Privacy Policy

1. Privacy

1.1

Anzu Limited is an Israel-based company that offers specialized and innovative solutions and concepts for modern advertising and the execution of empowered marketing campaigns. Anzu Limited is committed to protecting and safeguard the privacy of and personal data related to individual visitors of our corporate website as well as our prospective and / or existing clients (means, respectively, any Publisher and/or Publisher’s App End User and/or Advertiser and/or Anzu Website User). This privacy policy covers all information, including your personally identifiable information (the “Personal Information”, and together with other information – the “Information”) collected from the individual visitors of our corporate website as well as from our prospective and/or existing clients. Anzu Limited is in active co-operations with legally and economically independent external service partners. All partners and suppliers of Anzu Limited acknowledge our privacy policy and follow its content. Please refer to their privacy policies for further information on Data Protection with regards to personal information they collected, collect and will collect on our behalf.

1.2

We have created this privacy policy (the “Privacy Policy”) in order to let you know what Information we or our external, legally and independent service partners acting on behalf of Anzu Limited, collect during the use of the Software and/or Marketplace and/or Platform and/or Services and/or a Publisher’s App and/or Anzu Limited's corporate Website in relation to any of the aforementioned, how this Information is collected and how it is used / processed. How we collect, store and use the Information will be continually assessed against new technologies, business practices, and your changing needs.

1.3

When you use the Software and/or Marketplace and/or Platform and/or Services and/or Anzu Website, you agree that we may collect, use and disclose your Information in accordance with the terms of this Privacy Policy. This Privacy Policy is a part of our Terms and Conditions, and should be read in conjunction with them.

Anzu Limited has appointed a Data Protection Officer (DPO) to ensure compliance with the requirements as per data Protection Regulation 679/2016/EU. The DPO at Anzu Limited has direct and immediate connections with the top level management of Anzu Limited and remains in an independent position within the corporate structure of Anzu Limited. Visitors of the corporate Website of Anzu Limited as well as our prospective and / or existing clients can get in touch with our DPO by electronic mail service to dpo@anzu.io.




PUBLISHER

Collection of Information

  By default, you consent to submission of personal data as below to be collected. In case you wish to make use of your rights to personal data related to your individual case as per section 7., please submit your request to the Data Protection Officer by electronic communication services to dpo@anzu.io. When you use the Software and/or Marketplace and/or our corporate Website and/or in your communications with Anzu Limited, we (or our external partners on our behalf) may collect Information about you where such Information is sent to us through your computer, mobile phone or other access device, including but not limited to:   Personal identifying Information such as: - Full name and/or company name - Date of birth and/or company incorporation number - Corporate address - E-mail address - Phone number and/or other contact information - Company domain - Payment information and bank details   General and non-personal activity log Information unique to you that is automatically collected via Anzu Limited’s dashboard which cannot be easily used in order to personally identify you. This Information includes, but is not limited to:   App data such as app name, logo, app store URL, app store category, app bundle ID, app cross apps tag, blocked content categories, COPPA flag, etc.: - Browser user agent - Campaign data and activity events - Event analytics data - Financial key performance indicators - IP address - Log information

Use of Information

  We may use the information for the Publisher’s benefit in order to, without limiting: - Operate the Software and/or Marketplace - Serve and optimize Advertisements - Generate Advertisements tracking reports - Analyze performance, improve your user experience and resolve technical problems - Implement anti-fraud detection and protection tools - Improve the Software and/or Marketplace and/or our Website - Develop new products and tools - For billing purposes - Inform of new products and services, including promotional offers - Contact you with information that we believe will be of interest to you   Upon prior written request, we can encrypt the transmission of data received by us from the Publisher. By default, you consent to the use / processing of your personal information and personal data as per above list of purposes. In case you wish to make use of your rights to personal data related to your individual case as per section 7., please submit your request to the Data Protection Officer by electronic communication services to dpo@anzu.io.  



PUBLISHER’S APP END USERS

Collection of Information

By default, you consent to submission of personal data as below to be collected. In case you wish to make use of your rights to personal data related to your individual case as per section 7., please submit your request to the Data Protection Officer by electronic communication services to dpo@anzu.io. When you interact with a Publisher’s App in relation to the Software and/or Marketplace and/or Platform and/or Services, we passively collect information (often automatically), that includes but is not limited to:   General and non-personal Information, such as: - Country code - City and Zip code - Device information, such as: - Device manufacturer and type - Device model, OS and version - Device carrier name - Device user agent - Device hardware - Device connection type - Device ID - Device Identifier for Advertisers - Device physical height in pixels - Device physical width in pixels - Device pixels per linear inch - Device pixel ratio - Geo-location of the device when location services are enabled - Information about Advertisements served, viewed or clicked on, such as the type of Advertisement, where it was served and whether you clicked on it - IP address - Log information - Mobile browser user agent - Randomly generated Anzu user ID   We may also receive from the Publisher additional data, which the Publisher might collect from the Publisher’s App End Users, and choose to transfer to us. Such data includes but not limited to: - Gender - Year of Birth - Home Geo for App End User - Other user parameters or preferences that will be provided to us by the Publisher

Use of Information

By default, you consent to submission of personal data as below to be collected. In case you wish to make use of your rights to personal data related to your individual case as per section 7., please submit your request to the Data Protection Officer by electronic communication services to dpo@anzu.io. We use the Information we collect to provide and improve the Anzu Software and/or Marketplace and/or Platform and/or Services and/or our Website, including but not limited, for: - Serving and optimizing Advertisements - Advertisement reporting and tracking - Fraud detection and protection - Geo-targeting - Interest-based advertising - Providing and improving our services

Storing Information

We may continue to retain and store the Publisher’s App End Users’ Information following termination of the Terms and Conditions between the Publisher and ourselves.


ADVERTISER

Collection of Information

By default, you consent to submission of personal data as below to be collected. In case you wish to make use of your rights to personal data related to your individual case as per section 7, please submit your request to the Data Protection Officer by electronic communication services to dpo@anzu.io. When you use the Platform and/or Services and/or our Website in your communications with us, we (or others on our behalf) may collect Information about you where such Information is sent to us through your computer, mobile phone or other access device, including but not limited to:   Personal identifying Information such as: - Full name and/or company name - Date of birth and/or company incorporation number - Corporate address - E-mail address - Phone number and/or other contact information - Payment information i.e. bank account number and/or credit card details.   General and non-personal activity log information unique to you, that is automatically collected via the Advertiser and/or Open RTB technology, which cannot be easily used to personally identify you. This Information includes, but is not limited to: - Ad creatives - Advertiser campaign domain - Advertiser seat ID - App bundle ID - Campaign activity events - Campaign data - Financial key performance indicators - Performance reports generated by the system - Spending budgets - Targeting preferences - Time and date of access

Use of Information

We may use the Information in order to, including but not limited to: - Serve and optimize Advertiser campaigns - Operate the Platform and/or Services - Analyze the Platform and/or Services and/or our Website performances - Improve your user experience and resolve technical problems - Generate Advertisements tracking reports - Implement anti-fraud detection and protection tools - Improve the Platform and/or Services and/or our Website - For billing purposes - Inform of new products and services, including promotional offers - Contact you with information that we believe will be of interest to you


ANZU WEBSITE USERS

Collection of Information

When you use the Anzu Website, we (or others on our behalf) may collect Information about you where such Information is sent to us through your computer, mobile phone or other access device. Such information includes, but is not limited to the list below. By default, you consent to submission of personal data as below to be collected. In case you wish to make use of your rights to personal data related to your individual case as per section 7., please submit your request to the Data Protection Officer by electronic communication services to dpo@anzu.io.   Our servers automatically collect general and non-personal activity log Information unique to you and certain administrative and traffic information, but which cannot be easily used to personally identify you, such as: - Access times - Browser user agent - IP address - OS - Pages visited

Use of Information

We use this information to order to: - Operate our Website - Analyze our Website performance - Improve user experience - Resolve technical problems.

Additional Terms

You are responsible for ensuring the accuracy of the Information. Inaccurate Information will affect the information you receive from us and/or other third parties and our ability to contact you as contemplated in this Privacy Policy.   You hereby consent to having us and/or third parties contact you via any and all contact details included in the Information, as well as use these contact details to promote and market to you various products and services, including (but not limited to) products and services provided to us and/or by third parties.   We may also disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Site Terms and Conditions. Furthermore, your personal data is permitted to be disclosed to public bodies only in cases where the disclosure concerns matters of national and/or international security, the prevention or investigation of criminal activities, law enforcements, where a public interest is given, a juridical proceeding against the person, to which the personal data is related is pending or had been initiated or completed before and/or the personal security of the individual to which the personal data is related.   We may transfer the Information outside your country of residence and store it in other countries; the data protection and other laws of these countries may not be as comprehensive as those in your country - in these instances we will take steps to ensure that a similar level of protection is given to the Personal Information.

Cookies

We use a browser feature known as cookies, which are small text files that are placed on your computer or equipment when you visit certain online pages, to collect certain information about your use of our Website, internet log information, IP address and visitor behavior. The information collected through the cookies is then statistically analyzed by us or on our behalf for the purpose of compiling statistical analysis of our Website and to make the interaction with our Website more convenient. This information does not identify you personally and you remain anonymous, even if you have previously submitted personal information via the Software and/or Marketplace and/or Platform and/or Services and/or our Website. You may prevent your browser from saving cookies by adjusting the settings in your browser software, however, some websites may not function properly if you disable cookies.

Rights to personal data related to website visitors and customers

In line with the provisions and requirements of the Data Protection Regulation 679/2016/EU on the protection of personal data, you remain the following rights to your personal data:  
  • You remain the right to review all personal information, which is related to you and which was / is collected during your visit of our corporate website and during the use and processing as described in this privacy policy at any time and to check the accuracy of personal data, which is related to you individually.
  • You remain the right to have done corrections, rectifications and refreshments to your personal data.
  • You remain the right to have your personal data deleted partly or completely.
  • You remain the right to obtain information on the use and purpose to process your personal data.
  • You remain the right to limit the purpose for processing and use of your personal data. However, this may have an effect on the accessibility of our regulated financial services rendered to you. You can refer to our DPO at dpo@anzu.io for further clarifications on this.
  • You remain the right to opt-out from commercial and non-commercial newsletters and notifications from Anzu Limited by notification to our DPO accordingly.
  • You remain the right to have all personal data, which is related to you and which is or had been collected during your visit and use of our corporate website and during your correspondence with Anzu Limited, being transferred to another Data Controller nominated by you.
  • You remain the right to withdraw your previously given explicit consent with regards to the collection, use and processing of your personal data at any time by contacting our Data Protection Officer by electronic mail services to dpo@anzu.io.
You can submit your request to make use of the above rights to your personal data by contacting our Data Protection Officer (DPO) through electronic mail services to  dpo@anzu.io.

Security

We have implemented suitable security policies, rules and technical measures to protect and safeguard the Personal Information under our control from unauthorized access, improper use or disclosure, unauthorized modification, unlawful destruction or accidental loss. However, we are not responsible for the security policies, rules and technical measures used by third parties that received the Information and you hereby absolve us of any and all liability in connection with such use.

Links to Other Websites

Our Website and/or our communications may contain links to other websites, and you may reach third parties' websites as a result of marketing and promotional communications delivered to you on the basis of the use of the Information. Other websites may also reference or link to our Website. We are not responsible for the privacy practices and/or cookie practices and/or the content of such other websites, and any information collected by these third party websites (including if provided by you) is not governed by this Privacy Policy, and we assume no responsibility or liability whatsoever for the policies (including privacy policies), practices, actions or omissions of such third parties.

Right to Be Forgotten

For your convenience we have detailed below how should you file your form of request if you wish to request deletion of your personal information, you can do so at any time by filling out the information in this form and submitting it.

Please note that at any time you may address DPO@Anzu.io to receive further clarifications or instructions.

For more information see our Privacy Policy.


Form to be Submitted

As stated above, if you wish to “be forgotten” (i.e., personal data we have collected in association with you) please send the below information to DPO@ANZU.io:

  1. Device ID (so that we could recognize you)
    • Your Device ID is a 36-40 character string that can be found on your device. To understand how you extract your Device ID [add a hyperlink to the above]

  2. State if you are a resident of The European Economic Area (EEA)?
  3. State on behalf of whom this request is submitted (in case this is not being done by yourself))? If so, please state whether you are SSP, DSP, Publisher, Advertiser, or other.
  4. Date of the request
  5. Add the following representation
    • I, the undersigned, represent and warrant that the information in this request is accurate and that I am authorized to submit this request. I also grant your consent to process the personal data that I am providing.

  6. Signature and Consent – Please add your signature/printed full name - to make this a legally binding as your physical signature.

Data Subject Access Request

As part of the Data Protection Regulations we are committed to transparency, and we want you as a EU data subjects to have access to personal data that we may have about you and/or the devices that they may use to access the Internet.

See our Privacy Policy to further understand what personal data that we process.


Your EU Data Subject Access Rights

you are entitled to see the personal data that we have about you including any digital identifiers such as cookie IDs and mobile advertising IDs that Anzu may have.

Per your request, We will provide you with the ability to see the personal data that we have by providing you with a copy of that data and will also allow you to correct errors in this data or delete parts thereof (as long as it is not prohibited by applicable law and in order to continue provide you the services). You have the right to port that data to a different entity, however, we cannot guarantee that others will be in position to obtain such data.

Where we are merely the agents and/or processors of data, we may be prohibited from processing this data except as directed in writing by those clients. If that is the case, we will submit your request to the applicable client and await their written instructions. Also, if we are unable to locate any of the information you have requested, we will let you know.


How to Make Access Request

Once you file your request, as set force below, we will need to locate your information, either by “cookies” that are placed on your computer or device or by your digital identifiers. For further information and explanation, see our Privacy Policy.

The next step will be to authenticate of the information provided to make sure that we are only providing personal data to the correct person, we also will need to take reasonable steps to authenticate your request.

To do so we may request that you: (i) provide screenshots of any cookies and mobile Advertising Identifiers for which you are submitting a request; and/or (ii) send you an email to any addresses you provide in order to authenticate that portion of your request; and/or (iii) request that you fill out and sign the form & affidavit below.


Filling out the request:

  1. By sending a written request with all of the above-listed information to:
    • Anzu Virtual Reality Ltd.
      37 Rothschild Boulevard, Tel Aviv 6688306
      Israel

    Or

  2. By sending the below request to DPO@Anzu.io:
  • Device ID (so that we could recognize you)
    Your Device ID is a 36-40 character string that can be found on your device.To understand how you extract your Device ID [add a hyperlink to the above]
  • State if you are a resident of The European Economic Area (EEA)?
  • State on behalf of whom this request is submitted (in case this is not being done by yourself))? If so, please state whether you are SSP, DSP, Publisher, Advertiser, or other.
  • Date of the request
  • Add the following representation:
    I, the undersigned, represent and warrant that the information in this request is accurate and that I am authorized to submit this request. I also grant your consent to process the personal data that I am providing.
  • Signature and Consent – Please add your signature/printed full name - to make this a legally binding as your physical signature. 

Do not Process/Store Request

If you are considered a data subject under the GDPR and you do not wish Anzu to process or store your data, i.e. you wish to withdraw consent, then you can opt out at any time. Opting out will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. You can exercise your rights to opt out of our services and stop processing and/or storage of your personal information in the following ways:


Opt-Out via Device Settings

Your iOS or Android mobile device provides an “Opt out of interest-based advertising” or “Limit Ad Tracking” setting, you can enable the setting and we will not use information collected from that device to infer your interests, or to serve ads to that device that are targeted based on your inferred interests.

If you’ve enabled your device (whether iOS or Android), you can restore interest-based ads by turning the settings off.

Note that when you opt out, you still see the same number of ads on your mobile device. However, these ads may be less relevant because they won’t be based on your interests.


iOS Device:

Choose Settings > Privacy > Advertising > Enable “Limit Ad Tracking” setting

To learn more about the iOS settingclick here.


Android Device

Android devices with OS 2.2 and up, and Google Play Services version 4.0 and up: Open Google Settings App > Ads > Enable “Opt out of interest-based advertising”


Opt-Out via Advertising ID

To find Advertising ID on a mobile device:

iOS users have to download an app (e.g. The Identifiers) and copy the “Advertising Identifier”

Android users choose Google Settings > Ads and copy the “advertising ID”

Do Not Process or Store Data Request

By filing request to DPO@Anzu.io with the below information you may object Anuz’s processing or storing your personal data in association with your email address and/or your device (identified by your advertising ID).

  1. Device ID (so that we could recognize you)
  2. Your Device ID is a 36-40 character string that can be found on your device. To understand how you extract your Device ID [add a hyperlink to the above]

  3. State if you are a resident of The European Economic Area (EEA)?
  4. State on behalf of whom this request is submitted (in case this is not being done by yourself))? If so, please state whether you are SSP, DSP, Publisher, Advertiser, or other.
  5. Date of the request
  6. Add the following representation:
  7. I, the undersigned, represent and warrant that the information in this request is accurate and that I am authorized to submit this request. I also grant your consent to process the personal data that I am providing.[in case you are not filling the request on your own behalf – please state the following: I have legal authority to act on behalf of the resident, citizen or visitor whose Advertising ID I am entering here. I understand that this device will no longer receive personalized advertising.]

  8. Signature and Consent – Please add your signature/printed full name - to make this a legally binding as your physical signature.


How to extract your Advertising ID?

For Android Devices

Although the Android ID was used historically for mobile ad tracking, as of August 1st, 2014 Google has required all new app releases to utilize the Android Advertising Identifier.

To find your Android Advertising Identifier, open the Google Settings app on your Android device and click on “Ads.” Your Advertising Identifier will be listed at the bottom of the screen.

For iOS Devices 

At present, the advertising ID (also known as IDFA) on iOS devices is hidden from users by Apple by default. It can only be extracted using third-party apps such as My Device IDFA by AppsFlyer.

Resetting your Device ID

It should be noted that by resetting the IDFA or the Android Advertising Identifier may invalidate systems designed to respect your choices in advertising and may require you to submit any requests or forms again.

Also, if your Device ID is shown as a string of only zeroes, your device is already set to limit ad tracking by default.


Disclaimer

We are not responsible for events beyond our direct control. We cannot guarantee nor do we represent that there will be error-free performance regarding the privacy of the Information, and we will not be liable for any direct, indirect, incidental, consequential or punitive damages relating to the use or release of the Information.

Your Acceptance of this Policy

By agreeing to the Terms and Conditions or by continued use of the Software and/or Marketplace and/or Platform and/or Services and/or our Website, you agree to be bound by this Privacy Policy, and to any changes that we may make to this Privacy Policy from time to time. We will notify you of any such changes to the Privacy Policy by posting the changes on the Privacy Policy. We recommend that you revisit this Privacy Policy regularly. Your continued use of the Software and/or Marketplace and/or Platform and/or Services and/or App and/or our Website in relation to any of the aforementioned, following the posting of changes to this Privacy Policy, means you accept these changes.   If you feel the rights to personal data related to you had been infringed by Anzu Limited, please get in touch with our DPO at dpo@anzu.io.