Vinstant Privacy Policy

Updated December 10th, 2020

Welcome to the web site (the “Site”) of Smart Digital, LLC. (“Vinstant”, “we”, “us” and/or “our”). We believe that protecting our customers’ and business partners’ privacy is crucial to our business and values.

This Site is operated by Vinstant and has been created to provide information about our company and advertising automation services and related services (together with the Site, the “Services”) to our Service visitors (“you”, “your”). This Privacy Policy sets forth Vinstant’s policy with respect to information including personally identifiable data (“Personal Data”) and other information that is collected from visitors to the Site and Services.

Unless otherwise expressly stated herein, the terms used in this Privacy Policy shall have the meaning set forth in the General Data Protection Regulation (EU) 2016/679 (the “GDPR”).

Information We Collect

When you interact with us through the Services, we may collect Personal Data and other information from you, as further described below:

Personal Data That You Provide Through the Services: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services or use certain Services. Wherever Vinstant collects Personal Data we make an effort to provide a link to this Privacy Policy.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Vinstant and the authorized third parties referred to herein located in the United States, Netherlands, the Russian Federation.

Information we collect while you served our ads or pixels:

• - We provide ad-serving and performance measurement services to our clients.
• - We enable our clients to serve ads on third-party websites and we track the performance of those ads so that our clients can measure the performance of their advertising campaigns and improve the way they run the campaign while the campaign is progressing.
• - We occasionally enable clients to interact more closely with users who choose to engage with one of the ads running on our platform: and "engagement" is a clear indication by the user that they want to interact with the ad, including clicking on the ad, interacting with the ad, watching video in the ad, submitting forms for more information or to send a comment, and the like.
• - We also provide some clients with the ability to measure performance of other parts of their campaign, including measuring the performance of their campaign through other ad-servers by providing them with "measurement pixels". When you are shown one of these ads then we collect some information about you that is generally non-personally identifiable.

What exactly we collect while you served our ads or pixels:

• - When you are shown an ad or other device from our system then we may collect general usage information about your browser and system. This information may include browser information, operating system, IP address, referring website, search keywords. We may record this information with a timestamp and a record of the pages you viewed. This is standard practice by website operators.
• - Any Non-PII (Non-Personal Identifiable Information) is held on our systems and systems under our direct control.

We may set a cookie in your browser to enable us to recognise users who we have seen before in order to measure the effectiveness of a campaign, or to perform re-targeting in order to improve relevancy of our ads. “Cookies” are data files, which often include an anonymous unique identifier, sent to your browser from a website. Cookies can only be read by the party placing the cookie, they cannot erase or alter any of your data and when used in the context of collecting Non-PII, they do not include personal data. For more information about cookies visit www.allaboutcookies.org (http://www.allaboutcookies.org/).

Mobile Identifiers

When you are using a mobile application that incorporates our Services, we may also automatically record your Google Advertising ID (if you are using an Android device) or your Advertising Identifier (IDFA – if you are using an iOS device; together with the Google Advertising ID – "Mobile Advertising IDs"), for advertising or analytics purposes. The Google Advertising ID is an anonymous identifier, provided by Google Play services. If your device has an Advertising ID, we may collect and use it for advertising and user analytics purposes. If your device does not have Advertising ID, we may use other persistent identifiers. The information collected may be also stored on your device. Please see below how you can reset you mobile Advertising ID or opt-out of receiving targeted ads through your mobile Advertising IDs.

Mobile Device Opt-Out

You may opt out of receiving targeted ads on mobile devices using the Android operating system, iOS or iPadOS, by using platform level controls enabled through your device settings. You should consult your device settings and instructions provided by your device manufacturer. However, we provide the following information solely for informational purposes.

If you have an Apple device, you can opt out of targeted advertising by updating to iOS 6.0 or higher, and setting "Limit Ad Tracking" to "ON". You can do this by clicking on Settings -> Privacy -> Advertising, and toggling "Limit Ad Tracking" to "ON". This prevents apps that you use from using your Apple device’s Advertising Identifier to serve you targeted ads. In addition, or as an alternative, you may reset your device’s Advertising Identifier, which will result in your device being disassociated from ad targeting profiles based on the Advertising Identifier in effect prior to reset. You can do this by clicking on Settings -> Privacy -> Advertising -> Reset Advertising Identifier. Again, you should consult Apple’s support web pages and instructions for the most current applicable settings.

If you have an Android device, you can opt out of targeted advertising on your device. You can do this by clicking the menu icon to display the apps list, then find and select the Google Settings icon, then find and select "Ads" and check the box "Opt out of interest-based ads". In addition, or as an alternative, you may reset your device’s Android advertising ID, which will result in your device being disassociated from ad targeting profiles based on the Android advertising ID in effect prior to reset. You can do this by clicking the menu icon to display the apps list, then find and select the Google Settings icon, then find and select "Ads" and selecting "Reset advertising ID". Note that Android settings menus may vary among device manufacturers and these instructions may not be accurate for your device. You should consult Google’s settings and instructions for the most current settings information.

Other Information

Non-Identifiable: Data When you interact with Vinstant through the Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Vinstant may store such information itself or such information may be included in databases owned and maintained by Vinstant affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process.

Information from Third Party Data Sources: The Vinstant Service also requires access to your data, as well as the data of your team members, that is stored in or made available through other third party data sources in order to aggregate, analyze and visualize this data. We have access to that information when you connect the Vinstant Services to these data sources, which may include your Personal Information or Confidential Information.

The Vinstant Service allows you to connect various data sources such as Facebook, Google Adwords, and Google Analytics, Mail.ru MyTarget and to aggregate, analyze and visualize advertising data from these data sources in Vinstant.pro website.

In operating the Services, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services and help us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features.

Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Services, Vinstant often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Vinstant may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Vinstant may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Google Analytics: We may allow third party service providers to use cookies or similar technologies to collect information about your browsing activities over time and across different websites following your use of the Services. For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Service. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.

Our Use of Your Personal Data and Other Information

Vinstant uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. Vinstant and its subsidiaries and affiliates (the “Related Companies”) may also use your Personal Data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services. Vinstant and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

If Vinstant intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

Further, Personal Data may be used for invoicing and to send important information to the Data Subject e.g. regarding changes of applicable fees, price list and conditions, or to contact the Data Subject and provide information customized Services according to the interests of the Data Subject.

We processes Personal Data on the following basis:

• - for the performance of the contract between us and the Data Subject (Article 6.1(b) of the GDPR);
• - for the performance of the contract between us and the Data Subject (Article 6.1(b) of the GDPR);
• - to comply with legal obligations applicable to us (Article 6(c) of the GDPR, such as corporate and accounting).

We may ask for certain Facebook permissions allowing us to perform actions with the Data Subject’s Facebook account and to retrieve information, including Personal Data, from it. This allows our Services to connect with the User’s account on the Facebook social network, provided by Facebook Inc. In this context, the following permissions may be asked: About Me, Access Rights (including but not limited to Ad Account Access, Business Manager Access), App Notifications, Contact Email, Manage Advertisements, and Manage Pages. For more information about the Facebook permissions, refer to the Facebook permissions documentation and to the Facebook Data Policy.

We may ask for certain MyTarget permissions allowing us to perform actions with the Data Subject’s MyTarget account and to retrieve information, including Personal Data, from it. This allows our Services to connect with the User’s account on the MyTarget advertising network, provided by Mail.ru Group.

Our Disclosure of Your Personal Data and Other Information

Vinstant is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

• - Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
• - Related Companies: We may also share your Personal Data with our Related Companies for purposes consistent with this Privacy Policy.
• - Agents, Consultants and Related Third Parties: Vinstant, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
• - Legal Requirements: Vinstant may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Vinstant, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

Your Choices:

• - You can visit the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services.
• - Managing cookies in your browser.
• - Most browsers allow you to control how cookies get used as you’re browsing.
• - Some browsers automatically limit or delete cookies. Also, in some browsers, you can set up rules to manage cookies on a site-by-site basis, allowing you to permit cookies only from sites that you trust.
• - For example, in Google Chrome, the Settings contain an option to Clear Browsing Data. You can use this option to delete cookies and other browsing data. Many other browsers have the same functionality.
• - Google Chrome also supports private browsing with its Incognito mode. You can browse in Incognito mode when you don’t want your site visits or downloads to remain in your browsing and download histories. Once you close all your Incognito browsing windows, Chrome won’t save your browsing history, cookies, and other data.
• - Losing the information stored in cookies may make Site or Services less functional or stop them from working.

Exclusions

This Privacy Policy does not apply to any Personal Data collected by Vinstant other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to Vinstant through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Vinstant shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Children

Vinstant does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to Vinstant through the Services, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Web Sites

This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by Vinstant (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that Vinstant endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Integrating Third Party Services

One of the features of the Service is that it integrates information from various third party services like Facebook, Google and MyTarget (“Third Party Service(s)”). To take advantage of the Services, you will need to provide your login credentials for each Service that you connect to. When you add a Third Party Services account to the Service, we will collect relevant information necessary to enable the Service to access that Third Party Service and your data contained within that Third Party Service. As part of such integration, the Third Party Service will provide us with access to certain information that you have provided to the Third Party Service, and we will use, store and disclose such information in accordance with this Privacy Policy. However, please remember that the manner in which Third Party Services use, store and disclose your information is governed by the policies of such third parties, and Vinstant shall have no liability or responsibility for the privacy practices or other actions of any Third Party Services that may be enabled within the Service.

Security

Vinstant takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to Vinstant via the Internet.

Other Terms and Conditions and Data Security Policies

Your access to and use of the Services is subject to the Terms of Service at vinstant.pro/terms.

Changes to Vinstant’s Privacy Policy

The Services and our business may change from time to time. As a result, at times it may be necessary for Vinstant to make changes to this Privacy Policy. Vinstant reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Access to Information

To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services.

Contacting Vinstant

Please also feel free to contact us if you have any questions about Vinstant’s Privacy Policy or the information practices of the Services.

You may contact us as follows: info@vinstant.pro.