We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

Introduction to the ClickOcean Platform

ClickOcean is a CPA marketing platform with own data-driven solutions, high quality offers and traffic sources belonging to the company Novi Limited, a company that specializes in affiliate marketing and incentive-based advertising on the Internet. This policy explains how we collects, use, and disclose information through our marketing platform (the "Platform"). If you are interested in learning how we collect, use, and disclose information through other corporate activities, such as on our corporate website, https://novilimited.com/ , please click here. Our goal is to be transparent about our business by describing our technology and services in simple terms so that you can understand our practices. We know this is complicated, so if you have any questions about this information, please contact us.

The data our Platform collects and processes:

Data that is in our Platform is pseudonymous, which means that it does not directly identify people. Our Platform doesn't contain names, email addresses, phone numbers, or the like, and we prohibit our clients and partners from providing that kind of data into our Platform. Our clients and partners may, outside of our Platform, have access to other information about you, including information that directly identifies you. Such information is governed by the clients' own legal requirements, privacy policies, contracts, or other terms that they have in place.

Our references to our Platform in this policy only refer to our own advertising technology platform and systems and do not include the technology or systems of clients or partners that use or integrate with us. They are bound by our policies when they use our Platform.

The data that our platform collects:

• Device Information. We collect information regarding the Internet browser, computer, tablet, mobile phone, smartphone or other devices.
  
  
• Internet Protocol Addresses. Internet browsers automatically transmit information such as the URL of the website you just came from and the Internet Protocol (IP) address and the browser version of your computer.
  
  
• Location Information. If allowed, we (or the third party) may use this information to supply you with location specific advertisements, offers and functionality. Additionally, we may (or may enable a third party to) capture geolocation information (such as IP address data) and may use that geo-location information to targets ads, offers and functionality.
  
  
• Analytics. We use third party information, reports and analysis about the usage and browsing patterns of Internet users. We allow the third party analytics companies to include web beacons and cookies on certain of our websites and in some of our Advertising Technology Platforms. The collected information includes search terms, search parameters, click-throughs by users, and other similar information.
  
  
• Log Files. We may also automatically log certain anonymous information about visitors to our websites, including, but not limited to, where the user came from to visit our site, IP address, search terms utilized, browser type and a reading history of the pages viewed.
  
  
• Web Beacons. We (or our third party partners) may use web beacons. Web beacons communicate information from your Internet browser to a web server.
  
  
• Other. As new technologies develop we may implement and/or test them on our Platform. We only utilize technologies as permitted by law.
  
  

The information we collect about you does not reflect your name, email address, or Other Information that directly identifies you, and we take care to ensure that we do not collect any information that tells us who you are. However, the information listed above could be combined with Other Information to identify or reveal information about you, so it may qualify as personal information or personal data under the GDPR.

How We Use the Information We Collect

The Platform processes data both on our own behalf and on behalf of clients and partners for purposes related to measuring and reporting on advertising that allows us to tailor our marketing to better suit your needs. Nothing we store can be traced back to you as we use a unique and meaningless identifier to refer to the tracking data. We use aggregate trend data to improve the quality of the ads you will be served in the future and to maintain, improve and develop new services. We occasionally produce reports and analytics for our partners and customers. These reports show aggregate data over time to show historical performance and trends and do not contain individual data.

Specifically, we use this data for:

• Frequency and other reporting: We use data to keep track of how many times an ad was shown, as well as where and when.
  
  
• Measurement and analytics: We use data to measure how well ads perform, such as whether users clicked on the ad or went to a client's store after their ad campaign was shown.
  
  
• Reporting: We may use data to measure, attribute, and report on the performance and success of campaigns. This includes transaction reporting and verification.
  
  
• Clicks and conversions: We may use data to measure actions taken by a user with respect to a particular ad, i.e., a click on an ad, or a download of an app.
  
  
• Attribution: We may use data to match particular ad views to subsequent actions taken by a user. This would be done by stitching together data collected from our Platform with the advertiser's own data and data from other companies.
  
  
• Cross device graphing: We may use data and algorithms to associate devices that might be related to each other, such as devices used by the same person or in the same household.
  
  
• Detection of malicious or invalid activity: We process information in an attempt to prevent malicious activity or invalid ad traffic.
  
  

How do we collect information?

ClickOcean collects data through the use of "cookies" and "pixel tags". Cookies are small text files that web servers send to a user's computer when they visit a website. Cookies are stored as text files on the user's internet browser, and can be accessed by web servers when the user returns to a website or goes to another website. Cookies are used by companies to collect and send information about a user's website visit. ClickOcean uses cookies to provide information to advertisers on a user's web browsing activity as a means to tailor more highly relevant online advertisements for that user. ClickOcean cookies cannot be used to access any other data on a user's hard drive. ClickOcean cannot and does not use cookies to determine any individual's actual identity.

Pixel tags are small strings of HTML or JavaScript code that provide a method for delivering a graphic image on a Web page or other document. Pixel tags allow the operator of the Web page or a third party who serves the pixel tag, to set, read, and modify the ClickOcean cookies. ClickOcean uses Pixel only to obtain information about the computer being used to view that Web page such as the IP address of the computer that the tag is sent to, the time it was sent, the user's operating system and browser type, and similar information. We do not link this automatically collected data to other information we collect about you.

ClickOcean may also utilize data from a third party provider. This data may be combined with data collected directly by our platform. Some of our Data Providers, Displaying Publishers and Networks may place their own cookies on a user's internet browser outside of the ClickOcean service; however ClickOcean has no access to or control over these cookies.

Your Right to Opt-Out

You can generally activate or later deactivate the use of cookies through a functionality built into your web browser or mobile device.

To learn more about how to control cookie settings through your browser:

Firefox link

Chrome link

Internet Explorer link

Safari (Desktop) link

Safari (Mobile) link

Android Browser link

For other browsers, please consult the documentation that your browser manufacturer provides. You can opt out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance (http://youradchoices.com).

In addition, on your iPhone, iPad or Android device, you can change your device's privacy settings to control whether you see online interest-based ads:

What information do we share with third parties?

We will share your information with third parties only in the ways that are described in this policy.

• Some of the data processed on the Platform belongs to our clients. When this is the case, our clients can take this data, such as records of advertising impressions, off of the Platform. We also may share this data with third parties on their behalf pursuant to their instructions.
  
  
• We may share data in order to investigate or prevent reasonably suspected malicious activity, fake traffic, or other activity that may be harmful to us or our clients.
  
  
• We may share data with our service providers that store or process data in furtherance of the services we offer on the Platform on our behalf.
  
  
• We may transfer data to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.
  
  
• We may share aggregated data that does not include individual-level records with any party or publicly.
  
  
• We may disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
  
  
• We transfer personal data to countries other than the country in which it was collected. We do so under a valid legal framework. If we receive data and transfer it on to a third party acting as an agent on our behalf, we will take appropriate measures to ensure that the third party's processing of the data is in accordance with the framework.
  
  

Security and Data Retention

We retain the pseudonymous data collected on our Platform for up to 18 months. After 18 months (often sooner) the data is de-identified or aggregated and stored for up to 3 additional years. This retention policy does not apply to client or partner data.

We use industry standard practices to safeguard the confidentiality of information and treats data as an asset that must be protected against loss and unauthorized access. We employ many different security techniques to protect such data from unauthorized access by users inside and outside the company.

Your rights

As a data subject (a person whose personal information is collected, stored and processed) you have several rights under GDPR:

Right of access. You have the right to obtain confirmation if your personal information is being processed by us. If that is the case, you can access your personal information and the following information: (a) the purposes of the processing; (b) the categories of personal information; (c) to whom the personal information have been or will be disclosed; (d) the envisaged period for which the personal information will be stored, or the criteria used to determine that period.

If you would like to have a copy of your personal information from us, we will provide it based on (1) you will prove your identity, (2) it will not adversely affect the rights and freedoms of others. First copy will be provided for free, for any further copies we may charge a reasonable fee based on administrative costs.

Right to rectification. You have the right to demand us that we correct without undue delay your personal information which we have in our systems if they are inaccurate or incomplete.

Right to erasure ('right to be forgotten'). You have the right to demand that we erase your personal information, and we shall erase it without undue delay where one of the following grounds applies: (a) this personal information is no longer necessary in relation to the purposes for which they were processed; (b) you withdraw consent on which the processing is based, and where there is no other legal ground for the processing; (c) you object to the processing and there are no overriding legitimate grounds; (d) your personal information have been unlawfully processed; (e) your personal information have to be erased for compliance with a legal obligation.

Right to restriction of processing. You have the right to restrict us in the ability of processing of your information where one of the following applies: (a) you contest the accuracy of your personal information and we are verifying it; (b) the processing is unlawful and you want to restrict it instead of erasure; (c) we no longer need your personal information, but you need them for some legal reasons; (d) you have objected to processing and we are verifying whether the legitimate grounds override your request.

Right to data portability. You have the right to receive your personal information which you provided us in a structured, commonly used and machine-readable format and have the right to transmit those data to another company, where: (a) the processing is based on your consent or on a contract; and (b) the processing is carried out by automated means. Where technically feasible, you can demand us to transmit those data directly to another company.

Right to object. You have the right to object to processing of your personal information based on our legitimate interests. We shall no longer process your personal information unless we demonstrate compelling legitimate grounds for the processing or for the establishment, exercise or defense of legal claims.

Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on you. Please note that we don't make any automated decisions including profiling based on information that we have about you.

Right to withdraw consent. You have the right to withdraw you consent for processing of your personal information at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Right to lodge a complaint. You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal information infringes GDPR.

Breach Notification. If a breach/unauthorized access of personal information takes place that is likely to "result in a risk for the rights and freedoms of individuals", we will notify the supervisory authority within 72 hours of becoming aware of the breach.

Changes to the Privacy Policy

This Privacy Policy may be updated from time to time. When updated the "Effective date" below will be amended and the new Privacy Policy will be posted online.

Our contact details

Novi Limited

Stasinou, 1, MITSI BUILDING 1, 1st floor,

Flat/Office 4, Plateia Eleftherias, 1060, Nicosia, Cyprus



Effective date: 20 September 2020