These privacy policies are part of the General Conditions for the use of www.JotterAds.com or https://xml.JotterAds.com (hereinafter the Website). All personal information provided to Jotterbrew Pte Ltd or JotterAds through the Website or through any other electronic means made available to users will be handled with the utmost confidentiality. We are committed to protecting and respecting the privacy of our partner data and the one pof their final customers.

1. About JotterAds: we are a B to B operator and has such may collect information form our business partners (customers or providers) in order to conduct business with them. We do not collect personally identifiable data about the viewer of ads we promote. We do, however, record and use information that is not personally identifiable, including but not limited to the following: the IP address of the viewer device, to do geo-targeting, to identify mobile operator, connection type, and other details;the ‘user agent’ of the browser or application, and other relevant request headers, to help us identify your the device type; the date and time of the ad delivered a unique identifier, such as an HTTP cookie or an device advertising identifier, that enables us not to show the same ad over and over again.
2. Rights of affected parties: JotterAds commits itself to respecting and facilitating interested parties exercising their rights recognized by regulations in matters of data protection and, in particular, the rights to access, rectify, cancel and oppose data. Said rights may be exercised by sending a request at admin@JotterAds.com, attaching a photocopy of ID and specifying the right being exercised.
3. Quality of the data: When you provide information to JotterAds, you guarantee and are accountable, in any case, for the information provided to be true, accurate and complete and you commit yourself to keeping it up to date. The registration of your data through the use of the signup form is mandatory, at least for those fields marked as such, and you have been informed and have provided your consent to the contents of this privacy policy. Not providing said data or the supply of incorrect data shall make it impossible for JotterAds to operate with you. Moreover, JotterAds commits itself to never using personal data for purposes different from those specified in this privacy policy nor transfer them unlawfully to third parties.
4. Security measures: JotterAds states and guarantees that it maintains security levels for the protection of personal data in conformity with current legislation and that it has implemented all the technical means available to it to avoid loss, misuse, alteration, unauthorized access and theft of the data provided by users.
5. Commercial communications: Our partners may manifest the desire not to receive future commercial communication at any time by sending an email to admin@JotterAds.com, also, by following the instructions at the end of each commercial communication through the unsubscribe link.

This Website, as many others, uses cookies for a better experience while browsing the Internet. In this section, we inform you of what they are, which ones we use and how you can control them

1. What are cookies? Cookies are small files with text and numbers placed in the hard drive of your electronic device when you visit a website. Cookies allow for the identification of a user from the rest in order to provide a better experience while browsing the Website at the same time as helping to improve it. Cookies may be classified according to their duration in session and permanent cookies and according to their source as first-party or third-party.
2. Cookies used: While visiting our Website, said third-party cookies are generated. Buttons for social networks (third parties) have been enabled on our Website with the purpose of allowing you to share contents of interest with your contacts or to follow us on social networks. Said third parties may set their own cookies with the purpose of customizing the application and measuring its functionality. Because of how these cookies function, JotterAds cannot access them, in the same fashion that third parties cannot access the data of cookies used by us. Therefore, we recommend that you visit the websites of said third parties to understand their operation.
3. Controlling the use of cookies in your browser: You have the ability to accept or reject cookies. Currently, all browsers allow you to adjust the configuration to activate or deactivate the storage or cookies or reject them from specific sites.
4. Cookies description: “Session cookies” are those that are temporarily stored and expire immediately after leaving a website. “Permanent cookies” are those that allow a website to remember you for subsequent visits, improving your experience while browsing through the functions you have installed. “First-party cookies” are those installed by the website you are browsing itself. “Third-party cookies” are those installed by websites different from the one you are visiting. “Google cookies” are used to identified the requesting account, filling the web history folder and providing personalized search results and suggestions.
5. Contact: To obtain further information about this Privacy Policy or the use of cookies on our Website you can contact us at admin@JotterAds.com

1. Ownership: This website is managed by Jotterbrew Pte Ltd. (hereinafter referred to as JotterAds), with tax code 201634684W, corporate address at 21 Cavan Road #02-01, Singapore 209852 If you wish to contact JotterAds, you may do so by email, at the following address: admin@JotterAds.com
2. Conditions of use: 1. The use of www.JotterAds.com (here in after referred to as the Website) or of the JotterAds services confers the status of user, which implies knowledge of and full and unreserved acceptance of these General Conditions of Use (hereinafter referred to as Conditions). For the purposes of these Conditions, the term “JotterAds” or “Us” refers to the owner of the Website. The Owner reserves the right to modify these Conditions, and we therefore recommend reviewing them each time you visit the Website.2. You must use the Website/services in it in a proper and diligent way, and agree not to use it for the following purposes:- To carry out any activities that are against the law or are immoral or likely to disturb public order, and agree to use the Website in accordance with these Conditions.- For illicit or prohibited purposes or for reasons that harm the rights or interests of third parties, or to infringe regulations regarding intellectual and industrial property, or any other applicable legal regulations.3. We use all the technical means at our disposal to ensure that the Website/services is in ideal conditions for you. However, at times and given the nature of the digital environment, incidents may occur that are beyond our control, and we accept no responsibility for any delays or failures that may occur as regards access, functioning and operability of the Website/services, or for any interruptions, suspensions or misuse of the Website/services.4. All users have permanent, direct and free access to the public information contained on the Website/services; however, JotterAds reserves the right to restrict access to certain information, promotions and special offers to registered customers only.5. We may provide access by means of hyperlinks to other websites on the internet (hereinafter referred to as third-party websites) that we think might be of interest. We do not own nor are we in any commercial relationship or have any representation agreement with third-party websites, and will not therefore be held responsible for (including but not limited to) any information supplied or gathered by these third parties or for any poor functioning or damages that may occur as a result of using, accessing or browsing said websites.6. We are not responsible and cannot guarantee the absence of viruses or other similar elements on the website or the server where it is hosted. However, we have taken all the necessary measures that modern technology allows to ensure and prevent the existence or transmission of viruses and/or any other type of harmful software through the Website.7. The intellectual and/or industrial property rights of the contents, including but not limited to the texts, comments, illustrations, images, guides, corporate symbols and source code of the Website/services, are held by the Owner, and when applicable by the entities or persons indicated on the Website/services, and are all protected by all applicable EU and international regulations. Unless prior written authorisation is given by the Owner, the reproduction, distribution, marketing, transformation, copying or any other act of communication or dissemination, whether whole or in part, of this Website/service is prohibited.8. The conditions set out in this document are governed by Singaporean law. Having expressly waived any other jurisdiction to which they might be entitled, the parties submit to the Courts of the city of Singapore for the resolution of any disagreements or legal disputes that may arise. When one of the parties holds the status of consumer, the Courts applicable to the home address of said party will have jurisdiction to rule on any such disagreement.9. PayPal Acceptable Use Policy
3. You are independently responsible for complying with all applicable laws in all of your actions related to your use of PayPal’s services, regardless of the purpose of the use. In addition, you must adhere to the terms of this Acceptable Use Policy.-Prohibited Activities: You may not use the PayPal service for activities that:–violate any law, statute, ordinance or regulation.–relate to transactions involving (a) narcotics, steroids, certain controlled substances or other products that present a risk to consumer safety, (b) drug paraphernalia, (c) cigarettes, (d) items that encourage, promote, facilitate or instruct others to engage in illegal activity, (e) stolen goods including digital and virtual goods, (f) the promotion of hate, violence, racial intolerance or the financial exploitation of a crime, (g) items that are considered obscene, (h) items that infringe or violate any copyright, trademark, right of publicity or privacy or any other proprietary right under the laws of any jurisdiction, (i) certain sexually oriented materials or services, (j) ammunition, firearms, or certain firearm parts or accessories, or (k) certain weapons or knives regulated under applicable law.–relate to transactions that (a) show the personal information of third parties in violation of applicable law, (b) support pyramid or ponzi schemes, matrix programs, other “get rich quick” schemes or certain multi-level marketing programs, (c) are associated with purchases of annuities or lottery contracts, lay-away systems, off-shore banking or transactions to finance or refinance debts funded by a credit card, (d) are for the sale of certain items before the seller has control or possession of the item, (e) are by payment processors to collect payments on behalf of merchants, (f) are associated with the sale of traveler’s checks or money orders, (g) involve currency exchanges or check cashing businesses, (h) involve certain credit repair, debt settlement services, credit transactions or insurance activities, or (i) involve offering or receiving payments for the purpose of bribery or corruption.–involve the sales of products or services identified by government agencies to have a high likelihood of being fraudulent.

These Guidelines are only aimed to provide Advertiser with key principles to which it must adhere and does not derogate from Advertiser’s obligations to act at all times pursuant to any other obligations and industry best practices. In case of doubt, Advertiser need to have written approval of publisher before launching the material.

1. Compliance with law: Advertising Material must be compliant with applicable laws and rules, including but not limited to any false advertising laws, fair competition, Privacy and data collection, intellectual property, limitations and restrictions that are relevant to the distribution and display of advertisements or commercial offers, or to the promotion, sell or facilitation of products and services (collectively or in separate “Laws”). Advertiser further represents that it employs all necessary monitoring and reviewing procedures to achieve such compliance.. Without limiting the aforesaid, Advertiser represents and warrants that – No Advertising Material that promotes or sell services or products that are limited for sell, No Advertising Material will: (a) infringe upon any third party intellectual property Advertiser will not collect, transmit or use personally identifiable information about end user
2. No fraud No Advertising Material will require an end user to participate in any online activity nor will it incentivize an end user to click or interact with the content using a misleading, fraudulent or inaccurate representation or incentivize automated click or automated interaction with that content.Advertiser will not do any of the following:(a) take control of an end user’s computer by deceptively accessing, hijacking or otherwise using the computer’s modem or Internet connection or service and thereby causing damage to the computer or causing the end user, or a third party defrauded by such conduct, to incur charges or other costs that are not authorized by the end user;(b) deliver Advertising Material that an end user cannot close or otherwise disable without turning off the computer or closing all other sessions of the Internet browser for the computer;(c) using rootkits or other software that are typically used to hack into a computer and gain administrative-level access for unauthorized use of a computer;
3. Sanctions In case of breach of these guidelines, publisher will charge advertiser a $500 penalty and will terminate the account. Advertiser will be waved of any right of refund. Publisher reserves the right to engage any legal procedure against advertiser too.

This Data Processing Agreement ( DPA) is between Partner and JotterAds (as defined under the Terms and Conditions) and forms an integral part of Terms and Conditions available at https://www.JotterAds.com/legal/ and/or to the user agreement https://my.JotterAds.com/advertiser/agreement (if applicable). Partner and JotterAds are hereinafter jointly referred to as the “Parties”. In the event of any conflict between this DPA and the Terms and Conditions, the terms of this DPA shall prevail. This Agreement only applies to the extent that the EU Data Protection Law applies to the Processing of Personal Data under this Agreement, including if (a) the Processing is carried out in the context of the activities of an establishment of either Party in the European Economic Area (“EEA”), and/or (b) the Personal Data relates to Data Subjects who are in the EEA and the Processing relates to the offering to them of goods or services or the monitoring of their behavior in the EEA.

1. DEFINITIONS: “Controller” or “Data Controller” means the entity that determines the purposes and means of the Processing of Personal Data.“Processor” or “Data Processor” means the entity which Processes Personal Data on behalf of the Data Controller.“Data Subject” means the individual to whom Personal Data relates, including End Users.“End User” means the end user of an internet connected device, such as a visitor to a web page, a user of a mobile app, or a user of an IoT device, or a visitor on advertisement or campaign webpage.“GDPR” means Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (also known as “General Data Protection Regulation”).“Personal Data” means any information relating to an identified or identifiable person as defined in Article 4.1 of the GDPR.“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction (“Process”, “Processes” and “Processed” shall have the same meaning).“Sub-Processor” means any Data Processor engaged by the Processor. “Services” means services provided by the JotterAds in accordance with the general legal terms mentioned above.
2. PROCESSING OF PERSONAL DATA: Under this DPA and with respect to Personal Data, Partner is the Data Controller or Processor and JotterAds is engaged by Partner as Processor in respect to Personal Data, as applicable. The terms of this Agreement shall apply to either of the relations between the Parties regarding the Processing of Personal Data mentioned herein. Within the scope of this DPA, Partner hereby engages JotterAds to collect, process and/or use Personal Data on Partner’s behalf. JotterAds will only Process Personal Data on Partner behalf and in accordance with Partner instructions. The instructions from the Partner to Process Personal Data are the following: (i) Processing shall be carried out in accordance with this DPA, the Terms and Conditions and pursuant to the features and limitations of the applicable Services which JotterAds provides to Partner; and (ii) Processing shall be carried out in compliance with other reasonable instructions provided by the Partner, where such instructions are consistent with the Terms and Conditions. JotterAds will be under no obligation to comply with instructions that JotterAds deems as violating applicable laws.JotterAds uses the Personal Data solely to provide the Services in accordance with Terms & Conditions, i.e. in order to perform tracking services / serve End Users with interest–based advertising, as well as to measure the effectiveness of advertising campaigns and provide Partner with advertising reports. In that context, JotterAds – on Partner demand – may also combine Personal Data from different sources in order to improve Services and integrate Services with external platforms, all of which will be conducted on Partner behalf. JotterAds also processes Personal Data on Partner behalf and to serve Partner interests for the purposes of fraud prevention, bot detection, rating, analytics, viewability, ad security services. JotterAds may also process data based on the extracts of Personal Data in aggregated and non-identifiable forms, including for the purposes of testing, development, control and operation of the Services. JotterAds may process the following information on Partner behalf: IP addresses, language information, session-based browsing behavior, header information, End User’s device-related data (such as the type or model of the device), operating system, wireless carrier providing communication services to such device, geographical location (geo-location) of the device, cookies, advertising identifiers of the device, as well as other information we may receive from Partner or from third parties engaged by the JotterAds on Partner behalf, such as non-precise device location based on the IP address, device specifications and user’s interest’s information. Partner also authorizes JotterAds to store and use cookies or pixel tags on End User’s device on behalf of the Partner in order to perform Services. Without derogating from any of the obligations of the Partner hereunder, the Partner shall not provide JotterAds with any data a) which by itself identifies an individual, such as name, address, phone number, email address; and b) regarding children, or any special categories of personal data, as defined under Article 9 of the GDPR, except as may otherwise be expressly agreed in writing between the Parties and in accordance with the applicable law. This type of data is not necessary to use the JotterAds’s Services.Partner is responsible for ensuring their own compliance with various laws and regulations, including the GDPR. To the extent required under the applicable law, Partner shall provide an appropriate notice to Data Subjects about the Processing of their Personal Data in connection with the use of Services under this DPA and under the legal terms, and Partner shall receive and document the Data Subjects’ consent thereof to the extent required under the applicable law.to the extent required under the applicable law, Partner must also use commercially reasonable efforts to ensure that the End User is provided with clear and comprehensive information about cookies or other information on the End User’s device in connection with the use of Services by the Partner and, if applicable, consents to their storing and accessing. To the extent required under the applicable law, Partner shall inform the End User about third party cookies (or other tracking technologies) which may be placed on Partner’s site(s), specifying the purpose of these cookies (e.g., targeted advertising) and the type of data collected on the Partner’s site(s). Partner shall also inform End Users of options to deactivate JotterAds’s cookies by including in its privacy policy a link to the JotterAds’s legal terms and when legally compulsory, appropriate notice, consent and choice mechanisms that comply with relevant laws and regulations, including GDPR.Partner acknowledge and agree that Partner retain sole responsibility for the lawfulness of the Processing and warrant to the JotterAds that Partner are legally allowed to engage the JotterAds to process Personal Data on Partner behalf, have provided all necessary notices and obtained all required consents from the Data Subjects (if apply) for the purposes of the Processing described in this DPA.
3. RIGHTS OF DATA SUBJECTS: JotterAds shall notify Partner via e-mail if he receives a request from a Data Subject in the subject of access to, correction, amendment, deletion of or objection to the processing of that Data Subject’s Personal Data. JotterAds shall not respond to any such Data Subject request without Partner’s prior written consent, except in order to confirm that the request relates to the Partner.To the extent that Partner responds to any such Data Subject request, JotterAds shall provide Partner, to the extent required by law, with commercially reasonable cooperation and assistance in relation to handling of a Data Subject’s request, to the extent legally permitted.JotterAds reserves the right to charge additional fees in relation to the cooperation with the Partner in regard to this DPA.JotterAds’s staff: JotterAds shall ensure that its personnel engaged in the Processing of Personal Data is informed of the confidential nature of the Personal Data, has received appropriate training on their responsibilities and is subject to obligations of confidentiality. Such obligations shall survive the termination of that individual’s engagement with the JotterAds. JotterAds shall ensure that access to Personal Data is limited only to those members of personnel who require that access in order to fulfil JotterAds’s obligations under the Terms and Conditions.
4. SECURITY: Pursuant to Article 28, Section 3(c) of the General Data Protection Regulation, the JotterAds shall take the measures required by the Article 32 of the GDPR.JotterAds shall provide sufficient guarantees of implementation of the appropriate technical and organizational measures in a manner that the processing will meet the requirements of the GDPR and ensure the protection of the rights of the Data Subject.JotterAds imposes appropriate contractual obligations upon its personnel that engages in the Processing of Personal Data, including relevant obligations regarding confidentiality, data protection and data security. JotterAds ensures that its applicable personnel has been properly informed of the confidential nature of the Personal Data, has received appropriate training and has executed written confidentiality agreements. JotterAds will further ensure that such confidentiality agreements will survive the termination of employment or another form of engagement of its personnel.
5. AUDIT RIGHT To the extent that the applicable law requires Partner to be in a position to monitor the adequate Processing of Personal Data, Partner as the Partner have the right to request an audit from JotterAds to the extent necessary to review whether JotterAds and our Sub-Processors are compliant with the following regulations: (i) any provisions of the Law, (ii) the terms of this DPA, and (iii) Partner’s instructions. JotterAds may provide Partner with a copy of its most recent third-party audits or certifications issued by an independent, third-party auditor, as applicable, or any summaries thereof in order to fulfil Partner audit rights. If an audit is required by law and where its requirements cannot be fulfilled by the provision of such certification, Partner may conduct, either by Partner himself or through a third party independent contractor selected by Partner at Partner expense, an on-site audit of the JotterAds. Such audit may be conducted subject to the following terms: (i) the audit will be pre-scheduled in writing with JotterAds at least 30 days in advance and will be performed once a year at most; (ii) if applicable, all of Partner personnel performing the audit, whether employed or contracted by Partner, will execute a JotterAds’s standard non-disclosure agreement prior to the initiation of the audit, and a third party auditor will in addition execute a non-competition undertaking; (iii) Partner will undertake all necessary measures to ensure and verify that the auditors do not access, disclose or compromise the confidentiality and security of Personal Data other than Partner Personal Data on JotterAds’s information and network systems; (iv) Partner will take all necessary measures to prevent any damage or interference with JotterAds or its service providers’ information and network systems; (v) Partner will bear all costs and assume responsibility and liability for the audit and for any failures or damage caused as a result thereof; and (vi) any audit activities on JotterAds’s third-party service providers’ information systems will be pre-scheduled and agreed on with the applicable providers; (vii) Partner will keep the audit results in strict confidentiality, use them solely for the specific purposes of the audit under this Section 6 and the GDPR will not use the results for any other purpose, or share them with any third party, without the JotterAds’s prior explicit written confirmation; (viii) If Partner are required to disclose the audit results to a competent authority, Partner will provide the JotterAds with a prior written notice, explaining the details and necessity of the disclosure, as well as provide all further necessary assistance to prevent such disclosure.
6. SECURITY BREACH MANAGEMENT AND NOTIFICATION If JotterAds becomes aware of any accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to any Personal Data transmitted, stored, or otherwise Processed on JotterAds’s equipment or in JotterAds’s facilities (“Security Breach”), JotterAds will promptly: (i) notify the Partner of the Security Breach; (ii) investigate the Security Breach and provide Partner with all relevant information about the Security Breach; and (iii) take all commercially reasonable steps to mitigate the effects and minimize any damage resulting from the Security Breach.
7. SUBPROCESSING AND TRANSBORDER DATA TRANSFERS Partner authorizes JotterAds to appoint Sub-Processors in order to provide the Services.JotterAds may continue to use the Sub-Processors already engaged by the JotterAds according to this DPA.JotterAds may integrate the Partner’s services with external service providers’ platforms for the purpose of providing its Services, on Partner’s behalf and for the purposes of serving the Partner’s interests, where such external service providers may be Sub-Processors, which Partner hereby agrees to. A full list of such Sub-Processors is available upon the Partner’s written request directed to the JotterAds.Notwithstanding the provisions above, Partner hereby authorize JotterAds to subcontract the Processing to the Sub-Processors based outside of the European Economic Area (EEA) to the extent necessary to duly perform the Service(s), under the condition that the Sub-Processors will provide sufficient guarantees in relation to the required level of data protection, e.g. through a Privacy Shield certification according to the EU Commission Decision 2016/1250, or a subcontracting agreement based on the standard contractual clauses launched by virtue of the EU Commission Decision on standard contractual clauses for the transfer of personal data to processors established in third countries under Directive 95/46/EC or GDPR (the “Model Contract Clauses”), or based on other applicable transborder data transfer mechanisms.
8. OTHERS Term: This Agreement shall become effective as of May 25, 2018. Partner authorizes JotterAds to retain Personal Data for a period of 3 months from the date of its collection on Partner’s behalf and for the purpose of serving its interests, including for fraud prevention, ad security services, reporting services, complaints or chargebacks handling. This data may be deleted from JotterAds’s servers after this retention period and/or after the termination of Agreement or earlier, at Partner written request.Notices: If Partner wish to make any inquiries about this Agreement, please contact admin@JotterAds.com Liability: Partner shall indemnify and hold JotterAds, its officers, directors, employees, contractors, and agents harmless from and against all claims, liabilities, administrative fines, suits, judgments, actions, investigations, settlements, penalties, fines, damages and losses, demands, costs, expenses, and fees including reasonable attorneys’ fees and expenses, arising out of or in connection with any claims, demands, investigations, proceedings, or actions brought by data subjects, legal persons (e.g., corporations and organizations), or supervisory authorities under the data protection laws that apply to JotterAds in respect of processing of Personal Data on behalf of Partner through Services. The liability of each party under this Agreement shall be subject to the exclusions and limitations of liability set out in the legal terms. Governing law:This Agreement shall be governed by, and is construed in accordance with, the laws of the State of Spain, without giving any effect to any choice of law and provisions thereof that would cause the application of the laws of any other jurisdiction.