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DATA USE POLICY
This privacy policy is designed to describe how we approach your privacy as an internet user interacting with websites that have implemented our technology.

1. GENERAL INFORMATION

We are a marketing company that provides permission-based communication services to companies in various fields. Our role is to provide companies with an efficient tool to send relevant messages related to their products or services via email or sms. Our messages are personalized, that is, based on information from your previous online activity in relation to a company to which you have previously given consent to communicate via email or sms. Our messages are related to your purchase history, products added to your cart and/or products viewed on the company's website to which you have previously given consent to communicate

In order to deliver personalized messages, we process certain information about your online activity that helps us understand what your current shopping interests might be and allows us to display messages and analyze how it works. While doing so, we aim to ensure the highest level of privacy protection and transparency. We strictly comply with all applicable privacy laws, in particular the EU General Data Protection Regulation (GDPR), as well as digital marketing best practices.

2. HOW WE COLLECT YOUR DATA

To collect your data, we use cookies, which are text files placed in your web browser when you visit companies' websites or applications. They allow us to record certain activities you perform on those sites or applications.

We operate under the domain analytics.7w.ro and/or pa.7w.ro while providing our services. We store three cookies under this domain: a unique ID for the browser you are using, the cookie lifetime, the last access data

3. WHAT DATA DO WE PROCESS?

We process the following three main groups of data:

(a) Information related to your browsing activity on the websites or applications of companies - helps us understand what kind of products and services you are interested in and, consequently, to determine what messages need to be displayed to match your current shopping interests. We process this data on behalf of the companies for which we implement email or SMS communication processes, in particular for the purpose of creating user profiles.

(b) Information you enter into the company's website or application. We process this data on behalf of the companies for which we implement email or SMS communication processes, in particular for the purpose of creating the user profile.

(c) Information regarding interaction with sent messages (for example, whether you opened received emails, whether you clicked on a link). We process this information as a data controller for the purpose of determining relevant messages, for ad measurement and product development.

You can find a full list of data categories that we process as a data controller in our GDPR privacy notice (see section 5 below).

4. HOW WE USE YOUR DATA.

While you visit a company's website or application (for example, an online store), we collect certain information related to your activity, such as the items you have viewed, added to your cart, and purchased. These browsing patterns on the company's website or application help us understand what kinds of products and services you are currently interested in and allow us to send you certain messages that we believe are compatible with those interests.

For example, if you recently visited our client's online store looking for running shoes, we may send you a message with the same running shoes you saw there and similar running shoes or complementary products, such as running apparel, offered by that company.

Furthermore, we do not use your browsing data in relation to one company's website for another company. This means that browsing activity on one company's website or app does not affect messages from other companies. For example, the fact that you searched for swimming equipment in an online store of our client "A" will be information used strictly for client A.

We use information about messages sent and interactions with them to analyze how our messages perform, to create statistical reports for the client company regarding the delivery of their messages, and subsequently for attribution and billing purposes. We also process this data to control the frequency of messages we display to you (frequency capping) and for product development purposes.

Our platform is integrated with companies' websites by matching our technical identifiers, for example, cookie IDs. This allows us to consolidate the data collected and associate it with an identifiable user through an email address or phone number provided by filling out a form on the client company's website.

We do not purchase third-party data from data providers for the purpose of optimizing services, nor do we sell the data we process to third parties.

5. PROCESSING OF PERSONAL DATA (GDPR)

The data we collect online is considered by the GDPR to be online identifiers and falls into the category of pseudonymous data. This data is associated with personal identification data (email/mobile phone number) in order to be able to carry out individual communications via email/sms. Consequently, in cases where the GDPR applies to our services, we ensure compliance with all the requirements established by this regulation.

We have also appointed a data protection officer, whom you can contact if you have any further questions. He can be contacted at dpo@whiteimage.ro

As mentioned above, we process the data we use to provide services only as a data processor, that is, on behalf of the companies.

6. DATA SECURITY MEASURES

We have implemented organizational and technical measures to ensure an adequate level of security for your data. We have developed procedures for every aspect of data processing and carefully select the technologies used for such processing and any recipients of the data.

Your data is protected against human interaction, equipment failure, internal or external attacks, loss or misuse. We store it in top-notch multi-tenant data centers, operated by market-leading companies with appropriate data security certifications (particularly ISO 27001). To ensure the confidentiality and continued availability of your data, we use backup mechanisms.

We constantly monitor the security measures implemented and continuously develop awareness and knowledge about privacy and personal data protection at our company.
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