Privacy Policy
Last updated: March 28, 2022
1. Who we are
1.1. We are MGL MY.COM (CYPRUS) LIMITED located at 28 Oktovriou, 365 VASHIOTIS SEAFRONT, office 402 Neapoli, 3107, Limassol, Cyprus.
1.2. This Privacy Policy sets out how we collect and use information, that we obtain through our website, target.my.com, as well as through our advertising platform service, which serve ads either on our website or on third-party websites or mobile apps (“Services”) and the choices available to you in connection with our use of this information (the Privacy Policy).
The use we make of the Information, including Personal Information, collected through the website and Services may vary depending on whether you are (i) a customer ("Customer"), i.e., a publisher, advertiser, partner, with whom we have a contractual relationship; (ii) a visitor of our Customers' websites who interacts with our Services ("User"); or (iii) or a visitor of our own website ("Site Visitor"), which may include Customers as well as prospective customers.
This Privacy Policy should be read alongside, and in addition to, our Terms and conditions (accessible online at /help/advertisers/offer-juridical-advert/en, /help/advertisers/rulesjuridicaladvert/en, /help/agency/offer-juridical-agency/en, /help/agency/rulesagency/en, /partners/doc/terms-for-nonresidents, /partners/doc/offer-for-nonresidents) (Terms) and our Cookie Policy. In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail.
By registering and / or logging into the Service using VK Connect, the User agrees to the Rules for protecting information about users of VK Connect as a tool of the VK Ecosystem, which are posted at https://connect.vk.com/privacy.
2. This Privacy Policy
2.1. By making available the Services we, acting reasonably and in good faith, believe that you:
(a) have all necessary rights to register on and use the Services;
(b) provide true information about yourself to the extent necessary for use of the Services;
(c) are aware of and accept this Privacy Policy.
2.2. We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you.
3. Information we collect about you
3.1. In order provide you with access to the use of the Services, to improve, develop and implement new features to our Services, to enhance the available Services functionality and in compliance with applicable laws, we will collect, store, aggregate, organise, extract, compare, use, and supplement your data. We will also receive and pass this data, and our automatically processed analyses of this data to our affiliates and partners as set out in the table below and section 4 of this Privacy Policy.
3.2. We set out in more detail the information we collect when you use our Services, why we collect and process it and the legal bases below.
1. Who we are
1.1. We are MGL MY.COM (CYPRUS) LIMITED located at 28 Oktovriou, 365 VASHIOTIS SEAFRONT, office 402 Neapoli, 3107, Limassol, Cyprus.
1.2. This Privacy Policy sets out how we collect and use information, that we obtain through our website, target.my.com, as well as through our advertising platform service, which serve ads either on our website or on third-party websites or mobile apps (“Services”) and the choices available to you in connection with our use of this information (the Privacy Policy).
The use we make of the Information, including Personal Information, collected through the website and Services may vary depending on whether you are (i) a customer ("Customer"), i.e., a publisher, advertiser, partner, with whom we have a contractual relationship; (ii) a visitor of our Customers' websites who interacts with our Services ("User"); or (iii) or a visitor of our own website ("Site Visitor"), which may include Customers as well as prospective customers.
This Privacy Policy should be read alongside, and in addition to, our Terms and conditions (accessible online at /help/advertisers/offer-juridical-advert/en, /help/advertisers/rulesjuridicaladvert/en, /help/agency/offer-juridical-agency/en, /help/agency/rulesagency/en, /partners/doc/terms-for-nonresidents, /partners/doc/offer-for-nonresidents) (Terms) and our Cookie Policy. In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail.
By registering and / or logging into the Service using VK Connect, the User agrees to the Rules for protecting information about users of VK Connect as a tool of the VK Ecosystem, which are posted at https://connect.vk.com/privacy.
2. This Privacy Policy
2.1. By making available the Services we, acting reasonably and in good faith, believe that you:
(a) have all necessary rights to register on and use the Services;
(b) provide true information about yourself to the extent necessary for use of the Services;
(c) are aware of and accept this Privacy Policy.
2.2. We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you.
3. Information we collect about you
3.1. In order provide you with access to the use of the Services, to improve, develop and implement new features to our Services, to enhance the available Services functionality and in compliance with applicable laws, we will collect, store, aggregate, organise, extract, compare, use, and supplement your data. We will also receive and pass this data, and our automatically processed analyses of this data to our affiliates and partners as set out in the table below and section 4 of this Privacy Policy.
3.2. We set out in more detail the information we collect when you use our Services, why we collect and process it and the legal bases below.
3.3. Our legitimate interests include (1) maintaining and administrating the Services; (2) providing the Services to you; (3) improving the content of the Services; (4) processing of the information that you choose to provide to us via email or submitting on our website or Service; (5) ensuring your account is adequately protected; and (6) compliance with any contractual, legal or regulatory obligations under any applicable law.
3.4. As part of maintaining and administrating the Services we may use the information to analyse user activity and ensure that rules and terms of use for the Services are not violated.
3.5. Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defence or exercise of legal claims.
3.6. You may withdraw your consent the collection of location data and your apps by amending your privacy settings of your mobile device.
3.7. Please note, if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and your sexual orientation) you should take care not to send this information to us.
3.8. Please note, if you withdraw your consent to processing or you do not provide the data that we require in order to maintain and administer the Services, you may not be able to access or register or proper use the Services.
3.9. If we intend to further process your data for any other purpose to those set out in this Privacy Policy, we shall provide you with details of this further purpose before we commence processing.
4. Data sharing
4.1. We may share your data with My.com B.V. and our affiliates. Sometimes we may also need to share your data with a third party in order to provide our Services to you or to administer the Services, for example if you choose to share your data across other social media platforms.
4.2. Our ad management and recommendation system is designed so that your information will not be shared directly with our third party advertisers. An advertiser or maker of a recommendation can only choose to target advertisements to groups of users falling within criteria such as age, gender or location, or to target communities according to type, e.g. cars or fashion. If you fall within one of the target groups you will receive an advert or recommendation.
4.3. An advertiser or maker of recommendations may also choose to upload a list of emails, phone numbers and identities to our systems so that we (but not the adviser or maker of recommendations) can check for user matches. They will see the number of matches but not the matches themselves.
4.4. We may disclose non personally identifiable User Information to Customers. For example, we may provide publishers with information about the viewing and click-through patterns of postings of the content they publish and may provide advertisers with information to inform them about conversion rates for analytics purposes.
5. International Transfers
5.1. We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including in Russia.
5.2. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.
6. Retention Periods
6.1. We will retain collected information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.
7. Your Rights
7.1. You have the following rights, in certain circumstances, in relation to your personal information:
(a) Right to access your personal information.
(b) Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.
(c) Right to restrict the use of your personal information.
(d) Right to request that your personal information is erased.
(e) Right to object to processing of your personal information.
(f) Right to data portability (in certain specific circumstances).
(g) Right not to be subject to an automated decision.
(h) Right to lodge a complaint with a supervisory authority.
7.2. If you would like to exercise these rights, please send your request to us at mt.dataprotection@corp.my.com, or in writing to: 28 Oktovriou, 365 VASHIOTIS SEAFRONT, office 402 Neapoli, 3107, Limassol, Cyprus. We will aim to respond to you within 30 days from receipt of request. We will need to verify your identity before we are able to disclose any personal data to you.
8. Security Measures
8.1. We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.
8.2. Access to the Services is authorized using your login (e-mail address or mobile phone number) and password. You are responsible for keeping this information confidential. You should not share your credentials with third parties and we recommend you take measures to ensure this information is kept confidential.
8.3. If you forget your login details, you can requiest us to send you an SMS or email, which will contain a restoration code.
8.4. To reduce the probability of third parties gaining unauthorized access, if you login to your account from an unusual place or after several failed attempts to provide valid login details, we may block entry to your account. You will then need to contact Service support and provide certain additional information to verify your credentials and gain access to your account.
9. Changes to this Policy
9.1. From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation achieve. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such.
10. Contact Us
10.1. If you have any questions, please send your inquiries to us, in writing to 28 Oktovriou, 365 VASHIOTIS SEAFRONT, office 402 Neapoli, 3107, Limassol, Cyprus, or to mt.dataprotection@corp.my.com. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within 30 days from receipt of request.
10.2. All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.
10.3. The e-mail address of our DPO is dpo@corp.my.com.
3.4. As part of maintaining and administrating the Services we may use the information to analyse user activity and ensure that rules and terms of use for the Services are not violated.
3.5. Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defence or exercise of legal claims.
3.6. You may withdraw your consent the collection of location data and your apps by amending your privacy settings of your mobile device.
3.7. Please note, if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and your sexual orientation) you should take care not to send this information to us.
3.8. Please note, if you withdraw your consent to processing or you do not provide the data that we require in order to maintain and administer the Services, you may not be able to access or register or proper use the Services.
3.9. If we intend to further process your data for any other purpose to those set out in this Privacy Policy, we shall provide you with details of this further purpose before we commence processing.
4. Data sharing
4.1. We may share your data with My.com B.V. and our affiliates. Sometimes we may also need to share your data with a third party in order to provide our Services to you or to administer the Services, for example if you choose to share your data across other social media platforms.
4.2. Our ad management and recommendation system is designed so that your information will not be shared directly with our third party advertisers. An advertiser or maker of a recommendation can only choose to target advertisements to groups of users falling within criteria such as age, gender or location, or to target communities according to type, e.g. cars or fashion. If you fall within one of the target groups you will receive an advert or recommendation.
4.3. An advertiser or maker of recommendations may also choose to upload a list of emails, phone numbers and identities to our systems so that we (but not the adviser or maker of recommendations) can check for user matches. They will see the number of matches but not the matches themselves.
4.4. We may disclose non personally identifiable User Information to Customers. For example, we may provide publishers with information about the viewing and click-through patterns of postings of the content they publish and may provide advertisers with information to inform them about conversion rates for analytics purposes.
5. International Transfers
5.1. We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including in Russia.
5.2. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.
6. Retention Periods
6.1. We will retain collected information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.
7. Your Rights
7.1. You have the following rights, in certain circumstances, in relation to your personal information:
(a) Right to access your personal information.
(b) Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.
(c) Right to restrict the use of your personal information.
(d) Right to request that your personal information is erased.
(e) Right to object to processing of your personal information.
(f) Right to data portability (in certain specific circumstances).
(g) Right not to be subject to an automated decision.
(h) Right to lodge a complaint with a supervisory authority.
7.2. If you would like to exercise these rights, please send your request to us at mt.dataprotection@corp.my.com, or in writing to: 28 Oktovriou, 365 VASHIOTIS SEAFRONT, office 402 Neapoli, 3107, Limassol, Cyprus. We will aim to respond to you within 30 days from receipt of request. We will need to verify your identity before we are able to disclose any personal data to you.
8. Security Measures
8.1. We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.
8.2. Access to the Services is authorized using your login (e-mail address or mobile phone number) and password. You are responsible for keeping this information confidential. You should not share your credentials with third parties and we recommend you take measures to ensure this information is kept confidential.
8.3. If you forget your login details, you can requiest us to send you an SMS or email, which will contain a restoration code.
8.4. To reduce the probability of third parties gaining unauthorized access, if you login to your account from an unusual place or after several failed attempts to provide valid login details, we may block entry to your account. You will then need to contact Service support and provide certain additional information to verify your credentials and gain access to your account.
9. Changes to this Policy
9.1. From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation achieve. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such.
10. Contact Us
10.1. If you have any questions, please send your inquiries to us, in writing to 28 Oktovriou, 365 VASHIOTIS SEAFRONT, office 402 Neapoli, 3107, Limassol, Cyprus, or to mt.dataprotection@corp.my.com. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within 30 days from receipt of request.
10.2. All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.
10.3. The e-mail address of our DPO is dpo@corp.my.com.