DATA ETHICS & PRIVACY

Privacy compliance is at the heart of everything we do

Effective Date: 1st March 2021

 

Dear Visitor (hereinafter, “You” or the ‘”User”),

This privacy policy (www.audiencerate.co.uk/privacypolicy) (hereinafter, the “Page” and “Privacy Policy”) is provided by the company Audiencerate Ltd, having its registered office in Winnington House 2 Woodberry Grove North Finchley N12 0DR, London, VAT No. and Fiscal Code No. GB115691515, registered with the Company Register of London under No. 8164319406 (hereinafter, “We” or the “Company”, or the “Controller”). The Privacy Policy hereby explains to You how We collect such data, for which purposes and what your rights are, pursuant to Article 13 of the General Data Protection Regulation, Regulation (EU)
2016/679 (the “GDPR”, or “Privacy Laws”).


The Controller takes the utmost account of the right to privacy and protection of personal data of its Users. For any information related to this Privacy Policy, Users may contact the Controller at any time, using the following methods:

 

  • By sending a registered letter with return receipt to the registered office of the Company
  • By sending an e-mail to privacy@audiencerate.com
  • You can also contact the Data Protection Officer (RPD or DPO) of the Company, whose contact details are shown below:
    Mr Lapo Curini Galletti, mail dpo@audiencerate.com.

Audiencerate is a member of the Network Advertising Initiative (NAI) and we adhere to the NAI Codes of Conduct. To learn more about the NAI and the Code of Conduct please visit: http://www.networkadvertising.org/code-enforcement/code

Scope of Processing

Our Company carries out the activity of digital advertising and we are a third party in relation to the website and/or a mobile app/website where you are coming from (the “Third Party Data Source”). Our role is to help advertisers in providing more relevant advertising to users, for example, a user that visits travel sites often, will be categorized in a “travel lover” group, in such way he will served advertisements that could be interesting for him. Since when you visit the Third Party Data Source we install profile cookies on your browser, and we may deliver some service with them, we hereby aim at explaining the processing of data that we perform.

Types of data processed

The Company collects and processes your personal data by means of cookies and identifiers. We process only pseudonymous data, the data stored are limited to information collected about your visits on websites, your tastes, your behavioural and positions. We may collect:

  • a Platform ID (an identifier that allows us to supply our services)
  • IP address
  • Url visited (as the Third Party Data Source)
  • Time, hour and location
  • Browser and version of the browser
  • Cookie ID of our platform’s partners

The Company may also engage third party processor on the collection of your data, such as company providing user sync services.

Cross Device Linking and Cross App Advertising

We may also link multiple devices used by you, always in a pseudonymous way, also in partnership with technologies similar to cookies, that operate in environments that do not support cookies like mobile applications. Our linking process could be done using cross-site, cross-browser and cross-platform technologies, that links your activity between different websites, browsers and platforms. Please note that we never collect directly data from mobile applications, when we process a mobile advertising ID, such as an Apple Advertising ID (IDFA) or an Android Advertising ID (GAID) we do it on behalf of our partners that authorized us in doing so by using our onboarding data process. For opt out please see paragraph 4 and paragraph 6 below.

What cookies are and what they are used for

Cookies are small text files that the websites visited by a user send directly to its terminal (usually, to the browser), where they are memorised to be transmitted to the same websites at the following visit of the same by the same user (the so called proprium first part cookies). During the web surfing of a website, a user may receive on its terminal also cookies of other websites or of other web servers (the so called third parties cookies); this happens because there may be elements on the visited website, such as images, maps, sounds, links to specific web pages of other domains that are on servers other than the server on which the requested page is placed. In other words, such cookies are set up on a website other than the one that is currently visited.

Profiling Cookies

Profiling cookies are used to create a user’s profile, based on the preferences and likings showed by You during the navigation on Internet and to make You display advertisings consistent with your profile. In such way, the advertisings that You will display on the Third Party Data Source and the other websites that host our cookies could be more of interest for You. Your prior consent s requested in order to install such cookies, as provided pursuant the current privacy law. For such a reason, when you access the Third Party Data Source a specific banner is displayed, informing you that (i) profiling cookies are used on the Third Party Data Source and that (ii) closing the banner, surfing on the home page or clicking whatever element on the home page outside the banner, You are giving your consent to the use of cookies. In some cases the Third Party Data Source may ask you to give an explicit consent to the storing of these cookies, for example by requesting you to click on a specific acceptance button. For further information, please read the privacy policy of the Third Party Data Source.

You are clearly free to block the installation of profiling cookies in any moment whatsoever and this will not compromise in any manner whatsoever the possibility to visit the Third Party Data Source and benefit of its contents. 

Our profiling cookies are installed directly by the Company. Such cookies are lasting ones and have a maximum duration of 12 months. The first part profiling cookies used are the specified in the following table, together with the indication of the modalities to use in order to oppose to their installation:

Name Cookie’s category
arcki2 Third party profiling cookie

For disabling such profiling cookies please amend your browser’s settings (please see paragraph 4) or use the opt out  option at the bottom of this page.

The third parties that act as independent Data Controllers thought our technology are specified in the following table, together with the link to their policies:
 
Third Party Cookie’s category Link to the policy
Double Click Third party profiling cookie https://support.google.com/adsense/answer/2839090?hl=it
Adform Third party profiling cookie https://site.adform.com/privacy-center/website-privacy/website-privacy-policy/
Throtle Third party profiling cookie https://www.throtle.io/privacy/
ID5 Third party profiling cookie https://id5.io/privacy-policy 

How to manage the cookies and oppose to their use

There are several options to manage, disable and remove the cookies.

(1) Modify your browser settings

Please follow the instructions provided by your browser’s producer to discover how to manage, disable or remove all the cookies (technical, analytics and profiling):


Please be careful in making your choice. Indeed, by blocking the receipt of all the cookies indiscriminately, including the technical ones, without providing a specific exception for the Third Party Data Source, you might be no more able to surf on the Third Party Data Source or to benefit, in whole or in part, of its functionalities. Furthermore, removing all the cookies from the browser, also the technical cookies could be removed and, therefore, you could remove the preferences set up by using the Third Party Data Source or no more find products or services included in your basket.

When you opt out, we will place an opt out cookie on your computer. This cookie tells us not to collect your information. Please note that if you block, delete or restrict cookies in any way, or if you use a different computer or Internet browser, you may need to renew your opt out choice. To effectively opt out users must opt out on every device and browser using our opt out methods described below.

(2) Use our interactive instruments

In order to disable the first part profiling cookies, which means those installed directly by us, you can simply use the use the opt out at the bottom of this page.

(2a) Or NAI opt out instrument. http://optout.networkadvertising.org/

(3) Mobile opt out

As for any data collected through mobile application, you may autonomously deactivate the use of the advertising identifier (ID) of your Device, depending on the model, as illustrated below:

Apple: https://support.apple.com/en-gb/HT205223
Android: https://support.google.com/googleplay/answer/3129346?hl=en
Or following these instructions: http://www.networkadvertising.org/mobile-choice.

Processing methods and data retention timing

As highlighted under the preamble of this Privacy Policy, the Company collect and process certain personal data by means of the cookies. The Company acts as data controller of such data, in compliance with the provisions of the Privacy Laws. Please note that we will process your data with electronic instruments only, in a much automatized manner and without any human intermediation. Therefore, our employees and coworkers will never access the content of your personal data obtained by means of cookies.

Certain employees of ours and coworkers, appointed by us as persons in charge of the processor, could make maintenance operations on IT systems that host your data, without the possibility to access their actual contents. The personal data could be memorised on servers managed by third parties (for example, providers of IT systems) or may be managed by online marketing specialised subjects, acting as external data processors on the basis of a specific written appointment by the Company. We hereby inform you that, complying with the requirements and the guarantees provided under the law, your data could be transferred to Countries outside the European Economic Union that could not guarantee a level of privacy and personal data protection equal to the level of protection guaranteed by European privacy laws, but as Controller we take the utmost account of the right to security and protection of personal data of our Users, therefore we will process such transfers with all due care and guarantees. 

Your personal data will be kept for the time strictly necessary to carry out the primary purposes described in this statement, or in any case not longer than 12 (twelve months) and/or as necessary for the protection of the rights of both the interests of both Users and the Company.

We may share your PII with third parties in accordance with this Privacy Policy, as well as pursuant to judicial or other government subpoenas, warrants, orders, or if we merge with or are acquired by a third party, or pursuant to bankruptcy proceedings.

Your rights

In order to exercise your rights, or to obtain any other information or clarification in relation to this Privacy Policy, please contact the Company by means of:

  • registered letter with return receipt (to the following address: Winnington House 2 Woodberry Grove North Finchley N12 0DR, London,)
  • by e-mail (to the following address privacy@audiencerate.com)

Pursuant to Privacy Laws, the Data Controller informs that Users have the right to obtain indication (i) of the origin of personal data; (ii) the purposes and methods of the processing; (iii) the logic applied in the event of processing carried out with the aid of electronic instruments; (iv) of the identification details of the Controllers and Processors; (v) the subjects or categories of subjects to whom the personal data may be communicated or who may come to know them as Processors.

Furthermore, Users have the right to obtain:

a) access, updating, rectification or, when interested, integration of data;
b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case where this fulfillment is it proves impossible or involves a use of means manifestly disproportionate to the protected right.

Moreover, Users have:

a) the right to withdraw consent at any time, if the processing is based on their consent;
b) (and, if its is applicable) the right to data portability (right to receive all personal data concerning them in a structured format, commonly used and readable by automatic device), the right to limit the processing of personal data and the right to cancel (” right to be forgotten “);
c) the right to oppose:
i) in whole or in part, for legitimate reasons, to the processing of personal data concerning them, even if pertinent to the purpose of the collection;
ii) in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication;
d) if they believe that the processing that concerns them violates any Privacy Laws, the right to lodge a complaint with a Supervisory Authority (if a European citizen, in the Member State in which they usually reside, in the one in which they work or in the one in which the alleged violation has occurred).
The Controller is not responsible for updating all links that can be viewed in this Privacy Policy, therefore whenever a link is not functional and/or updated, Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to such link.

We may update this Privacy Policy and its version/effective date to reflect changes to our data governance practices. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

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