Last updated: January 16, 2020
Interpretation and Definitions
The words of which the initial letter is capitalized have meanings defined under the
The following definitions shall have the same meaning regardless of whether they
appear in singular or in plural.
- You means the individual accessing or using the Service, or the company, or other legal
entity on behalf of which such individual is accessing or using the Service, as
Under GDPR (General Data Protection Regulation), You can be referred to as the Data
Subject or as the User as you are the individual using the Service.
- Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement)
refers to Dynamic Digital Advertising, LLC (DDA), located at 2713 Easton Road, Willow
Grove, PA 19090.
- For the purpose of the GDPR, the Company is the Data Controller.
- Affiliate means an entity that controls, is controlled by or is under common control with
a party, where "control" means ownership of 50% or more of the shares, equity interest
or other securities entitled to vote for election of directors or other managing authority.
- Account means a unique account created for You to access our Service or parts of our
- Service refers to the Website.
- Country refers to: the United States
- Service Provider means any natural or legal person who processes the data on behalf
of the Company. It refers to third-party companies or individuals employed by the
Company to facilitate the Service, to provide the Service on behalf of the Company, to
perform services related to the Service or to assist the Company in analyzing how the
Service is used.
For the purpose of the GDPR, Service Providers are considered Data Processors.
- Third-party Social Media Service refers to any website or any social network website
through which a User can log in or create an account to use the Service.
- Facebook Fan Page is a public profile named Dynamic Digital Advertising specifically
created by the Company on the Facebook social network, accessible from https://www.facebook.com/DDAcorp/
- Personal Data is any information that relates to an identified or identifiable individual.
For the purposes for GDPR, Personal Data means any information relating to You such
as a name, an identification number, location data, online identifier or to one or more
factors specific to the physical, physiological, genetic, mental, economic, cultural or
For the purposes of the CCPA, Personal Data means any information that identifies,
relates to, describes or is capable of being associated with, or could reasonably be
linked, directly or indirectly, with You.
- Cookies are small files that are placed on Your computer, mobile device or any other
device by a website, containing the details of Your browsing history on that website
among its many uses.
- Usage Data refers to data collected automatically, either generated by the use of the
Service or from the Service infrastructure itself (for example, the duration of a page
- Data Controller, for the purposes of the GDPR (General Data Protection Regulation),
refers to the Company as the legal person which alone or jointly with others determines
the purposes and means of the processing of Personal Data.
- Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities,
in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to
develop and implement a mechanism for allowing internet users to control the tracking
of their online activities across websites.
- Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the
Company as the legal entity that collects Consumers' personal information and
determines the purposes and means of the processing of Consumers' personal
information, or on behalf of which such information is collected and that alone, or jointly
with others, determines the purposes and means of the processing of consumers'
personal information, that does business in the State of California.
- Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a
natural person who is a California resident. A resident, as defined in the law, includes
(1) every individual who is in the USA for other than a temporary or transitory purpose,
and (2) every individual who is domiciled in the USA who is outside the USA for a
temporary or transitory purpose.
- Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling,
renting, releasing, disclosing, disseminating, making available, transferring, or otherwise
communicating orally, in writing, or by electronic or other means, a Consumer’s
Personal information to another business or a third party for monetary or other valuable
Collecting and Using Your Personal Data
Types of Data Collected
While using Our Service, We may ask You to provide Us with certain personally
identifiable information that can be used to contact or identify You. Personally
identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address
(e.g. IP address), browser type, browser version, the pages of our Service that You visit,
the time and date of Your visit, the time spent on those pages, unique device identifiers
and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain
information automatically, including, but not limited to, the type of mobile device You
use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile
operating system, the type of mobile Internet browser You use, unique device identifiers
and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our
Service or when You access the Service by or through a mobile device.
Tracking Technologies and Cookies
and store certain information. Tracking technologies used are beacons, tags, and
scripts to collect and track information and to improve and analyze Our Service.
You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is
being sent. However, if You do not accept Cookies, You may not be able to use some
parts of our Service.
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your
personal computer or mobile device when You go offline, while Session Cookies are
deleted as soon as You close your web browser.
We use both session and persistent Cookies for the purposes set out below:
- Necessary/Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through
the Website and to enable You to use some of its features. They help to authenticate
users and prevent fraudulent use of user accounts. Without these Cookies, the services
that You have asked for cannot be provided, and We only use these Cookies to provide
You with those services.
- Cookies Policy/Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
- Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the
Website, such as remembering your login details or language preference. The purpose
of these Cookies is to provide You with a more personal experience and to avoid You
having to re-enter your preferences every time You use the Website.
For more information about the cookies we use and your choices regarding cookies,
please visit our Cookies Policy.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To manage Your Account: to manage Your registration as a user of the Service. The
Personal Data You provide can give You access to different functionalities of the
Service that are available to You as a registered user.
- For the performance of a contract: the development, compliance and undertaking of
the purchase contract for the products, items or services You have purchased or of any
other contract with Us through the Service.
- To contact You: To contact You by email, telephone calls, SMS, or other equivalent
forms of electronic communication, such as a mobile application's push notifications
regarding updates or informative communications related to the functionalities, products
or contracted services, including the security updates, when necessary or reasonable
for their implementation.
- To provide You with news, special offers and general information about other goods,
services and events which we offer that are similar to those that you have already
purchased or inquired about unless You have opted not to receive such information.
- To manage Your requests:To attend and manage Your requests to Us.
We may share your personal information in the following situations:
- With Service Providers: We may share Your personal information with Service
Providers to monitor and analyze the use of our Service, to show advertisements to You
to help support and maintain Our Service, to contact You, to advertise on third-party
websites to You after You visited our Service or for payment processing.
- For Business transfers: We may share or transfer Your personal information in
connection with, or during negotiations of, any merger, sale of Company assets,
financing, or acquisition of all or a portion of our business to another company.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the
extent necessary to comply with our legal obligations (for example, if we are required to
retain your data to comply with applicable laws), resolve disputes, and enforce our legal
agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is
generally retained for a shorter period of time, except when this data is used to
strengthen the security or to improve the functionality of Our Service, or We are legally
obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating
offices and in any other places where the parties involved in the processing are located.
It means that this information may be transferred to — and maintained on — computers
located outside of Your state, province, country or other governmental jurisdiction where
the data protection laws may differ than those from Your jurisdiction.
represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is
Personal Data will take place to an organization or a country unless there are adequate
controls in place including the security of Your data and other personal information.
Disclosure of Your Personal Data
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data
may be transferred. We will provide notice before Your Personal Data is transferred and
Under certain circumstances, the Company may be required to disclose Your Personal
Data if required to do so by law or in response to valid requests by public authorities
(e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action
is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of
transmission over the Internet, or method of electronic storage is 100% secure. While
We strive to use commercially acceptable means to protect Your Personal Data, We
cannot guarantee its absolute security.
Detailed Information on the Processing of Your
Service Providers have access to Your Personal Data only to perform their tasks on Our
behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service providers to monitor and analyze the use of our
- Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports
website traffic. Google uses the data collected to track and monitor the use of our
Service. This data is shared with other Google services. Google may use the collected
data to contextualise and personalise the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google
Analytics by installing the Google Analytics opt-out browser add-on. The add-on
information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy
& Terms web page: https://policies.google.com/privacy?hl=en.
- Email Marketing
We may use Your Personal Data to contact You with newsletters, marketing or
promotional materials and other information that may be of interest to You. You may
opt-out of receiving any, or all, of these communications from Us by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
- Consent: You have given Your consent for processing Personal Data for one or more
- Performance of a contract: Provision of Personal Data is necessary for the
performance of an agreement with You and/or for any pre-contractual obligations
- Legal obligations: Processing Personal Data is necessary for compliance with a legal
obligation to which the Company is subject.
- Vital interests: Processing Personal Data is necessary in order to protect Your vital
interests or of another natural person.
- Public interests: Processing Personal Data is related to a task that is carried out in the
public interest or in the exercise of official authority vested in the Company.
- Legitimate interests: Processing Personal Data is necessary for the purposes of the
legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies
to the processing, and in particular whether the provision of Personal Data is a statutory
or contractual requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to
guarantee You can exercise Your rights.
- Request access to Your Personal Data. The right to access, update or delete the
information We have on You. Whenever made possible, you can access, update or
request deletion of Your Personal Data directly within Your account settings section. If
you are unable to perform these actions yourself, please contact Us to assist You. This
also enables You to receive a copy of the Personal Data We hold about You.
- Request correction of the Personal Data that We hold about You. You have the
right to to have any incomplete or inaccurate information We hold about You corrected.
- Object to processing of Your Personal Data. This right exists where We are relying
on a legitimate interest as the legal basis for Our processing and there is something
about Your particular situation, which makes You want to object to our processing of
Your Personal Data on this ground. You also have the right to object where We are
processing Your Personal Data for direct marketing purposes.
- Request erasure of Your Personal Data. You have the right to ask Us to delete or
remove Personal Data when there is no good reason for Us to continue processing it.
- Request the transfer of Your Personal Data. We will provide to You, or to a third-
party You have chosen, Your Personal Data in a structured, commonly used, machine-
readable format. Please note that this right only applies to automated information which
You initially provided consent for Us to use or where We used the information to
perform a contract with You.
- Withdraw Your consent. You have the right to withdraw Your consent on using your
Personal Data. If You withdraw Your consent, We may not be able to provide You with
access to certain specific functionalities of the Service.
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by
contacting Us. Please note that we may ask You to verify Your identity before
responding to such requests. If You make a request, We will try our best to respond to
You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and
use of Your Personal Data. For more information, if You are in the European Economic
Area (EEA), please contact Your local data protection authority in the EEA.
Facebook Fan Page
Data Controller for the Facebook Fan Page
The Company is the Data Controller of Your Personal Data collected while using the
Service. As operator of the Facebook Fan Page (https://www.facebook.com/DDAcorp/),
the Company and the operator of the social network Facebook are Joint Controllers.
The Company has entered into agreements with Facebook that define the terms for use
of the Facebook Fan Page, among other things. These terms are mostly based on the
Facebook Terms of Service: https://www.facebook.com/terms.php
information about how Facebook manages Personal data or contact Facebook online,
or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park,
CA 94025, United States.
We use the Facebook Insights function in connection with the operation of the
Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized
statistical data about Our users.
For this purpose, Facebook places a Cookie on the device of the user visiting Our
Facebook Fan Page. Each Cookie contains a unique identifier code and remains active
for a period of two years, except when it is deleted before the end of this period.
Facebook receives, records and processes the information stored in the Cookie,
especially when the user visits the Facebook services, services that are provided by
other members of the Facebook Fan Page and services by other companies that use
For more information on the privacy practices of Facebook, please visit Facebook
Your Rights under the CCPA
- The right to notice. You must be properly notified which categories of Personal Data
are being collected and the purposes for which the Personal Data is being used.
- The right to access / the right to request. The CCPA permits You to request and
obtain from the Company information regarding the disclosure of Your Personal Data
that has been collected in the past 12 months by the Company or its subsidiaries to a
third-party for the third party’s direct marketing purposes.
- The right to say no to the sale of Personal Data. You also have the right to ask the
Company not to sell Your Personal Data to third parties. You can submit such a request
by visiting our "Do Not Sell My Personal Information" section or web page.
- The right to know about Your Personal Data. You have the right to request and
obtain from the Company information regarding the disclosure of the following:
- The categories of Personal Data collected
- The sources from which the Personal Data was collected
- The business or commercial purpose for collecting or selling the Personal Data
- Categories of third parties with whom We share Personal Data
- The specific pieces of Personal Data we collected about You
- The right to delete Personal Data. You also have the right to request the deletion of
Your Personal Data that have been collected in the past 12 months.
- The right not to be discriminated against. You have the right not to be discriminated
against for exercising any of Your Consumer's rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or services, including the use of discounts or
other benefits or imposing penalties
- Providing a different level or quality of goods or services to You
- Suggesting that You will receive a different price or rate for goods or services or a
different level or quality of goods or services.
Exercising Your CCPA Data Protection Rights
In order to exercise any of Your rights under the CCPA, and if you are a California
resident, You can email or call us or visit our "Do Not Sell My Personal Information"
section or web page.
The Company will disclose and deliver the required information free of charge within 45
days of receiving Your verifiable request. The time period to provide the required
information may be extended once by an additional 45 days when reasonable
necessary and with prior notice.
Do Not Sell My Personal Information
We do not sell personal information. However, the Service Providers we partner with
(for example, our advertising partners) may use technology on the Service that "sells"
personal information as defined by the CCPA law.
If you wish to opt out of the use of your personal information for interest-based
advertising purposes and these potential sales as defined under CCPA law, you may do
so by following the instructions below.
Please note that any opt out is specific to the browser You use. You may need to opt
out on every browser that you use.
You can opt out of receiving ads that are personalized as served by our Service
Providers by following our instructions presented on the Service:
- From Our "Cookie Consent" notice banner
- Or from Our "CCPA Opt-out" notice banner
- Or from Our "Do Not Sell My Personal Information" notice banner
- Or from Our "Do Not Sell My Personal Information" link
The opt out will place a cookie on Your computer that is unique to the browser You use
to opt out. If you change browsers or delete the cookies saved by your browser, you will
need to opt out again.
Your mobile device may give you the ability to opt out of the use of information about
the apps you use in order to serve you ads that are targeted to your interests:
- "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
- "Limit Ad Tracking" on iOS devices
You can also stop the collection of location information from Your mobile device by
changing the preferences on your mobile device.
"Do Not Track" Policy as Required by
California Online Privacy Protection Act
Our Service does not respond to Do Not Track signals.
However, some third-party websites do keep track of Your browsing activities. If You are
visiting such websites, You can set Your preferences in Your web browser to inform
websites that You do not want to be tracked. You can enable or disable DNT by visiting
the preferences or settings page of Your web browser.
Our Service does not address anyone under the age of 13. We do not knowingly collect
personally identifiable information from anyone under the age of 13. If You are a parent
or guardian and You are aware that Your child has provided Us with Personal Data,
please contact Us. If We become aware that We have collected Personal Data from
anyone under the age of 13 without verification of parental consent, We take steps to
remove that information from Our servers.
We also may limit how We collect, use, and store some of the information of Users
between 13 and 18 years old. In some cases, this means We will be unable to provide
certain functionality of the Service to these users.
If We need to rely on consent as a legal basis for processing Your information and Your
country requires consent from a parent, We may require Your parent's consent before
We collect and use that information.
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click
on a third party link, You will be directed to that third party's site. We strongly advise
We have no control over and assume no responsibility for the content, privacy policies
or practices of any third party sites or services.
We will let You know via a prominent notice on Our Service, prior to the change