We advise you to refer to such privacy policies each time you choose to interact with Third-Party Content.

  • We, and third-party services or affiliate entities, implement data security systems and procedures to secure information transmitted, processed and stored in our computer servers and systems. For example, the Site is encrypted by using SSL and so is any other information at transport and at rest. We periodically review our information and data collection practices to ensure constant monitoring, we use third party processing and serving services that implement various information security standards and certifications , and we monitor and filter access to data when it comes to personnel in our organization. Such systems and procedures reduce the risk of data security breaches, but as they do not provide absolute security, , we cannot 100%guarantee that the Services and our servers are immune to unauthorized access to the information stored therein and to other information security risks. If you have any questions about our security and safeguards efforts, contact us atprivacy@engageya.com.

  • Unless we are instructed otherwise by applicable laws, we retain Information we collect for as long as needed to provide, operate and monitor the Services, and to comply with our legal obligations, resolve disputes and enforce our agreements.

  • For the purposes listed in this Privacy Policy, we may transfer your Information (including Personal Information) outside the country in which it is collected or in which you reside.In such cases we make sure to apply all the applicable regulation requirements, including by applying contractual safeguards, to ensure that Personal Information is processed in a way that offers an adequate level of protection when it is shared with or among third party vendors. If applicable to your type of interaction with our Services, by providing your consent in the ways described in this Privacy Policy, and by keep on using the Services you expressly consent to the transfer of your Information to another country.

  • The Services are not designed for children under the age of 16. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 16. If we learn that we have collected Personal Information from a child under 16, we will use commercially reasonable efforts to delete that information as quickly as possible. If you believe that we might have such information, please contact us in accordance to the contact information below.

  • If you have any comments or questions about this Privacy Policy, please contact us at privacy@engageya.com.

For Data Subjects in the EU
We have appointed GDPR-Rep.eu as representative according to Art 27 GDPR. If you want to make use of your GDPR data privacy rights, please visit: https://gdpr-rep.eu/q/19616340

Contact GDPR-Rep.eu

Maetzler Rechtsanwalts GmbH & Co KG
Attorneys at Law
c/o Trackonomics Ltd
Schellinggasse 3/10, 1010 Vienna, Austria

Please add the following subject to all correspondence:
GDPR-REP ID: 19616340