- General
We at Lemma Media Inc. (“Lemma technologies”, “we” or “us”) value your privacy and are committed to taking care of your Personal Data, which is a responsibility that we take very seriously. This Privacy Policy explains how we may use the Personal Data we collect when you visit our website, inquire about our products, or when you access websites, apps, or other digital properties that are being monetized through our products.
This Privacy Policy is not applicable to any information collected offline.
- Definitions
Data Controller means the party that determines the purposes and means of the Processing of Personal Data (“Controller”).
GDPR is a regulation in EU law on data protection and privacy in the European Union (EU) and the European Economic Area (EEA); Regulation (EU) 2016/679 (“GDPR”).
Personal information means information that (either in isolation or in combination with other information) enables you to be directly or indirectly identified (“Personal Information” or “Personal Data”).
Recipient means an entity, authority or agency to which the Personal Information is disclosed (“Recipient”).
Third party means a party that processes Personal Information on the Controller’s behalf (“Third Party”).
- Personal Information we collect
The Personal Information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Information.
If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.
Lemma technologies follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this as part of hosting services’ analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.
When you register for an Account, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number.
- How and on what legal basis we use your Personal Information
The table below describes the main purposes for which we process your Personal Information, the categories of your information involved and our lawful basis for being able to do this.
| Purpose | Personal Information used | Lawful basis |
| Providing, operating and maintaining our website | IP address, browser type | We have a legitimate interest in our website working properly |
| Improving, personalizing, and expanding our website | IP address, date and time stamp of your visit, referring/exit page, number of clicks | We will obtain your prior consent for these purposes |
| Understanding and analyzing how you use our website | IP address, date and time stamp, referring/exit page, number of clicks | We will obtain your prior consent for these purposes |
| Dealing with inquiries, and other communications from you | Name, email address, phone number, content of the message and other information you provide | This is necessary to fulfil our contract with you |
| Marketing products which may be of potential interest to you and offering promotions | Name, email address, telephone number and marketing preferences | We have a legitimate interest to provide you with information about or products including those that are the same or similar to the ones you have inquired about
If we cannot rely on legitimate interest as our lawful basis for processing, then we will obtain consent from you |
| Detecting fraud and troubleshooting | IP address, date and time stamp of your visit, ISP, device ID | We have a legitimate interest in ensuring our systems are secure |
| Delivering and presenting advertising content | IP address, device ID, geographical location | We have a legitimate interest to process your Personal Data to deliver and present advertising to you
If we cannot rely on legitimate interest as our lawful basis for processing, then we will obtain consent from you |
| Creating an account with us | Name, company name, address, email address, telephone number | This is necessary to fulfil our contract with you |
Where we process your Personal Information on the legal basis of legitimate interest, we have a legitimate business or commercial reason to process your data which has been balanced against your rights and interests and those reasons do not override your rights and freedoms.
To achieve the purposes mentioned above, it may be necessary in some cases for us to disclose your IP address and geographical location to our demand partners. This disclosure may occur through transmission, distribution, or another form of provision.
- Retention period for Personal Information we collect
We retain your Personal Information until it is no longer necessary to fulfil the purposes of collecting your Personal Information, or until you request us to erase or destroy your Personal Information. We may be required to retain certain information in order to comply with the laws which we are subject to.
- International Data Transfers
We may transfer and process your Personal Information outside the European Union (EU) and European Economic Area (EEA). This may include transferring Personal Information to other countries that might not have an adequate level of data protection under the GDPR, such as the United States, Singapore and Australia. When we engage in such international data transfers, we ensure that your information is adequately protected in accordance with the GDPR. We implemented Standard Contractual Clauses (SCCs) issues by the European Commission to safeguard your privacy and maintain the security and confidentiality of your personal data during these transfers, in compliance with relevant regulations.
- Advertising Partners Privacy Policies
You may consult this list to find the Privacy Policy for each of the advertising partners of Lemma technologies.
Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Lemma technologies, which are sent directly to users’ browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit.
Note that Lemma technologies has no access to or control over these cookies that are used by third-party advertisers
- Third Party Privacy Policies
Lemma technologies’ Privacy Policy does not apply to other advertisers or websites. Thus, we are advising you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.
You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers’ respective websites.
9. Personal Information collected from other sources than from you
If we process your Personal Information, we usually collect Personal Information from you, and it is usually you who provides us with the Personal Information. Nevertheless, in individual cases, we may also obtain Personal Information from other sources, such as the IP address, device ID and the device latitude and longitude from our third-party partners.
- CCPA Privacy Rights (Do Not Sell My Personal Information)
Under the CCPA, among other rights, California consumers have the right to:
Request that a business that collects a consumer’s personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
Request that a business delete any personal data about the consumer that a business has collected.
Request that a business that sells a consumer’s personal data, not sell the consumer’s personal data.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
- GDPR Data Protection Rights
We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access – You have the right to request copies of your personal data.
The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to withdraw consent or Right of Opposition– You have the right to object or withdraw consent at any time to processing of your personal data e.g. for marketing purposes, provided that no legitimate interest exists prevailing over your interests, rights and freedoms, such as defending a right in a judicial process
The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
The right not to be subject to any automated decision making and profiling – You have the right to avoid decisions based solely on automated processing if they have legal or significant effects on you.
The right to complain – You have the right to complain to the supervisory authority.
If you make a request, we have one month to respond to you, unless it is a particular complex request. If you would like to exercise any of these rights, please contact us.
We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:
European Union (EU)
United Kingdom (UK)
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data).
If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website: https://prighter.com/q/16169978399
- Children’s Information
Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
Lemma technologies does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.
- Contact information
Controller
If you have any question or comments about this Privacy Policy, the ways in which we collect and use your Personal Information, your choices and rights regarding such use please do not hesitate to contact us:
Controller’s identity: Lemma Media Inc.
Email: privacy@lemmatechnologies.com
Postal Address: 530 Fifth Ave, 9th Floor New York, New York 10036
