Privacy Policy

Last Updated April 29, 2024

We deeply care about the protection of your personal data and believe that you should have full control on your personal data. In order to do so, we, Archon Programmatic House (‘‘Archon’’) as the Data Controller, prepared this privacy policy (the “Privacy Policy” or the “Policy”) enlightening you about the data we collect from you or by means of your transactions related to https://archonph.com/ (the ‘‘Website’’) and the application of Archon Looks (‘‘Application’’) and our business in general (collectively, the “Services”). Please read this document carefully and with attention. If you have any questions please consult your attorney.

 

General Provisions

 

Who we are

Use of the terms “we” and “us” in this Privacy Policy means Archon Programmatic House  and its affiliates. We are a boutique publisher network who offers our publishers custom and top quality monetization/adops services. 

 

This Privacy Policy

This Privacy Policy explains how information, including personal information, may be collected, processed, used, and disclosed by Archon advertisement materials and/or inventory with respect to the following instances: (i) use of this Website and/or the Application, and (ii) how personal information is collected, used, and processed through our technology on behalf of the businesses that use our Services (hereinafter referred to as “clients”).

 

Our Services

Providing our services, we typically do not directly interact with the owners of personal information unless the owner of information is our client. Rather we process information (including personal information, if any), provided by our clients using various software and services, and not always our software in this regard. Therefore, we obligate our clients to comply with all applicable laws in all applicable jurisdictions, while obtaining information and to indemnify us of any claims arising from such non-compliance. If you are our client, we collect, process and use information in accordance with applicable agreement between you and us and this Policy.

 

Information Our Clients and Vendors Collect

As stated herein, our clients, our contractors, and our clients’ contractors may use our technology and operate it using tags, pixels, cookies, or other similar technologies for their business activities. We are not responsible for our clients, or our clients’ contractors’ manner of use of any personal information or any sort of tracking technologies.

 

Contact Us

If you have questions, want to find out more about our privacy practices, or if you would like to make a complaint, please contact us by e-mail: info@archonph.com.

 

Changes to this policy

We reserve the right to revise this Privacy Policy from time to time. The most current version of the Privacy Policy will determine the order and procedure of your information usage and will always be reflected on our Privacy Policy page. You agree that you are solely responsible for tracking changes on the Website and/or the Application. We do our best to publish any new information about changes in the Privacy Policy, but the user must independently check the Privacy Policy for updates when accessing the Website and/or the Application. Your continued use of the Website and/or the Application constitutes your acceptance of the new Privacy Policy and any changes made.

 

Information Collected 

By using the Website and/or the Application, you are accepting the terms of this Privacy Policy. IF YOU DO NOT AGREE TO TERMS OF THIS PRIVACY POLICY IN THEIR ENTIRETY, YOU MAY NOT ACCESS OUR SERVICES OR OTHERWISE USE THE SERVICES, REGISTER AS A PUBLISHER OR ADVERTISER OR ENTER ANY PROMOTION.

 

Collecting Personally Identifiable Information

For purposes of this Privacy Policy, the “Personally Identifiable Information” shall mean any information obtained through your use of the Website and/or the Application. This section does not refer to any information we store, collect, or process using our services. The Personally Identifiable Information that you must submit in order to enter into an agreement with us, may include, without limitation, your name, title, company name, mailing/billing address, e-mail address, telephone number, Skype name, etc. To the extent the Personally Identifiable Information has been collected from you, you acknowledge that such collection is done on a voluntary basis to enable us to provide you efficient access to our materials and/or inventory, services, promotions, and our other products and/or services.

 

Collecting Non-Personally Identifiable Information

We automatically collect the Non-Personally Identifiable Information when you access and use this Website and/or the Application. This Non-Personally Identifiable Information includes, without limitation, the type of browser that you use (e.g., Internet Explorer, Chrome, Safari), your IP address, the type of operating system that you use (e.g., Windows or Mac OS), and the domain name of your Internet service provider (e.g., Verizon, AT&T), etc. We use Non-Personally Identifiable Information to help diagnose problems with our server, to customize  your Internet experience, and to identify ways of making the Website and/or the Application better. We also may use this Non-Personally Identifiable Information in the aggregate to analyze the Website and/or the Application usage, as well as to offer you products and services. This Non-Personally Identifiable Information is not linked to any Personally Identifiable Information.

 

IP address

An IP address is automatically assigned to your computer every time you establish a connection to the Internet. Our advertisement materials and/or inventory uses your IP address to help diagnose problems with our server and to administer our Website and/or the Application. When you open an account on our advertisement materials and/or inventory, your IP address will be associated with personally identifiable information.

 

Cookies

We use cookies on this Website. We do not link the information we store in cookies to any Personally Identifiable Information you submit while staying on our Website. We use both session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate our Website. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period. You can remove them by following directions provided in your Internet browser’s “help” file.

This Website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses so-called cookies, which are text files placed on your computer, to help the Website analyze how users use the Website. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google on servers in the United States. In the event that IP anonymization is activated on this Website, however, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states to the agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

On behalf of the website operator, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google. For any further questions in this regards please refer as well to the Google designated policies via the following link https://policies.google.com/technologies/partner-sites.

 

Information Collected from end users or owners of personal data other than our clients

 

Information We Collect, Process, or Store

In the course of providing services to our clients we do not intentionally collect information (data) that reveals your real-world identity, such as your name, address, phone number, or social security number. Our clients may use our services to process some sensitive information, which may come from our clients’ websites and may be processed through our technology without our awareness or control of thereof. Rather we collect data about your computer or device using a number of technologies, the explanation to which you will find below. The information (data) we collect is pseudonymous, generalised, and is not considered to be personal information in the majority of jurisdictions. In some other jurisdictions in which we provide services to our clients, in certain contexts, such information (data), including Internet Protocol (IP) addresses and other pseudonymous information, like certain unique device identifiers that may identify a particular computer or mobile device (for instance, in European Union)) may be considered as the personal information (data).

Please take notice, that we may work with third party data platforms or applications that may be directly integrated into our technology or used separately, supplementing our technology by us or our clients. It helps to deliver targeted advertisements using our advertising technology more efficiently or it allows our clients to use multiple interfaces and manage data more efficiently. Finally, our clients may use third-party data in combination with your user information (data) to deliver targeted advertisement materials and/or inventory across multiple devices that may ultimately be processed by our technology without our knowledge thereof.

 

Information that we may process includes:

YOU SHOULD REVIEW THE PRIVACY POLICY AND TERMS OF USE FOR ANY SITE OR APPLICATION YOU VISIT OR INSTALL TO LEARN ABOUT WHAT INFORMATION THOSE SITES COLLECT FROM YOU, AND HOW THEY USE AND SHARE SUCH INFORMATION. THE INFORMATION IN THIS PRIVACY POLICY MAY NOT REFLECT WHAT AND HOW OUR CLIENTS OR WE COLLECT ON ANY INDIVIDUAL SITE.

Information about your behaviour on our client’s resources, websites, and platforms: including information about the domain, your referring website addresses, date and time of your visits, page view data, search keywords, visitor activities and actions on publisher’s sites, referring and exit pages, platform type, date/time stamp, geolocation (including city, country, zip code, and potentially geographic coordinates if you have enabled location services on your device), click data, types of advertisements viewed.

Information about your browser: your browser type, languages, browser history etc.

Information about your device: including information about your IP address, device make, device model, device operating system, device operating system version, and data connection type.

Information about your Internet service: including information about which Internet Service Provider (ISP) you use.

Information regarding your interactions with our clients, including your use of our clients’ websites, software, and mobile applications, the websites and applications or other pages on the Internet or other resources our clients operate and control.

Any additional data that is reasonably necessary to calculate a statistical ID in certain cases.

Pseudonymous and generalised information collected by our clients or third parties that may include identifiers (similar to mobile advertising IDs and alike) and interest-based advertising data related to or connected with said identifiers.

 

How We Collect User Information

We act on the assumption that consumers prefer relevant ads, tailored in accordance with their interests. Therefore, we collect a variety of data using cookies and various other standards (typical for the industry) and unique (if our technology allows so) web technologies to collect information automatically from your device, including:

Cookies. Cookies are a technology that is based on a small-size data files containing a string of alphanumeric characters that usually include a unique identifier and are placed on a visitor’s device or computer. Cookies are usually stored at user’s computer permanently (persistent cookies) or temporally. We use cookies on our clients’ websites in order to operate our technology and collect user information and statistically analyze advertisement preferences. For more detailed information, please check the paragraph “Cookies” below.

Tags and Pixels. Tags and Pixels are blocks of code that we and our clients may use to track your browsing on the Internet: from resources to any particular websites or applications to track your browsing behavior. Sometimes web beacons are used for these purposes. They are usually transparent or invisible graphic images, no larger than 1×1 pixel, they are placed on a page or otherwise, Internet resource or sent within an e-mail to monitor the behavior of the user visiting the resource or sending the e-mail. It is often used in combination with cookies. We create and use a unique synchronization system to check the quality of information that we have collected with information that our clients collected independently, and later help our clients or third parties that intend to provide you with targeted advertisements.

Mobile Device Identifiers. Mobile Device Identifiers or Mobile Device IDs are unique identifiers which can be used to identify a mobile device. We may use standard device identifiers, to track your use of mobile applications and to determine if a piece of advertisement inventory has been delivered to a specific user or retargeted, or to determine the frequency of certain inventory for a certain user. Ultimately, passing device’s ID back to advertisers helps us and our clients to improve the quality of advertising and its efficiency.

Software Development Kits. These are blocks of code or algorithm similar to Tags and Pixels that are embedded into a digital resource that allows us to track certain information related to the application use, gathered during the process of utilizing our technology.

Other technologies. Please be aware that we use other technologies, including locally stored objects, to collect user information in order to assist users with the inventory delivery and to provide reporting to our clients or to evaluate the quality of advertisement.

 

How We Use User Information

The information that we collect about you, both Personally Identifiable Information and Non-Personally Identifiable Information, may be used by us, or shared by us as set forth in this Privacy Policy or otherwise with your consent. If we or our affiliates are involved in a merger, acquisition, financing due diligence, reorganisation, bankruptcy, receivership, sale or company assets, or transition of service to another provider, then any information may be sold or transferred as part of such a transaction as permitted by law and/or relevant agreement.

We primarily use the user information we collect to enable our clients to find and purchase advertising space. In particular, our clients use two types of information in order to deliver end users a targeted advertisement material: our client’s information and information that we provide in the course of our services delivery. Those two types of information are usually synchronised and mutually filtered and checked to identify what are the main interests of the user, and what targeted advertisement materials should be sent to him or her based on all the information that we stated as collected in this section.

Additionally, we may use the information that we collect directly for our purposes: to create sophisticated advertising segments, to run analytics, including forecasting analytics of inventory, and to check the quality of advertisement or for any other and further research and development purposes acceptable as our legitimate business interests. Further, we constantly improve our algorithms targeting users with particular advertisement materials and/or inventory and measure the efficiency of advertisement materials. We use user information to improve our services and products that we provide to our clients, and to develop new products and services, to analyse the market, and generate performance reports. For said purposes we may share information with our clients, partners, and service providers, taken, however, that all the information sharing is done in aggregate without identifying particular users. Finally, we use user information to protect users, investigate security breaches, and to prevent all illegal activities within our systems.

SUBSECTION FOR EEA USERS ONLY

 

Your Rights and Applicability of the EU Laws

You can reach us via e-mail: info@archonph.com. 

Legal basis for Processing EEA Users’ Information

If you are a user located in the European Economic Area (hereinafter the “EEA”), as defined in GDPR, or a user located in the United Kingdom, our legal basis for collecting and using your user information shall be subject to particular circumstances of collection and/or processing your information. The basis for collection, storage, or processing your personal data is your informed consent. Where we rely on your consent to collect and/or process your user information, we obligate our clients to obtain such consent in compliance with applicable GDPR provision and applicable laws.

With respect to personal data collected through our Application, we are acting as a processor. With respect to personal data collected through our Website, we are acting as a controller.

If you have questions or need further information regarding the manner of use and legal basis for collecting and using your user information, please contact us. Please be advised that we will require reasonable proof that you are a subject to GDPR protection in order to process your inquiry in accordance with this subsection.

 

Data Subject Rights of The Residents of The European Economic Area and The UK

If you are a resident of the EEA or the UK, you have certain data protection rights. Archon endeavours to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal information, thus to enforce all rights provided to you under the GDPR/the UK GDPR (whichever is applicable) .

The GDPR/the UK GDPR gives certain rights to individuals in relation to their personal data. Accordingly, Archon are happy to offer transparency and access controls to help users take advantage of those rights.

You (as a ‘data subject’) may send official requests to us regarding your personal data via email to the following address: info@archonph.com

At any time, you have the following rights:

 

  1. Right of access to your data ( the “data subject access request”). This right gives you the opportunity to get a copy of your personal data that we process and to find out detailed information about how and why we process this data. In this Policy, you can read the general information about what the personal data we process and for what purposes. If you want to know more and fail to find this information in the Policy, you can request this information from us, in particular, by contacting us.
  2. Right to rectification gives you the opportunity to amend any incomplete or inaccurate data about you that we process. If you find that some of your personal data that we process is incorrect or outdated, please inform us of this, including contacting Archon. However, in some cases, we will not be able to change your data, for example, when it has already been used in an offer contract and/or is contained in any written document issued and presented to us.
  3. Right to erasure (“right to be forgotten”) and withdrawal of consent to the processing of your data. This right gives you the opportunity to demand data deletion if Archon has no legal grounds to continue processing. If we process your data in accordance with the consent to processing (in particular, for the purpose of marketing distributions), any further processing can be stopped at any time by withdrawing the consent to the processing. In the cases referred to in Article 14 of GDPR, Archon will delete the processed personal data, with the exception of the data that we must store in accordance with the law. At the same time, we will not always be able to fulfil your request for the deletion of data for specific reasons about which you will be informed in response to the request.
  4. Right to object to the processing of your data. This right gives you the opportunity to object if you think that our processing of your data affects your personal rights and freedoms. In some cases, we can demonstrate that we have significant legal grounds for processing your personal data that prevail over your rights and freedoms.
  5. Right to restrict the processing of your data gives you the opportunity to suspend or restrict the processing of your data. This means the requirement to stop any processing of your data, except for storage under certain circumstances, namely:
    1. you want us to verify the accuracy of your data;
    2. if we illegally process your data, but you do not want to delete it;
    3. if you need to save your data since it is necessary for you to establish, exercise or defend a legal claim, even if we have stopped processing such data;
    4. you have objected to our processing of your data, but we need to establish that there are overriding legal grounds to grant your objection.
  6. Right to data portability gives you the opportunity to request, in some cases, the transfer of personal data to you or to a third party of your choice. We provide personal data in a structured, commonly used and machine-readable format. This right applies only to cases where personal data was received from you based on your consent or for the conclusion and fulfilment of a contract with you.
  7. Right to automated decision-making, including profiling. You have the right not to be subject to a decision based solely on automated data processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
  8. Right to lodge a complaint. You may lodge a complaint with the relevant supervisory authority (data protection regulator).

Please contact us if you would like to exercise any of your rights above.

There are individual exceptions when some of these rights do not apply to your data processed by us.

Please note that when you contact us, you must go through the identification process and describe your specific requirements so that we can process your lawful request and give a lawful response. If we cannot identify you via messages or requests, or if we have reasonable suspicions about your identity, we may ask you to provide proof of identity. This is the only way we can avoid disclosing your personal data to someone who may impersonate you, i.e. the identification process is carried out in your best interests. Any additional information collected for verification purposes will only be used to verify identity.

While we process requests as quickly as possible, we ask you to keep in mind that providing a complete and lawful response regarding personal data is a complex process that can take up to a month. If we need more time to prepare a complete response, we will let you know. If Archon needs something from you to be able to deal with your request (eg. ID documents), the time limit will begin once we have received this.

 

Legal Necessity

We process personal data in case of necessity to comply with applicable laws and regulations. For instance, for the mere purpose of identification, the jurisdiction of the information and where it comes from, we have to collect the user IP address. Similarly, your mobile device identifier will likely be used (unless our technology allows otherwise), in order to identify a user who had withdrawn his/her personal data processing consent. Similarly, as soon as you withdraw your consent, we will have to provide our clients with your personal information to make sure that your consent has been withdrawn throughout the entire system.

 

Legitimate Interest

In some cases, legitimate interest allows us to process certain information without consent: for instance, to prevent fraudulent activity. Legitimate interest use will be determined by us on ad hoc basis for each particular platform or service. Where we rely on legitimate interests as the legal basis for processing your personal data, we will balance those interests with your interests, fundamental rights and freedoms, as required by applicable law and best industry practice.

 

Data Protection Rights of The Residents of Brazil

Archon comply with the principles and requirements of data processing under the Lei Geral de Proteção de Dados Pessoais (LGPD), including, but not limited to, age-gating requirements. All the data received by using our services is anonymized and therefore falls outside the scope of LGPD. We hereby inform You about the following rights You have under the LGPD: Confirmation: confirmation of the existence of processing; Access: access to the data; Rectification: correction of incomplete, inaccurate or outdated data; anonymization, blocking or elimination of unnecessary or excessive data or of data processed in noncompliance with the provisions of LGPD; Data portability: portability of the data to other service providers or suppliers of product, at the express request; Anonymization: anonymization, blocking or elimination of the personal data processed with the consent of the data subjects, except in the events set forth in article 16 of LGPD; Deletion: You have the right to have their personal data deleted if the processing of that data was based on consent; Information: You have the right to be informed about sub-processors and other third parties that access or process their personal data. You also have the right to be informed about Your consent choices and the consequences of refusing consent; Revocation: revocation of the consent, pursuant to the provisions of paragraph 5 of article 8 of LGPD; Bring complaint: lodging a complaint with the Data Protection Authority; Opposing the processing of personal data where there is non-compliance with the provisions of LGPD; Request review: You have the right to request the review of decisions made solely on the basis of automated processing of personal data which affect Your interests. This includes decisions used to define Your personal, professional, consumer and credit profile, or the aspects of Your personality. If You would like to exercise any of these rights, please contact us via: info@archonph.com.

 

Data Protection Rights of The Residents of China

Archon comply with all the principles and requirements of data processing under the Personal Information Protection Law (the “PIPL”). The aforementioned principles include among others: accuracy, accountability and security, purpose limitation, collection limitation, openness and transparency, lawfulness and necessity.

We hereby inform You about the rights You have under the PIPL:

  1. You have the right to know, decide, refuse, and limit the handling of their personal information by others unless laws or regulations stipulate otherwise;
  2. You have the right to access and copy Your personal information in a timely manner, except when the laws and regulations require confidentiality;
  3. You have the right to correct or complete inaccurate personal information in a timely manner;
  4. You have the right to request Us to explain Our personal information handling rules;
  5. You have the right to deletion of Your personal information if (i) the agreed retention period has expired, or the handling purpose has been achieved; (ii) We as a personal information handler cease the provision of Our services; (iii) You rescind consent where the processing of personal information was based on Your consent; (iv) the information is handled in violation of laws, regulations or agreements;
  6. You have the right to request Us to transfer Your personal information to another personal information handler.
  7. If You would like to exercise any of these rights, please contact us via: info@archonph.com

 

Data Protection Rights of The Residents of Turkey, California, Virginia, Colorado, Connecticut and Utah

Archon complies with all the principles and requirements of data processing under California Privacy Rights Act (CPRA) on January 1, 2023; Virginia Consumer Data Protection (CPDA) on January 1, 2023; Colorado Privacy Act (CPA) on July 1, 2023; Connecticut’s Act Concerning Personal Data Privacy and Online Monitoring, also known as the Connecticut Data Privacy Act (CTDPA) on July 1, 2023; Utah Consumer Privacy Act (UCPA) on December 31, 2023; Turkish Law on the Protection of Personal Data No. 6698 on 7 April 2016.

If You have any questions in regard to Your rights under the aforementioned legislation, please don’t hesitate to contact us via: info@archonph.com.

 

Storage and Sharing of User Information

We only store information in case of necessity. Typically, we delete all the information quarterly based on the analysis of the traffic and inventory quality control. Some information such as cookies may expire in accordance with your device settings. We do not need such information and we usually delete it unless it is necessary for performing our services to the client.

Please be aware that certain laws and regulations may subject us to store user information for a particular period: money laundering laws, financial reporting regulations, tax laws etc. Furthermore, we may have to comply with the decision of the court of appropriate jurisdiction and maintain information for the longer period.

To determine the corresponding retention period for personal data, in addition to processing objectives, we also consider the volume, nature, and category of data, the potential risk of harm from unauthorised use or disclosure of data, as well as the relevant requirements of the applicable legislation. Normally we don’t store your data for more than 90 days unless there is a specific need otherwise.

Eventually, we can minimise your data that we process or even make your data anonymous (for research or statistical purposes) so that it is no longer connected with you personally. If the data is anonymised, we can use this information essentially indefinitely since it no longer contains any data.

We share user information that we collect as follows:

We share information with our clients. It is done to help them identify, buy advertising, and target particular publishers. Clients may use this information in conjunction with other information they have independently collected to provide you targeted advertising materials. They also evaluate and analyze particular advertisement campaigns, inventory, etc.

Change of Control. We may share user information in connection with mergers, acquisitions, events of change of control, including but not limited to sale or transfer of all or a part of our business or assets. In this case, your informed consent, if applicable, will be granted to a new entity in accordance with the event of a change of control.

Compliance with laws and regulations. We may share user information with law enforcement, regulatory authorities, courts with competent jurisdictions, emergency services or other necessary third parties for legal, protection, security, and safety purposes, including but not limited to the purpose of compliance with laws or regulatory requirements and to responses to lawful requests including requests of governmental entities, enforcement of our own policies and agreements, protection of our clients, agents, employees, directors, officers and alike.

We also use some third-party services that use cookies or similar tracking tools to help our business model achieve its goal and thus provide you with a better and more customized experience, and for marketing, statistical analysis, auditing and reporting purposes. Currently, we use Google Ad Manager / AdX, Adform, Appnexus, Criteo, Index, Pubmatic, RTB House, Rubicon, Smart Ad Server, Taboola, Teads.tv to accomplish these goals; but please note that they may change over time. We sign a partnership agreement with these third parties; however, we would like to underline that we are not responsible for the privacy policies that these individuals apply with their services.

 

Your Choices to Avoid Targeted Advertising

Please be aware that although we believe that targeted advertisement is beneficial for all parties involved, we do not circumvent any devices, and there are many ways and technologies to stop receiving targeted advertising that our clients may apply using our technology. Note that different platforms and devices use different identifiers and different technologies, and also that each browser and each device has its own applicable settings. Please be advised that should you delete your cookies the information of your withdrawal from a targeted advertisement may also be deleted. Same may be applicable to cookie-blocks. We do not respond to or honor “do not track” (a/k/a DNT) signals or similar mechanisms transmitted by web browsers, except as required by applicable law.

If your consent to the targeted advertisement was granted through the application, please withdraw your consent directly from that application. In addition, your device setting likely allows you to generally withdraw or block personalized advertising: for instance, in iOS, you can do that by changing the appropriate “Limit Ad Tracking” setting; on Android devices, you can do so by changing “Opt out of Ads Personalization” setting. Please be advised that this Provision is not intended to serve as your user manual for your device, and you should always contact the manufacturer to obtain all relevant information on how to withdraw your consent.

 

Security

To prevent unauthorized access and disclosure, to maintain data accuracy, and to ensure the appropriate use of your information, we utilize industry standard physical, technical, and administrative procedures to safeguard any personal information we collect. Please note that no transmission or storage of information, however, can ever be guaranteed to be completely secure, though we take all reasonable precautions to protect against security incidents.

Archon is very serious about the security of personal data. To ensure the secure storage of your data, we have implemented a variety of technical and administrative tools that protect  data from any unauthorised or illegal processing and any loss, destruction or damage. We regularly test our security measures to ensure they remain operational and effective.

The data you provide will be safely stored on servers, which are inaccessible to the public and provided by other third parties secure providers.

Archon adheres to the principle of data minimisation. We process information that is really necessary for us to perform certain functions and for the specific goals defined in this Policy. Your data is available only for a limited number of employees who need access to the relevant data to fulfil their functional duties.

 

Policy towards children

Our services are not directed to people under 18. If you become aware that your child has provided us with personal information without your consent, please contact us. We do not collect personal information from children under 18. If you are a minor, you may use our services only in conjunction with a parent or guardian.

 

 

International Data Transfers

Archon is an international company that collaborates with various companies in different parts of the world to promote and/or provide customer access to its services. Accordingly, your data can be processed outside your country of residence, including countries that may not provide the same level of protection of your data as your country.

When we transmit Personal Data to recipients in other countries outside the European Economic Area, Switzerland or the United Kingdom, we take measures to comply with the relevant legal and technological requirements, as described in this Policy and under the applicable legislation on data protection, including the requirements in Articles 44-50 of the General Data Protection Regulation (EU GDPR).

When transferring your Data to third countries that are not bound by an “adequacy decision” of the European Commission, Archon will use Standard Contractual Clauses, mandatory corporate rules, and special agreements on data transfer and processing. In addition, we will require all data recipients to ensure the proper level of protection and security of your data that is required by the applicable data protection legislation.

In some cases, Archon may need your explicit consent to the international data transfer.