Serpzilla Ltd Privacy policy

  1. 1. INFORMATION ON THE DATA CONTROLLER

    SERPZILLA LIMITED, having its seat in Nicosia, Cyprus (3 Menandrou street, GLAFKOS TOWER) 1066 registered as a limited liability company by shares (LTD) with registration number HE272015 (together “SERPZILLA”, “the company”, “we”, “us”, “our”), takes your data protection rights and its legal obligations seriously.

    This Privacy Policy (“Policy”) describes how we use your personal data collected via our link building platform named SERPZILLA.COM (“serpzilla.com”, “the platform”). Please read this Policy carefully.

    SERPZILLA is the sole data controller of your personal data operating from Cyprus, and we make sure that all your personal data stay in the EU.

  2. 2. PERSONAL DATA WE COLLECT & PURPOSES OF PROCESSING

    Depending on the purpose for which we may need to process your data from time to time, we will try to acquire the least possible data and process on a case-by-case basis certain categories of your personal data, which means information from which you are identifiable, and includes, but is not limited to the following:

    Remember that, when we ask you to fill in personal data this is because they are required to afford you access to the functionality or service of the platform and we will mark certain fields as mandatory, since these are the minimum that we need to be able to provide the service. Please consider that, if you decide not to make such data available to us, you may be unable to complete your campaigns, may not be able to receive payments from us or may not be able to enjoy those services in general.

    Depending on how you interact with our website, we will process your personal data for the following purposes:

    1. 2.1 To manage your registration as a user of the platform

      If you decide to make use of our webmaster’s platform, we need to process your data to identify you as a user of the website and grant you access to it as a registered user. You may cancel your registered user account by requesting a deletion through our Customer Support service.

    2. 2.2 Creation of campaigns

      SERPZILLA enables you to use website monetization through backlinks. You must provide personal data to use our platform and place websites on our systems, which we process to provide the given service. Additional voluntary information that may also be provided is marked accordingly (optional).

      In the context of the monetization platform, the following personal data will be processed in accordance with Article 6(1.)(b) of the GDPR for the performance of the contract:

      First and last name, email address and mobile phone number (master data). Your IP and operation system information at the time of submitting, the initiation of a campaign, information on the provided websites and subsequently ownership information on them and the password you have chosen (in a hash - encrypted - form) are also processed.

      You may enter the personal data (e.g. your name) at the time of registration. If you choose not to provide personal data your payments or money acquisitions will still be executed through our payment processors in a secure environment with the data you have provided to them.

      It will not be possible for you to use the platform and for us to provide the service if we do not process the mandatory personal data shown above. This does not apply to optional information.

    3. 2.3 Payments

      You can start making money through the platform and you will be able to collect these moneys through the platform’s payment processor. We will credit the amounts to your specified means of payment, if your credit card details are provided. Then, they will be transmitted directly to the payment service provider engaged by us via an encrypted connection and without any further disclosure of credit card information to us except for the last four digits of your credit card which are transmitted to us and in a pseudonymized form for security reasons. We store such pseudonymized information for the purposes of identification and verification.

      In the context of payment, the following personal data will be processed in accordance with Article 6(1.)(b) of the GDPR for the performance of the contract:

      First and last name, address, country, language, email address, mobile phone number, credit card key, last four digits of the credit card number, the email address of your processor’s account if applicable, and information about your terminal equipment (device ID, MAC, etc.).

      We cannot offer you certain means of payment if we do not process these personal data.

    4. 2.4 News, promos and personalized offers

      You will receive offers and advertising from us if you have agreed to receive news and personalized offers (advertising, and promotions), though you can opt-out at any time. This concerns both non-personalised (sent to all customers) and personalised (sent only to you and based on an analysis your personal data that you have either explicitly provided to us or were generated as part of your use of the platform) newsletters sent electronically (email, SMS, and push notifications) to your terminal equipment (desktop, laptop, tablet, mobile device, etc.). To send you personalized advertising, we will process your data and, where possible, other information from your accounts, such as campaigns you may have started and completed successfully in our platform. Based on this data, you may receive special offers, special content, and advertising from us. Accordingly, please take into account that this data processing implies an analysis of your profile to establish your preferences and therefore which services are most relevant to your preferences.

      We will also process your personal data to organize promotional actions. By participating in any promotional action, you authorize us to process the personal data that you have shared with us depending on the promotional action and disclose them through different media such as social networks or the platform itself. In each promotional action in which you participate, the terms and conditions will be available to you and will provide more detailed information about the processing of your personal data.

      In this context, we will process the following personal data based on your consent in accordance with Article 6(1.)(a) of the GDPR:

      First and last name, email address, mobile phone number, payment methods, registration date, log-in details, device IDs, IDFA (Ad-ID, Apple, identifier for advertisers), IFV (Ad-ID, identifier vendor), GAID (Google advertising identifier), IP address as well as usage data (usage frequency, campaigns, etc.).

      If you do not wish to receive the news and personalized offers already discussed, you can – just as easily as when you agreed to it – withdraw your consent by contacting our Customer Support service.

      Please note that the withdrawal and ensuing changes are valid only for the future and will be effective or implemented by no later than 5 working days from withdrawal.

    5. 2.5 Facebook Connect

      We give you the option of registering for or logging in to our platform using your Facebook log-in information, a service provided by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (“Facebook”). This requires the operation of the Facebook Connect button. For logging in, you will be redirected to a Facebook page, where Facebook will request certain permissions and you can log in using your Facebook user data. This will link your Facebook profile with our systems. This link will allow us to view the data you have provided Facebook (first and last name, email address, public profile, age range, gender, profile picture, time zone, Facebook ID). For the purpose of Facebook Connect, we use only your email address, first and last name, profile picture, and Facebook ID for identification purposes in accordance with Article 6(1.)(f) of the GDPR. At the same time, the type of device (e.g desktop, laptop, tablet, mobile, etc.), operating system, language, time zone, resolution, browser type and version and the location of your time zone (e.g. Europe/Nicosia, etc.) are transmitted to Facebook automatically.

      See Facebook’s data policy and terms of use for more information about Facebook Connect and the privacy settings: https://www.facebook.com/policy.php.

      We kindly ask that you refrain from using the Facebook Connect function if this is not in accordance with your wishes.

    6. 2.6 Web tracking
      1. 2.6.1 Google analytics

        SERPZILLA uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”).

        For this purpose, a cookie is installed on your device. The information generated by the cookie about your use of the platform (including your IP address) will be transmitted to and stored by Google on servers in the United States.

        Google will use this information for the purpose of evaluating your use of the platform and website in general, compiling reports on your activity and providing other services relating to website activity and internet usage to the provider. Google will not associate your IP address with any other data held by Google. For further information on how Google uses your data, please refer to https://policies.google.com/privacy?hl=en - infocollect.

        Objection to data collection:

        Besides changing your browser settings, you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en

      2. 2.6.2 Facebook Custom Audience Program

        We participate in Facebook’s Custom Audience program which enables us to communicate with people that are already using our platform, or exclude people that are already using our platform from seeing our advertisements. To this end, we share your email address or phone number in a hashed format with Facebook, in order to allow it to identify you, if you are a Facebook user.

        Objection to data collection:

        You can adjust your ad preferences through your Facebook settings if you do not want to receive interest-based ads on Facebook.

  3. 3. DISCLOSURE OF YOUR PERSONAL DATA TO 3rd PARTIES

    In order to achieve the purposes described in this Privacy Policy, we may also disclose or grant access to your personal data to third parties that provide us with support in the services that we offer you, e.g.:

    who assist us in providing the services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analyzing data, providing support services or performing other tasks, from time to time.

    Your personal data will be accessible by SERPZILLA’s authorized personnel and service providers acting on our behalf, on a need-to-know basis.

    For service efficiency purposes, some of these providers are located in territories outside the European Economic Area that do not offer a level of data protection comparable to that of the European Union.

    We may also share your personal data with third parties in connection with the potential or actual sale of our company or any of our assets, or those of any associated company, in which case personal data held by us about our users may be one of the transferred assets.

    We will also respond to requests for personal data where required by to do so by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us.

  4. 4. YOUR RIGHTS

    You have the following rights with respect to your personal data

    Right to withdraw consent – where applicable, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. For example, if you wish to opt-out of receiving marketing communications, you can opt-out at any time, use the “unsubscribe” link provided in our emails or otherwise contact us directly through our Customer Support service and we will stop sending you communications

    Right of access, rectification, and erasure – you have the right to request access to any of your personal data that we may hold, to request correction of any inaccurate data relating to you and, under certain circumstances, to request the deletion of your personal data. You can see and update most of this data yourself online

    Right of data portability – Under certain conditions, you have the right to receive all such personal data which you have provided to us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible

    Right to restriction of processing – you have the right to restrict our processing of your personal data where

    you contest the accuracy of the personal data until we have taken sufficient steps to correct or verify its accuracy

    the processing is unlawful but you do not want us to erase the data

    we no longer need your personal data for the purposes of the processing, but you require such data for the establishment, exercise or defence of legal claims; or

    you have objected to processing justified on legitimate interest grounds (see below) pending the verification as to whether we have overriding compelling legitimate grounds to continue the processing.

    Where personal data is subject to restrictions in this way, we will only process it with your consent or for the establishment, exercise or defense of legal claims

    Right to object to the processing – provided that the conditions of the law are met, you have the right to object to the processing of your personal data. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or where we need to process the data for the establishment, exercise or defense of legal claims

    You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data infringes applicable law. In Cyprus that is th

    Office of the Commissioner for Personal Data Protection
    https://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/home_el/home_el?opendocument

    Office address:
    1, Iasonos, 1082 Nicosia, Cyprus

    Postal address
    P.O.Box 23378, 1682 Nicosia, Cyprus

    Tel: +357 22818456
    Fax: +357 22304565
    Email: commissioner@dataprotection.gov.cy

    For further information regarding your rights, to exercise any of your rights, or if you have any questions regarding the processing of your personal data please send an email to privacy@serpzilla.com

    Please note that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly unfounded or excessive. We will endeavor to respond to your request within all applicable timeframes.

  5. 5. MINIMUM AGE

    Protecting the safety and privacy of children is very important to us. We do not accept registrations submitted by, and will not knowingly collect or use personal data from anyone under the age of fourteen (14) years. By registering and using our platform, you confirm that you have reached fourteen (14) years of age.

  6. 6. DATA SECURITY

    SERPZILLA uses appropriate technical, physical, legal and organizational measures, which comply with data protection laws to keep your personal data secure.

    As most of the personal data we hold is stored electronically we have implemented appropriate IT security measures to ensure this personal data is kept secure, including the use of strong encryption, access restriction and extensive logging and auditing functionality in our production systems. We have procedures in place at our premises to keep any hard copy records physically secure. We also train our staff regularly on data protection and information security.

    In the event SERPZILLA will engage a third party as a data processor (including our service providers) to collect or otherwise process personal data on our behalf, such processor will be selected carefully and required to use sufficient guarantees, in particular in terms of expert knowledge, reliability and resources as well as appropriate technical and organisational measures which will meet the requirements of the General Data Protection Regulation (GDPR), including those referring to the security of processing.

    Unfortunately, no data transmission over the Internet or any electronic data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any personal data you might have sent to us has been compromised), please immediately notify us.

  7. 7. RETENTION PERIOD

    We will retain your personal data for as long as is necessary for the purposes for which we collect it during the performance of our contract, always taking into consideration each time applicable statute of limitations.

    For example:

    where we hold your personal data to comply with a legal obligation (including your security and avoidance of fraudulent behavior), we will keep the information for at least as long as is required to comply with that obligation;

    where we hold your personal data in order to provide you with a service (such as in order to ensure at all times that our services are properly functioning), we will keep the information for at least as long as we provide the service, and for a number of years thereafter, as appropriate or required by law.

    We will retain your data for a period of five years after termination of the contractual relationship at your request or by us for cause (e.g. in a case of non-payment). Moreover, statutory provisions (e.g. retention periods under tax legislation) require that we retain data for six years and under conditions, up to twenty years, from the end of the referenced financial year.

  8. 8. CHANGES TO THE PRIVACY POLICY

    We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business activities, legal requirements, and the manner in which we process personal data.

    Should we do so, we will notify you by various procedures through the platform (for example, through a banner, a pop-up or a push notification), or we may even send you a notice to your e-mail address or your mobile device.

    In any case, we suggest you review this Privacy Policy from time to time in case minor changes are made or we make any interactive improvement, taking the opportunity that you will always find it as a permanent point of information on our platform.

  9. 9. CONTACT

    For further information regarding your rights, to exercise any of your rights, or if you have any questions regarding the processing of your personal data please send an email to privacy@serpzilla.com

    SERPZILLA has appointed DK HAUS GRUPPE LTD as Data Protection Officer to oversee compliance with this Notice. If you have any questions about this Notice or how we handle your Personal Data, or you wish to exercise your rights, please send an email to vik@hausgruppe.org.