Last updated on 2nd March 2020

• Introduction
Clever Advertising and its group companies (“Clever Advertising”) respect your privacy and are committed to protecting your personal data. This privacy notice (“Privacy Notice”) governs Clever Advertising’s use of personal data. The definition of personal data may vary from country to country. To ensure the protection of your personal data, we define it as any information that may, directly or indirectly, identify you.

• Who we are and what we do
Clever Advertising, Lda. (with registered office at Rua Doutor Brito Câmara, 20, 1, 9000-039 Funchal, Portugal, VAT number PT509477178) (“Clever Advertising”, “we” or “our”) is the controller of your personal data under this Privacy Notice with which you had, have or will have a relationship.
Clever Advertising is an advertising agency, specialised in media buying. We acquire advertising spaces from publishers located in different countries.

• User Types
Much of this Privacy Notice is divided into sections based on the way you may interact with Clever Advertising. Please determine what user type you are. For each user type we have explained what information we collect and why, what cookies and other similar technologies we use, how we share such information, and your rights.

Third-Party Users
Visitors of our Websites
Business Partners

• Sensitive Personal Data
Clever Advertising does not collect sensitive personal data. The definition of “sensitive personal data” varies from country to country. Clever Advertising considers sensitive personal data to be any information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs and trade union membership as well as data concerning your health, genetic and biometric information in addition to sex life or sexual orientation.

• Children’s Personal Data
Clever Advertising does not knowingly collect personal data from children. Please note that the definition of “children” is subject to local laws and may vary accordingly.

• Links to third-parties’ websites
Our websites contain links to third-parties’ websites, which we do not control. In this respect, we do not accept any liability for any content, product, service, privacy policy or practice of these third-parties’ websites.

• How we process your personal data
Clever Advertising processes your personal data at all times in accordance with the applicable privacy laws and the data protection principles.

Lawfulness, fairness and transparency
We process your personal data in a lawful, fair and transparent manner.

Purpose limitation
Your personal data is collected for specified, explicit and legitimate purposes and we do not process personal data in a manner incompatible with the purposes for which it was collected.

Data minimisation
We solely process personal data which is necessary for the purposes for which it is collected (e.g. provision of services).

We will keep your personal data as accurate and up to date as possible and you may rectify such data at any time.

Storage limitation
We do not retain your personal data for a longer period than is necessary for the purposes for which your personal data is processed.

Integrity and confidentiality
We implemented appropriate technical or organisational measures to ensure the protection of your personal data, including against unauthorised or unlawful processing and accidental loss, destruction or damage.]

• How long we retain your personal data
The data retention period of each Clever Advertising’s cookie is set out in our Cookie Notice.
Clever Advertising has data retention policies for the personal data we process that details the retention periods based on our analysis of the period each data is reasonably required for legal or business purposes. When we no longer need personal data for the purposes it was collected, we securely delete it.
Aggregated information, which cannot identify a natural person and is processed for analytical purposes is retained for as long as reasonably necessary.

• How we share your personal data

In addition to the description of how we may share your personal data for each user type (please see the How we may share information section for your user type), we may share your personal data as follows:
- within group companies, for business and operational purposes, as well as to their subcontractors or other third-parties;
- if we go through a business transition, such as acquisition by another company, a merger or the sale of all or a portion of our assets, your personal data will likely be among the assets transferred; - when we are legally required to do so.

• Personal Data transfers to outside the European Economic Area (the “EEA”)
If your personal data is collected within the EEA and transferred to countries outside the EEA in which the applicable laws do not ensures an adequate level of protection, we will provide for at least one of the following safeguards, and on the condition that enforceable data subject rights and effective legal remedies are available:

- we will transfer your personal data to countries for which the Commission has decided they ensure an adequate level of protection for personal data;
- where we partner with companies in the United States, we may transfer Personal Data to them if they are part of the Privacy Shield scheme, which requires them to provide a similar level of protection of your personal data to what is required in the EEA;
- we will execute an agreement with standard data protection clauses with our partners that are based in countries outside the EEA.

• What data subject rights you have
You have the following data subject rights:

- Right of access
You have the right to obtain from us confirmation as to whether we process your personal data. Should that be the case, you have the right of access to your personal data and to obtain further information concerning the processing of your personal data.
- Right to rectification
You have the right to have your personal data rectified if it is inaccurate and, in certain cases, completed if it is incomplete.

- Right to erasure (‘right to be forgotten’)
Under certain circumstances, you have the right to obtain the erasure of your personal data.

- Right to restrict processing
Under certain circumstances, you have the right to restrict the processing of your personal data.

- Right to data portability
You have the right to receive your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller, where technically feasible, and, in any case, where the processing is based on your consent or on a contract between us and is carried out by automated means.

- Right to object
Under certain circumstances, you have the right to object to the processing of your personal data.

- Right not to be subject to a decision based solely on automated processing
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you in a similar manner.
- Right to complain to a Data Protection Authority
If you consider that the processing of your personal data infringes any applicable privacy law, you have the right to complain to a competent supervisory authority, without prejudice to any other administrative or judicial remedy.

- Right to withdraw the consent
You have the right to withdraw your consent to the processing of personal data based on your consent, at any time.
This does not apply if the processing of your personal data is not based on your consent.
• Security of your personal data
Clever Advertising has implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk involved in order to protect your personal data against a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data transmitted, stored or otherwise processed.

Our employees and contractors are bound by confidentiality obligations regarding the personal data processed.

• Non-Discrimination
We will not discriminate you for exercising any of your rights.

• “Do Not Track”
Some browsers transmit “Do Not Track” (“DNT”) signals to websites. Clever Advertising does not respond to DNT signals or other mechanisms from these browsers.

• How this Privacy Notice may be amended
Clever Advertising reserves the right to amend this Privacy Notice at any time.
If we amend this Privacy Notice, we will publish a new version of this Privacy Notice on this website and provide a prominent notice that will be visible on our websites.
You should check this page regularly to confirm if the Privacy Notice has been amended. We will display the date of the latest amendment of this Privacy Notice at the top of the page, so you can see when it was last amended.
All amendments to this Privacy Notice shall come into force:
- on the day after its publication, if required by any applicable privacy law;
- within 7 (seven) days after its publication, if any other case.

• How to contact us
Should you have any questions regarding the processing of your personal data or should you intend to exercise your rights under any privacy law and/or this Privacy Notice, please send a request to [email protected]