Privacy Policy

Last Revised: August 19th, 2020

In order to ensure transparency and give you more control over your Personal Data, this privacy policy (“Privacy Policy”) governs how we, Chompi CCnetworkings Ltd. d/b/a Bidalgo and its affiliates (together “Bidalgo”, “we”, “our” or “us”) use, collect and store personal data we collect or receive from or about you (“you”) such as in the following use cases:

When you browse or visit our website, https://www.bidalgo.com (“Website”)
When you make use of, or interact with, our Website
1. When you create an account and when you log into our platform
2. When you request and schedule a demo
3. When you subscribe to our newsletter
4. When you contact us via the “let’s talk” (e.g. chat, customer support, request help, submit a request)
5. When you apply for a job and we process your job application

When you attend a marketing event and/or we exchange business cards and you provide us with your Personal Data for marketing purposes
When we use the Personal Data of our resellers, distributors, agents and/or finders (e.g. contact details)
When we use the Personal Data of our customers (e.g. contact details)
When we use the Personal Data of our service providers (e.g. contact details)
When you interact with us on our social media profiles (e.g., Facebook, Instagram, LinkedIn, YouTube)

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of contents:

What information we collect, why we collect it, and how it is used
How we protect and retain your Personal Data
How we share your Personal Data
Additional information regarding transfers of Personal Data
Your privacy rights
Use by children
Log files
Analytic tools
Specific provisions applicable under California privacy law
Contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Site or by other means.

WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Specific Personal Data we collect

Why is the Personal Data collected and for what purposes?

Legal basis (GDPR only, if applicable)

Third parties with whom we share your Personal Data

Consequences of not providing the Personal Data

When you browse or visit our Website

Cookies, pixels, analytic tools and log files

For more information, please read our cookies policy https://www.bidalgo.com/cookie-policy/

To develop, display, and track content and advertising tailored to your interests on our service and other sites, including providing our advertisements to you when you visit other sites

To create cumulative statistical data and other cumulative information and/or other conclusive information that is non-personal

To improve our Website and provide related services

Consent

Legitimate interest (e.g. essential cookies)

3rd party platforms such as:

SiteGround

HubSpot

Certain Website features may not be available

Read more about the purposes of each cookie here https://www.bidalgo.com/cookie-policy/

When you make use of, or interact with, our Website

When you create an account and when you log into our platform

Username

Password

SSO email

Any other information that you decided to provide or supply us with

To create an account, and log in

To enjoy features available to registered users only

To give you access to our platform

To provide and improve our services and manage our business

To customize your experience

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (i.e. to engage with Bidalgo).

Legitimate interest (e.g., to allow you to login to your account and use Bidalgo’s platform).

3rd party platforms such as:

Leaseweb

AWS

Google Cloud

Cannot create an account and log in

Cannot enjoy all the features available to registered users

Cannot give you access to our platform

Cannot provide and improve our services and manage our business

Cannot customize your experience

When you request and schedule a demo

Full name

Email address

App name

Company

Job title

Phone

User acquisition monthly spend

Current media buying tool

Preferred pricing plan / requested services

Country

Your comments

Any other information you provide us with

To provide you with a demo of Bidalgo’s services

Legitimate interest (e.g. to provide a demo)

3rd party platforms such as:

Leaseweb

AWS

Google Cloud

Cannot provide you with a demo

When you subscribe to our newsletter

Email address

To send you marketing communications

To send you updates, notices, notifications, announcements, and additional information related to the services

Consent

3rd party platforms such as:

HubSpot

Salesforce

Cannot send you marketing communications

Cannot send you updates, notices, notifications, announcements, and additional information related to the services

When you contact us via the “let’s talk” (e.g. chat, customer support, request help, submit a request)

Full name

Email address

App name

Company

Job title

Phone

User acquisition monthly spend

Current media buying tool

Preferred pricing plan / requested services

Country

Your comments

Any other information you provide us with

To process and answer your questions and respond to your requests

To be able to manage your account and provide you with customer support

To customize your experience

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest

(e.g., to process and answer your questions)

3rd party platforms such as:

HubSpot

Salesforce

Cannot process and answer your questions and respond to your requests

Cannot manage your account and provide you with customer support

Cannot customize your experience

Full name

Email address

To send you marketing communications

Consent

3rd party platforms such as:

HubSpot

Salesforce

Cannot send you marketing communicaitons

When you apply for a job and we process your job application

Full name

Email address

Phone number

Resume

LinkedIn Profile URL

Personal website

Any other information that you decide to provide/supply us

To process your job application

To assess your suitability for the role

To schedule an interview

To communicate with you regarding the role

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to process your job application)

3rd party platforms such as:

Comeet

Cannot process your job application

Cannot assess your suitability for the role

Cannot schedule an

interview

Cannot communicate with you regarding the role

When you attend a marketing event and/or we exchange business cards and you provide us with your Personal Data for marketing purposes

Full name

Company name

Email address

Phone number

Country

Any other data you decide to provide/supply

To establish a business connection

To display or send to you marketing and advertising material and general and personalized content and advertisements via the services

Consent

Legitimate interest (e.g. to send you more information about Bidalgo)

3rd party platforms such as:

HubSpot

Salesforce

Cannot establish a business connection

Cannot display or send to you marketing and advertising material and general and personalized content and advertisements via the services

When we use the Personal Data of our resellers, distributors, agents and/or finders (e.g. contact details)

Full name

Company name

Job title

Business address

Phone number

Payment information

Any other data you decide to provide/supply

To discuss business terms and to perform the applicable agreement

To communicate with our resellers, distributors, agents and/or finders

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Legitimate interest (e.g. send you contract-related communications).

3rd party platforms such as:

Salesforce

Cannot discuss business terms and to perform the applicable agreement

Cannot communicate with our resellers, distributors, agents and/or finders

When we use the Personal Data of our customers (e.g. contact details)

Full name

Company name

Job title

Business address

Phone number

Payment information

Any other data you decide to provide/supply

To provide our services

To perform the applicable agreement

To communicate with our customers (e.g., to inform you when a new version of our platform is available)

Processing is necessary for the performance of a contract to which our customer is a party.

Compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.).

Legitimate interest (e.g. send you contract-related communications).

3rd party platforms such as:

Salesforce

Cannot provide the services

Cannot perform the agreement

Cannot communicate with you

When we use the Personal Data of our service providers (e.g. contact details)

Full name

Company name

Job title

Business address

Phone number

Payment information

Any other data you decide to provide/supply

To contact our service providers and suppliers

To perform the applicable agreement

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Legitimate interest (e.g. perform the contract, send contract-related communications)

3rd party platforms such as:

None

Cannot contact our service providers and suppliers

Cannot perform the applicable agreement

When you interact with us on our social media profiles (e.g., Facebook, Instagram, LinkedIn, YouTube)

User name

Any other data you decide to provide/supply

To reply and/or respond to your request or question

Legitimate interest (e.g. to respond your questions)

3rd party platforms such as for the following purposes:

Facebook [Social media channel communication]

Instagram [Social media channel communication]

LinkedIn [Social media channel communication]

YouTube [Social media channel communication]

Twitter [Social media channel communication]

Cannot reply or respond to your request

Finally, please note that some of the abovementioned Personal Data will be used for fraud detection and prevention, and for security purposes. The abovementioned Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize your Personal Data “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

HOW WE PROTECT AND RETAIN YOUR PERSONAL DATA

Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

Retention of your Personal Data. Your Personal Data (as described above) will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. In addition to the retention periods mentioned above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually. Regarding retention of cookies, you can read more in our cookie policy https://www.bidalgo.com/cookie-policy.

HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described above, we may share your Personal Data as follows:

With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies.
To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;
In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events; and/or
Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

If you want to receive the list of the current recipients of your Personal Data, please make your request by contacting us to privacy@bidalgo.com.

ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

Storage: Leaseweb – Amsterdam, AWS and Google Cloud – EU, US East and US West

Access from Israel: Access from Israel is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

Access from UK: The access from the UK does not required to have transfer mechanism in place.

Internal transfers: Transfers within the Chompi CCnetworkings Ltd. will be covered by an internal processing agreement entered into by members of the Chompi CCnetworkings Ltd. (an intra-group agreement) which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to.

External transfers: Where we transfer your Personal Data outside of EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your Personal Data.

YOUR PRIVACY RIGHTS

The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;
You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;
You have the right to object, to or to request restriction, of the processing;
You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
You have the right to object to profiling;
You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the CCPA:

You have the right to know what personal information is being collected about you;
You have the right to request the erasure/deletion of your personal data (e.g. from our records and the records of our service providers). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
You have the right to know whether your personal information is sold or disclosed and to whom;
Restriction of, or object to, processing of your Personal Information, including the right to opt in or opt out of sale of your Personal Information to third parties, if applicable, where such requests are permitted by law;
You have the right to equal service and price, even if you exercise your privacy rights;
You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence (e.g. the Attorney General in your State). We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

You can exercise your rights by contacting us at privacy@bidalgo.com. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

USE BY CHILDREN

We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@bidalgo.com.

LOG FILES

We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Site, track users’ movement around the Site, and gather demographic information.

ANALYTIC TOOLS AND OTHER TOOLS

Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personal information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
Hotjar. The Website uses Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our Website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy at https://www.hotjar.com/legal/policies/privacy. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our Website and Hotjar’s use of tracking cookies on other websites on this link https://www.hotjar.com/legal/compliance/opt-out.
Google API. Our Website and platform uses Google API in order to monitor, analyze and optimize AC campaigns. For further details please see the Google API terms of service at https://developers.google.com/terms and the Google privacy policy at https://policies.google.com/privacy.
YouTube API. Our Website and platform uses YouTube API to analyze creative performance and distribute new creatives. For further details please see the YouTube API terms of service at https://developers.google.com/youtube/terms/api-services-terms-of-service and the Google privacy policy at https://policies.google.com/privacy.
We reserve the right to remove or add new analytic tools.

SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW
- This Privacy Policy for California Residents supplements and is expressly made part of the information contained in this Privacy Policy, and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Privacy Policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Privacy Policy.
- Our California Do Not Track Notice: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, but we may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.
- Deletion of Content from California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or personal information you have publicly posted. If you wish to remove such content or personal information and you specify which content or personal information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or personal information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.
- Sale of Personal Information. Disclosure of Personal Information for business purposes. Financial incentives for collection of personal information: We do not sell any personal information and we do not disclose any personal information for any business purpose. Therefore, we have not sold or disclosed consumers’ personal information for a business purpose in the preceding 12 months. Also, we do not offer financial incentives for collection of Personal Information.
- Your Choices

Personal Information collected in the last 12 months it is described above in Section 1. If you have further questions with respect the collection, use, disclosure or sale of your personal information, please make your request by contacting us to privacy@bidalgo.com.
Your privacy rights: Please see Section 5 above.
Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject “BLOCK” to marketing@bidalgo.com. Please note that the email must come from the email account you wish to block.
Non-Discrimination. If you decide to exercise your rights, you will not receive any discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA. However, note that some features of our website, our products and/or our services will not function without your Personal Information. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
- However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s

CONTACT US

If you have any questions (or comments), concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@bidalgo.com