Privacy Policy

CADS Iraq (“Mediam”) respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you about how we use your personal data when you visit our website (“Website”) and use our services and tell you about your rights and how the law protects you.

This Privacy Policy is provided in a layered format. You can click through to the specific areas below:

1. IMPORTANT INFORMATION AND WHO WE ARE
2. FOR RESIDENTS IN IRAQ
3. FOR RESIDENTS IN THE EU/EEA, UK AND SWITZERLAND
   1. PERSONAL DATA WE COLLECT ABOUT YOU
   2. HOW WE COLLECT YOUR PERSONAL DATA
   3. HOW WE USE YOUR PERSONAL DATA
   4. YOUR RIGHTS
   5. COOKIES
   6. SHARING YOUR PERSONAL DATA WITH THIRD PARTIES
   7. INTERNATIONAL TRANSFERS
   8. DATA SECURITY
   9. HOW LONG WE KEEP YOUR PERSONAL DATA FOR
   10. GLOSSARY

I. IMPORTANT INFORMATION AND WHO WE ARE

This Privacy Policy aims at providing you with information on how Mediam collects and processes your personal data when you use our Website such as when you sign up to our newsletter and sign up for one of our events or webinars.
This Website is not intended for children, and we do not knowingly collect data relating to children. It is important that you read this Privacy Policy so that you are fully aware of how and why we are using your personal data.

i. CONTROLLER

Aleph Group Inc. is the holding company of different legal entities, including CADS IRAQ, which is the provider of this Website. When we use “Mediam”, “we”, “us”, or “our” in this Privacy Policy, we are referring to the relevant company, member of the Aleph Group, providing you services which is considered to be the Data Controller of your personal data.

We have appointed a Group Data Protection Officer who is responsible for overseeing compliance with applicable data protection legislation and will respond to your questions about this Privacy Policy. If you have any questions about this Privacy Policy, including requests to exercise any of your rights, please contact our Group Data Protection Officer using the details below

ii. CONTACT DETAILS

If you have any questions about this privacy policy or our personal data processing practices,, please contact us at:
Email address: privacy@alephholding.com and privacy@httpool.com

iii. CHANGES TO THE PRIVACY POLICY

We keep our Privacy Policy under regular review. This version was last updated on June 24th, 2023. You can obtain historic versions by contacting us via email.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes at any time.

iv. THIRD PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. For example we may use Mailchimp for the contact forms on the website, Google's Blog, Skillshop and we might link to content on our partner's websites or other similar sites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

II. FOR RESIDENTS IN IRAQ

If you reside in Iraq, the country’s local legislation does not require us to offer you a detailed overview of how and why we collect and use your personal data. However, for informational purposes, you can visit section III (i., ii., iii.) below if you are interested in learning more about this. You might have certain rights under applicable civil laws in Iraq when it comes to your personal data. You can contact us to inquire further information or exercise your rights. If you try to exercise a right not granted to you under your country’s applicable legislation, we will let you know as soon as possible. In all other instances, we will respond to your request within the deadline set in the applicable legislation (if any).

To get more information about transfers of personal data outside Iraq, cookies, information security, retention, and sharing your personal information with third parties, please go to section III (vii., v., viii., ix., and vi.).

III. FOR RESIDENTS IN THE EU/EEA, UK AND SWITZERLAND

i. PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together below:

1. On our websites: We collect personal data when you fill out and submit forms (for example, when you register for a webinar) or interact with our sites (for example cookies). We may collect your email address, full name and IP address. We may also ask whether you are an agency or advertiser, what country you come from, and other relevant business information. You can freely browse our website without having to provide personal data.
2. Special events: When you register for our Mediam webinars or special events, we collect information such as your full name, address, telephone number and email address. We may use this information to contact you and, in some cases, assist you with registration.
3. Client Onboarding information: the personal data you provide to us when you fill out the Onboarding questionnaire for our services.
4. Customer Testimonials: We post comments and testimonials on our websites and these may contain personal data. We obtain consent from each client by email or through other agreements with us before publishing their name and testimonial.
5. Linking with Google: If you use linking from Gmail or your Google account to link your Google Ads account, you will be asked to give us access to information from your Google Ads or Google account. The use and transfer to any other application of information that Mediam receives from Google APIs adheres to the Google API Services User Data Policy, including limited use requirements.
6. Integration with Google Ads: For the connection with Google Ads to work correctly, Mediam will be able to see the main KPIS of your campaigns, upload and download them, and store their content and titles. Mediam uses these permissions to activate the features of our Impression Share and recommendations platform, which will allow it to show you relevant information and recommendations to improve your campaigns. The use and transfer to any other application of information that Mediam receives from Google APIs adhere to the Google API Service User Data Policy, including limited use requirements.

We also collect, use and share Aggregated Data, such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy

We do not collect any Special Categories of Personal Data about you (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data under applicable law, or under the terms of our contract, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to discontinue our services to you, but we will notify you before that happens

ii. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data about you.

• Direct interactions. You may provide to us your personal data by filling in forms or by corresponding with us by post, over the phone or via email. This includes personal data you provide when you;
  • Apply for our products or services;
  • Subscribe to our service or publications;
  • Request marketing to be sent to you;
  • Enter a competition, promotion or survey; or
  • Give us feedback or contact us.
• Automated technologies or interactions. We may collect this information directly from you, from your organization, and from third parties who own or operate applications available in the Service. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for more information.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

  Technical Data from the following parties:

  1. Analytics providers
  2. Advertising networks
  3. Search information providers
  4. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  5. Identity and Contact Data from data brokers or aggregators
  6. Identity and Contact Data from publicly available sources
  7. Social media interactions with any of our channels

iii. HOW WE USE YOUR PERSONAL DATA

Below you can find the details of how we use your personal data and the legal bases we rely on to do so. Please note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. You can contact us if you need more details.

We use the information you provide to Mediam to promote our products, services and events. For example, we use your email or postal address to send you information or content from Google Ads that we think you might be interested in and marketing communications related to our company. We also use this data to promote the use of our services and share promotional and informational content with you in accordance with your communication preferences. In addition, we may contact you by phone to discuss other Mediam products or services that may be of interest to you. If you have a scheduled call with a Mediam representative, we may record and transcribe the call. We will notify you of this beforehand, so that you can cancel it if you wish.

For use of Mediam GPS

• We use your account information and customer data to provide you with our products and services. For example, we use the email address you provide us when you sign up to create your user account.
• We collect data about how our products and services are used by monitoring and tracking our users. We use this data to develop and improve our products and services. For example, usage data allows us to evaluate trends and product usage to help us determine what new features or integrations our users might be interested in. We may share Usage Data externally, but only after it is anonymized and/or aggregated to create or improve features.
• We use anonymized customer information for machine learning that is used in certain features and functionality of products within the subscription service. For example, machine learning is used to improve the business card scanning tool when you use our mobile apps and makes it easier to import information into your Mediam account. You can request that your data not be used for the latter purpose by sending an email to us.

To protect Mediam users:

• We use your account information to investigate and prevent security incidents. We may also use this information to comply with legal requirements.

For research and development purposes:

• We may provide statistical information to Google about our users, although such information will not be used to identify any individual person and will only be shared in an aggregated, deidentified manner; for example, we might post blog posts about trends and product interaction data.

Other activities we can do with your consent.

There may be cases where Mediam discloses your information for purposes not listed above. Mediam will take steps to provide notice to you prior to these unforeseen disclosure

We will share your data with third parties after you give us your permission to do so.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising

PROMOTIONAL OFFERS

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

iv. YOUR RIGHTS

In short: Under data protection legislation in the UK, EU/EEA and Switzerland you may have certain rights, including but not limited to the right to access or manage your personal data, to delete or update it, and restrict its use.

1. Right to be informed: you have the right to be informed about how we collect and use your personal data. We provide you with this information in this Privacy Policy and by answering any privacy-related questions you address to us.
2. Right to access your data: you have the right to request a copy of the personal data we hold about you.
3. Right to rectification: you have the right to have inaccurate or incomplete personal data rectified.
4. Right to erasure: under certain circumstances, you may have the right to have your personal data deleted. Examples of when this request may be granted include when:
   • it is no longer necessary to process your data for the purpose it was collected
   • you have withdrawn your consent for consent-based data processing,
   • we have used your personal data unlawfully, or
   • we have a legal obligation to remove your data.
5. Right to restrict or object to the processing of your personal data: in certain circumstances, we may agree to restrict or suppress the processing of your personal data. Examples of when we may agree to this include:
   • you have asked us to verify the accuracy of your data,
   • we have processed your data unlawfully, but you do not wish your data to be deleted,
   • we no longer need your personal data, but you do not wish your data to be deleted in order to establish, exercise, or defend a legal claim, or
   • you objected to us using your personal data, but your objection was outweighed by our legitimate interests.
6. Right to challenge an automated decision: you have the right to request us to manually review an automated decision made about you if that decision has a legal or similarly significant effect on you.
7. Right to withdraw consent: if the legal basis we use for the processing of your personal data is consent, you can withdraw your consent at any time.
8. Right to opt-out of commercial communication: you have the right to opt-out of any future commercial communication through the unsubscribe link provided with each commercial email. You further have the right to not be contacted by phone regarding any commercial offering. Please note that your country may offer a telemarketing do-not-calllist.

If you wish to exercise any of the rights set out above, please contact us at: privacy@httpool.com or privacy@alephholding.com.

HOW TO EXERCISE YOUR RIGHTS

If you wish to exercise any of your rights, please use the information provided under Contact Details above.

HOW TO LODGE A COMPLAINT

You have the right to lodge a complaint with your national data protection authority if you are not satisfied with how we use your personal data. A list of all competent authorities in the EU can be found here. In the UK, you can refer the issue to the Information Commissioner’s Office (“ICO”), the UK’s supervisory data protection authority. If you reside in Switzerland, you can contact the Federal Data Protection and Information Commissioner (“FDPIC”).

v. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see COOKIE POLICY.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

vi. SHARING YOUR PERSONAL DATA WITH THIRD PARTIES

1. Aleph group companies

   We share your personal data within the Aleph group of companies to:

   1. provide you with the best service;
   2. send you information about Aleph products and services we think you’ll be interested in hearing about.

2. Suppliers

   Here we have included companies that help Aleph Express provide the services you use, and need to process details about you for this reason. We always share as little information as we can and encrypt and/or make it impossible for the recipient to identify you where possible. These are:

   • payment processing partners;
   • analytical and cyber security service providers that help us with fraud and security checks;
   • cloud computing power, storage and software providers;
   • our business intelligence and analytics platform provider;
   • companies that help us with functional analytics (to help us solve technical problems with the app, for example);
   • companies that help us with marketing (we won't share identifiable personal data with third parties for their own direct marketing unless you give us permission, and you can opt out any time);
   • software companies that we use to email you, or for processing and storing emails with you;
   • companies that help us with customer support, surveys, and developers.

3. Partners who help to provide our services

   We may share your personal data with our partners to provide you with certain requested services. We‘ll only share your personal data in this way if you have asked for the relevant service. From time to time, we may work with other partners to offer co-branded services or promotional offers, and we will share some of your personal data with those partners. We will always make sure you understand how we and our partners process your personal data for these purposes.

   For example, we will share your personal data with Google, for the purpose of direct communications or quality assessments. We obtain the consent of each client by email or through other means before sharing your personal data with Google.

4. For legal reasons

   We also share your personal data with government authorities, law enforcement authorities, tax authorities or courts:

   • if we have to do so under any law or regulation;
   • if we sell our business;
   • in connection with suspected or actual criminal or fraud investigations;
   • to enforce our rights (and those of our customers or others);
   • in connection with legal claims.

   We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

vii. INTERNATIONAL TRANSFERS

We may share your personal data within the Aleph Group Inc.
Mediam will store your personal data in accordance with your local regulations and will provide the security required to protect it

TRANSFERRING DATA OF EU/EEA, UK AND SWISS RESIDENTS

Is my personal data transferred internationally?

In short: We may transfer, store, and process your information in countries other than your own. We provide an international service which, in some instances, may require transferring, storing, and processing of your personal data in a country outside the UK, EU/EEA and Switzerland. To do so, we have taken all necessary steps to ensure that your data is afforded a level of protection that is essentially equivalent to that guaranteed within the EU/EEA, the UK and Switzerland. For that reason, we will only transfer your data to a third country:

• if the European Commission has adopted a decision confirming that a third country provides adequate protection (or the competent authority in Switzerland) has done so for transfers outside these territories; or
• if we’ve agreed to Standard Contractual Clauses (“SCCs”) approved by the European Commission (for EEA), to SCCs via the ICO’s UK Addendum (for the UK) or an equivalent mechanism (for Switzerland) with a third party.

viii. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

ix. HOW LONG WE KEEP YOUR PERSONAL DATA FOR

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

You can request details of retention periods when we process your personal data by contacting us.

In certain cases, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

HOW AND WHEN WE WILL RESPOND TO YOUR REQUEST

We strive to promptly respond to your requests. In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the reasons that prevent us from complying with your requests. In cases where we are not processing your personal information, we will indicate to you the natural or legal person to whom you should address your requests, if we are in the position to do so.

We try to respond to all requests as soon as possible and at least within one (1) month of receiving the request. However, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.

You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.

In the latter case, we’ll respond as soon as possible, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.

WHAT WE MAY NEED FROM YOU

We may need additional information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure we need to have so that personal data is not disclosed to any person who is not authorized to receive it . We may also contact you to ask you for further information in relation to your request to speed up our response.

YOU EXPRESSLY ACKNOWLEDGE THAT YOU HAVE READ THIS PRIVACY POLICY AND YOU UNDERSTAND THE RIGHTS, OBLIGATIONS, TERMS AND CONDITIONS SET FORTH HEREIN.

x. Glossary

GOOGLE: means Google EMEA HQ, Dublin 4 Ireland and its affiliates. LAWFUL BASIS
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.