Last Modified: April 27th, 2021
MindGeek S.A.R.L., (hereinafter “we”, “us” or “our”) operates the website mindgeek.com (hereinafter “Mindgeek” or the “Website”) and is the controller of the information collected or provided via this Website.
If you have any questions about our privacy practices, please see “Contact Information” below for information on how to contact us.
It does not apply to information collected by:
Personal data, or personal information, means any information about an individual from which that person can be identified by (“Personal Information”). It does not include data that has been anonymized or pseudonymized.
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
We may also collect, use and share your data to produce and share aggregated insights that do not identify you. Aggregated data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Website feature.
We do not collect special categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, information about your health and genetic and biometric data).
We use different methods to collect data from and about you including through:
As you navigate through and interact with our Website, we use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including information such as your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information.
We also use these technologies to collect information about your online activities over time and across third-party websites or other online services (“interest-based advertising”). See “Choices About How We Collect, Use and Disclose Your Personal Information” below for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking. The technologies we use for this automatic data collection may include:
Cookies (or browser cookies). Cookies are small text files that are stored in your web browser or downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie, and allow a website to recognize a user’s device.
We currently use the following types of cookies:
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see “Choices About How We Collect, Use and Disclose Your Personal Information”.
We will only use your personal data when the applicable local law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
In general, we use information that we collect about you or that you provide to us, including Personal Information and Sensitive Personal Information, for following purposes:
We do not disclose your Personal Information except in the limited circumstances described here.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We also may share aggregated information with third parties for conducting general business analysis. This information does not contain any Personal Information and may be used to develop content and services that we hope you and other users will find of interest and to target content and advertising.
By using the Website you consent to the transfer of information that we collect about you, including personal information, to any country in which we, members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) or our service providers are located.
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Where permissible, we will also delete your Personal Data upon your request. Information on how to make a deletion request can be found under “Your Rights Related to Your Personal Information”.
If you have questions about our data retention practices, please send us an e-mail at firstname.lastname@example.org.
The period for which we keep your Personal Information that is necessary for compliance and legal enforcement purposes varies and depend on the nature of our legal obligations and claims in the individual case.
We take appropriate security measures (including physical, electronic and procedural measures) to safeguard your Personal Information from unauthorized access and disclosure. For example, only authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions. In addition, 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. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data.
You are responsible for maintaining the secrecy of your unique password and account information at all times. We are not responsible for circumventions of any privacy settings or security measures contained on the Website.
We strive to provide you with choices regarding the Personal Information you provide to us.
Under certain circumstances, you have rights under data protection laws in relation to the Personal Information we collect, use or disclose and that is related to you, including the right:
If we ask for your consent to use your Personal Information, you can withdraw your consent at any time. Note that in case of a withdrawal of your consent you may no longer able to use several functionalities of our Website and our services.
You may, at any time, send us an e-mail at email@example.com to exercise your above rights in accordance with the applicable legal requirements and limitations. If you are located in the European Economic Area, you have a right to lodge a complaint with your local data protection authority.
Note that some requests to delete certain Personal Information will require the deletion of your user account as the provision of user accounts are inextricable linked to the use of certain Personal Information (e.g., your e-mail address). Also note that it is possible that we require additional information from you in order to verify your authorization to make the request and to honor your request.
The following information serves as a guideline for law enforcement officials seeking disclosure of records. You may serve us a valid Court Order, Subpoena, Search Warrant or equivalent Legal or Official Administrative Document by respecting the following conditions:
The document(s) is uploaded, and all required fields have been filed out adequately on our Legal Service Process Platform located at:
The document(s) you are serving is correctly issued by a valid Court of Law or equivalent legal or administrative authority to the right operating entity for the Site in question. (See Platform to find the operating entity);
We reserve the right to refuse online service through our Platform, namely in cases where the above requirements are not met and require formal legal service at the above address. In such event, you will be notified. We may raise or waive any legal objection or right available, in our sole discretion.
Our Website is not directed to persons under the age of 18 or the applicable age of majority in the jurisdiction from which the Website is accessed and we do not knowingly collect Personal Information from minors. If you become aware that your child has provided us with Personal Information, please contact us at firstname.lastname@example.org. If we become aware that a minor has provided us with Personal Information, we take steps to remove such information and terminate that person’s account.