LAST UPDATED: 8/7/2019

Archived Privacy Policy—EEA

European Economic Area

We comply with the General Data Protection Regulation ( GDPR ) (Regulation (EU) 2016/679 to the extent required for the conduct of our activities when under the GDPR.

Data Controller. 33Across is the data controller of the personal data we process when we serve personalized ads on Client websites and process cookie information about you. Our contact information appears at the bottom of this policy.

EU Representative. Our European representative for purposes of our processing activities is Yuri Burka. If you are within the European Economic Area, you may contact our European representative at [email protected].

Legal Bases. The legal basis under EU law for collecting and processing your personal data through cookies used in our Products is your explicit consent. The legal basis for disclosures of your personal data to third parties when required by law is our legal obligations to comply with such requirements and our legitimate interests in complying with legal requests from authorities. The legal basis for sharing your personal data with others to investigate, prevent, or take action regarding suspected or actual prohibited activities, is our legitimate interest in enforcing our legal rights and those of other parties. The legal basis for sharing your information to enable a structural change in our operations is our legitimate interests in business continuity following the structural change.

Data Subject Rights. If you are in the EEA, you have the following rights under the GDPR.

    • Right to Access your personal data that we process about you through cookies, and to receive a copy of it.
    • Right to Data Portability, that is, to receive the personal data that we process about you through cookies, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another party.
    • Right to be Forgotten. You can ask us to erase the personal data we process about you through cookies.

You may exercise the above rights through our automated user access portal, located here.

You also have these additional rights if you are in the EEA, and you may contact us through the channels listed at the end of this privacy policy to exercise them:

    • Right to Rectify inaccurate personal data we process about you through cookies and to have incomplete personal data completed.
    • Right to Restrict processing the personal data we process about you through cookies, if you contest the accuracy of that personal data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you oppose the erasure of the personal data and request instead to restrict its use; if we no longer need the personal data for the purposes outlined in this Policy, but you require them to establish, exercise or defense relating to legal claim.

You also have a right to withdraw your consent to processing your personal data through cookies, at any time. For more information on how to do so, please review the “Opting out” section above. Opting out will not affect the lawfulness of data processing we carried out based on your consent before such withdrawal.

We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information in response to your request to exercise your data subject rights. Where we are not able to provide you with the information that you have asked for, we will explain the reason for this. Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work, or of an alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.

Contact Info

privacy[at]33across.com
33Across, Inc.
Attn: Privacy Officer
229 West 28th Street
12th Floor
New York, NY 10001