Adsfactor Limited GDPR Data Protection

Effective Date, Date Last Modified: April 12, 2018.

As of April 2018, Adsfactor Limited holding company Pixels Limited will be re-branded to DaVinci11 (Hong Kong) Limited (“DaVinci11”).

Compliance with law:
DaVinci11 will comply with obligations under all Applicable Laws with respect to the Processing of Personal Data in connection with the Agreement. DaVinci11 will not be Processing, Safeguarding, Personnel handling, Transferring, Controlling of Personal Data from within the EEA [or Switzerland].
Safeguarding, Processing, Personnel handling Personal Data, Transfers, Data Exchange:
In relation to any Personal Data that is provided by an operator of a digital property (including for example websites and apps), DaVinci11 will not be Processing, Safeguarding, Personnel handling, Transferring, Controlling of Personal Data from within the EEA [or Switzerland]. DaVinci11 will include a clear and unambiguous link to an easy-to-use mechanism that provides the Data Subject the ability to opt out, including where applicable the ability for a Data Subject to opt out of Interest-Based Advertising.
Personal Data Breach:
DaVinci11 confirm that there will be no Personal Data Breach for Personal Data within EEA [or Switzerland] as DaVinci11 will not be Processing, Safeguarding, Personnel handling, Transferring, Controlling of Personal Data from within the EEA [or Switzerland].
DaVinci11 shall make the final decision on notifying (including the contents of such notice) clients, employees, relevant Supervisory Authorities, service providers, third party partners, Data Subjects and/or the general public of such Personal Data Breach, and the implementation of the remediation plan, to the extent Personal Data in relation to which DaVinci11 acts as a Controller is concerned.
Privacy Policy & Disclosures:
If you are uncertain of the technology DaVinci11 use in relation to Personal Data and how we will use Personal Data provided by you, please see our privacy statement at https://pixels.asia/privacy_policy or submit a request to DaVinci11 for further information at privacy@pixels.asia.
Definitions:
Applicable Laws means laws, rules, directives, regulations issued or enacted by any government entity (including any domestic or foreign, supra-national, state, county, municipal, local, territorial or other government, which includes to the extent applicable, GDPR, Directive 95/46/EC, Directive 2002/58/EC, European Commission decisions and guidance) each as transposed into domestic legislation of each member state of the European Union or other country and as amended, replaced or superseded from time to time, including by the GDPR and laws implementing or supplementing the GDPR, and any industry self-regulatory principles that are applicable in the location or region where the Services are provided or received, related to the Processing of Personal Data or the interception, recording or monitoring of communications.
GDPR means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the Processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation);
GDPR means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the Processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation);
Interest-Based Advertising means each of (i) the collection of data across multiple digital properties or other sources for the purpose(s) of profiling and delivering advertising based on preferences or interests known or inferred from the data collected and (ii) the collection of data about a user’s activity on or in one digital property or source for the purpose(s) of profiling and delivering advertising based on that data on a different digital property;
The terms “Data Subject”, “Controller”, “Processor”, “Personal Data”, “Personal Data Breach”, and “Processing”, and “Supervisory Authorities” shall have the same meaning as in the GDPR, and their cognate terms shall be construed accordingly:
  • Data Subject means an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
  • Processor means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller;
  • 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;
  • Personal Data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
  • Personal Data Breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise Processed
  • Process(ing) means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction; and
  • Supervisory Authorities means an independent public authority which is established by a member state of the European Union pursuant to GDPR Article 51.