Website Privacy Policy

Last updated: 08.08.2024

We, as the data controller, pay great attention to protecting personal data and complying with the law when we collect, process and use such data. We want you to feel safe when you visit our site and use our services – and that is why we are providing you with this Privacy Policy. Here you can find out about our data collection and use of data policy.

This Privacy Policy sets forth our current privacy practices with regard to the information we collect when you interact with our site or by using our services. Please note that if you are a California resident special provisions of section XI. Additional Notice for California residents apply to you, in accordance with the California Consumer Privacy Act effective from January 1, 2020. If you happen to be left with even more questions after reading our policy – or already have some – do not hesitate to contact us.

I. Glossary

Below you will find an explanation of the basic terms used in this Privacy Policy. We gathered them here in order to make it easier for you to navigate through the policy and understand our role and purpose in the collection and the use of Information (as defined below).

“Applicable laws” means all the laws and regulations relevant to the collection, processing and storage of data, especially all the data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the California Consumer Privacy Act (“CCPA”; California Civil Code Section 1798.100 et seq.).

“Retail Media Ninja” or “we” or “us” or „our” means Commerce Media Tech sp. z o.o., with a registered office at ul. Lubicz 17G, 31-503 Kraków, Poland  incorporated under the laws of Poland and registered in the companies register of the National Court Register held by District Court Krakow – Srodmiescie in Cracow XI Commercial Division (Sąd Rejonowy dla Krakowa – Śródmieścia w Krakowie XI Wydział Gospodarczy) under (KRS) no. 0000830352, having EU VAT ID: PL5272922087 and the share capital in the amount of 5 000 PLN

“Cookies” means small text files stored in a web browser by a website (here specifically: Site) or by an ad server. By storing certain information in a cookie, those web browsers, ad servers, and explicitly our Site are able to remember your preferences and recognize websites visited and/or web browsers used from one visit to another.

“Data Protection Officer” means a person appointed by Retail Media Ninja to, in particular, watch over the security of your Data, monitor our compliance with Applicable laws, and be a point of contact in all matters regarding data protection.

“Legal Grounds” means the legal basis for the collection, processing and storage of your Personal Information, as defined in Applicable laws.

“Group of undertakings” –  a group of undertakings affiliated to a central body in the meaning of Recital 48 of the GDPR.

“Log Data” means information that is automatically reported by your browser each time you access our Site or use our Services and which is sent by your web browser that our servers automatically record. Log Data may include information such as your IP address, browser type, web requests, domain names or pages viewed.

“Personal Information” or “Information” or “Data” means any information relating to an identified or identifiable person as defined in Applicable laws, particularly in article 4.1 of GDPR and Section 1798.140 of CCPA.

“Site” means the Retail Media Ninja website retailmedianinja.com.

“Services” means services provided by Retail Media Ninja.

“You” means an individual that uses the Site or/and our Services.

II. Personal Information we collect about you

We collect Information about you through:

• your use of our contact forms
• your use of our Services
• your use of Site
• you contacting us, for example via email

The categories of your Data that we collect may include:

• Name and surname
• Company name
• Company address
• Company phone number
• Mobile telephone number
• Skype number
• Tax identification number
• E-mail address
• Payment and invoice details.

III. Log Data, Cookies and similar technologies

When you interact with our Site, we may also automatically collect information from your Site activities through the usage of Cookies, Log Data and similar technologies on our Site.

By using those technologies we aim to personalize our Site to better meet your needs, as well as to provide you with customized Site content and to act within our advertising purposes. We may also use this information for the purposes of analytics and monitoring of the effectiveness of our performance, including the collection of the aggregate Site usage data (such as the overall number of Site visitors or pages viewed).

The information mentioned above may include:

• information about your interactions with the Site;
• technical information about your computer hardware and software that may include URL information, cookie data, your IP address, the type of devices you are using to access our Site and/or use the Services, device ID, device attributes, network connection type, browser type, language, internet service provider, clickstream data, access times, the files viewed on our Site;
• demographic information such as your ZIP code, age, gender and preferences by using Log Files; such information is not associated with your name or other Personal Information.
• you contacting us, for example via email

We currently only use essential/strictly necessary cookies.

IV. Purposes and Legal Grounds for Data processing

Your local law may require to set out the Legal Grounds on which we rely in order to process your Data. Below you will find an outline of the purposes for which we may process your Data accompanied by an indication of a relevant Legal Grounds for such processing pursuant to GDPR:

Additionally, when you give us your voluntary consent, we process your Personal Data by using Cookie technology in scope and for the purposes described in our Website’s cookies notification.

V. Newsletter, electronic publications, contact forms

Newsletter, Blog and Webinar Subscriptions

In order to ensure that we are able to send you our newsletter or information regarding our blog or webinars (including inviting you to the webinar), we may process your name, surname and email address (which is necessary in order to provide you such services). Your consent is voluntary and it is expressed by clicking in the subscription button (legal basis – Article 6 (1) (a) of the GDPR). If you do not provide us with relevant information we will not be able to perform such services for you. You can withdraw your consent at any time by clicking “unsubscribe” link or contacting us (our contact details are in the last section of this Privacy Policy). This means you no longer consent to receiving the information subscribed to earlier. You can also change your preferences with regard to the type of information you wish to receive (e.g. if are signed at the same time to the newsletter and blog).

The terms and conditions related to the processing of data by Retail Media Ninja, especially including the data retention period, indicated in this Privacy Policy apply to the processing of your Data for the purposes of sending information regarding newsletter, blog and webinars.

Contact and Support Forms

In order to reply to your inquiry sent us in the contact or support form and to correspond with you, we may process your name, surname and email address (which is necessary in order to provide you such services). We may also process other information if provided by you. Providing such information is voluntary and we process it on the basis of our legitimate interest (Article 6 (1) (f) of the GDPR). If you do not provide us with relevant information we will not be able to perform such services for you. You can object at any time to the processing of your Personal Data when the objection is justified by the particular situation in which you have found yourself. We shall no longer process the Personal Data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. You can exercise your rights by contacting us (our contact details are in the last section of this Privacy Policy). This means you no longer consent to receiving information from us.

The terms and conditions related to the processing of Data by Retail Media Ninja, especially including the Data retention period, indicated in this Privacy Policy apply to the processing of your Data for the purposes of corresponding with you.

Marketing services

If you give us your voluntary consent on sending commercial information on your email address or contacting you by special means such as phone, SMS or skype, we will be able to perform marketing activities related to you, including direct marketing of our own services, as well as contacting with you for purposes related to permitted marketing activities by aforementioned means (email, phone, SMS, skype etc.). We can process your Data to perform marketing activities on the basis of our legitimate interest (Article 6 (1) (f) of the GDPR), however your consent on a specific means of contact is required in accordance with applicable law (telecommunication law, act on providing services by electronic means).

You can withdraw your consent at any time by clicking “unsubscribe” link or contacting us (our contact details are in the last section of this Privacy Policy). Then you no longer consent to receiving information by specific means of contact. You also have a right to object at any time to the processing of your Personal Data when your Personal Data is processed for direct marketing purposes, including profiling for this purpose. You can exercise your rights by contacting us. The terms and conditions related to the processing of Data by Retail Media Ninja, especially including the data retention period, indicated in this Privacy Policy apply to the processing of your data for the purposes of marketing services.

VI. Your rights

Retail Media Ninja will respect your legal rights to your Data. You can manage and control your privacy by contacting our Data Protection Officer: dpo@cm.tech.

Below you will find the description of your rights that you have under the law, and what Retail Media Ninja does to protect those rights:

In any above-mentioned matter please contact our Data Protection Officer: dpo@cm.tech. Please include information that will enable us to verify your identity within your request.

VII. How Data is protected

Retail Media Ninja uses various security technologies and procedures that help protect your Personal Information from unauthorized access, use, disclosure, alteration or destruction.

For example:

• Personnel. Only qualified and authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions;
• Data Protection Officer. We appointed a Data Protection Officer who in particular watches over the security of your Data, monitors our compliance with Applicable laws, and is a point of contact for you in all matters regarding Data protection; here you have contact to our Data Protection Officer: dpo@cm.tech;
• Security Measures. We use encryption in the transmission of your Personal Information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Information;
• Additional Safeguards. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your Information. Our security procedures mean that we may request proof of your identity before we disclose Personal Information to you;
• Trusted vendors. We rely only on vendors who ensure an appropriate level of security of your Data. In this context, we use only secure cloud servers, including AWS cloud – a secure, private cloud platform. Amazon Web Services is our processor. AWS Amazon cloud platform uses various security technologies and procedures to protect personal data and is compliant with third-party assurance frameworks such as ISO 27017 for cloud security, ISO 27018 for cloud privacy, PCI DSS Level 1, and SOC 1, SOC 2, and SOC 3. For more details please see AWS Amazon security and privacy policy at www.aws.amazon.com.

We want you to feel confident using our Site to conduct business. However, you should also take care of how you handle and disclose your Data and avoid sending Personal Information through insecure channels or networks. It is important for you to protect yourself against unauthorized access to your password and to your computer. Be sure to sign off when you finish using a shared computer and under no circumstances share your password with anyone, even with us – we will NEVER ask for it.

Please see more Information about security measures we use here.

VIII. International transfer of Data

We may transfer Data to a country outside of the European Economic Area (EEA) based on a decision of the European Commission, stating that a third country may be considered as providing an adequate level of data protection or based on standard contractual clauses approved by the European Commission (the EU Commission Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council). If you are located in the EEA, you may contact us if you require a copy of the safeguards which we have put in place to protect your Data transferred outside of the EEA and your privacy rights in these circumstances. You may also learn more about EU Commission Decision on standard contractual clauses for the transfer of personal data to entities established in third countries here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.

IX. Retention of your Information

Retail Media Ninja stores your Information for a period of time required for the purposes for which it was collected using generally accepted security standards and in compliance with applicable laws. Retail Media Ninja will not retain your Personal Information for longer than required.

In particular, we store Information about you when you have an account on our Site and when you use our Services. Please note that Retail Media Ninja may have the right to process your Data for the purpose of creating statistics, pursuing claims or defending against claims, handling your complaints and chargebacks as well as in order to meet the tax and accounting law requirements, where such processing will last only for the period of time necessary to achieve the intended purposes (e.g. for pursuing claims or defending against claims, the period of retention of your Data is no longer than limitation period for claims as defined in statutory law).

Please note, that for marketing purposes your Data will be processed until such time you object to it. Where you have consented to marketing communications via e-mail or other telecommunication means for our marketing purposes (e.g. you agree to receive our newsletter or contacting you by phone), you may withdraw your consent at any time by contacting us as well as you may unsubscribe from newsletter at any time by clicking the unsubscribe link in an email from us. In these circumstances, your personal data will be processed until your withdrawal of the consent.

If you need more detailed information about the retention of your Information, please contact our Data Protection Officer.

X. Disclosures

We may disclose your Personal Data only to the following trusted third parties:

• Safety, Legal Purposes and Law Enforcement. We may use and disclose the Data when we believe it is necessary: (i) under applicable law, and (ii) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities.
• Service providers. We may also engage third parties that support the operation of our Services (acting on our behalf), such as analytics providers, IT services providers (e.g. cloud or host services providers) or advertising agencies.

XI. Additional Notice for California residents

If you are a California resident special additional provisions of this section apply to you, in accordance with the California Consumer Privacy Act effective from January 1, 2020 (“CCPA”). In matters not covered in this section, the remaining provisions of this Privacy Policy apply.

California residents rights

CCPA provides additional privacy protections for California data subjects including:

• the right to request access to your Personal information and request additional details about our practices regarding the processing of your Personal information (right to access),
• the right to request deletion of your Personal information (right to deletion),
• the right to opt out of the “sale” of your Personal information (right to opt out), and
• the right to not be discriminated against for exercising any of your rights granted under the CCPA (right not to be discriminated).

To submit an access or deletion request as well as non-discrimination request please contact our Data Protection Officer via e-mail: dpo@cm.tech or by using contact form on the Website. Retail Media Ninja does not sell customer’s Personal information, hence the right to opt-out does not apply to them (please check detailed information below in this section).

Your request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal information or an authorized representative and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Please note that if you wish to exercise your rights with any of Retail Media Ninja other customers, you must make your request directly to them, based on information and procedures that they individually supply.

Disclosure

Categories of Personal Information. We may collect the following categories of Personal information about you:

• Name and surname
• Company name
• Company address
• Company phone number
• Mobile telephone number
• Skype number
• Tax identification number
• E-mail address
• Payment and invoice details
• when you interact with our Site, we may also automatically collect information from your Site activities through the usage of Cookies, Log Data and similar technologies on our Site.

We may have collected all of the above listed categories of your Personal Information during the 12-month period prior to the effective date of this Privacy Policy.

Purposes of use of Personal Information. We may use the categories of Personal information listed above for the purposes of:

• entering into a contract with you, performing the contract, in particular performing the Services, providing you with customer support, processing transactions / issuing invoices, handling your requests, complaints and chargebacks
• pursuing claims or defending against claims
• responding to your inquiries
• improving Services, detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement
• monitoring compliance with our Terms and Conditions
• ensuring accountability (demonstration of compliance with our obligations under the law)
• storing data for archiving or statistical purposes
• conducting necessary tax and accounting operations
• performing marketing of our products and Services (our direct marketing, customer satisfaction survey, analysis, enabling you to download the information or publication requested by you)

In addition, we may use the these categories of Personal information for certain business purposes, as specified in the CCPA, in particular as described in this table:

We may have used your Personal Information for the above listed purposes during the 12-month period prior to the last update of this Privacy Policy.

Sale of Personal Information

Please note that Retail Media Ninja does not and will not sell Personal information of their customers, as defined in section 1798.140 of the CCPA.

Sharing of Personal Information for Business Purposes

If it is necessary to perform our business purposes we may share Personal information in the manner, however, that does not constitute “sell” under CCPA, for example with the parties on behalf of which we operate. Particularly, we may share your Personal information with third parties or allow them to collect Personal information from our sites or services if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal information, or if you use the Retail Media Ninja platform or our services to interact with third parties or direct us to disclose your Personal information to third parties.

We may have disclosed (shared) the following categories of your Personal information during the 12-month period prior to the last update of this Privacy Policy: all of the above listed categories.

For detailed information concerning categories of third parties with whom we may share customers’ Personal information please see section X. Disclosures of this Privacy Policy.

XII. Children’s privacy

Protecting children’s privacy is very important to Retail Media Ninja. Our Site is not intended for, designed to be used by, or targeted at children as defined in Applicable laws.

We are in compliance with the requirements of EU General Data Protection Regulation 2016/679, , the California Consumer Privacy Act as well as COPPA (Children’s Online Privacy Protection Act) and we do not knowingly collect any Personal Information from anyone under the age of 13.

XIII. Notice to parents

If you are a parent or a guardian who knows or has otherwise discovered that your child under the age of 13 has submitted his or her Personal Information, or other information, to us without your consent, permission or authorization, do not hesitate to contact our Data Protection Officer using the following email address: dpo@cm.tech.

We will promptly remove your child’s Personal Information or other information from our system, cease the use of such Information and direct any third party with access to it to do the same.

XIV. Online Privacy Policy Only

This online Privacy Policy applies only to Information collected through our Site and not to Information collected offline.

XV. Contacting us

If there are any questions regarding this Privacy Policy, you may contact us using the information below:

Commerce Media Tech sp. z o.o., with a registered office at ul. Lubicz 17G, 31-503 Kraków, Poland incorporated under the laws of Poland and registered in the companies register of the National Court Register held by District Court Krakow – Srodmiescie in Cracow XI Commercial Division (Sąd Rejonowy dla Krakowa – Śródmieścia w Krakowie XI Wydział Gospodarczy) under (KRS) no. 0000830352, having EU VAT ID: PL5272922087 and the share capital in the amount of 5 000 PLN

General contact form: https://retailmedianinja.com/#contact

Retail Media Ninja’s Data Protection Officer contact: dpo@cm.tech