Privacy Policy


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Last updated January 24, 2021

The present document contains the privacy policy provided by OnMedia Ltd. (“Company", "we", "us", "our") concerning the management and administration of the LadySmart website accessible via http://ladysmart.net (“Site”), and it regulates the data protection mechanisms provided by the LadySmart to any user of the information services and content accessible through the LadySmart website. If you have any questions or concerns about the content and security measures provided in this Privacy Policy, you may contact OnMedia Ltd. using the following email address: policy@onmedia.com.

We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have concerning it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

Personal Information We Collect

We at OnMedia Ltd. believe that protecting and safeguarding the confidentiality, integrity, and availability of data relating to you is an integral part of the values and objectives of the company and the level of service we offer.

Some of the services we offer require the processing of your personal data. This document gives you information about the compliance measures we have taken to protect your rights and freedoms in compliance with the principles of lawful, transparent, and conscientious processing of personal data.

You can exercise your right to object to the processing of personal data concerning you at any time by contacting us directly.

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, information about how you interact with the Site, log-in information for the Site; and others. We refer to this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:

  • “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
  • “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
  • “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

Additionally, when you make a registration or comment on the Site, we collect certain information from you, We refer to this information as “User Information.”

User information you provide to us directly may include any of the following information about you, depending on the portion of the Services used: your name; your email address; password, any user-generated content that you submit; information regarding your social media accounts; information provided when you correspond with us; and any updates to the information provided to us.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and User Information.

Principles Of Personal Data Processing

We process personal data per the following principles:

Legality, transparency, and good faith

We process personal data concerning you only on the grounds provided for in the General Data Protection Regulation. With our policy of transparency regarding the processed personal data, we aim to create lasting relationships with the users of the services, based on trust and guaranteed by the possibility for the active participation and control of the users in the implementation of the personal data processing activities. Our activities based on the processing of personal data are carried out per the principles of good faith and accountability.

The principle of lawful, transparent, and conscientious processing puts data subjects at the center. It authorizes them with the ability to exercise control over the activities of the controller and the processors of personal data. For example, for personal data processed based on consent, you have the opportunity at any time to withdraw your consent and exercise the full range of rights guaranteed by the regulation, including the right of access, the right to object, the right to delete, etc.

Limitation of objectives

We process personal data only for specific, explicit, and legitimate purposes. This data is not further processed in a way incompatible with these purposes. Defining the goal is a key first step in implementing legal measures to protect personal data and developing guarantees for their protection in any processing activity. Defining the goal is a prerequisite for applying other data quality requirements, including the adequacy, relevance, proportionality, and accuracy of the data collected and the requirements for the data retention period. The purpose limitation principle aims to establish the limits within which personal data collected for a given purpose can be processed and can be used for further use.

When you share personal data with us, you have expectations for the purposes for which that data will be used. We take these expectations into account and comply with them to maintain the confidence you place in us and to ensure the predictability of the processing. As a cornerstone of the data protection regime, we adhere to the principle of limitation of purposes, which prevents the use of personal data for purposes other than those for which they were originally collected.

Minimize data

We only process personal data that is relevant, relevant, and limited to what is necessary for the purposes for which it is processed. Our activities and processes are organized around the minimum of personal data that is necessary to achieve the respective goals. Our platform and processes are designed to ensure that we process only the personal data that is necessary to achieve a specific, clearly defined goal.

Accuracy

The personal data we process is accurate, correct, and up-to-date. We take measures that allow timely updating of data, incl. deleting inaccurate or outdated data. In our activities we take several measures to ensure the timely deletion or correction of inaccurate personal data, taking into account the purposes for which they are processed.

Storage restriction

We store personal data in a form that allows the identification of the data subject for a period not longer than necessary for the purposes for which the personal data are processed. In cases where we know the exact period required, it is explicitly stated, and in all other cases, we provide guidance on the criteria used to calculate this period.

Security of processing

We process personal data in a way that ensures an appropriate level of security of personal data. Personal data concerning you is protected against unauthorized or unlawful processing and accidental loss, destruction, or damage. To comply with this principle, we apply appropriate technical and organizational measures per the risks to your fundamental rights and freedoms.

Accountability

The processing of personal data is based on the trust between you, as data subjects, and us, as the controller. As the personal data we process may reveal different aspects of your identity, we take care not only to maintain trust between us but also to counteract the risks to your rights and freedoms arising from each processing. For this reason, we keep up to date information on the measures and means of compliance that we have taken, incl. data protection policies, risk assessments, technical and organizational measures taken, etc.

How Do We Use Your Personal Information?

We process personal data relating to you to provide you with quality, adequate and professional service. Processing is any activity with personal data, including initial collection, processing, modification, and deletion. Any processing of personal data shall be carried out only for specific purposes and only on one of the legal bases listed in the General Data Protection Regulation.

We do not use the information for any purpose other than that stated.

We implement measures to ensure that your data is kept up to date and processed reliably.

We disclose your personal data for direct marketing only to the explicitly designated third parties, after your explicit consent.

You have the right to access your personal information, the right to correct it, and the right to complain at any time if you believe that your rights have been violated as a result of the unlawful processing of personal data concerning you.

We do not keep your personal information for longer than necessary for the purposes for which we collect it. However, we may store your information for a longer period for historical, statistical, or scientific purposes by providing appropriate safeguards to protect it through aggregation, anonymization, and/or pseudo-minimization.

Sharing Your Personal Information

We only share information with the following third parties.

Sometimes, in carrying out some of the activities we offer through this website, we rely on other persons to process personal data relating to you on our behalf - these persons are called personal data processors

Your personal data may also be disclosed to third parties, such as:

  • Advertising, Direct Marketing, and Lead Generation

Google AdSense, Mail Chimp, and others.

  • Affiliate Marketing Programs

Amazon Affiliation, CJ Affiliate Program, and others.

  • Content Optimization

YouTube video embed, Google Site Search, Instagram embed, Pinterest embed. Getty images embed and others.

  • Social Media Sharing and Advertising

Facebook social plugins, Twitter social plugins, and others.

  • Web and Mobile Analytics

Google Analytics.

We use service providers to process personal data for certain purposes, such as measuring and tracking user behavior on sites, sending emails, sharing content from users, logging in with a social media account, and more. These companies are (not exhaustive):

If necessary, OnMedia may share personal data with external consultants (eg lawyers, accountants, auditors).

Our servers are located in Germany. If you are accessing our Website from outside Germany, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in and other countries.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

Your Rights

EU residents

If you are a European resident, you have the right to access the personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

You can exercise your rights using the following email address: policy@onmedia.com.

If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies....

California residents

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request the removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

We have collected the following categories of personal information in the past twelve (12) months:

Category

Examples

Collected

A. Identifiers

Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name

NO

B. Personal information categories listed in the California Customer Records statute

Name, contact information, education, employment, employment history and financial information

YES

C. Protected classification characteristics under California or federal law

Gender and date of birth

NO

D. Commercial information

Transaction information, purchase history, financial details and payment information

NO

E. Biometric information

Fingerprints and voiceprints

NO

F. Internet or other similar network activity

Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements

YES

G. Geolocation data

Device location

NO

H. Audio, electronic, visual, thermal, olfactory, or similar information

Images and audio, video or call recordings created in connection with our business activities

NO

I. Professional or employment-related information

Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us

NO

J. Education Information

Student records and directory information

NO

K. Inferences drawn from other personal information

Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

NO

We collect and shares your personal information through:

  • Targeting cookies/Marketing cookies
  • Social media cookies

More information about our data collection and sharing practices can be found in this privacy notice and our Cookie Notice.

If you have questions or comments about your privacy rights, you may email us at policy@onmedia.com.

Data Retention

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period of time in which users have an account with us.

Social Media

We use social media platforms to present our work to a wide range of people through widely used modern communication channels: facebook.com, instagram.com, twitter.com, youtube.com, pinterest.com. We have placed electronic links to our accounts on these social media and platforms on the website, but we do not put their cookies on your computer (or other devices) when loading the pages via a link from our website.

Each social media platform has its own policy regarding the way they process your personal data when you access their sites.

For example, if you choose to watch one of our videos on YouTube, you will be asked for your explicit consent to accept the placement of cookies by YouTube or to familiarize themselves with their privacy policy, etc. If you have any concerns or questions about the use of your personal information, you should carefully read their privacy policies before using them.

The website may include features for social media and networks, such as the button for Facebook, LinkedIn, or Youtube. These features may collect information about you, such as IP address and websites you visit, and enable a cookie to properly set up the functionality. The processing of information through the interaction with these functionalities is regulated by the rules of the privacy policy of the company that provides the functionality.

Third-Party Website

The Website may provide links to websites that are not under the control of OnMedia. Once you click on a third-party link, you will be directed to that third party's website. If you visit any of these websites, you should review their privacy policies. We are not responsible for the policies and practices of other companies. OnMedia does not control or assume responsibility for the content, privacy policies, notifications, or practices of third party websites or services.

Minors

The Site is not intended for individuals under the age of 13, and we do not knowingly collect or solicit user information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any information about yourself to us. If a parent or guardian becomes aware that their child has provided us with user information without their consent, please contact us at policy@onmedia.com.

Changes

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

Contact US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at policy@onmedia.com or by mail using the details provided below:

150 Vasil Levski blvd., Sofia, 22, 1510, Bulgaria

Please do not disclose any sensitive personal information when contacting us (eg information related to racial or ethnic origin, political views, religion or other beliefs, health or trade union membership, criminal record, etc.)