Privacy policy

LLC "ACTIONPAY" (hereinafter "COMPANY") is - online marketing and advertising company specializing in Cost-Per-Action campaigns. To provide Clients with internet advertising services COMPANY uses its  own technology platform “Actionpay” (hereinafter  “Actionpay”).

The COMPANY provides access to its Advertisers (the "Clients") to the platform “Actionpay”, performing displaying advertising ads to their potential customers – users. The COMPANY may collect anonymised personal data of Users during the process of internet advertising services.

The COMPANY endeavors to safeguard and protects their Users’ information. For better protection of Users’ privacy The COMPANY provides this Privacy Policy regarding the types of collected information, the protection of such information and the ways of  “Opt-Out” from any collection of User’s information.

The COMPANY is guided by the following Privacy Policy’s  Rules  on the collection and protection of information.

1. COMPANY shall to bring  to the  Customers’ and Users’ notice  the basic rules of “Actionpay”, the principles and rules of information processing, the type and amount of information collected by  “Actionpay”.

Under any circumstances  The COMPANY   does not process personal data of Users except in the case of the direct provision  by Users of personal data to contact with the COMPANY.

2. “Actionpay “ and Users’ information.

Providing Internet Advertising Services  “Actionpay “may collect anonymous data of  users regarding the IP address of the user’s  equipment, the Internet service provider, type, browser language in use, and his version of the operating system installed on user’s  equipment, information about  user’s visited sites such as the address (URL) is an Internet page that displays information about the user and advertising clicks on them.

Above mention Users’ Information does not apply to personal data of the User in accordance with the rules of the Federal Law № 152-FZ "On Personal Data". User identification is impossible on any, or in the aggregate of these data types.

Collected by the COMPANY’s platform  “Actionpay”  User Information  is the statistical information.

3. Cookies files.

Cookies are small files that a Actionpay  transfers to your computer’s hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information.

The COMPANY’s  Customers can use their own database, which may contain personal data information. In this case, personal data information is used only by this Customer for targeting their  advertising campaigns .

The COMPANY under any circumstances is not responsible for the use of personal data, the  compliance with the requirements of the Federal Law № 152 "On Personal Data" regarding the personal data’s process and storage,  if such personal data  were provided and used by Customer.

4. What do The COMPANY uses  the  information of Users for?

-To render  properly  the COMPANY’s services

-To improve customer service

- To implement targeted display ads.

 -for the statistical research;

5. Confidentiality

The COMPANY shall not  pass by any means  or/ and  under any circumstances received  user information to third parties, except for the provision of this  information to such third parties, which operates on behalf of the COMPANY  and  solely for the provision of Internet Advertising Services by Actionpay. The COMPANY may provide third parties with information about Users in anonymous form only and solely in the cases stipulated by the legislation of the Russian Federation.

6. The right of “Opt-Out”.

Any User has the right to prohibit the COMPANY  to collect User’s statistical information via the function «Opt-Out».