PRIVACY POLICY

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it.

1. WHO ARE WE?

RELSA, INC. ("Relsa", "Controller", "we") is a technology-driven company offering the service for creating and managing advertising campaigns for customers.

You may find our contacts below (Clause 19).

If you have a question concerning the processing of your personal or other data, you may contact us at any time via support@relsa.io.

The purpose of this privacy policy ("Privacy Policy") is to inform you of the steps we take regarding the collection, processing, and use of the Personal data and other data you provide to us when using the website https://relsa.io/ and all subdomains of it.

We have done our best to make this Privacy Policy easy for you to understand and enable you to navigate easily through its contents.

2. GENERAL PROVISIONS & SERVICE

This Privacy Policy applies to the processing of Personal data of the data subjects located in the European Union ("EU") and the European Economic Area ("EEA") by Relsa in respect of the following website: https://relsa.io/ and all subdomains of it, constant improvements, and all other future services to be delivered by Relsa to its Customers inside the EU and the EEA ("Services").

From time to time, we may develop new or offer additional services. They'll also be subject to this Privacy Policy unless stated otherwise when we introduce them.

This Privacy Policy is not the Terms of Service available at https://relsa.io/terms-of-service, which is a separate document. The Terms of Service outline the legal contract between you and Relsa for using the Services.

This Privacy Policy is also applicable to the processing of Personal data of US residents. We have included further information about rights and disclosures as required under the California Consumer Privacy Act ("CCPA") and Delaware's Online Privacy and Protection Act ("DOPPA").

3. DEFINITIONS AND INTERPRETATION

The following definitions apply to this Privacy Policy:

Data subject, Customer, "you" or "your" means:

• visitors to our website;
• subscribers to Free Services or Services we offer through our website;
• potential or existing customers communicating with us by email or other means.

Representatives mean, in relation to a party, its employees, officers, contractors, subcontractors, representatives, and, advisers;

Controller means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal data; where the purposes and means of such processing are determined by EU or Member State law, the controller or the specific criteria for its nomination may be provided for by EU or Member State law;

Processor means a natural or legal person, public authority, agency, or other body which processes Personal data on behalf of the controller;

Personal data means any information relating to an identified or identifiable person (data subject) from which that person can be directly or indirectly identified such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological etс. It does not include data where the identity has been removed (anonymous data);

Member States mean all European Union member states, plus Iceland, Lichtenstein, Norway, and Switzerland — which are part of the European Economic Area;

The above definition and other terms under this Privacy Policy include, where applicable, the definitions included in the General Data Protection Regulation (EU 2016/679) ("GDPR").

The following rules of interpretation will apply unless otherwise stipulated by Privacy Policy:

• unless the context otherwise requires, words in the singular shall include the plural and, in the plural, shall include the singular;
• unless the context otherwise requires, a reference to one gender shall include a reference to the other gender.

4. PRINCIPLES FOR THE PROCESSING OF PERSONAL DATA

When processing Personal data, we comply with the following principles:

• Personal data are processed lawfully, fairly, and transparently in relation to the Data subject ("lawfulness, fairness and transparency");
• Personal data are collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes, or for statistical purposes shall not be considered incompatible with the original purposes ("purpose limitation");
• Personal data are adequate, relevant, and limited to what is necessary for relation to the purposes for which they are processed ("data minimisation");
• For our part, we make sure that Personal data is accurate and, where necessary, they are kept up to date; we take all reasonable steps to ensure that any Personal data that are inaccurate, having regard to the purposes for which they are processed, erased or rectified without delay ("accuracy");
• Personal data are kept in a form that permits identification of Data subjects for no longer than is necessary for the purposes for which the Personal data are processed; Personal data may be stored for longer periods insofar as the Personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, taking into account the implementation of appropriate technical and organisational measures required by the GDPR to safeguard the rights and freedoms of the Data subject ("storage limitation");
• Personal data are processed in a manner that ensures appropriate security of Personal data, including protection against unauthorised, or unlawful processing and accidental loss, destruction, or damage, using appropriate technical or organisational measures ("integrity and confidentiality").

We shall take all necessary measures to demonstrate that we comply with the above principle.

5. INFORMATION WE COLLECT AND HOW WE COLLECT IT

We may collect several types of information, including but not limited to Personal data, from and about you:

• Data received from Customers: when you engage with us, you may provide us with certain Personal data, such as your name, email address, and the details of the potential Authorised Users (invited persons). Such data may be provided to us directly by you or by your representatives.
• Data automatically collected or generated: when you visit or interact with our Site and Free Services or Services, we may collect, record, or generate certain technical data about you (“cookies” and other tracking technologies (for more details, see here https://relsa.io/cookie-policy)). Such data usually consists of connectivity, technical or aggregated usage data, such as general locations, device and application data (such as type, operating system, mobile device ID, browser version, locale, and language settings used), date and time stamps of usage, the cookies and pixels installed or utilized on the such device and your recorded activity (sessions, clicks, and other interactions) in connection with our Sites or Free Services and Services.
• Data received from other third parties: we may receive data concerning you, your users (players of the games, app users, and anyone who has seen an advertisement of the Customer), and metrics for your advertising campaigns from Ad Networks such as “Impressions”, “Clicks”, “Installs” (if a campaign is for installs), etc. 

6. DATA FROM AD NETWORKS

We can receive the following types of data:

General technical information about a device: technical information such as the device’s time zone, battery status, operating system name and version, the language of the operating system, the name of the mobile carrier, etc.

Advertising Campaign information (metrics): an indication if an advertisement was viewed, or clicked, or if there was an install of an advertised app, CTR, CVR, CPM, CPA, CTI, CPC, IPM, customer's key metrics like retention, churn, MAU, DAU, LTV, etc.

We use Ad Network data information for the following purposes:

Reporting: we generate reports and provide analytics about the characteristic of the Advertising Campaigns, Advertising Creatives, and other single files;

Internal Operations: we use Ad Network information for internal operations, such as debugging, support, and improving our Free Services and Services.

Recommendations: we use Ad Network information (in an anonymized manner) for providing recommendations for the optimization of Advertising Campaigns and Advertising Creatives, based on the machine-learning-based cueing system. You may opt-out of having your Customer data from Ad Networks used for machine learning purposes by emailing support@relsa.io.

7. USING AD NETWORKS

In using our Free Services or Services you may access links to websites and services that are owned or operated by Ad Networks. Any information that you provide on or to an Ad Network or that is collected by an Ad Network is provided directly to the owner or operator of the Ad Network and is subject to the owner’s or operator’s privacy policy. We are not responsible for the content, privacy, or security practices and policies of any Ad Network. To protect your information, we recommend that you carefully review the privacy policies of all Ad Networks that you access.

8. WHAT PERSONAL DATA, FOR WHAT PURPOSES, HOW LONG, AND BASED ON WHAT GROUNDS DO WE PROCESS AS A CONTROLLER?

If you reside or are using the Free Services and Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data or other data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us or via the Services, or due to nature of such processing), your acceptance of our Terms of Service https://relsa.io/terms-of-service and this Privacy Policy will be deemed as your consent to the processing of your personal data and other data for all purposes detailed in this Privacy Policy, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at support@relsa.io.

Changes of Personal Data. When you register or use the Free Services or Services, you voluntarily provide us with certain Personal Data (Personally identifiable information), including your name (surname), e-mail address, and photo. If you would like to change it, you may do so on the settings page of your personal account on the Site.

9. WHAT DATA DO WE PROCESS AS A PROCESSOR OF OUR CUSTOMERS (CONTROLLERS)?  

Relsa processes Personal data on behalf of its Customers inside the EEA and the EU in respect of the Free Services and Services and therefore acts as a processor in the sense of the GDPR (“Processor”).

Relsa’ Customers determine the purposes and means of the processing of Personal data in respect of the Services inside the EEA and the EU and therefore act as a controller in the sense of the GDPR (“Controller”).

The processing of Personal data by Relsa on behalf of its Customers is only allowed in respect of providing Free Services and Services inside the EEA and the EU. Relsa is not allowed to process Personal data for its own purposes and means. Should Relsa nevertheless process Personal data for its own purposes and means in respect of the Services inside the EEA, then in such case only, Relsa acts as a Controller in the sense of the GDPR.

We usually process the following Personal data on behalf of our Customers in respect of the Free Services and Services: names, email addresses, device data from which the website is viewed, and cookies.

10. SECURITY OF DATA

We are ensuring the confidentiality of the processed Personal data and other data on behalf of our Customers, under the procedure provided by applicable legislation. Protection of Personal data and other data is supported by the implementation of legal, organisational, and technical measures necessary and sufficient to ensure that the requirements of the applicable data protection legislation are met.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your collected information, we cannot guarantee the security of the collected information transmitted to or through Relsa or an absolute guarantee that such information may not be accessed, disclosed, altered, or destroyed. Any transmission of your collected information is at your own risk. We are not responsible for the circumvention of security measures contained in Relsa. Please understand that there is no ideal technology or measure to maintain 100% security.

The safety and security of your information also depend on you. Your privacy settings may also be affected by changes in the Ad Networks, through which you may share your content. We are not responsible for the functionality, privacy, or security measures of any other organization.

11. AUTOMATED DECISIONS

We do not make any automated decisions about you or with your Personal Data that would result in legal or other similarly significant effects on you.

12. REQUEST FOR ADDITIONAL INFORMATION TO IDENTIFY THE DATA SUBJECT

During the processing of your data, we may ask you to provide us with additional information to enable us to identify you.

On our part, we endeavour to obtain a minimum of additional information in order to be able to carry out such identification. If you do not provide us with said additional information upon our request, we will not be able to exercise your rights.

13. YOUR RIGHTS AS A CUSTOMER

You have the following rights under the GDPR with respect to Personal data:

• the right to access to information held about you;
• the right to rectification of the processed data;
• the right of erasure ('the right to be forgotten');
• the right to restriction of processing;
• the right to data portability;
• the right to object and automated individual decision-making;
• the right to withdraw consent;
• the right to lodge a complaint.

To exercise these rights, please contact us via email support@relsa.io. 

1. THE RIGHT OF ACCESS TO INFORMATION HELD ABOUT YOU

The Data subject has the right to obtain from the Controller confirmation as to whether or not Personal data concerning him or her are being processed and, if so, access to the data, as well as other information, namely:

• information about the purposes for which the Personal data are processed;
• information on the categories of Personal data concerned;
• information on the recipients or categories of recipients to whom the Personal data have been or will be disclosed, including recipients in third countries (outside EU and EEA) or international organisations;
• information on the envisaged period for which the Personal data will be stored, or, if not possible, the criteria used to determine that period;
• information on the existence of the right of rectification or the right to erasure or the right to object to processing of Personal data concerning the data subject or to object to such processing;
• if the data are not collected from you, any available information on the source of the data;
• information on the right to lodge a complaint with a supervisory authority;
• information on the guarantees of data transfer to third countries (outside the EU and EEA) or to international organisations, where such transfer will take place;
• information about the availability of automated decision-making, including profiling, and, where available, information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

1. THE RIGHT TO RECTIFICATION OF PROCESSED DATA

We take all measures to detect any inaccurate, incomplete, or outdated Personal data.

You have the right to rectify your Personal data without undue delay if it is inaccurate, incomplete, or out of date.

Once we have rectified your Personal data, we will promptly provide you with an appropriate notification.

2. THE RIGHT OF ERASURE

You have the right to request the erasure of your Personal data, and this will be done without undue delay.

If we cannot erase your Personal data, we will anonymise it in a way that you are not identified.

Once your Personal data has been erased or anonymised, you will be notified.

We cannot exercise the right to the erasure of your Personal data in particular if your Personal data is processed:

• in order to exercise the right to freedom of expression and information;
• in order to comply with a legal obligation that requires the processing of data in accordance with the provisions of Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest, or in the exercise of official authority vested in the controller;
• for reasons of public interest in the area of public health;
• for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes;
• for the establishment, exercise, or defence of legal claims.

1. THE RIGHT TO RESTRICTION OF PROCESSING

Where the processing is restricted, we will store your Personal data, but we will not process it further until the restrictions are removed. Restrictions on processing can be removed at any time upon request.

The right to restrict data processing can only be exercised in the following cases:

• the accuracy of the Personal data will be contested by you for a period of time that allows us to verify the accuracy of the Personal data;
• the processing of your Personal data is unlawful and you oppose the erasure of the Personal data and request the restriction of their use instead;
• where we no longer need the Personal data for the purposes of the processing, but they are required by you for the establishment, exercise, or defense of legal claims;
• you object to the processing pending verification of whether the legitimate grounds indicated by the controller override the grounds indicated by you.

Exceptions to this right. Once we have restricted the processing of your Personal data, we may continue processing in the following cases:

• with the data subject's consent, in order to establish, exercise or defend against legal claims;
• in order to protect the rights of another natural or legal person;
• for reasons of important public interest of the Union or a Member State.

1. THE RIGHT TO DATA PORTABILITY

You have the right to receive the Personal data that you have provided to us in a structured, commonly used, and machine-readable format and the right to transmit this data to another controller, as far as this is technically possible.

You can exercise the aforementioned right if the data are subject to processing on the basis of your consent or a contract signed with you and the data are processed electronically.

2. THE RIGHT TO OBJECT

You have the right, at any time, to object to the processing of Personal data based on your particular situation:

• in relation to the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• in relation to the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by interests or fundamental rights and freedoms of the data subject, which require protection of personal data, in particular where the data subject is a child.

We will no longer process your Personal data unless we identify compelling legitimate grounds for the processing.

You have the right at any time to object to the processing of your Personal data for direct marketing purposes.

3. THE AUTOMATED INDIVIDUAL DECISION-MAKING INCLUDING PROFILING

You have the right not to be subject to decisions based solely on automated processing, including profiling, which produces legal effects on you or has a similar significant impact on you.

Exceptions to this right:

• it is necessary for the entering into or performance of a contract between the Data subject and the Controller;
• it arises from a provision of EU or Member State law to which the Controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests;
• it is based on the explicit consent given by the Data subject.

1. THE RIGHT TO WITHDRAW CONSENT

If you have consented to the processing of your Personal data or other data, you have the right to withdraw such consent at any time.

We process your Personal data on the basis of consent for processing, mailing, push notifications, and cookie processing.

We process other data on the basis of consent for the performance of a contract (Terms of Service) to which you are the party (for further details, see clauses 5 and 6).

We provide you with the possibility to withdraw your consent in a simple way, i.e:

• You can withdraw your consent to receive emails by clicking on the "unsubscribe" link that is available in every email communication;
• You have the option to manage your marketing preferences for push notifications using your browser or phone settings, or by contacting us;
• You can withdraw your consent to the processing of cookies through any of our websites using the cookie control tool.
• You can withdraw your consent to process other data by contacting us (see Clause 19).

1. THE RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

You have the right to lodge a complaint with the supervisory authority of your own country if you have concerns about the manner in, which we process your Personal data and about the protection and exercise of your rights.

You can find the contact details of your country's supervisory authority on the website of the European Data Protection Board here: https://edpb.europa.eu/about-edpb/board/members_en.

14. CONDITIONS UNDER WHICH WE PROVIDE YOU WITH INFORMATION RELATED TO YOUR RIGHTS

Information related to your rights is provided free of charge. Where the data subject's requests are manifestly unfounded or excessive, in particular, because of their repetitive character, we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the requested action, or refusing to act on the request.

15. PAYMENTS

We will not store or collect your payment card details or any other relevant valid, up-to-date, and complete contact and billing details. We use the third-party service Stripe for payment processing (e.g. payment processors).

The payment card details or any other relevant valid, up-to-date, and complete contact and billing details are provided directly to our third-party payment processor Stripe whose use of your personal information is governed by Stripe's privacy policy.

We may ask you to provide information to facilitate this transaction and verify your identity.

16. COOKIES

Relsa also uses cookies. You can find more information about cookies here ​​https://relsa.io/cookie-policy.

17. DO NOT TRACK

"Do Not Track" is a privacy preference that you can set in certain web browsers. We do not change our practices in response to a "Do Not Track" signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Free Services or Services.

18. CHANGES TO THIS PRIVACY POLICY

We may occasionally make changes to this Privacy Policy.

When we make material changes to this Privacy Policy, we'll provide you with prominent notice as appropriate under the circumstances. For example, we may display a prominent notice within the Free Service or Service or send you an email, and we will update the "Last updated date" above to indicate when those changes were made.

19. HOW TO CONTACT US

We welcome your feedback and sincerely apologize in advance for any errors that may occur while we are in test mode. If you have any questions about this Policy, complaints, or claims, please contact us via e-mail: support@relsa.io

This Addendum reflects the parties’ agreement on the processing of Customer Personal Data in connection with the California Consumer Privacy Act of 2018 (“CCPA”).

Relsa and the Customer have entered into the Addendum Privacy Policy which supplements the Privacy Policy (the “Addendum”).

Beginning 1 January 2020, the California Consumer Privacy Act ("CCPA") gives California residents certain rights with respect to the processing of Personal Data (known as "personal information" under the CCPA). We provide this statement to USA residents ("you") in accordance with requirements under the CCPA to make certain disclosures about the collection and processing of their personal information.

For information about how we’ve extended the CCPA core rights to control personal information to all of our users in the United States, please see our provisions of the Privacy Policy.

This supplement provides additional privacy disclosures and details additional rights and should be read in conjunction with our Privacy Policy.

1. PERSONAL INFORMATION

Section 8 of our Privacy Policy sets forth the categories of personal information (categories of data) that Relsa collects and processes about you, the purpose of the processing of each category, and the storage period.

2. REQUESTS TO EXERCISE YOUR RIGHTS

1. RIGHT TO KNOW REQUEST

Under the CCPA, you have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and ask that we provide you with the following information:

• Categories of and specific pieces of personal information we have collected about you;
• Categories of sources from which we collect personal information;
• Purposes for collecting personal information;
• Categories of third parties with whom we share personal information;
• Categories of personal information disclosed about you for a business purpose;
• If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.

To make a verifiable request for information about the personal information we have collected about you, please email us at support@relsa.io.

2. RIGHT TO DELETE REQUEST 

You also have a right to request that we delete personal information, subject to certain exceptions. You may exercise your right to delete via email support@relsa.io.

3. HOUSEHOLD REQUESTS

Relsa currently does not collect household data.

4. SALE OF PERSONAL INFORMATION

Relsa does not sell personal information. We have taken substantial steps to identify and remediate any data sharing arrangements that could constitute a "sale" under the CCPA.

Revised April 20, 2023.