Effective from April 15, 2019
Go NET is not an ad network or a data broker which is part of Go Mobile Company ( LLC "Go Mobile" / OOO “Гоу Мобайл” ). Go Net is a digital advertising technology platform (Platform) where advertising agencies, corporate businesses and other technology providers (Clients) can manage their advertising campaigns in the most efficient way possible and buy advertising spaces on third-party websites and other digital media properties and intermediaries that have integrated our technology or that use the technology that integrates with our Platform (Sites). Go NET provides the Clients the services to remotely access and use our Platform (Services). Our Clients and Sites own their own data, and Go NET has only limited rights to process their data on their behalves for the purpose of providing the Services.
We may process your data when you (an Internet user) visit a Site.
What is this document
We take privacy seriously, and we would like to be transparent about the data processed on the Platform.
This notice describes our Platform and Services and explains how we may process your data.
We will also explain how you can manage your privacy choices and exercise your rights to your data.
To ensure privacy, Go NET complies with the EU General Data Protection Regulation (GDPR), e-Privacy Directive and supports initiative for self-regulation including the Internet Advertising Bureau (IAB) GDPR Transparency & Consent Framework.
If you have any questions or comments regarding this notice, please see the “contact us” section at the end of this notice.
You can opt out of receiving the tailored advertisements shown by our Clients from the Platform in your current browser. To opt-out or opt-in please visit the following pages: https://dmp.gotechnology.io/dmp/opt-out
Please note that Cookies and other mobile advertising IDs are different on different browsers and devices, this ‘opt-out’ only applies to this browser and this device.
What we do
Go NET is an advertising technology company.
Our Clients include advertising agencies and corporate businesses that use our Platform to manage their advertising campaigns. Go NET does not provide services directly to any consumers.
We own and operate the Platform.
The Platform provides a tool to the Client to buy the most relevant advertising spaces corresponding to the parameters of the Client’s advertising campaign submitted by the Client to the Platform. We also provide a technology that enables the delivery of the advertisement to the Site.
This is how it works. The Sites send to the Platform notices (bid requests) when an advertising space becomes available. Each bid request contains the description of the interests of the audience that is likely to see the advertisement. The Platform compares the description of the audience under the bid request with the parameters of the Client’s advertising campaign. If they match, the Platform provides a tool to the Client to automatically make a transaction to buy such advertising space and deliver the advertisement to the Site.
As a result, the Client will show the advertisements to the users who are likely to have an interest in the Client’s advertisements. The Platform helps to make online advertising more relevant and not generic and consequently helps to keep Internet meaningful and free. The advertisers are likely to pay more when their ads are tailored to the audience’s interests, which may allow the publishers to provide their content to the users for free.
Do we collect personal data
We do not collect personal data that identifies you (an Internet user) in the ‘real world’. When you visit a Site, we do not know your name or email address or any information that directly identifies you. We take care to ensure that we do not collect any information that tells us who you are.
When the Sites send to the Platform bid requests (as explained in section What we do above), these bid requests may include some information about you including IP address, unique mobile advertising ID’s (IDFA/GAID), and the latitude and longitude of your device when you view a Site or use an App.
This information (including IP addresses and certain unique mobile advertising ID (IDFA/GAID) may identify a particular computer or device. When we receive such personal data from the Sites we act as independent controller (and never as a joint controller with the Site).
What data is processed
We may also process certain data for and on behalf of our Clients relating to the interaction of the users with the Sites:
The type of browser used by a user, and its settings;
Information about the device operating system;
Information about Cookie IDs
Mobile advertising IDs: IDFA/GAID;
IP addresses from which a device interacts with the Site; IP addresses may be encrypted as required by applicable laws;
Information about the user’s activity on a Site, including time of activity and URL;
Information about the approximate geographic location (city, region, post code) of the device when it accesses a Site derived from the IP address information or GPS data.
The Platform may receive the data from third parties for the use by its Clients in their advertising campaigns on the Platform; in doing so we will always act strictly in accordance with the permissions and restrictions imposed by the third party providing the data.
When our Clients use the Platform, they may also use their data received from other sources (not from Go NET) and other data that identifies the Client that is collected as a result of or generated by the Client’s use of the Platform (Client Data). When Go NET receives the Client Data, in legal terms Go NET processes the Client Data on behalf of the Client (Go NET acts as a data processor, and Go NET is bound by the instructions of the Client when Go NET processes such Client Data. The Client gives instructions to Go NET through the Client’s interface of the Platform, and the Client’s instructions are recorded in the Platform’s logs. It is the Client’s obligation to ensure that all Client Data used on the Platform is collected and used by the Clients in the lawful way. While this notice may also explain how the Clients may use the Client Data when using the Platform, this notice does not apply to the use of the Client Data outside of the Platform.
For the purpose of providing the Service, Go NET collects and processes the data used by the Platform for bidding and delivery (bid requests), the data derived from or generated by the use of the Platform and the data relating to any error, issue or enhancement to the operation or use of the Platform.
In order to provide the Services, we may process the following data:
Mobile Advertising ID
Mobile Advertising ID is a technical ID on a smartphone operating system (for example Android and Apple IOS), that is under the control of the user and owner of that device, and the user can reset this ID at any time.
ID for iOS users - here
• Reset ID for Android users - here and here
Our Platform may automatically exchange pseudonymous IDs with our business partners. These IDs are strictly pseudonymous on both sides.
Our Platform collects cookies from web sites users visit.
How data is processed
Our Platform uses the following technologies to process the data about web-browsers and Advertising ID’s across the Sites and over time:
Cookies. A Cookie is a small text file that is stored in a web-browser by a Site or a Client through the Platform. By saving information in a Cookie, the Sites and Clients can remember preferences or recognize web-browsers from one visit to another or from one website to another. The Clients may also use alternative methods with the functions similar to Cookies in order to identify unique browsers or devices. For example, Apple iOS and Google Play Services for Android provide unique IDs for advertising.
Beacons, pixels, tags, mobile SDKs. Beacons (including clear GIFs or 1×1 pixels) and tags are items included in a webpage that enable the Clients to collect data, serve advertisements, and measure ad effectiveness or prevent fake ad traffic. They do this by allowing communication between a web-browser and a server. A beacon is a small transparent graphic that is placed on a webpage. A tag is a small element of the website code that is run by the web browser. An SDK is an element of the computer code included by the developers in the mobile applications.
We may also receive the data from our Clients or Sites via server-to-server connection, or via secure file transfer.
Cookies enable our Clients to serve targeted advertisements to the users, to evaluate how efficient are their advertisements, and to see the users’ opt-out choices.
How data is used
We use the data processed by the Platform for the purposes of providing the Services to the Clients, in particular
to analyze and report on advertising performance: the data processed is attributed to each certain advertising campaign of the Client, so the Client can monitor the performance of its advertising campaign;
to improve online advertising experience and efficiency: our Platform helps the Clients to decide which advertisement to show or whether to show it and to display the Client’s particular products in response to users’ interest;
to satisfy end users opt-out requests based on the user’s choices stored in Cookies and other IDs;
to detect not ‘real’ traffic, and to prevent fraudulent activities including the use of robots, malware and other suspicious activities.
How data is shared
With the Clients
The Clients have access to the data they collect, upload or use on the Platform, and may have access to the data generated through their use of the Platform.
With Third Parties
If instructed by our Clients, we may also share the data that is controlled by our Clients and which we process on behalf of our Clients with third parties.
We may also disclose the data as follows:
To any applicable law enforcement body, regulatory, government agency, court or other third party where in our opinion the disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
To any other person with your consent to the disclosure.
Legal Basis for Processing
If you are an Internet user from the European Economic Association (EEA), we collect and process your personal data (if any) only where we have your consent or a legitimate interest to do so depending in each case on what data is processed and the context of the processing activities.
For example, we may rely on our legitimate interests when we process Cookie IDs for advertising-related purposes (as explained in How data is used above). Where we process the data on behalf of our Clients when providing Services, we may process your data on the basis of consent obtained by our Clients, or if our Clients have a legitimate interest to use your data on the Platform.
The Cookies sets by the Platform expire 30 days after the last interaction.
Mobile Advertising IDs may be reset by mobile users, and the Platform does not have control of any Mobile Advertising ID. We will see the same Mobile Advertising ID until it is not changed by the mobile user
Advertising ID information (as explained in what data is processed) may be stored up to 13 months (for EEA users), and longer for users from other regions.
International Data Transfers
Users’ data may be transferred to and processed in countries outside of the European Union where data protection laws may be different from the laws of the European Union.
Security and integrity of your data
Go NET has implemented reasonable security measures to protect your data collected, used and processed by the Platform on behalf of our Client.
We use encryption and pseudonymisation.
We store data and our technologies only in Tier 3 or Tier 4 data centres, classified according to official data centre classification.
Please note however that no method of electronic storage or Internet transmission, is entirely secure. We take commercially reasonable efforts to protect your data, but we cannot guarantee its absolute security.
Go NET processes your data in a way that is compatible with and relevant to, the purposes for which it is processed. To the extent necessary for those purposes, Go NET is committed to take reasonable steps to ensure that your data is accurate, complete and reliable for its intended use.
Your privacy rights
You have the following privacy rights:
You can opt out from having a Cookie identifier stored on your device when ads are shown by our Clients from the Platform. Please refer to the next section Your privacy choices.
You can request deletion of your personal information at any time by sending an email to email@example.com
You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information (for EEA Internet users only) at any time by sending an email to firstname.lastname@example.org
You can complain to a local data protection authority for any allegations that your personal data has been used in a way that is not consistent with this notice or applicable legislation.
If you receive our newsletters you have the right to opt-out these at any time by clicking on the ‘unsubscribe’ or ‘opt-out’ link in the e-mails.
Your privacy choices
You can opt-out of receiving the tailored advertisements shown by our Clients from the Platform in your current browser. To opt-out or opt-in please visit the following page: https://dmp.gotechnology.io/dmp/opt-out
The opt-out mechanism works as follows. The Cookie previously set your browser is deleted and replaced with the Platform ‘Opt-out Cookie’ indicating your ‘opt-out’ only.
Your ‘opt-out’ will only opt you out of tailored advertising delivered by our Clients through the Platform in this browser and not other browsers you use.
If you delete Cookies in your browser, this may delete the Platform opt-out Cookie, then you may need to update your opt-out choice for that browser.
opt out of receiving the tailored advertisements on mobile devices,
you are suggested to consult your device settings and instructions
provided by the device manufacturer.
Interactive Advertising Bureau Europe
Go NET adheres to the principles of the IAB Europe EU GDPR Transparency & Consent Framework.
Changes to this notice
If you have any privacy related issues or queries, please contact our Data Protection Officer by e-mail at: email@example.com.