Optomaton

- a Ve company

Developing a machine learning Demand Side Platform - VOLVELLE

Privacy Policy

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Last updated: 24 May 2018

 

Introduction

Optomaton UG (“Optomaton”) is a provider of data driven marketing software.  Volvelle is Optomaton’s DSP through which advertising and marketing buyers to purchase inventory and to manage and access multiple ad exchanges and publishers in real time. Optomaton and its ultimate holding company, Ve Global UK Limited, and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006, constitute the “Optomaton Group”.

Volvelle enters into a conversation with a publisher site and will bid in real time on ad inventory on behalf of Advertisers who are clients of Optomaton or a company in the Optomaton Group or Advertisers who are customers of Optomaton’s clients (“Advertisers”) via SSPs and via an aggregator.  Those publishers with whom we win a bid (“Publishers”) will then display personalised ads on their sites.

We take privacy seriously and are committed to ensuring a safe online experience. This privacy policy (“Privacy Policy”) explains how we use and protect personal information that we receive or collect, as set out further in this Privacy Policy.

We collect personal information about:

Ø  End users who visit publisher websites: when you visit or interact with Publishers’ websites, mobile applications and services (“Publisher Sites”), we collect and process personal information about you. We use this information to understand more about you and to advertise or promote Advertisers’ products and services to you. Please see Opting-out below if you wish to opt-out. You may have been redirected here because you have visited a Publisher Site; and

This Privacy Policy is set out in three parts:

·       Part I – Information for end users who visit Publisher Sites: this section is relevant to you if you visit any of our Publisher Sites – this is likely to be the case where you have been redirected here from another website. Our policy describes what personal information we collect and how we use it in relation to your interaction with Publisher Sites.

·       Part II – Miscellaneous: this section contains further information about our use of personal information, including the rights you have.

This Privacy Policy:

·       explains the nature of the personal information about you that is processed by Optomaton and how you can request that we delete, update and/or transfer it and/or provide you with access to it;

·       is designed to help you to make informed choices when using Publisher Sites.  Please take a moment to read it; and

·       applies only to the use of your personal information when obtained by Optomaton. It doesn’t apply to personal information collected during your communications with Publishers and/or third parties unless that personal information is shared with Optomaton in any of the circumstances described in this Privacy Policy.

How do I opt -out?

If you have visited one or more Publisher Sites and wish to opt-out of Optomaton processing your personal information, including where you wish to opt-out of Optomaton displaying personalised ads to you when you visit third party websites and platforms, please see How to opt-out of our use of your personal information.

 

Who are we?

Optomaton is a company registered in Germany under company number HRB 16736 and has its registered office at Amsetsr. 70, 41363 Juchen.

Where Optomaton receives your personal information as a result of your interaction with Publisher Sites, Optomaton is, either alone or jointly with Publishers, a controller (as the terms is defined in the EU General Data Protection Regulation) and is responsible for the collection and processing of such personal information in accordance with applicable privacy laws.

 

Part I - Information for end users who visit Publisher Sites

What personal information do we collect and how do we collect it?

We collect the following categories of personal information from you:

Ø  email addresses and/or telephone numbers, if voluntarily entered into a Publisher Site by you (e.g. to buy a product or service) (“Contact Details”);

Ø  data relating to your browsing activity through the use of cookies, web beacons and pixel tags and similar technologies deployed on Publisher Sites (“Behavioural Data”), including:

·       IP (internet protocol) address; referring site URL (website address) where your session started, and details about your device, including type (e.g. mobile or tablet), brand, model, operating system name and version, browser name, version, language and protocol, and other unique numbers assigned to a device (e.g. IDFA on iPhone, Google adID on Android);

·       details about the pages of Publisher Sites visited and activities on Publisher Sites (e.g. products viewed or purchased, including details of purchases made and the time and duration of visits to pages of the Publisher’s Site), page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;

·       using your IP address, your approximate geolocation (e.g. postcode); and

·       events relating to ads served on you, such as the number of ads displayed to you and whether you clicked on an ad; and

Ø  mailing address, age and/or date of birth, gender, marital status, number of children, nationality and/or country or city of residency, telephone number and first name, in each case if input into a Publisher Site by you (“Profile Data”).

For more information about the technology that we use to collect Behavioural Data, please see our Cookie Policy.

We also receive Behavioural Data from, and may share it with, third party partners (through “cookie synching” or similar matching technologies). 

We do not share Contact Details or Profile Data relating to you with third parties outside of the Optomaton Group for commercial purposes.

We may receive personal information about you (including Behavioural Data and Profile Data) from other companies within the Optomaton Group to enable us to provide and improve our services. 

We do not collect sensitive information from you (such as data relating to health or religious beliefs). Although it may be possible for us to infer certain information, such as your religious beliefs, from certain Behavioural Data that we may collect, we do not create or use segments that rely on the use of sensitive personal information for the purposes of online behavioural advertising.

How do we use the information we collect?

The primary purpose for which we collect personal information from you is a) to help Advertisers to market, and facilitate the sale of, their products and services more effectively and/or efficiently and b) to provide a more personalised online experience for you.  We achieve this by using information that we have collected (including Behavioural Data) to create inferences about your personal preferences, interests and behaviour.

Optomaton combines some geo-location information that it collects from you on Publisher Sites and uses that personal information for the benefit of each Advertiser. By way of example:

·       if Optomaton collects personal information when you visit Publisher Site A, that personal information may be used to display an ad to you, on a third party website, for products available on Publisher Site B. 

The purposes for which we use your personal information are described further below:

Ø  Deliver relevant and interest-based advertising.

We use inferences about your personal preferences, interests and behaviour to serve relevant and personalised advertisements for Advertisers’ products and services to you when you visit Publisher Sites. This means that you receive advertisements for products and services that are more likely to be of interest.

You can learn more about interest-based advertising here:

https://www.networkadvertising.org/understanding-online-advertising/

http://www.aboutads.info/consumers

http://www.youronlinechoices.eu/

Who do we share personal information with for this purpose?

We share Behavioural Data with companies within the Optomaton Group for billing purposes and with Advertisers and third party partners in advertising networks who use the data to select and serve relevant adverts to you. We do not disclose Contact Details or Profile Data to our Advertisers or advertising networks outside of the Optomaton Group.

We also share personal information about you (including Behavioural Data and Profile Data) within the Optomaton Group of companies to enable us to provide and improve our services. 

Please see Storage and sharing of personal information and transfers overseas in Part III of this Privacy Policy for further information about where your personal information is stored.

What is our legal basis?

It is in our legitimate interest to use your personal information for the purpose described above as this helps Advertisers to a) personalise your online experiences and/or b) promote, and facilitate the sale of, relevant products to you.

Ø  Help Advertisers to analyse the effectiveness of their ad campaigns and to improve the services we provide to Advertisers.

We use the information we collect to operate, manage, maintain and improve our services and to help Advertisers analyse the effectiveness of their ad campaigns.

Advertisers who are clients of any company in the Optomaton Group are able to access reports through a reporting platform that helps them to analyse the effectiveness of their ad campaigns.

Who do we share your personal information with for this purpose?

Optomaton provides Advertisers with personal information where the personal information relates to sales that are attributed to advertisements served by Optomaton. This may include the sharing of email addresses and order IDs with Advertisers for accounting purposes.

We also provide Advertisers with aggregated information about you and others (for example, we may inform Advertisers that 500 men aged under 30 have clicked on their ad on any given day).

Please see Storage and sharing of personal information and transfers overseas in Part III of this Privacy Policy for further information about where your personal information is stored.

What is our legal basis?

It is in our legitimate interest to use your personal information for the purpose described above as this helps Advertisers to a) personalise your online experiences and/or b) promote, and facilitate the sale of, relevant products to you.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to enhance the quality of the services that we provide to Advertisers.

Ø  Providing Advertisers with market insight and analysis.

We collate and aggregate personal information that we collect about you and others and analyse this to provide Advertisers with market research reports and other information about industry trends (“Reports”). However, the Reports contain only aggregated and anonymised information and do not contain any personal information relating to you or any other specific or identifiable person.

Who do we share your personal information with for this purpose?

We do not share your personal information with third parties outside of the Optomaton Group for this purpose.

Please see Storage and sharing of personal information and transfers overseas in Part III of this Privacy Policy for further information about where your personal information is stored.

What is our legal basis?

In relation to the creation of the Reports, it is in our legitimate interest to use your personal information for the purpose described above as this helps Advertisers to a) personalise your online experiences and/or b) promote, and facilitate the sale of, relevant products to you.

In relation to the provision of the Reports to Advertisers, your personal information is presented in an aggregated and anonymised form. We do not require a legal basis to use it for this purpose, as the information will no longer constitute personal information that is regulated under data protection laws.

Ø  Business administration and legal compliance.

We use your personal information for the following business administration and legal compliance purposes:

·       to comply with our legal obligations;

·       to enforce our legal rights;

·       protect rights of third parties; and

·       in connection with a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets.

Who do we share your personal information with for these purposes?

We may share your personal information with professional advisers and/or governmental or regulatory authorities.

Please see Storage and sharing of personal information and transfers overseas in Part III of this Privacy Policy for further information about where your personal information is stored.

What is our legal basis?

Where we use your personal information in connection with a business transaction, enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so.

For all other purposes described in this section, it is our right to use your personal information to comply with any legal obligations to which we are subject.

If we wish to use your personal information for any new purpose that is not listed above, we will, prior to using such personal information, evaluate whether it is in our legitimate interest to use the personal information for that purpose.  If we determine that it is in Optomaton’s legitimate interest to do so, we will update this Privacy Policy to explain the new purpose.  Please check back frequently to see any updates or changes to this Privacy Policy.  

 

Part II – Miscellaneous

Our use of cookies and similar technologies

Optomaton makes use of certain cookies, pixels, beacons, log files and other technologies used on Publisher Sites.

Please see our Cookie Policy to find out more about the cookies we use on Publisher Sites.

How to opt-out of our use of your personal information

This section explains how you can opt-out of our use of your personal information collected in relation to your interactions with Publisher Sites, including how you can opt-out of us displaying personalised ads to you when you visit third party websites and platforms.

We explain below various mechanisms which you can use to opt-out of our use of your personal information in respect our services that we provide to Advertisers in relation to Publisher Sites.

Note that some of these mechanisms are subject to various limitations and conditions. In particular some of the mechanisms require that we place a cookie on your browser in order to identify you as a person who has opted-out of our use of your personal information. If you clear cookies or reset your device settings, we will not be able to identify you as a person who has opted-out of our use of your personal information.

Where you opt-out using the below mechanisms, we will restrict our use of your personal information according to the opt-out that you have chosen, but we may retain your personal data as described in this Privacy Policy (for further information please see How long do we keep your personal information for?):

Ø  Deleting cookies on your device or browser.

We rely on cookies and other online identifiers to collect and use your personal information. You can delete cookies from your devices and browsers to prevent us from collecting data about you and identifying you.

If you opt-out of our use of your personal information using this method, we would still use personal data that we hold and collect about you from other devices and/or browsers, unless you also delete the cookies from all of the other devices and/or browsers that you use.  Accordingly, you may wish to opt-out of the relevant use by using the other toggle buttons above.

Ø  Using Safari’s ‘Limit Ad Tracking’ function.

If you are using Safari browser version 11.2 or above, you can prevent us from using your personal data for the purposes of displaying relevant and interest-based advertising to you by toggling the “Limit Ad Tracking” setting on your device or computer.

On an iPhone, this is typically located under Settings>Privacy>Advertising.

On a computer, this is typically under Safari>Preferences>Privacy.

 

Ø  Native apps – Apple/iOS.

If you have an Apple device, you can opt out of targeted advertising services by updating to iOS 6.0 or higher and setting Limit Ad Tracking to ‘ON’. You can do this by clicking on Settings -> General -> About -> Advertising and toggling Limit Ad Tracking to ‘ON’. Our systems are designed to respect your choice and not use information to provide targeted advertising when this setting is ON. Again, you should consult Apple’s support web pages and instructions for the most current applicable settings.

If you have an Android device, you can opt out of targeted advertising services by navigating to your device’s main settings menu and selecting "Google." From there, choose the "Ads" option and select "Opt out of Ads Personalization" to disable targeted advertising services.

Storage and sharing of personal information and transfers overseas

Ø  Within the Optomaton Group.

We may share your personal information with any member of the Optomaton Group.

The use of your personal information is governed by an intra-group agreement which, in relation to transfers of personal information from the EEA to a non-EEA jurisdiction, incorporates EU approved model clauses.

Ø  With Microsoft Azure.

Optomaton stores data in Microsoft Azure data centres in Europe, the US, Singapore and Russia. The transfer of personal data to Microsoft Azure data centres that are located outside the EEA is governed by a contract incorporating EU Model Clauses.

Ø  With other third party suppliers and partners.

Where we have explained that personal information is shared with a third party supplier, some of those third party suppliers may be located outside of the jurisdiction where the personal information was collected, or they may transfer personal information to jurisdictions which are outside of the jurisdiction where the personal information was collected.

In some cases, the data protection laws of these other jurisdictions may not be as comprehensive as those of the jurisdiction in which the personal information was collected.

Where this is the case, Optomaton will take appropriate steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy and all applicable laws. This may include ensuring that there is a lawful basis for transferring personal information outside the EEA.

How to access your information and your other rights

In addition to your right to opt-out of our use of your personal information in respect of services which we provide to Advertisers in relation to Publisher Sites (please see How to opt-out of our use of your personal information), you have the following rights in relation to the personal information we hold about you:

Ø  Your right of access.

If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

Ø  Your right to rectification.

If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Ø  Your right to erasure.

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Ø  Your right to restrict processing.

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Ø  Your right to data portability.

With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

Ø  Your right to object.

You can ask us to stop processing your personal information, and we will do so, if we are:

·       relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or

·       processing your personal information for direct marketing.

Ø  Your rights in relation to automated decision-making and profiling.

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

Ø  Your right to withdraw consent.

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

Ø  Your right to lodge a complaint with the supervisory authority.

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

 

How do we obtain your consent?

Where our use of your personal information requires your consent, you can provide such consent:

·       at the time we collect your personal information following the instructions provided; or

·       by informing us by e-mail, post or phone using the contact details set out in this Privacy Policy.

 

How long do we keep your personal information that we obtain in relation to your use of Publisher Sites, as described in Part I of this Privacy Policy?

We retain your Contact Details, Behavioural Data relating to you and Profile Data (for further information see Part I of this Privacy Policy - What personal information do we collect and how do we collect it?) for a period of three years from the date of expiry of the cookie that is associated with the collection of such personal information.

Please see our Cookie Policy, which explains when cookies that we use on Publisher Sites are set to expire.

Confidentiality and security of your personal information

We are committed to keeping secure the personal information that you provide to us and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. For more information.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

·       unauthorised access;

·       improper use or disclosure;

·       unauthorised modification; and

·       unlawful destruction or accidental loss.

All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all persons who use our services.

 

Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time.

To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.

 

How to contact us

If you have any questions or wish to exercise your rights set out in this Privacy Policy, please contact our Data Protection Officer at: Optomaton Data Protection Officer, c/o Ve Global UK Limited, White Collar Factory | Old Street Yard | London | England | EC1Y 8AF | Email: privacy@ve.com.

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