Privacy Policy

PORTUMA PRIVACY POLICY

Last updated version: December 08, 2021

In order to ensure transparency and give you more control over your personal data, this privacy policy (“Privacy Policy”) governs how we, Portuma Software Technology Joint Stack Company. and its affiliates (together, “Portuma” “we”, “our” or “us”) use, collect and store personal data we collect or receive from or about you (“you”) such as in the following use cases:

  1. When you browse or visit our website, www.portuma.com(“Website”)
  2. When you make use of, or interact with, our Website
    1. When you subscribe to our newsletter
    2. When we process your job application
    3. When you contact us (e.g. customer support, need help, get in touch, and submit a request).
  3. When you are a Publisher and you create an account, log in and make use of the dashboard environment, market place and/or any other software that we provide (“Services”) for its intended use (e.g., advertising and the execution of empowered marketing campaigns).
  4. When the Portuma SDK is initiated by the Publisher's game on a User device
  5. When you attend a marketing events and provide us with Personal Data and/or exchange business cards with us
  6. When we use the Personal Data of our service providers and suppliers
  7. When we use the Personal Data of the Advertisers
  8. When we use the Personal Data of the Publisher and Partner
  9. When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)
  10. Any in-person interaction with you.
Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal Data” or “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.

Important note:

Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of Contents:

  1. Introduction
  2. What Information we Collect, Why we Collect it, and How it is Used
  3. Period of Storage of Collected Personal Data
  4. How we Protect your Personal Data
  5. How we Share your Personal Data
  6. Additional Information regarding Transfers of Personal Data
  7. Your Privacy Rights; How to Delete your Account
  8. Use by Children
  9. Interaction with Third Party Products
  10. Log files
  11. Specific Provisions Applicable Under California Privacy Law
  12. Contact us

1. INTRODUCTION

Portuma offers specialized and innovative solutions and concepts for modern advertising and the execution of empowered marketing campaigns (the “Services”). Ad creative files that are parsed, rendered and displayed to Users in places defined by the publisher, such as, in a game or app (the “Ad” or “Advertisement”). For purposes of clarity, the publisher is an entity or individuals that develop computer games (the “Publisher”, “Customer”).

Portuma´s partners are companies that provide advertisements, demand side platforms, advertising networks, or other advertising demand sources that bid on ad inventory through the Portuma ´s advertising exchange and serve ads, and those partners will assist Portuma to provide a monetization service and other connected Services, Also, through our services, we allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, identifiers, page(s) visited, location, time of day) (the “Partner” or “Advertisers”).

Portuma displays contextual Ads, behavioral Ads and safe-mode Ads. The types of Ads that the User will be allowed to receive and the types of Personal Data that can be used as part of the advertising and reporting processes are decided by the Publisher using the API provided by the Portuma SDK and the settings set by the Publisher in the Portuma dashboard for Publishers. If you are an individual, receiving Ads as a result of our relationship with Customer (the "User(s)"), please note that the Customer is the responsible party for obtaining the required consents and complying with any applicable laws or regulations.

When you interact with our website, we serve as the data controller for the purpose of GDPR. Because we do not yet hit the applicable thresholds, CCPA does not apply to our operations on our website. However, we are happy to offer Non-EU and California Residents rights as set forth in Section 7.2 below.

When we process your information as part of our relationship with our Customers, unless otherwise stated, we serve as the data processor (for the purposes of GDPR) and as the service provider (for the purposes of CCPA). You should contact the publisher in connection with any data subject rights or consumer rights to which you may be entitled under data protection laws and we will work with the Customers to respond to them.

2. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Data we collect
Why is the Personal Data collected and for what purposes?
Legal basis (GDPR only, if applicable)
Consequences of not providing the Personal Data

When you browse or visit our Website

We automatically collect: Internet and other electronic network information, such as cookies, analytic tools and log files
  • For the Website to function properly
  • To analyze and improve the Website based on your usage of it.
  • For debugging purposes and to resolve technical problems
  • To improve user experience
  • To engage in internet-based advertising
Consent
Legitimate interest (e.g., to improve your user experience)
Cannot collect and store the information.
Cannot improve your user experience.
Certain Website features may not be available
Cannot make re-targeting
When you make use of, or interact with, our Website
When you subscribe to our newsletter

We collect from you: Personal identifiers, including:
  • Email address
  • Full name
  • To add you to our mailing list and keep you updated of new services, features and functionalities as well as updates about Portuma
  • To send you marketing communications
  • To track your interactions with the email (email opens)

Consent
Cannot add you to our mailing list and keep you updated
Cannot send you marketing communications
When you contact us (e.g. customer support, help, get in touch, submit a request)

We collect from you: Personal identifiers and internet and other electronic network information, including:
  • Full name
  • Email address
  • Title
  • Company name
  • Reason for inquiry
  • Comments
  • IP address
  • Geolocation
  • Usage pattern
  • Any other information you decide to provide/supply us with
  • To process and answer questions
  • To provide support (e.g., to solve problems, bugs or issues) and handle your complaints and/or feedback
  • To customize your experience
NOTE: We do ask that you do not provide us with any personal information (other than the information required in the form, which we need to respond to your queries) for such purposes.Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Legitimate interest (e.g., respond to a query sent by you)
Cannot assist you and respond your query
Cannot provide support and handle your complaints and/or feedback
Cannot customize your experience
We collect from you: Personal identifiers, including:
  • Full name
  • Email address
  • To send you marketing communications
Consent
Cannot send you marketing communications
When you are a Publisher and you create an account, log in and make use of the Portuma Services for its intended use

We collect from you: Personal identifiers and internet and other electronic network information, including:
  • Admin full name
  • Admin email address
  • Admin phone number
  • Full name, email, phone number and permission settings for regular users of Portuma´s dashboard
  • Company name
  • IP address
  • Geolocation
  • Usage pattern
  • Any other information you decide to provide/supply us with
  • To allow you to create an account and log in
  • To allow you to create regular users
  • To perform/execute the agreement
  • To grant you access to the Services
  • To allow you to make use of our Services
For avoidance of doubt, all of the purposes stated before for regular users, also apply to the Admin users in addition to the mentioned hereby.
Processing is necessary for the performance of a contract to which our customer is a party or in order to take steps at the request of the data subject prior to entering into a contract
Legitimate interest (e.g. to allow you to create an account)
Cannot allow you to create an account and log in
Cannot allow you to create regular users
Cannot perform/execute the agreement
Cannot grant you access to the Services
Cannot allow you to make use of our Services
We collect from you: Personal identifiers, internet and other electronic network information, and inferences, including:
  • Full Name of the user
  • Email address of the user
  • Phone number of the user
  • IP address
  • Geolocation based on IP address
  • Usage pattern
  • Browser user agent -
  • Campaign data
  • advertising activity events - Event analytics data
  • Financial key performance indicators
  • Log information / usage pattern
  • Any other information you decide to provide/supply us with
  • To provide you the Services
  • To fulfill your requests for our services and for related activities (e.g., account management, support and to provide other Services related to your relationship with Portuma)
  • To allow you to manage your ad placement inventory, to review reports/analytics, list new apps, update ad placement configuration, create campaigns for internal promotions, manage black/white lists, review ads shown to users, and setting bid floor prices
  • To serve and optimize advertisements
  • To generate advertisements tracking reports
  • To analyze performance, improve your user experience and resolve technical problems
  • To improve the Service
  • To calculate and pay revenue share according to your contract with us
  • To communicate with you (service-related communications)
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Legitimate interest (e.g., to provide you with the services)
Cannot provide you the Services
Cannot fulfill your requests for our services and for related activities
Cannot allow you to manage your ad placement inventory, to review reports/analytics, list new apps, update ad placement configuration, create campaigns for internal promotions, manage black/white lists, review ads shown to users, and setting bid floor prices.
Cannot serve and optimize advertisements
Cannot generate advertisements tracking reports
Cannot analyze performance, improve your user experience and resolve technical problems
Cannot improve the Service
Cannot calculate payment and send it
Cannot communicate with you (service-related communications)
We collect from you: Personal identifiers, including:
  • Full name
  • Email address
  • To send you marketing communications (including, surveys)
Consent
Cannot send you marketing communication
When the Portuma SDK is initiated by the Publisher's game on a User device

We automatically collect: Internet and other electronic network information, including:
  • IP address
  • User agent
  • Estimated location data from IP
  • To understand which type of Ads we should display to the User (e.g., Consent under GDPR, COPPA) once activated Portuma's services by the Publisher

Important note:

In some cases we chop the IP address to store it in a manner not identifiable and we do not share it with the Advertisers (e.g., GDPR user that did not provide consent to the Customer, or a COPPA User)
Compliance with a legal obligation (e.g. to understand which type of Ad we will need to display you).
Legitimate interest (e.g., to understand which type of Ads we should display to you)
Cannot understand which type of Ads we should display you, per Publisher´s request
Cannot chop the IP address to store it in a manner not identifiable.

When the Portuma SDK is initiated by the Publisher's game on a User device

BEHAVIORAL ADVERTISEMENT

We automatically collect: Internet and other electronic network activity information, including

  • IP address
  • Advertising identifier (e.g., IDFA, Google Ad ID) or other device identifier
  • Limit ad tracking status
  • The user's estimated location data estimated by IP address that includes: country, city, zip, metro code, lat, lon
  • The detected language of the user's device
  • Basic device information (desktop/mobile, manufacturer, model, operating system, operating system version, user agent, lmt flag, location type, screen width and height in pixels)
  • Connection type, ISP and carrier name
  • The device precise GPS data of latitude and longitude (in case permitted by the publisher)
  • Randomly generated Portuma user ID per game/app
  • Analytics data (session start, session end, click and etc)
  • Any other Personal Data that the Publisher decided to share In most cases we receive this information automatically through our SDK. In some cases we receive this information from management platforms.
  • To serve the User personalized Ads
  • To store and/or access information on a device
  • To select and serve personalized ads when the User makes use of the Publisher´s game or application
  • Measure ad performance, monitor, analyze and optimize the User's use of our Services, including analyzing seasonal and annual usage trends, and providing the User and our business partners with new functionality and features
  • To apply market research to generate audience insights
  • To match and combine offline data sources
  • To develop, update, fix and improve our products and Services
NOTE: If you are a User (as defined above), note that in most cases we act as a data processor and, therefore, our Customer is the data controller in relation to these activities. You should contact the Customer for any privacyrelated questions

In limited contexts where we are/act as a separate data controller
  • In order for Portuma to process your Personal Data in the context of our Services, you normally will have already consented to data processing (please note that when Portuma does not have a relationship directly with you, the Publisher will ask you to consent and complying with any applicable laws or regulations for Portuma to collect your information and serve you with the Ads).
  • Performance of a contract with the Publisher
  • Legitimate interest (processing per publishers’ instructions, performance of the relevant instruction or contract)
Cannot serve the User personalized Ads when the User makes use of the Publisher´s game or application Cannot store and/or access information on a device
Cannot select and serve personalized ads when the User makes use of the Publisher´s game or application
Cannot measure ad performance, monitor, analyze and optimize the User's use of our Services, including analyzing
seasonal and annual usage trends, and providing the User and our business partners with new functionality and features
Cannot apply market research to generate audience insights
Cannot match and combine offline data sources with the Personal Data that Portuma receives from the User
Cannot develop, update, fix and improve our products and Services

CONTEXTUAL ADVERTISEMENT

We automatically collect: Internet and other electronic network activity information, including:

  • IP address
  • Limit ad tracking status
  • The user's estimated location data estimated by the IP address that includes: country, city, zip, metro code, latitude, longitude
  • The detected language of the user's device
  • Basic device information (desktop/mobile, manufacturer, model, operating system, operating system version, user agent, limited tracking flag, location type, screen width and height in pixels)
  • Connection type, ISP and carrier name
  • Randomly generated Portuma user ID per game/app
  • Analytics data (session start, session end, click and etc…)
  • Any other Personal Data that the Publisher decided to share with us
  • To serve the User contextual when the User makes use of the Publisher´s game or application
  • To measure ad performance, monitor, analyze and optimize the User's use of our Services, including analyzing seasonal and annual usage trends, and providing the User and our business partners with new functionality and features
  • To apply market research to generate audience insights
  • To match and combine offline data sources
  • To develop, update, fix and improve our products and Service
NOTE: If you are a User (as defined above), note that in most cases we act as a data processor and, therefore, our Customer is the data controller in relation to these activities. You should contact the Customer for any privacy- related questions.

In limited contexts where we are/act as a separate data controller:
  • In order for Portuma to process your Personal Data in the context of our Services, you normally will have already consented to data processing (please note that when Portuma does not have a relationship directly with you, the Publisher will ask you to consent and complying with any applicable laws or regulations for Portuma to collect your information and serve you with the Ads).
  • Performance of a contract with the Publisher
  • Legitimate interest (processing per publishers’ instructions, performance of the relevant instruction or contract)
Cannot serve the User contextual Ads when the User makes use of the Publisher´s game or application
Cannot measure ad performance, monitor, analyze and optimize the User's use of our Services, including analyzing seasonal and annual usage trends, and providing the User and our business partners with new functionality and features
Cannot apply market research to generate audience insights
Cannot match and combine offline data sources with the Personal Data that Portuma receives from the User
Cannot develop, update, fix and improve our products and Service

SAFE-MODE

We automatically collect: Internet and other electronic network activity information, including:

  • IP address with the lowest 8 bits removed for IPv4 and lowest 32 bits removed for IPv6
  • Limit ad tracking status
  • The user's estimated location data estimated by the truncated IP address that includes: country, city
  • The detected language of the user's device
  • Basic device information (desktop/mobile, manufacturer, model, operating system, operating system version, user agent, limited tracking flag, location type, screen width and height in pixels)
  • Connection type, ISP and carrier name
  • Randomly generated Portuma user ID per game/app
  • Analytics data (e.g., session start, session end, click)
  • To serve the User contextual Ads when the User makes use of the Publisher´s game or application
  • To measure ad performance, monitor, analyze and optimize the User's use of our Services, including analyzing seasonal and annual usage trends, and providing the User and our business partners with new functionality and features
  • To apply market research to generate audience insights
  • To match and combine offline data sources
  • To develop, update, fix and improve our products and Services
N/A
Cannot serve the User advertisement (contextual Ads – without having access to Personal Data) when the User makes use of the Publisher´s game or application
Cannot measure ad performance, monitor, analyze and optimize the User's use of our Services, including analyzing seasonal and annual usage trends, and providing the User and our business partners with new functionality and features
Cannot match and combine offline data sources
Cannot develop, update, fix and improve our products and Services
When you attend a marketing event and provide us with Personal Data and/or exchange business cards with us

We collect from you: Personal identifiers, including:
  • Full name
  • Email address
  • Company name
  • Job position
  • Phone numbers
  • Any other data you decide to provide/supply us with
  • To establish a business connection
  • To send marketing communications
Consent
Legitimate interest (e.g. send you more information about Portuma)
Cannot establish a business connection
Cannot send marketing communications
When we use the Personal Data of our service providers and suppliers

  • Full name
  • Email address
  • Company name
  • Job position
  • Phone numbers
  • Any other data you decide to provide/supply us with
  • To contact our service providers
  • To perform the applicable agreement
  • To communicate with you (e.g., service-related communications)
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Legitimate interest (e.g. perform the contract, send contract-related communications)
Cannot communicate with you
Cannot perform the applicable agreement
Personal identifiers, including:
  • Full name
  • Email address
  • To send you marketing communications, updates, upgrades, surveys and other relevant information
Consent
Cannot send you marketing communications
When we use the Personal Data of the Advertiser

We collect from them: Personal identifiers and customer records information, including:
  • Full name
  • Email address
  • Company name company incorporation number and other details about the company
  • Job position
  • Phone numbers
  • Payment information (i.e. bank account number and/or credit card details)
  • Any other data you decide to provide/supply us with
  • To contact our Advertiser
  • To perform the applicable agreemen:
Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Legitimate interest (e.g. perform the contract, send contract-related communications)
Cannot communicate with you
Cannot perform the applicable agreement
Personal identifiers, including:
  • Full name
  • Email address
  • To send you marketing communications, updates, upgrades, surveys and other relevant information
Consent
Cannot send you marketing communications
When we use the Personal Data of the Publisher and Partner

We collect from them: Personal identifiers, including:
  • Full name
  • Email address
  • Company name
  • Company details, including address
  • Job position
  • Phone number
  • Company incorporation number
  • Billing information
  • Any other data you decide to provide/supply us with
  • To provide our products and services
  • To perform the applicable agreement
  • To communicate with the Publisher
  • To calculate the billing activities
Processing is necessary for the performance of a contract to which our customer is a party.
Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.).
Legitimate interest (e.g. send you contract-related communications)
Cannot provide the services and/or our products
Cannot perform the agreement
Cannot communicate with you
Cannot calculate the billing activities
Personal identifiers, including:
  • Full name
  • Email address
  • To send you marketing communications (including surveys)
Consent
Cannot send you marketing communications
When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

Personal identifiers, including:
  • Full name
  • Social media handle
  • Any other data you decide to provide/supply
  • To reply and/or respond to your request or question
  • To establish a business connection and/or to send you more information about Portuma (when requested by you)
Consent
Legitimate interest (e.g. send you more information about Portuma)
Cannot reply or respond to your request


Finally, please note that some of the abovementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Our legal basis in these cases is for compliance with a legal obligation (e.g., fraud detection, security and/or debug). Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our Services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

3. PERIOD OF STORAGE OF COLLECTED PERSONAL DATA

3.1. Personal Data: Your Personal Data will be stored until we: (i) no longer need the information and proactively delete it; or (ii) you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.

3.2. Retention of your Personal Data: In addition to the retention periods mentioned in this section, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

4. HOW WE PROTECT YOUR PERSONAL DATA

We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, no security measure of modality of data transmission is 100% secure. . As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

5. HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described in Section 1, we may share your Personal Data as follows:

5.1. To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
5.2. If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.
5.3. Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality); and
5.4. Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.
5.5. Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
5.6. To the extent necessary to third parties, such as legal advisors, law enforcement, or governmental agencies in order to protect our legal interests and other rights, protect against fraud or other illegal activities, prevent harm, for risk management purposes, or to comply with a legal obligation.
5.7. With service providers that assist us in providing the Website and the Services.
5.8. For a business purpose. In the preceding twelve (12) months, Portuma has disclosed your Personal Data for a business purpose with the following categories of third parties:
5.8.1. We have disclosed your internet or other electronic network information collected by cookies to our IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair Website errors.
5.8.2. We have disclosed your internet or other electronic network information collected by cookies to our IT support to update, improve, and maintain the Website.
5.8.3. We have disclosed your internet and other electronic network information, personal identifiers, and customer records information with service providers that perform services on our behalf. These service providers include our website provider, communications vendors, CRM provider
5.9. In the preceding twelve (12) months, Portuma has shared your internet or other electronic network activity information collected via cookies and other tracking technologies with data analytics providers and advertising partners. To opt-out of this sharing, visit our cookie management platform using the cookie settings button in the Portuma website footer.
5.10. If you want to receive the list of the current recipients of your Personal Data, please make your request by contacting us to hello@portuma.com

6. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

6.1. Storage: AWS with servers located in the US, and Google with servers located in the US. 6.2. Internal transfers: Transfers within the Portuma group will be covered by an internal processing agreement entered into by members of the Portuma group (an intra-group agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to. 6.3. External transfers: Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your Personal Data. When Portuma engages in such transfers of personal information, it relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR) (for example, when we access from Israel), or ii) Standard Contractual Clauses issued by the European Commission. Portuma also continually monitors the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR.

7. YOUR PRIVACY RIGHTS; HOW TO DELETE YOUR ACCOUNT

7.1. EU Residents: If our processing of your Personal Data is subject to the General Data Protection Regulation (GDPR) , you are entitled to the following rights (which may be subject to certain exemptions or derogations):

  • You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
  • You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
  • You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;
  • You have the right to object, to or to request restriction, of the processing;
  • You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
  • You have the right to object to profiling;
  • You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
  • You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
  • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution
You can exercise your rights by contacting us at privacy@portuma.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

7.2. Non-EU and California Residents: Even though we do not meet the applicable thresholds for the California Consumer Privacy Act (CCPA), we are happy to offer Non-EU and California Residents to the following rights:
  • You have the right to request what Personal Data we have collected, used, disclosed, and sold about you within the preceding twelve months. You may only make a request for access twice within a twelve-month period.
  • You have the right to request the deletion of your Personal Data that we collect or maintain, subject to certain exceptions.
  • You have the right to opt-out of the sale of your Personal Data to third parties. Portuma does not have actual knowledge that it sells Personal Data of minors under the age of sixteen (16) years.
  • You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, or opt-out under the CCPA.
7.2.1. You can do this email us at privacy@portuma.com. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information.
7.2.2. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your Personal Data. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.
7.3. Nevada Residents: If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your Personal Data.
7.4. Deleting your account: Should you ever decide to delete your account, you may do so by emailing: privacy@portuma.com. If you terminate your account, any association between your account and Personal Data we store will no longer be accessible through your account

8. USE BY CHILDREN

8.1. Sensitive personal information: We ask that you do not send us, and do not share any sensitive Personal Information (for example, government-issued IDs, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, genetic, or biometric data, criminal background or trade union membership).
8.2. Website: We do not offer our products or services specifically intended for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@portuma.com.
8.3. Services: The Ads could be displayed to children protected by specific laws, including, COPPA and GDPR. Our services are not directed to minors and we and/or our Publisher do not promote or market its services to minors, except in very limited circumstances, in such cases with the applicable parental permission and with technological services that safeguard such collection in limited circumstances. For more, information please refer to Section 1 ("safe-mode (no personal data is involved)"). When Portuma controls the Personal Data of such children, Portuma delegates Portuma's obligations regarding consent to the Publisher. For any privacy/related question and or to obtain more information you should contact the Publisher. If you believe that we might have any such information, please contact us at privacy@portuma.com.

9. INTERACTION WITH THIRD PARTY PRODUCTS AND PARTNERS

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

10. LOG FILES

We use log files. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

11. DO NOT TRACK

We do not support Do Not Track (DNT). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

12. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at: privacy@portuma.com TO THE MAXIMUM EXTENT PERMIITED BY LAW, YOU UNDERSTAND AND AGREE THAT PORTUMA’S LIABILITY FROM ANY DISPUTE OVER PRIVACY OR THIS PRIVACY POLICY WILL BE LIMITED AS SET FORTH IN THE TERMS AND CONDITIONS OF OUR APPLICABLE WEBSITE TERMS AND CONDITIONS

WE ARE ALWAYS HERE TO HELP YOU.

ABOUT US


We are an innovative in-game advertising platform which was founded in 2021. Our mission is to bring together advertisers and game developers on the same platform.


LOCAL ADDRESS


  PHONE: +90 (212) 212 12 42


  EMAIL: hello@portuma.com


  ADDRESS: Huzur Mh. Azerbaycan Cad. B Blok Kat:10 Ofis: 157-160 Sarıyer / İstanbul