Effective date: May 12, 2019
Last update: October30, 2021
This Privacy Policy pertains to the Pure Alpha Ventures FZ-LLC website https://purealphaventures.com/ and is applicable to all users that visit the site.
Pure Alpha Ventures FZ-LLC (“Pure Alpha Ventures FZ-LLC”, “we” “us”) functions as a leading direct-to-publisher digital media agency (the “Agency”) facilitating digital media buys between top brands and publishers. This Privacy Policy pertains to the Pure Alpha Ventures FZ-LLC Website at https://purealphaventures.com/(the “Website”) as well as the Agency. Please read the following policy to understand how your personal information will be treated. This policy may change periodically to reflect any changes in legal requirements, company procedures, company products, service offerings and/or technology.
Privacy Practices for the Website
The Website is used for providing business information to prospective clients and business partners. It is not directed to consumers. We do not sell consumer data as part of our business operations including via the Website. The Website serves as a marketing vehicle for Pure Alpha Ventures FZ-LLCPure Alpha Ventures FZ-LLC is committed to respecting your privacy and conducting business matters that follow all policies as required by law.
Collection and Use of “PII” (Personally Identifiable Information) on the Website
Personally identifiable information is only collected when you choose to provide it to Pure Alpha Ventures FZ-LLC, such as in an email or by completing a form on the Website. The Website does contain a contact page where you can contact Pure Alpha Ventures FZ-LLC personnel and request additional information. This PII may include: name, company name, address, telephone number or email address. This information is only used by Pure Alpha Ventures FZ-LLC to contact you in response to your inquiry, conduct business activities with you, provide customer service and provide new products and services to existing and prospective customers. While Pure Alpha Ventures FZ-LLC may use the information it collects to notify you of necessary changes to the Website, new services/offerings and unique opportunities, you can contact Pure Alpha Ventures FZ-LLC at any time if you do not wish to receive these notices by emailing Pure Alpha Ventures FZ-LLC at privacy@purealphaventures.com.
Collection and Use of “Non-PII” (Non-Personally Identifiable Information)
Pure Alpha Ventures FZ-LLC also collects Non-Personally Identifiable Information (“Non-PII”) from visitors to this Website. Non-PII is information that cannot by itself be used to identify a particular person or entity, and may include your IP host address, pages viewed, browser type, Internet browsing and usage habits, Internet Service Provider, domain name, the time/date of your visit to this Website, the referring URL and your computer’s operating system. This Website uses Google Analytics to help analyse how users use the Website. The tool uses “cookies,” which are text files placed on your computer, to collect standard Internet log information and visitor behaviour information in an anonymous form. The information generated by the cookie about your use of the Website (including IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of the Website and to compile statistical reports on Website activity for Pure Alpha Ventures FZ-LLC
Cookies and Other Tracking Technologies
Pure Alpha Ventures FZ-LLC and our partners use cookies or similar technologies to analyse trends, administer the website, and track users’ movements around the Website. Users can control the use of cookies at the individual browser level. For more information about cookies, please visit https://www.allaboutcookies.org/cookies/.
We work with third party advertising technology platforms to manage our advertising on other sites. Our third party partners may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. Sometimes this practice is referred to as interest based advertising.
Privacy Practices for the Agency
Pure Alpha Ventures FZ-LLC functions as a leading direct-to-publisher digital media agency (the “Agency”) which facilitates digital media buys between top brands and publishers. The Agency directs 3rd party technology platforms, including other third party advertising networks and consumer data providers (our “Partners”) to help advertisers (our “Clients”) find the right digital audience and to help website and mobile application publishers (our “Publishers”) do a more effective job monetizing their content. The Agency does not physically store any data. Rather, we purchase media on behalf of our Clients and engage our Partners to serve the ads and provide additional services pursuant to ensuring the media we buy for Clients from our Publishers. We adhere to the Digital Advertising Alliance Code to the extent that it is applicable to our business.
Collection of Information via the Agency
The Agency doesn’t physically store information directly. Rather, information is collected and processed by our Partners pursuant to their privacy policies. We encourage you to read our Partners’ privacy policies. Generally, these partners collect Non-PII including but not limited to browser type, operating system, Internet Service Provider, IP address, and basic ad serving information such as the time and date an ad is served, the name of the mobile app or URLs from the web page visited. Some Partners work with us and our Clients to enable our Clients to bring their offline data into our systems for use by our technology. The business purpose(s) this data is used includes delivery and reporting of targeted advertising, measurement, attribution and market research – working generally with the types of pseudonymous personal data described above.
Cookies and Tracking Technologies
Our Partners generally use cookies, mobile advertising IDs and similar tracking technologies in order to more effectively run ad campaigns on our behalf. Pure Alpha Ventures FZ-LLC does not generally use cookies in connection with the Agency.
Choice Mechanisms
Pure Alpha Ventures FZ-LLC provides you with choices regarding how your data is processed. You can request the PII that Pure Alpha Ventures FZ-LLC has collected about you, correct factual inaccuracies in information, remove personal information and/or update your personal information by contacting privacy@purealphaventures.com.
While Pure Alpha Ventures FZ-LLC doesn’t directly process data via the Agency, many of our Partners provide choices regarding how information is collected or used. Each of these opt-out mechanisms are designed to enable you to exercise choice as is applicable for each Partner:
Google Campaign Manager - https://adssettings.google.com/u/0/authenticated?hl=en
In general, in order for any of these tools to work on your computer, your browser must be set to accept third party cookies. If you buy a new computer, change web browsers or delete this cookie, you will need to perform the opt-out task again.
You may also visit the Digital Advertising Alliance’s (DAA) website and use the opt-out procedure, which can be used to opt-out from the use of data for interest based advertising purposes from digital advertising companies, including many of our Partners. To access this service, please visit the https://www.aboutads.info/choices/.
The NAI also provides a mechanism to opt out of its member networks here: https://www.networkadvertising.org/managing/opt_out.asp and the European Digital Advertising Alliance opt-out page may be found at https://youronlinechoices.com/.
If you are looking to exercise choice regarding your mobile device, please visit the NAI’s Mobile Choice information page at https://www.networkadvertising.org/mobile-choice/ and follow their instructions.
Onward Transfer of Information
We do not share PII collected via the Website with anyone outside of Pure Alpha Ventures FZ-LLC, unless specifically stated otherwise. Pure Alpha Ventures FZ-LLC does not sell, rent or lease such PII collected on the Website to non- affiliated third parties without your consent. We don’t generally sell or share PII provided from Clients, Publishers or Partners other than with our agents and service providers who are bound by confidentiality provisions.
We may disclose the information we collect to third party vendors, service providers, data processors, contractors or agents who perform functions on our behalf and are not permitted to use such data except on behalf of Pure Alpha Ventures FZ-LLC The types of service providers to which we transfer data include: a) cloud computer and data storage providers, b) companies offering tools to send emails and similar communications on our behalf, c) website and b2b sales analytics providers, d) customer relationship management and project management software providers, e) customer billing systems partners, f) outsourced computer programmers helping ensure our systems are operating properly, g) auditing, debugging and security vendors. As legally required, we have contracts with these service providers instructing them to only process data as we direct them to and for no other purpose.
Pure Alpha Ventures FZ-LLC may share information for the following purposes: (i) to third party vendors, service providers, data processors, contractors or agents as described above to assist or facilitate in the services Pure Alpha Ventures FZ-LLC provides; (ii) to comply with applicable laws and regulations or to respond to a subpoena, search warrant or other lawful request for information Pure Alpha Ventures FZ-LLC receives, whether or not a response is required by applicable law, and to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms of Access, or as otherwise required by law; (iii) for law enforcement or national security purposes including sharing data of EU and Swiss individuals in response to lawful requests from public authorities to meet national security and law enforcement requirements; (iv) to enforce an agreement or to protect Pure Alpha Ventures FZ-LLC’s rights; with any parent, affiliated or successor entity; (v) in connection with any asset sale, transfer, divestiture, bankruptcy or liquidation; (vi) in connection with strategic alliances, partnerships or other business arrangements to permit the offering of products or services Pure Alpha Ventures FZ-LLCbelieves may be of interest to you or where Pure Alpha Ventures FZ-LLC has determined that the information will be used in a responsible manner by the third party; or (vii) as permitted under any agreement with you. Pure Alpha Ventures FZ-LLC may also share aggregated data with others.
While our Partners may provide Pure Alpha Ventures FZ-LLC, our Publishers and our advertising Clients with reports pertaining to advertising campaigns, neither Pure Alpha Ventures FZ-LLC, our Publishers nor our Clients have access to IP addresses, cookie IDs or other forms of pseudonymous data from the Agency, although Publishers and Clients may obtain this data independently. To the extent that our partners may transfer data across international borders, they are required by law to have an appropriate data transfer mechanism.
Children’s Information
Pure Alpha Ventures FZ-LLC is respectful and keenly aware of the privacy rights of children. Pure Alpha Ventures FZ-LLC’s products and services are not intended for persons under 18 years of age and the Website is not directed to children. Pure Alpha Ventures FZ-LLC does not knowingly solicit or collect any PII from children under the age of 18, nor knowingly markets Pure Alpha Ventures FZ-LLC products and services to children under this age. If you are a parent and are aware that your child has provided Pure Alpha Ventures FZ-LLC with PII without your knowledge or consent, please contact us immediately at privacy@purealphaventures.com.
Data Subject Access Rights
You can request the PII that Pure Alpha Ventures FZ-LLC has collected about you, correct factual inaccuracies in information, remove personal information and/or update your personal information by contacting privacy@purealphaventures.com. Some of the Non-PII collected on behalf of the Agency is considered personal data under EU Data protection laws. While Pure Alpha Ventures FZ-LLC doesn’t place cookies nor process any data directly as an Agency, interested persons may contact our Partners to see what type of access rights they offer.
Security Measures
Pure Alpha Ventures FZ-LLC uses appropriate measures to ensure the security of all information, including the use of passwords, firewalls, encryption and remote servers, and routinely evaluate our practices to identify security threats or opportunities for the improvement of our services. No transmission of information is guaranteed to be completely secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. You acknowledge and agree to assume this risk when communicating with us.
Other Notices
Pure Alpha Ventures FZ-LLC uses appropriate measures to ensure the security of all information, including the use of passwords, firewalls, encryption and remote servers, and routinely evaluate our practices to identify security threats or opportunities for the improvement of our services. No transmission of information is guaranteed to be completely secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. You acknowledge and agree to assume this risk when communicating with us.
California Data Subjects
Starting January 1, 2020, the California Consumer Privacy Act (CCPA) provides additional privacy protections for California data subjects and users, including: a) the right to see what data we have about you, your computer or device (i.e., the right to know), b) the right to delete the data we have about you, your computer or device (i.e., the right to delete) and c) the right to opt-out of the sale of data about you, your computer or device to certain third parties (i.e., the right to opt-out from sales of your information). We do not discriminate against you if you exercise any of the above rights. Moreover, we may not be able to honour a right if doing so would violate applicable law.
You may access those rights with respect to Pure Alpha Ventures FZ-LLC by scrolling up and reading the section entitled “Data Subject Access Rights” or by sending us an email at privacy@purealphaventures.com. As a California data subject, if you make a subject access request as set out in this policy, you are entitled to see and delete the personal information that we have about you. We will confirm your request within 10 days and make a good faith attempt to fulfil your request within 45 days. In 2020, Pure Alpha Ventures FZ-LLC did not directly receive any requests to know, delete or opt-out from California consumers.
Under the CCPA, your request to see the personal information that we have about you may include: (1) specific pieces of personal information that we may have about you; (2) categories of personal information we have collected about you; (3) categories of sources from which the personal information is collected; (4) categories of personal information that we sold or disclosed for a business purpose about you; (5) categories of third parties to whom the personal information was sold or disclosed for a business purpose under the CCPA; and (6) the business or commercial purpose for collecting or selling personal information.
We may take reasonable steps to verify your request. We will fulfil requests we are able to verify so long as we are not prohibited from doing so by applicable law and/or the information is not essential for us for billing, fraud prevention or security purposes. We will share our reason(s) for denying your request in the event that we are unable to fulfil your request.
You may make an access or deletion request via an authorized agent by having such agent follow the process below. Please note that we will request any authorized agent demonstrate that they have been authorized by you to make a request on your behalf. And we will attempt to verify your request. We require any authorized agents to provide us with contact details such as an email address and phone number so that we may ensure a timely response.
European Economic Area
The General Data Privacy Regulation (“GDPR”) affords additional data protection rights to EU data subjects. For example, with respect to EU data subjects, the definition of personal data includes pseudonymous data such as an IP address, a mobile advertising ID or a cookie ID. EU Data subjects have the right to complain to EU Supervisory Authorities and the right to access, port, correct and delete certain personal data processed by Pure Alpha Ventures FZ-LLC (e.g., via the Website) and those Partners that serve ads on our behalf to EU data subjects via the Agency. You may access those rights with respect to Pure Alpha Ventures FZ-LLC by scrolling up and reading the section entitled “Data Subject Access Rights” or by sending us an email at privacy@purealphaventures.com.
While Pure Alpha Ventures FZ-LLC does not physically store personal data in the context of the Agency, we do have Clients located in the EU and we do place media buys on behalf of Clients which may collect data from data subjects located in the EU. Our Clients and Publishers direct us to process data under their general instructions, but we may direct our technology Partners to adjust advertising campaigns where we feel appropriate. We rely on the consent of the individual to process personal data in some instances (for example, when the user inputs personal data onto a web form of our Website). On other occasions, Pure Alpha Ventures FZ-LLC may process personal data when needed to fulfil a contract with a Client or partner or where required to do so by law.
We may also process data when it is in our or our Clients’ legitimate interests to do this and when these interests are not overridden by the individual’s data protection rights (which may vary based on an individual’s jurisdiction). Certain Publishers, Clients and Partners choose not to operate in the EU and/or collect data from EU data subjects – and each has a process to ensure they are not collecting personal data from the EU in relation to the Agency.
To the extent that our processing activities require the transfer of personal data from EU data subjects to a jurisdiction that does not have an adequacy designation from the EU, we will find a suitable data transfer mechanism such as the Standard Contractual Clauses. If you have questions about this, or want to understand your rights in more detail, please feel free to contact us at privacy@purealphaventures.com.
Third-party Websites
Pure Alpha Ventures FZ-LLC is not responsible for the methods by websites or applications that contain links on the Website or are linked to its website nor the contact and information presented therein. Third-party Internet websites and services accessible through Pure Alpha Ventures FZ-LLC have separate privacy and data collection practices, independent of Pure Alpha Ventures FZ-LLCPure Alpha Ventures FZ-LLC has no responsibility or liability for these independent policies or actions. The collection and use of that data is governed by the privacy policy and legal terms of the data collector and the website using the data; it is not governed by Pure Alpha Ventures FZ-LLC
Contact
If you have any questions or concerns about your privacy in connection with this policy, please send us a thorough description to privacy@purealphaventures.com and we will try to resolve it. You may also contact us by mail at
Attn: Privacy Officer
Pure Alpha Ventures FZ-LLC,
RKN 220, RAKEZ Business Zone,
Al Nakheel Area,
P.O Box No 10055,
Ras Al Khaimah,
UAE.
California Data Processing Agreement for Pure Alpha Ventures FZ-LLC Clients
This Pure Alpha Ventures FZ-LLC (“Pure Alpha Ventures FZ-LLC”) California Data Processing Addendum (“California DPA”) incorporated by reference into any and all services agreements, insertion orders and addendums currently in place between Pure Alpha Ventures FZ-LLC and ______________________(“Client”) (the “Agreement(s)”).
Effective January 1, 2020 or as otherwise proscribed under the CCPA, the parties agree to comply with the following provisions with respect to any personal information processed in connection with the Agreement that is subject to the California Consumer Privacy Act (“CCPA”). The purposes of this California DPA is to ensure such Processing is conducted in accordance with data protection laws, including the CCPA. References to the Agreement will be construed as including this California DPA.
1. Definitions:
2. Mutual Warranties: Each of the parties represent and warrant that it understands the rules, restrictions, requirements and definitions of the CCPA and agrees to adhere to the requirements of the CCPA that applies to each party’s processing of Client Personal Information, including, but not limited to: a) providing privacy policy notice as required by CCPA; b) providing data subjects with a notice and opt-out choice where required by CCPA; c) providing each other reasonable cooperation with respect to verifiable consumer requests as required under CCPA.
3. Pure Alpha Ventures FZ-LLC Warranties: Pure Alpha Ventures FZ-LLC agrees that: a) it shall collect, store, transfer, dispose, disclose and use all Pure Alpha Ventures FZ-LLC Personal Information using the highest standard of care to ensure the protection of such data and in compliance with all applicable federal, state and international laws, regulations and directives; b) it shall not collect, retain, process, share or otherwise use Client Personal Information except for performing the services as described in the Agreement unless as required by law or a government authority (in which case Pure Alpha Ventures FZ-LLC shall use its best efforts to notify Client before such disclosure or as soon thereafter as reasonably possible); c) it shall act as a service provider and shall not sell Client Personal Information; d) it shall take reasonable steps as a service provider to ensure that the transfer of Client Personal Information is not a sale of personal information; e) except for Approved Sub-processors, it shall only transfer Client Personal Information to a third-party as specifically directed by Client. Any Sub-processors will be permitted to obtain Client Personal Information only to deliver the services Pure Alpha Ventures FZ-LLC has retained them to provide and are prohibited from using Client Personal Information for any other purpose. Pure Alpha Ventures FZ-LLC shall remain fully liable for all acts or omissions of its subcontractors.
4. Data Retention : Pure Alpha Ventures FZ-LLC shall retain Client Personal Information only for as long as necessary to provide Services to Client. Upon termination of the parties agreement for any reason, Pure Alpha Ventures FZ-LLC shall promptly erase or destroy all or any part of such Client Personal Information.
5. Security: