1. Introduction

Bidsvision (“Bidsvision“, “we“, “us” or “our“) runs an advertising exchange (the “Ad Exchange”).  This means that we connect companies that offer advertising space on their websites, mobile applications, or connected television applications (called “Publishers” in this Privacy Policy) with brands, advertising agencies, and demand side platforms (called “Advertising Partners” in this Privacy Policy) looking to purchase that advertising space in order to advertise their products or services to consumers like you.

We know you may have questions and concerns about who is collecting your data, how your data is used, and how Publishers and Advertising Partners seem to know which products and services you may be interested in as you engage online.  We’ve designed this Privacy Policy to help answer those questions with respect to the data that flows through our systems, and to make sure you know how to take action to prevent or limit our collection and use of your data for interest-based advertising (sometimes called “targeted advertising” or “cross-context behavioral advertising.

We encourage you to read the whole Privacy Policy, because it provides important information about how we may process your data, and the choices or rights you may have with respect to our processing of your data.  In the meantime, here are some key takeaways:

• We collect data about you from Publishers, Advertising Partners, and third party data providers. 
  • This data may include personal information about you such as your device identifiers, location, browsing history, and specific interests, and it may be collected from a variety of partners, such as Publishers operating websites and apps.
• We use this data to understand your online activity and interests over time so we can serve you relevant ads.
  • Using cookies and other persistent identifiers that track your online activity, we collect data about you across different websites and apps, and across different devices. So, we may know you visited a website on Monday from your desktop computer to look at a product, returned to the website on Tuesday from your mobile phone to add the product to your check-out basket, and finally completed your purchase of the product on Wednesday from your tablet. We use this data to learn about your interests over time and understand what products and services may be most relevant to you.
• We share this data with third parties.
  • We share the data we collect about you, and the information we learn from it, with the Advertising Partners that use our Ad Exchange to help them decide whether, where, and how to serve (or re-serve) advertisements for particular products or services to you. We may also share some of your data with trusted third party data providers and service providers.
• We don’t know your name, but we do know your online identifier.
  • None of the data we collect or share about you via our Ad Exchange is connected to your clear-text name, contact information, or other information that could directly identify you as an individual.  But, it is connected to the cookies and other persistent identifiers that are affiliated with your unique online activity.  So, while we (and the partners who use our Ad Exchange) may know about the interests and online activity of device ABC123 and use it to serve that device ads as described above, we don’t know that device ABC123 is used by a person with your name.

2. What personal data do we collect?

Unless you contact us directly, we do not knowingly collect information that directly identifies you, such as your clear-text (i.e., unhashed) name, physical address, email address, phone number, online usernames, or user passwords. But, we may collect the following categories of personal data about you from Publishers, Advertising Partners, and third party data providers that partner with us to serve you advertisements:

• Unique online identifiers 
  • These are persistent identifiers that help us identify you across devices and over time, such as your IP address, cookie ID, mobile advertising ID, hashed email address, and user agent string
• Online and offline activity and interests (including inferences)
  • This includes information about your online activity and interests, such as your browsing history and online behavior
  • This may also include information about your offline activity and interests, such as your purchase history
  • And, this may include information derived or inferred from your online and offline activity and interests, such as your likelihood to be interested in buying a particular product, using a particular service, or visiting a particular website
• Geolocation information
  • This is information about your or your device’s location, such as your country, region, metro, zip, or postal code, or geographic coordinates, typically as inferred from your IP address
• Browser, device, and service information
  • This is information about the devices you are using to engage online, such as your browser or device type (e.g., Google Chrome, iPhone), screen dimensions, operating system, and preferred language
• Ad reporting and delivery information 
  • This is information about the advertisements you have been served and how you interacted with them, such as the size and format of advertisements you were served and whether you clicked on them

As described above, we collect this information primarily using cookies and other persistent identifiers that track your online activity.

We will also collect your personal data if you visit our website or contact us for any reason, although we will not use this data for advertising via our Ad Exchange.

3. Why do we collect, use, and store this personal data?

Depending on where you live, we may need a valid legal basis to collect, use, and store your personal data. If we do, depending on the circumstances, our valid legal basis may be: (i) that you have given us permission to process your data by consenting to our processing or by choosing not to opt out of our processing after receiving notice of our processing activities (we’ll collectively refer to this legal basis below as “consent”), in which case you can always withdraw your consent or opt out of our processing by contacting us  (note, though, that withdrawing or opting out will not affect the lawfulness of processing based on consent before a withdrawal or opt out); (ii) that it is in our legitimate interests to process your data, taking into consideration your interests, rights, and expectations (we’ll refer to this legal basis below as “legitimate interest”); or (iii) that we are legally required to process your data (we’ll refer to this legal basis below as “legal requirement”).

When we are legally allowed to process your personal data, we may do so for the following purposes, with the caveat that some of our processing activities vary depending on where you live:

• To facilitate non-interest based advertising
  • We may help serve you an ad on one of our Publisher’s online properties based solely on information you have provided directly to that Publisher
  • Our legal basis for this purpose is legitimate interest
• To facilitate interest-based advertising
  • We may help serve you an ad on one of our Publisher’s online properties based on information you have provided to that Publisher, in addition to information we have collected independently or from third parties, including other Publishers, Advertising Partners, and third party data providers
  • You can opt out of interest-based advertising (sometimes called “cross-context behavioral” or “targeted” advertising)
  • Our legal basis for this purpose is consent
• To understand your activity and preferences over time 
  • We may use the data we collect (whether directly or from our partners) to learn about your online activity across sites, apps, and devices over time and infer information about your online and real-world preferences (e.g., we may infer that device ABC123 is used by a female in the New York Metro area interested in buying new shoes)
  • We only maintain information about your activity and preferences for the last 90 days (at most), and we use this information only to improve our ability to serve interest-based advertisements
  • Although we can’t control our partners’ actions, we also include restrictions in our agreements with our Advertising Partners and third party data providers requiring them to limit their use of this information, to the extent it is shared with them
  • You can opt out of this kind of data processing, which facilitates interest-based advertising
  • Our legal basis for this purpose is consent
• To control the content and frequency of ads
  • Whenever we help serve you an ad, we may use real-time information about the context in which it will be shown to help make sure the ad is relevant to you and delivered in a format that will work on your device
  • We also take steps designed to make sure that you are being shown a reasonable amount of ads, that those ads do not contain malware and otherwise meet our ad standards, and that you are not receiving the same ads too frequently
  • Our legal basis for this processing is consent or legitimate interest, depending on the circumstances
• To measure ad performance
  • Whenever we help serve you an ad, we may measure the delivery and performance of the ad to understand whether it displayed correctly; how long you had the opportunity to see it; and how, if at all, you interacted with it
  • We use this information to provide reporting to our Publishers and Advertising Partners so that they can understand how their ad campaigns are working or can be improved
  • Our legal basis for this processing is consent or legitimate interest, depending on the circumstances
• To build and improve our products, features, and models
  • We use data to build and improve our products and features, including by building and improving models and algorithms through machine learning
  • Our legal basis for this processing is legitimate interest
• To respond to valid legal requests and protect our legal interests
  • In rare instances, we may be required to produce your data in response to a valid legal request from a governmental, law enforcement, or other legal entity
  • It is also possible, although unlikely, that we may need to produce your data to protect our rights and property, or to protect someone’s safety
  • If we are required to produce your data in either of these circumstances (or any similar circumstances), we will limit our response to the information required to resolve the legal request or situation
  • Our legal basis for this processing is legitimate interest or legal requirement, depending on the circumstances

4. How and to whom do we share your personal data?

We may disclose the information that we collect about you to the following third parties, for the following reasons:

• Advertising Partners and third party data providers
  • As described throughout this Privacy Policy, we pass data to our Advertising Partners, subject to data use restrictions, so that they can combine this information with other information they have independently collected to determine whether to serve (or re-serve) you an ad, and so that they can understand how well their advertising campaigns are working
  • We may also pass data to trusted third party data aggregators or data partners, subject to data use restrictions, so that they can combine this information with other information they have independently collected to understand, and in some cases help us understand, your online activity and preferences across sites, apps, and devices over time
  • Some of these transfers of data may considered “sales” or “sharing” of data under privacy laws applicable to you; you can opt out of any “sales” or “sharing” of data
• Service providers
  • We share certain data with contracted vendors, subject to data use restrictions, so that they can perform functions on our behalf, such as fraud and malware prevention, identification of invalid traffic, and data storage and hosting;
• Regulators, law enforcement entities, and other legal actors
  • In rare instances, we may share data with regulatory, governmental, law enforcement, courts with competent jurisdictions, emergency services, or other legal entities or public authorities in response to a valid legal request, to protect our rights or property, to protect someone’s safety, or to meet national security or law enforcement requirements
  • If we are required to produce your data to these entities, we will limit our response to the information required to resolve the legal request or situation

6. What are cookies and how do we use them?

What are cookies?

A cookie is a very small text document, containing a string of characters that uniquely identifies your web browser. Cookies are created when your browser loads a particular website. The website sends information to the browser which then creates a text file. This allows the browser to remember the websites you visit, and that information is shared with other parties such as our Advertising Partners. This also allows us to collect information about your browsing habits over time in order to facilitate interest-based advertising and make advertising more relevant to you and your interests, as described throughout this Privacy Policy.

In other words, when you visit a Publisher’s website or a digital property, we may assign a random, unique identifier, specific to Bidsvision, to your browser or device.  Using that Bidsvision identifier, our Ad Exchange can automatically recognize your browser or device the next time it visits another website or digital property owned by a Publisher we work with.  This means that, over time, our Ad Exchange can track your online activity to learn about your online browsing behavior and preferences. The Publishers and Advertising Partners we work with can also map their own unique identifiers against our Bidsvision identifier via a process called “cookie syncing,” so that they can use data they have collected independently on our Ad Exchange. In the case of Advertising Partners, the aggregated insights cookie syncing facilitates may influence their decision to bid (or not bid) on opportunities to advertise products or services to you. For example, certain Advertising Partners may be more willing to serve you an advertisement for a particular product if they know, via insights learned from cookie syncing, that you have seen and clicked on advertisements for the same or similar products in the past.

We also use cookies for frequency capping, meaning that we may use data they collect to limit the number of times you see an advertisement, as well as to help measure the effectiveness of our Advertising Partners’ advertising campaigns.

What cookies do we use?

• Cookie ‘i’ – this is the user / market cookie. It includes a random string created to recognize your device for the purpose of delivering advertisements, as well as the timestamp of the string’s creation. By matching this cookie with data collected by Advertising Partners, we and our Advertising Partners can deliver more relevant ads to you. This cookie is stored on your device for 1 year and is refreshed for the next year on each bid request.
• Cookie ‘pd’ – this cookie stores information about which other third parties the user cookie (‘i’ cookie) has been synced with to reduce the amount of user matching done on your device. This cookie is stored on your device for 15 days.
• Cookie ‘OX_dnt’ – this cookie acts as a flag which we set if you indicate that you want to opt-out of interest-based advertising. Please see the information above on opting out of interest-based advertising. This cookie is stored on your device for 5 years.

Third parties

Third parties, such as our Publishers and Advertising Partners, may also serve cookies on your computer or mobile device to facilitate advertising, analytics, and other functions. They may also use information about your visits to different online properties to provide you with more relevant advertisements and measure the effectiveness of their advertising campaigns. We do not have access to or control over these cookies and encourage you to review the privacy and cookie policies of any companies you engage with online to find out about their data collection practices, including how they may use cookies.

7. What choices and rights do you have with respect to the data we process?

Depending on the country or state where you live, you have different legal rights with respect to your personal data and how we may process it.

8. How long do we retain your personal data?

We may keep each data point we collect about you for a maximum of 90 days from the last date that we received it.  For example, if we collect data indicating that you visited a particular website on day 0, we may keep that data until day 90 (at the latest) unless we collect data indicating that you visited that particular website again within that initial 90 day period (in which case, the 90 day clock would reset). For most categories of data, this is limited to 14 days.

Additionally, we’ve set retention limits on the cookies that may be set on your devices. In particular, the market cookie (“i”) used for Bidsvision’s device recognition is set to remain on your device for a maximum of one year, while the cookie implemented to recognize your opt-out from interest-based advertising is set to last for five years, should you choose to opt out.

9. What if we update this privacy policy?

We reserve the right to update this Privacy Policy at any time.  If we do so, we will post the updated policy here. We may also notify you in other ways from time to time about the processing of your personal data.

10. How can you contact us? 

You can reach us at:

ADTECH TECHNOLOGY LLP

41 DEVONSHIRE STREET GROUND FLOOR LONDON ENGLAND W1G 7AJ

support@bidsvision.com