Privacy Policy

How we collect, use, and protect your personal data on afinaplatform.com

IVT COMMUNICATIONS FZC LLC ("IVT", "Company", "we") is a company incorporated under the laws of the United Arab Emirates and committed to compliance with applicable data protection laws.

This Privacy Policy applies to the corporate website afinaplatform.com (the "Website"), which presents the Afina platform and routes visitors to its two product propositions:

IVT acts as the data controller for personal data collected through the Website and its contact form. Processing of personal data inside the products themselves (Afina DMP / Afina CLP) is governed by the respective product privacy policies and, where relevant, by data processing agreements with the operating Mobile Network Operators (MNOs); IVT typically acts as a processor in those scenarios.

By visiting this Website and requesting information, products, or services, you agree to be bound by the terms of this Privacy Policy. If you do not agree, please do not provide any information or use any of the services offered through this Website.

This Privacy Policy may be updated from time to time, with changes effective on posting. Please check back for updates — it is your sole responsibility to be aware of changes. We do not provide notices of changes other than by posting them at this Website.

1. Definitions

"Personal data" means any information relating to you as an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an online identifier, or one or more factors specific to your physical, physiological, genetic, mental, economic, cultural, or social identity. Personal data does not include information from which you cannot be identified (anonymous or de-identified data).

"Processing" means any operation performed on personal data, whether or not by automated means — including collection, recording, storage, use, disclosure, restriction, erasure, or destruction.

IVT does not knowingly collect personal data of children under the age applicable in their jurisdiction (e.g., 16 in the EU; 13 under COPPA in the US). If we learn that we hold such data, we will promptly delete it from active systems and securely delete or anonymize backups within a reasonable timeframe.

2. How we collect personal data and for what purposes

IVT acts as a controller for the following Website processing scenarios.

2.1 Provision of requested information

The Website provides (a) a "Contact Us" link that opens a mailto: to sales@afinadmp.com, and (b) a contact form that routes inquiries to the Afina DMP or Afina CLP product team based on the Interest selector. Form submissions are delivered to the corresponding IVT sales mailbox.

2.2 Website administration and security

2.3 Compliance and legal obligations

Note (operational scope): the Website contact form is used for operational replies only. We do not currently send marketing newsletters or campaigns from this Website. Marketing communications, where applicable, are handled separately through the DMP and CLP product sites under their own opt-in mechanisms.

3. Retention

We retain personal data only for as long as necessary for the purposes described above, after which we delete or anonymize it. Specific retention periods depend on the nature of the data and applicable legal requirements. Once your inquiry has been resolved, contact-form submissions are kept for a reasonable period to support follow-up communications and demonstrate compliance, and then deleted or anonymized in line with our retention schedule.

If you fail to provide required personal data (for example, where it is needed by law or under the terms of a contract), we may not be able to perform the contract we have or are trying to enter into with you, and certain services may not be available. You will be notified if this occurs.

The Website may contain links to external websites (including afinadmp.com, afinaclp.com, and third-party sites). If you follow these links, your data may be transferred to those websites. IVT is not responsible for the privacy practices or content of external sites, and we encourage you to review their privacy policies.

4. Confidentiality and security

IVT is committed to taking all necessary measures to protect personal data from unauthorized access, loss, alteration, or disclosure. We implement commercially reasonable technical and organizational safeguards, including encryption, access controls, and secure servers, in accordance with data protection legislation.

No data transmission over the Internet can be guaranteed to be fully secure. Any transmission is at your own risk. Once we have received your personal data, we apply strict procedures and security features to minimize the risk of unauthorized access.

All information you provide is stored on our or our subcontractors' secure servers in various locations worldwide and accessed and used subject to our security policies and standards.

5. Cookies and tracking

We use cookies and similar technologies to operate the Website, support security, and improve performance. Categories of cookies used on this Website are described in detail in our separate Cookie Notice, which is always kept up to date and accessible via the Website footer.

At the time of drafting this Policy, the Website does not use Google Analytics, Google Tag Manager, Yandex Metrica, Facebook Pixel, or other third-party advertising trackers, and it does not set any first-party cookies on visit. The only third-party request made by the Website is to cdnjs.cloudflare.com for open-source JavaScript libraries (no cookies). Web fonts are self-hosted on the Website's own origin. If this changes in the future (for example, if we add analytics or marketing cookies), the Cookie Notice will be updated and a consent banner will be implemented before any non-strictly-necessary cookies are set.

6. Third parties (sub-processors) and disclosures

IVT engages third-party service providers under written Data Processing Agreements (DPAs) imposing obligations no less protective than those in applicable data protection laws. Providers may not use personal data for their own purposes. Where personal data is transferred outside the EEA, transfers rely either on an adequacy decision or on appropriate safeguards such as Standard Contractual Clauses (SCCs).

Providers supporting the operation of afinaplatform.com include:

Each of the above providers (other than the passive CDN) has entered into a DPA with IVT, ensuring that personal data is processed only as instructed by IVT and in accordance with the GDPR, UK GDPR, Swiss FADP, LGPD, and other applicable laws.

In addition, personal data may be disclosed to competent authorities where required by law, or in connection with legal proceedings, fraud prevention, or compliance with anti-money laundering (AML) and counter-terrorism financing (CFT) obligations.

7. Your rights as a data subject

You have rights under applicable data protection laws, including the EU GDPR, UK GDPR, Swiss FADP, the Brazilian LGPD, the UAE PDPL, the Thailand PDPA, and the South African POPIA. These rights include:

How to exercise your rights: contact us at privacy@afinadmp.com. To withdraw marketing consent specifically, you can also write to sales@afinadmp.com. We may request proof of identity to verify your request.

Right to lodge a complaint: you have the right to lodge a complaint with a competent data protection authority in your country of residence or where you believe that your rights have been violated.

Limitations and fees: in certain cases permitted by applicable law, IVT may charge a reasonable fee to cover administrative costs of processing a request, or refuse to act on a request that is manifestly unfounded, excessive, or repetitive.

8. International application of data protection laws

This Privacy Policy is intended to comply not only with the EU GDPR but also with other applicable personal data protection laws in regions where IVT operates or provides services, including:

Where personal data is transferred outside the EEA, the UK, or Switzerland, IVT relies either on adequacy decisions or on appropriate safeguards such as SCCs or other lawful transfer mechanisms.

9. Contacting us

If you have questions or concerns regarding this Privacy Policy or the way your personal data is processed, you can contact us at:

This Website is owned and operated by IVT COMMUNICATIONS FZC LLC, a company incorporated and operating under the laws of the United Arab Emirates, located at: BLA-SP1-97, AMC — Boulevard A Building, Ajman Media City. Registered number: 3621.