GDPR

For Underdog Media’s complete privacy policy, click HERE.

Articles 13 and 14 of the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0679&from=EN

Article 13

Information to be provided where personal data are collected from the data subject

Where personal data relating to a data subject are collected from the data subject, the controller shall, at the time when personal data are obtained, provide the data subject with all of the following information:

(a) the identity and the contact details of the controller and, where applicable, of the controller’s representative: The Data Collection Officer

(b) the contact details of the data protection officer, where applicable: privacy@underdogmedia.com

(c) the purposes of the processing for which the personal data are intended as well as the legal basis for the processing; L 119/40 EN Official Journal of the European Union 4.5.2016: Log Data is collected primarily for the purpose of identifying Invalid Traffic (IVT) or Non-Human Traffic (NHT).

(d) where the processing is based on point (f) of Article 6(1), the legitimate interests pursued by the controller or by a third party: Santa Barbara, CA, USA

(e) the recipients or categories of recipients of the personal data, if any: Underdog Media LLC

(f) where applicable, the fact that the controller intends to transfer personal data to a third country or international organization and the existence or absence of an adequacy decision by the Commission, or in the case of transfers referred to in Article 46 or 47, or the second subparagraph of Article 49(1), reference to the appropriate or suitable safeguards and the means by which to obtain a copy of them or where they have been made available. Underdog Media is concerned with safeguarding your information. We employ a variety of measures designed to protect your information from unauthorized access. Including secure socket layer authentication (SSL) for the transfer of Log Level Data which may include IP Address, Browser, Operating System, Referring URL and Time Stamp.

In addition to the information referred to in paragraph 1, the controller shall, at the time when personal data are obtained, provide the data subject with the following further information necessary to ensure fair and transparent processing:

(a) the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period ; 72 hours
(b) the existence of the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability. Yes, you may exercise your right to review, rectify or delete the personal information about you that is stored in our systems, or object to its processing for the purpose of personalized advertising, if such rights are conferred by applicable law. If you wish to exercise these rights, contact us, detailing the right you wish to exercise, through our address provided at the end of this policy or via email at privacy@underdogmedia.com . In order to process your request, we may require additional information or corroborative documents from you, to verify or confirm your identity.

(c) where the processing is based on point (a) of Article 6(1) or point (a) of Article 9(2), the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal: Santa Barbara, CA USA

(d) the right to lodge a complaint with a supervisory authority: Individuals have the right to lodge a complaint with a supervisory authority.

(e) whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data: Personal information is a contractual requirement for Publisher and Marketing clients of Underdog Media.

(f) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. Underdog Media does not engage in user profiling.

Where the controller intends to further process the personal data for a purpose other than that for which the personal data were collected, the controller shall provide the data subject prior to that further processing with information on that other purpose and with any relevant further information as referred to in paragraph 2. 4. Paragraphs 1, 2 and 3 shall not apply where and insofar as the data subject already has the information. Underdog Media only processes Log Level data for the purpose of identifying invalid traffic (as described above and on https://underdogmedia.com/privacy-policy/) from data acquired by our technology, ( https://udmserve.net) and processes personal information for the purpose of entering a contract with clients. Personal data is not processed for a purpose other than that for which the personal data were collected.

Article 14

Information to be provided where personal data have not been obtained from the data subject

Where personal data have not been obtained from the data subject, the controller shall provide the data subject with the following information:

(a) the identity and the contact details of the controller and, where applicable, of the controller’s representative: Data Collection Officer, Mike Tarpey

(b) the contact details of the data protection officer, where applicable: privacy@underdogmedia.com

(c) the purposes of the processing for which the personal data are intended as well as the legal basis for the processing: Log Data is collected primarily for the purpose of identifying Invalid Traffic (IVT) or Non-Human Traffic (NHT).

(d) the categories of personal data concerned: Underdog Media does collect some forms of Non-Personally Identifiable Information or what we refer to as Log Data. examples of Log Date include: the referring http location from the page our Underdog Media ad placement or technology was placed, the IP Address, browser type, operating system, and a timestamp of these related events.

(e) the recipients or categories of recipients of the personal data, if any: Underdog Media LLC

(f) where applicable, the fact that the controller intends to transfer personal data to a third country or international organization and the existence or absence of an adequacy decision by the Commission, or in the case of transfers referred to in Article 46 or 47, or the second subparagraph of Article 49(1), reference to the appropriate or suitable safeguards and the means by which to obtain a copy of them or where they have been made available. Underdog Media is concerned with safeguarding your information. We employ a variety of measures designed to protect your information from unauthorized access. Including secure socket layer authentication (SSL) for the transfer of Log Level Data which may include IP Address, Browser, Operating System, Referring URL and Time Stamp.

In addition to the information referred to in paragraph 1, the controller shall provide the data subject with the following information necessary to ensure fair and transparent processing in respect of the data subject:

(a) the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period : 72 hours

(b) where the processing is based on point (f) of Article 6(1), the legitimate interests pursued by the controller or by a third party: Santa Barbara, CA USA

(c) the existence of the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject and to object to processing as well as the right to data portability: Yes, you may exercise your right to review, rectify or delete the personal information about you that is stored in our systems, or object to its processing for the purpose of personalized advertising, if such rights are conferred by applicable law. If you wish to exercise these rights, contact us, detailing the right you wish to exercise, through our address provided at the end of this policy or via email at privacy@underdogmedia.com . In order to process your request, we may require additional information or corroborative documents from you, to verify or confirm your identity.

(d) where processing is based on point (a) of Article 6(1) or point (a) of Article 9(2), the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal: Santa Barbara, CA USA

(e) the right to lodge a complaint with a supervisory authority: Individuals have the right to lodge a complaint with a supervisory authority.

(f) from which source the personal data originate, and if applicable, whether it came from publicly accessible sources: The information originates from the header of the webpage where our technology or ad placements have been placed, ( https://udmserve.net)

(g) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. Underdog Media does not engage in user profiling.

The controller shall provide the information referred to in paragraphs 1 and 2:

(a) within a reasonable period after obtaining the personal data, but at the latest within one month, having regard to the specific circumstances in which the personal data are processed;

(b) if the personal data are to be used for communication with the data subject, at the latest at the time of the first communication to that data subject; or

Where the controller intends to further process the personal data for a purpose other than that for which the personal data were obtained, the controller shall provide the data subject prior to that further processing with information on that other purpose and with any relevant further information as referred to in paragraph 2. Personal data is not processed for a purpose other than that for which the personal data were collected.

Paragraphs 1 to 4 shall not apply where and insofar as:

(a) the data subject already has the information;
(b) the provision of such information proves impossible or would involve a disproportionate effort, in particular for processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, subject to the conditions and safeguards referred to in Article 89(1) or in so far as the obligation referred to in paragraph 1 of this Article is likely to render impossible or seriously impair the achievement of the objectives of that processing. In such cases the controller shall take appropriate measures to protect the data subject’s rights and freedoms and legitimate interests, including making the information publicly available;
(c) obtaining or disclosure is expressly laid down by Union or Member State law to which the controller is subject and which provides appropriate measures to protect the data subject’s legitimate interests; or
(d) where the personal data must remain confidential subject to an obligation of professional secrecy regulated by Union or Member State law, including a statutory obligation of secrecy.