Privacy policy

23-05-2018 Filwise S.L. has created this Privacy Policy for their partners who wish to spread advertisements through the Filwise network.
This Privacy Policy is provided to help you understand how Filwise handles User Data on behalf of advertisers and to outline to protection of this Data.

European Union’s General Data Protection Regulation (GDPR, Directive 95/46/EC) introduces Controllers (here: Filwise) and Processors (here: Publishers/Affiliates). The Regulation is designed to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework where commercial organisations can legally operate. Considering this updated Data Protection Regulation, we have renewed our Privacy Policy.

Definitions:

Filwise S.L. – owner of the network

Publisher or Affiliate – Person, entity or company with access to visitors in a database or through a web portal

Advertiser – Advertisement partners of Filwise S.L.

User – Consumer or business to which the publisher shows advertisements

Advertisements – Advertisement campaigns made available by Filwise

Conversion – Lead, sale, action or click generated by publisher

Data Controller – entity that carries out significant judgement and decision-making in relation to data.

Data Processor – entity that focuses on the more technical side of an operation, handling data. Processes personal data on behalf of the controller.

Data Subject – subject, end-user, physical person that has given permission regarding data handling, storage and erasure.

Disapproved conversion – Leads, sale, action or click considered not valid by the Filwise advertiser

Services performed by Publisher
Publisher will display the Advertisement and perform lead and/or sale generation services

Services performed by Filwise
Filwise will create, organize and offer specific advertisement campaigns to be used by the publisher

Who is Filwise?
Filwise S.L. (“Filwise”) is a global ad network serving both advertisers and publishers from all corners of the world. We connect online Advertisers and Publishers/Affiliates for online marketing purposes. www.filwise.com is the Website used by Filwise for displaying company information and http://partners.filwise.com for our interactive Tracking solution Platform ( Scaleo Affiliate Tracking software).

What is our goal?
Filwise aims to promote advertising together with their partners, in a legally compliant, mutually beneficial and user-friendly transparent way.

Why do we process data?
The Data we process is for the sole purpose of digital advertising. For the tracking of the  advertising results, we use Scaleo Affiliate Tracking software. Partners (Publishers/Affiliates) can also overview their statistics in this Tracking Platform. 
Furthermore, Publishers/Affiliates will display the Advertisement and perform lead and/or sale generation services.

Rights of Data Subjects
GDPR presents changed and improved rights for Data Subject as the new standard. Those rights include:
The right to access – individuals have the right to request access to their personal data and to ask how their data is used by the company after it has been gathered.

The right to be forgotten – Subjects have the right to withdraw their consent. Opt-out can be done by clicking the sign out link in email campaigns.

The right to data portability – Individuals have a right to transfer their data from one service provider to another.

The right to be informed – Subject have to opt in for their data to be gathered, and consent must be freely given rather than implied.

The right to have information corrected – The right to data updated if it is out of date, incomplete or incorrect.

The right to restrict processing – Individuals can request that their data is not used for processing. Their record can remain in place, but not be used.

The right to object – to stop the processing of their data for direct marketing.

The right to be notified – If there has been a data breach which compromises an individual’s personal data, the individual has a right to be informed within 72 hours of first having become aware of the breach.

Data collection via Affiliate Tracking software
Via our Tracking software solution, we collect the following types of information from Users to help clients optimize and measure their Affiliate marketing business:
– Ad Identifiers
– IP address
– Cookies
– Pixel Tags
– Geo Location Data derived from IP address and/or wifi networks.
– Device Type and/or Brand/Model used
– OS and/or Browser used

How is Data Subject data collected?
On the Tracking Platform, Pixel or Server Postback tracking is used to collect information about Data Subjects/User.
Pixel tracking stores a session identifier in a User’s cookie on click.
In postback tracking, Scaleo directly create and send a unique identifier to the advertiser on click.
If a conversion happens, Advertiser then communicates back this unique identifier to Scaleo for validation purposes.

Duration of Data Usage
Personal Data will be only used for the purpose intended and described during the opt-in process. Duration starts from time of freely consented opt-in and ends until above described rights, right to be forgotten, right to restrict processing, right to object or right to portability, go into effect. Withdrawal can be done via the Opt-out link, located in the email campaign.

The Usage of Cookies
Our Website, www.filwise.com, contains cookies. This Site sends your browser a cookie – a tiny piece of data stored on your PC’s hard drive. Storage of the cookie is done to improve your reading of and your search possibilities on our Site.

If you do not want to accept that your computer receives and stores cookies, you can alter your security settings on your web browser (Internet Explorer, Google Chrome, Safari etc.). However, note that certain parts of our Site may only be used fully if your browser allows cookies. Reading experience and the functionality of our Site may be negatively impacted by removing and not allowing cookies.

Consent
The acceptance of our Terms and Conditions is required before being able to enter our Tracking Solution Platform (partner.filwise.com). By visiting our website (www.filwise.com), you agree with our Terms and Conditions and hereby give consent to our updated Privacy Policy, taking effect starting 25th of May 2018.

Changes to this Privacy Policy
Filwise may update this Privacy Policy from time to time. Any changes, additions and removals will be published on this page.

Contact Information
In case there are any questions or doubts regarding this Privacy Policy, please feel free to contact us at privacy@filwise.com