Privacy Notice - Advertising End Users
This Privacy Notice explains how Threedium Limited (“Threedium”, “us”, “we” or “our”) manages the personal information that we collect, hold, use, sell, share, retain and disclose and how to contact us if you have any further queries about our management of your personal information. This Notice also describes the rights that you may have regarding our processing of your personal information under applicable local law.
In addition to the practices described in this notice, we also adhere to the Interactive Advertising Bureau Europe Transparency & Consent Framework and are in the process of registering on the Global Vendor List.
Please note that this privacy notice does not describe Threedium’s data practices relating to information Threedium collects through its own website www.threedium.com or as a result of the administration of its business, which is accessible on this link Threedium Website Privacy Notice.
Who are we?
Threedium is a technology provider in the online advertising industry. We provide services to both publishers and advertisers. We collect information about End Users from our publisher and advertising partners and/or their agents. We act under the instruction of our clients when they use our products or services. If you are a customer of one of our clients, please visit their website to understand how your personal data is processed.
Publishers use our technology to monetize their ad spaces. To provide these services, we may access your data when you visit a website where publishers use our technology for online ads.
Advertisers or media agencies on advertisers behalf display their advertising campaigns through Threedium technology on their websites or apps or on the websites and apps of our publisher partners. To provide these services, we may access your data when you visit an advertisers website using our tracking technology.
What personal information do we collect?
In the course of our business, Threedium may collect personal information about you that is necessary for us to perform our functions and activities. Threedium will only collect personal information about you by lawful and fair means.
The types of personal information we may collect and hold may vary depending on the nature of our interaction with you and may include:
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Data Category |
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IP Address |
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Device Characteristics |
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Device Identifiers |
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Probabilistic Identifiers |
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Authentication-derived identifiers |
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Browsing and interaction data |
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End User-provided data |
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Non-precise location data |
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Precise location data |
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End User’s profiles |
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Privacy Choices |
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Inferences (including segments) |
We do not collect:
- Children’s Data. That allows us to detect that an individual is a minor in any deterministic way. Nor do we allow our clients or partners to do so through our Services.
- Criminal convictions and offences Data. Threedium does not knowingly collect nor process any data relating to criminal offences or accusations.
- EU Special Category Data. Threedium does not knowingly collect nor process any EU special category data, including EU data concerning health, race or sexual orientation.
How do we collect personal information?
We typically collects your personal information from:
- our publisher partners websites and mobile applications;
- Our advertisers websites;
- Our service providers (like Google) that assist us in providing our Service to advertisers and publishers.
For what purposes do we collect, hold, use and disclose your personal information?
In general, Threedium collects, holds, uses and discloses personal information for the following purposes and on the following legal basis:
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Purposes of processing |
Threedium Legal Basis |
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Setting our Cookies: Store and access information on the device Cookies, device identifiers, or other information can be stored or accessed on End Users device for the purposes presented to the End Users on the cookie banner. |
Consent We integrate with publishers CMPs to obtain consent prior to setting our cookies. |
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Delivery of non-personalised ads |
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Use limited data to select advertising Ads can be shown to you based on the content you’re viewing, the app you’re using, your approximate location, or your device type. |
Legitimate Interest Our legitimate interest in providing our services to advertisers and publishers. |
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Delivery of personalised ads |
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Create profiles for personalised advertising A profile can be built about the End User by Publishers and shared with Threedium to show their personalised ads that are relevant to them |
Consent We integrate with publishers CMPs to obtain consent prior to setting our cookies. |
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Use profiles to select personalised advertising Personalised ads can be shown to the End User based on a profile about their ads that are relevant to them. |
Consent We integrate with publishers CMPs to obtain consent prior to setting our cookies. |
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Measurement and reporting |
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Measure advertising performance: The performance and effectiveness of ads that a End User sees or interacts with can be measured. |
Consent We integrate with publishers CMPs to obtain consent prior to setting our cookies. |
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Understand audiences through statistics or combinations of data from different sources: Market research can be used to learn more about the audiences who visit sites/apps and view ads. |
Consent We integrate with publishers CMPs to obtain consent prior to setting our cookies. |
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Product improvement, security and technical measures |
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Develop and improve products and services: End User data can be used to improve existing systems and software, and to develop new products and services. |
Consent We integrate with publishers CMPs to obtain consent prior to setting our cookies. |
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Ensure security, prevent and detect fraud, and fix errors: End User data can be used to monitor and prevent unusual or possibly fraudulent activity and ensure systems and processes work properly and securely and to correct problems. |
Legitimate Interest Our legitimate interest in ensuring the safety, security and proper functioning of our products and services. |
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Technically provide advertisements or content: The End User's device can receive and send information that allows you to see and interact with ads and content |
Legitimate Interest Our legitimate interest in providing our services to advertisers and publishers. |
We also may disclose information in the following circumstances.
- Business Transfers. If we are or may be acquired by or merged with another company, if any of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer your personal information to the other company.
- In Response to Legal Process. We also may disclose your personal information in order to comply with the law, a judicial proceeding, court order, or other legal processes, such as in response to a court order or a subpoena.
- To Protect Us and Others. We also may disclose your personal information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Notice, or as evidence in litigation in which Threedium is involved.
- Aggregate and De-Identified Information. We may share aggregate and de-identified information about End Users with third parties for marketing, advertising, research or similar purposes.
Our approach to Profiling and Automated Decision Making?
Profiling is an automated processing of personal data to evaluate certain things about you. When we collect information for the purpose of “the delivery of personalised ads”, it may lead to profiling since we use audience segments based on your behaviour to personalise the ads.
The advertising you see on publisher websites that use our technology is based on our ad selection algorithms. However, the processing of your information does not involve “automated decision making” as referred to in Article 22(1) and (4) of the GDPR. This means that we do not use automated processing to make decisions which have any legal effect or similarly significant effect on you.
Where required under applicable local law, our legal bases for processing your information may also include:
- Performance of a contract: We process personal information where necessary for the performance of our contractual obligations to you.
- Compliance with legal obligations: We process personal information where necessary to comply with the legal obligations to which we are subject.
Who do we share your personal information with?
Threedium works with various partners and service providers to deliver its services and improve your experience. We share your personal information with:
- Our business partners, such as integration partners, advertising partners, and publisher partners, who use Threedium’s platform and services to deliver ads to you;
- Our service providers, including vendors, consultants, contractors, and other service providers who perform services or functions on our behalf, for business purposes.
We may also share your personal information with:
- regulatory authorities; and
- parties involved in a prospective or actual transfer of our assets or business.
How do we hold your personal information and manage the data quality and security of your personal information?
Threedium stores your personal information as encrypted electronic data on Amazon Web Services servers located in the US and the Republic of Ireland, with high level security and access only available by password.
Threedium will take reasonable steps to ensure that personal information that is held which is no longer required, including under any contractual or legal requirement, is destroyed or de-identified in a secure manner.
Do you transfer personal information overseas?
Our servers are located in the US and Republic of Ireland. Your personal information may be processed, transferred to, and maintained on servers and databases located outside of the jurisdiction in which you are based and where the privacy laws may not be as protective as your jurisdiction. Where required by applicable law, we have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below in the “Contact Us” section of this Policy.
How do you use your data rights?
Depending on the jurisdiction in which you live, including if you are a consumer in California, Colorado, Connecticut, Utah, or Virginia, or a data subject in the EEA, China, UK, or Switzerland, you may have the following rights under applicable local law:
- request information about our processing of your personal information (right to know);
- request a copy of your personal information (right to access)
- rectify, correct, or update the personal information we hold about you (collectively right to correct);
- request deletion of your personal information;
- opt-out of “sales” of personal information or “sharing” of personal information for cross- contextual behavioural advertising purposes (as these terms are defined under applicable law);
- opt-out of targeted advertising;
- restrict or limit our use of your personal information or your sensitive personal information (right to restrict);
- object to our use of your personal information;
- where you have provided consent, withdraw such consent to our processing of your personal information at any time;
- ask that we transfer the personal information we maintain about you to another organisation, or to you, in certain circumstances (right to portability);
- not be unlawfully discriminated against for exercising your rights;
- lodge a complaint with your local data protection authority.
If you wish to exercise any of the above rights, send us an email at privacy@threedium.io headed “Data Subject Request.”
Before we process any request, we may ask you for certain Personal Data to verify your identity, and in situations where Threedium is the Data Processor, consult with the Data Controller of your data. Where permitted by local law, we may refuse requests that are unreasonable or impractical. Please allow us a reasonable time to respond to your inquiries and requests in line with local law requirements.
How Threedium handle complaints?
If you have any concerns or complaints about the manner in which your personal information has been collected or handled by Threedium, please advise us of your concern or complaint in writing and send it to the Data Protection Officer using the email address set out above.
It is our intention to use our best endeavours to resolve any complaint to your satisfaction. However, if you are unhappy with our response, you may contact your local data or privacy authority who may investigate your complaint further.
Contact
For any questions about this privacy notice, our data practices or the way in which you can exercise your rights, you can contact the Data Protection Officer (DPO) by email on Privacy@Threedium.io.