Privacy Policy

PROTECTED MEDIA LTD. (“PROTECTED”)

 PRIVACY STATEMENT

1. • This Privacy Statement applies to Protected’s solutions and services (the “Services“).
   • For more information about how we process Personal Data collected through our website, please see https://www.protected.media/privacy-statement/.
   • For more information about how we process Personal Data collected through our dashboard, please see https://www.protected.media/privacy-statement/.
   • Capitalized Terms. All capitalized terms used but not defined herein shall have the meaning ascribed to them in the applicable data protection laws.
2. Protected attaches great importance to your right to privacy and the protection of your Personal Data. We want you to feel secure that when you deal with Protected, your Personal Data are in good hands. Protected protects your Personal Data in accordance with applicable laws and maintains the appropriate technical and organizational measures to protect your Personal Data against unauthorized or unlawful processing.
   • Personal Data. Protected does not require the processing of any Personal Data to provide its Services, except for the IP address of viewers of advertisements Protected analyzed delivered on a website or an app (“End Users“). In case a specific Protected customer (“Customer”) , in its role as controller, requires Protected to process additional Personal Data of such  End Users or individuals who create accounts and content within the Customer’s environments, Protected can accommodate such request and shall handle such Personal Data in accordance with any applicable law and regulation. In any such scenario, the determination as to what Personal Data is processed is made by the Customers, who in their role of controllers, also determine, in their sole discretion, the legal basis of processing of such Personal Information.
   • No Tracking, Targeting, or Profiling. Moreover, Protected does not (i) combine, analyze or enrich the Personal Data with additional information for the purpose of identifying End Users. As it relates to Protected’s Services, Protected limits any information it collects to information that does not allow the identification of an individual without additional information. For example, Protected may process IP addresses. While Protected treats such information as Personal Data, in accordance with best practices and applicable laws, it never combines that information with any other data that would enable Protected to identify the individual to whom it relates; (ii) track End Users or their online activities across apps and websites over time; (iii) rely on persistent technologies such as third-party cookies (unless configured otherwise by Customer); and/or (iv) create profiles or audience groups to target individuals.
   • No Legal Obligation. Neither Customer nor end user is under any legal obligation to provide Protected with Personal Data.
   • Data Retention and Pseudonymization. Any Personal Data processed by Protected (including the IP address of the Customer’s end user) will be pseudonymized by Protected within fourteen (14) days. Technical Information, as it is anonymous in nature, may be retained by Protected for 12 months or if needed as long as otherwise permitted by applicable laws and Protected’s agreements with its Customers.
   • Legal Basis. As it relates to law such as the GDPR, Protected’s legal basis for processing Personal Data through the Services as a data processor is the legitimate interest of: (i) Protected’s Customers avoid ad-related fraud and present geographically accurate and compliant information to End Users, (ii) the End Users receiving fraud-free and geographically accurate and compliant information, and (iii) the general public in the continued availability of a free internet.
   • IAB TCF. Protected participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Protected’s identification number within the framework is 762. Protected use legitimate interest as our basis for collecting data for the following purposes: (i) Ensure security, prevent and detect fraud, and fix errors (Special Purpose 1); (ii) Deliver and present advertising and content (Special Purpose 2); (iii) Save and communicate privacy choices (Special Purpose 3); (iv) Measure ad performance (Purpose 7); (v) Develop and improve services (Purpose 10).
3. Data Collected and Purposes. The categories of Personal Information and non-personal information (“Technical Information“) processed through the Services are outlined below. To the extent Personal Information is required for the operation of one or more features of a Service, such Personal Information will be used only for the specific purposes outlined below, unless otherwise required by law. Additionally, in some circumstances, it may be necessary to process the Personal Information in conjunction with some Technical Information for Services to properly function. In any such scenarios, the combined data is considered Personal Information and protected accordingly.

Categories of Technical Information collected and used to power the Services:

• Advertising campaign attributes – The identifier of the advertiser that delivers an advertisement, its campaign and placement identifiers, the identifiers of the media property selling the inventory to the advertiser or any intermediary advertising platform are collected and processed to identify the Customer we are servicing, to apply the correct settings for the Customer, to segment the Customer reports according to these identifiers and to bill the Customer.
• Web content attributes – The web address (URL) of the page/frame where the advertisement is being delivered to, and the address of any referring pages/frames are collected to ensure the ads are delivered in the right context the Customer has set in the profile settings in Protected system.
• Digital environment attributes – The type of connected device the advertisement is being delivered to: mobile, desktop, the browser type and version used to render the page where the ad appears and the operating system are collected to determine what version of our code would properly run in that environment and to properly measure if the advertisement had the chance to become viewable on the screen according to industry standards which vary between environments.
• Viewability attributes – The location of the advertisement on the page, the size of the advertisement, the size of the screen, the size of the viewport, the tab focus status, the browser focus status, the time duration the advertisement was in the viewable part of the webpage and the scroll position of the webpage are collected to determine and report to the Customers if the advertisement had the chance to become viewable on the screen.
• Exposure and engagement attributes – Data that shows if the advertisement was clicked is collected to help the Customers measure the performance of the advertisement, the advertising campaign or the media property.

Categories of data collected and used to power fraud identification and elimination:

• Pseudonymous electronic presence and device identifiers – i.e. IP address, user agent string or derivatives of these two values – are used in order to assess whether the online presence or device is participating in or associated with a fraudulent scheme.

• Country location, mobile identifiers for advertisers such as IDFAs; cookie IDs.

Protected may be required by some of its Customers, to process additional Personal Information to enable its Services. Such additional Personal Information may relate to End Users, to individuals who create accounts and content within the Customer’s environments. To the extent Protected is required by one of its Customers to process additional Personal Information, it shall process such Personal Information solely for the purpose of fulfilling its obligations to the Customer and strictly in accordance with the Customer’s instructions and applicable laws, as required to operate, maintain and, where applicable, improve the Services. We work diligently with these Customers to ensure the Personal Information processed is limited only to the Personal Information necessary to achieve these purposes. Since in these scenarios the specific categories of Personal Information are dependent on the custom integration and decisions of the Customer, and vary from Customer to Customer, if you have further questions, we recommend that you contact the individual Customer or review the privacy documentation they make available on their properties.

4. Data Security. Protected has taken appropriate technical and organizational measures to protect all information it collects from loss, misuse, unauthorized access, disclosure, alteration, destruction, and any other form of unauthorized processing. However, no data security measures can guarantee 100% security.
5. Data Subjects in the European Economic Area (EEA).
   • Legal Basis for Processing of Personal Data. If at all, Protected will only process data subject’s Personal Data, if it has a legitimate interest to process data subject ‘s Personal Data or if processing of data subject’s Personal Data is necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders; or with data subject’s
   • Data Subject’s Rights regarding Personal Data. Subject to applicable law, each data subject has certain rights with respect to its Personal Data, including the following:
     • data subject may ask whether Protected holds personal data about it and request copies of such Personal Data and information about how it is processed;
     • data subject may request that inaccurate Personal Data is corrected;
     • data subject may request the deletion of certain Personal Data;
     • data subject may request Protected to cease or restrict the processing of Personal Data where the processing is inappropriate;
     • When data subject consents to processing its Personal Data for a specified purpose by Protected, data subject may withdraw its consent at any time, and Protected will stop any further processing of data subject ‘s Personal Data for that purpose.
   • In certain circumstances, Protected may not be able to fully comply with data subject’s request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, however, in those circumstances, Protected will still respond to notify data subject of such a decision. 
   • Data subject can exercise its rights of access, rectification, erasure, restriction, objection, and data portability by contacting Protected at privacy@protected.media. In some cases, Protected may need data subject to provide it with additional information, which may include Personal Data, if necessary to verify data subject’s identity and the nature of data subject’s request.
     • Transfer of Data Subject ‘s Personal Data outside of the EEA. Personal Data may be processed outside data subject’s jurisdiction, and in countries that may not provide for the same level of data protection as data subject’s jurisdiction. Protected ensures that the recipient of data subject’s Personal Data offers an adequate level of protection, for example by entering into the appropriate data processing agreements and, if required, standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR).

6. Data Subjects in California, USA. To the extent the California Consumer Privacy Act of 2018, Cal. Civ. Code 1798.100 et seq. (“CCPA“), including any subordinate or implementing legislation, is applicable, the following shall apply:
   • Protected will only process Personal Information on Customer’s behalf.
   • Protected will (i) not collect, retain, use, or disclose Personal Information for any purpose other than for the specific purposes set out in this Privacy Statement; (ii) not sell Personal Information (as defined under the CCPA); and (iii) put in place appropriate technical and organizational measures to protect Personal Information against unauthorized or unlawful processing or accidental destruction, loss or damage.
7. Updating this Privacy Statement. Protected may from time to time revise this Privacy Statement to reflect updates in the Services, regulatory requirements, or other needs. Any modifications will be posted upon becoming effective.
8. Any Questions regarding Privacy at Protected? 

For any questions about this Privacy Statement or Protected’s data practices in general, please contact Protected using the following information:

Protected Media Ltd.

3 Shaham St., Petach Tikva, Israel

Email: privacy@protected.media

Last update: January 2025