April 5, 2018
The integrity of individuals is an important factor of Tradedoubler's business success. Tradedoubler's advertisers, publishers, media agencies and other customers (hereafter the "Client/Clients") that from time to time provide Tradedoubler with personal data, as well as web surfers whose digital data is processed by Tradedoubler as part of its provision of services to its Clients (hereafter the "User/Users"), must be able to trust that data is processed by Tradedoubler in accordance with applicable privacy laws and regulations.
Part 1 - General privacy principles
Personal data and controller of personal data
Personal data comprises all information that directly or indirectly can be referred to a natural person who is alive, e.g. name, postal address, e-mail address and phone number. A controller of personal data is the natural or legal person who processes personal data and who decides why and how such data shall be processed.
Tradedoubler AB is the controller of personal data provided by you through the website
'www.Tradedoubler.com'. Tradedoubler AB is the Controller of personal data provided to us by you through sub-sites of www.Tradedoubler.com, that are published and maintained by Tradedoubler AB or its subsidiaries (all Tradedoubler websites hereafter referred to as the "Site") unless otherwise indicated when such data is collected, or personal data that you are asked to provide us with in other situations if not otherwise is indicated.
Collection of personal data
Personal data for which Tradedoubler is controller may be provided by you to us e.g. in the following situations:
• If you are a Client you may be required to provide us with personal and corporate information, such as name, address, email address and other account information, in order to be able to access and use our services;
• As part of our sales efforts, we may collect and store data through online forms for contact purposes;
• If you are a prospect Client, you may provide us with personal data through this Site when applying to join our network;
• The collection of personal data is based on legitimate interest according to the above and for the performance of a contract to which you and TradeDoubler are the parties.
Use of personal data
Personal data provided to Tradedoubler may be used for the following purposes; provide you requested products and services; manage Tradedoubler's agreed obligations and rights towards you; process payments; administration; internal analysis to improve or more effectively tailor Tradedoubler's Site, business or offerings generally; allow you access to agreed products and services; direct marketing; any other purpose you have consented to or which is allowed under applicable law. Your personal data may also be processed for additional purposes stated on any relevant part of the Site or otherwise in connection with the provision to us of your personal data. Your personal data may be combined with other information collected from you or third parties for the above purposes.C
Disclosure and transfer of personal data
Personal data may be transferred to other companies within the Tradedoubler group of companies.
Tradedoubler may as a consequence of service agreements with third parties, also transfer personal data to such third parties who process personal data on behalf of Tradedoubler. Such service agreement shall contain obligations for third parties to process data only in accordance with Tradedoubler's instructions and to take appropriate measures to secure that the processing of the personal data is secure.
Withdrawal of consent
You are at all times entitled to withdraw your consent to process personal data if you have provided consent to Tradedoubler. In such case Tradedoubler will not process your personal data based on consent any more.
You are entitled to request that Tradedoubler shall not process your personal data for direct marketing purposes.
Contact details for withdrawal of consent and/or for request that Tradedoubler shall not process your personal data for direct marketing purposes are set out in Part 3 below.
Right to information and rectification of personal data
Destruction of personal data
Any personal data that we hold on you is only stored as long as it is required for us to keep them in order to fulfill the purposes for which they were collected. Data may however be necessary to store for a longer period due to legal requirements, e.g. for accountancy purposes.
Tradedoubler is dedicated to maintain the security of personal data and preventing unauthorized access through the implementation of appropriate technical and organizational measures, as far as is reasonably possible. Such security measures also include that personal data may be accessed only by a limited number of persons within Tradedoubler.
The Site contains cookies. This Site sends your browser a cookie - a small piece of data stored on your computer's hard drive. The purpose of the cookie is to improve your reading of and your search possibilities on our Site. If you are a registered Client (e.g. a publisher), the cookie will also manage and control your login and session on those part of our Site that are only available to registered Clients.
If you do not want to accept that your computer receives and stores cookies, you can alter your security settings on your web browser (Internet Explorer, Google Chrome, Safari etc.). However, note that certain parts of our Site may only be used fully if your browser allows cookies. Thus, your reading experience of our Site may be affected negatively by removing and not allowing cookies.
If you wish to alter your cookie settings, by going to your browsers settings, below are short instructions for how to do this in the four most popular browsers:
Microsoft Internet Explorer
Click the 'Tools' icon in the top right hand corner and select 'Internet options'. In the pop up window select the 'Privacy' tab. From here you can adjust your cookie settings.
Click the spanner in the top right hand corner and select 'Settings'. From here select 'Under the hood' and change the settings under 'Privacy'.
From the drop down menu in the top left hand corner select 'Options'. In the pop up window select the 'Privacy' tab. From here you can adjust your cookie settings.
From the settings drop down menu in the top right hand corner select 'Preferences'. Select the 'Security' tab and from here you can adjust your cookie settings.
In addition, Tradedoubler may serve ads on this and other websites using our own ad-serving technology. In doing so, one of our ad servers will place or read a unique ad-serving cookie on your computer and will use non-personal information about your browser and your activity at this site to serve ads on this and other sites. The ad-serving cookie is a persistent cookie. For more information about Tradedoubler ad serving or to opt-out of the Tradedoubler ad-serving cookie read the instructions below in section “Tradedoubler’s targeting technologies.
The table below explains the cookies we use and why.
Part 2 - Interest Based Advertising and Retargeting privacy principles
What is Interest Based Advertising and Retargeting?
There exists a range of different kinds of online Interest Based Advertising and Retargeting services; from fairly simple forms to the far-reaching monitoring of web surfer activities carried out by search-engine owners or services carried out in partnerships between technology companies and Internet Service Providers. As a common denomination, you could say that Interest Based Advertising and Retargeting is intended to make online display advertising more relevant to web surfers' likely interests.
Tradedoubler's Interest Based Advertising and Retargeting services use a combination of cookie- and cookieless technologies.. "Cookies" are small simple text files (not programs or spyware) stored on the hard drive of a web surfer's computer. Cookie-less solutions gather data points from the User´s device to create a unique ID for the device. The data points collected are non-PII (non-Personally Identifiable Information). Based on the anonymous information stored in the User's cookie, Tradedoubler is able provide more relevant advertising to the User on behalf of our Clients. For example, a User that visits sports sites often will be categorized in the "sports fan" segment, and will primarily be served advertisements that are relevant to the interests of a sports fan, and a User that shows interest in a certain car model or a certain computer model, may be served advertisements or specific offers for such car model or computer model.
Tradedoubler may also link multiple devices used by a single User into an anonymous user profile. This is done withhashed (anonymous, de-identified) User login IDs used across various devices to login to websites belonging to Tradedoubler's Advertising Network by the User. Such linking enables Tradedoubler to offer its IBA and Retargeting services across devices but not to identify the User.
The fundamental integrity principle underlying all Tradedoubler's processing of digital data relating to Users, is that such data shall be anonymous. Therefore, we do not store IP addresses on the cookie of a User, only a unique randomly generated ID that does not allow Tradedoubler to identify the User; we do not have, and will not initiate, any co-operation with Internet Service Providers in order to identify Users. The data stored on the cookie is limited to information collected at the User's visits to websites belonging to Tradedoubler's Advertising
Network. With the exception of a marginal proportion of cookie data saved for statistical purposes solely, a User's cookie can only be viewed by Tradedoubler when the User visits a website that belongs to our Advertising Network.
What is interest based advertising?
Interest based advertising is Tradedoubler’s solution for optimizing the selection of ads for a certain user. The selection of ads is based on an interest profile built up during visits to websites in the Tradedoubler network.
Interest based advertising step by step:
1. A website user browses sites across the Tradedoubler network (affiliate- and ad networks). The category of each website is saved to a cookie in the web browser.
2. When the website user browse sites related to cars the counter for category “Automotive” is updated in the cookie.
3. Ads are selected and shown to the user based on the category count in the cookie. A user with a higher than average count in the “Automotive” category will be shown more ads related to cars.
Categories and interest profiles
The system is based on 20 categories; for example Sport and Travel. The only information that is saved in the cookie is a counter showing the amount of times a certain category of website has been visited and the time of the latest update of the counter.
Below you can see the information that have been stored in your web browsers cookie.
Retargeting is Tradedoubler’s solution for displaying ads based on which websites or pages the user has visited before.
Retargeting step by step:
1. The user browses the website of a Tradedoubler client that runs a retargeting campaign.
2. Information on what pages the user visits on the website is stored in a cookie in the user’s web browser.
3. When the user visits sites in the Tradedoubler publisher network ads are shown to the user based on the information in the retargeting cookie.
For the website user targeting means that more relevant ads will be displayed, ads that match the user’s interests. For example, a user visiting more travel websites than average will be served more ads related to travel. A user being interested in a certain product will be served ads with offers related to that product.
For the advertiser targeting means enhanced possibilities to reach a certain audience across Tradedoubler’s network.
For the publisher targeting means a possibility of higher return from the advertising inventory. As more relevant ads are shown for a user the probability that the user notices the ad and acts upon its message increases. This will in turn affect the value of the inventory and hence the possible return from it.
Tradedoubler does not save any personal information in the cookie and cannot identify the information in the cookie to a specific person.
You can opt out from our targeting solutions by clicking the button “Block targeting” below, when you have opted out you will not be served ads based on your interests and no targeting information will be stored in your web browser. Tradedoubler will also stop linking your various devices together to an anonymous user profile for the purposes of cross-device tracking and targeting. Note that the blocking ends if you clear your browser from cookies.
Also a publisher can choose not to serve ads with Tradedoubler’s targeting solutions; this is done in the publisher account settings (“Site information” section).
Delete targeting cookies
Your interest profile can be removed by clicking the button “Empty cookie” below or by deleting your browser’s cookies.
Information stored on cookies
The cookie information stored on the User's hard drive for Interest Based Advertising and Retargeting purposes is: (i) User segment hits or information on a specific product, service, brand or model in which the User has shown interest during its visit to a certain website (for example a User that visits a sport site of one of Tradedoubler's Clients, will record a hit in the 'sports' segment and a User that has shown interest in a certain car model will record a hit of that car model) and (ii) time and date stamp of the latest update of the User profile. The User segments used by Tradedoubler for cookie hits are: (1) Animals; (2) Humanities; (3) Automotive (4) Business; (5) Computers & electronics; (6) Entertainment; (7) Finance; (8) Food & drink; (9) Gaming; (10)
Health & beauty; (11) Home & garden; (12) Insurance; (13) Lifestyle & society; (14) News & current events; (15)
Reference; (16) Shopping & retail; (17) Social; (18) Sports & recreation; and (19) Telecom & utilities
For the sake of clarity, no segments relating to sensitive information have been or will be created, such as segments relating to political opinions, religious beliefs, physical or mental health conditions or sexual life. Further, Tradedoubler is very sensitive to the issue of children's privacy and marketing directed to children. No segments are intended to be established for the profiling of children.
Use of collected digital data
Tradedoubler will use the User data in order to better target advertisements on behalf of our Clients, to provide aggregated non-personal reporting to our Clients, and to improve our advertising systems and products. The data may be combined with other anonymous information collected from other sources so that we may better serve Users with offers that may be of interest to them. We may also share anonymous data between companies within the Tradedoubler group of companies.
Tradedoubler is dedicated to maintain the security of all its data and to prevent unauthorized access through the implementation of appropriate technical and organizational measures, as far as is reasonably possible. Such security measures also include access restrictions, i.e. that data may be accessed only by a limited number of persons within Tradedoubler.
You may at any time easily block further Interest Based Advertising and Retargeting activities which are based on cookie-, cookieless or Cross-device tracking from Tradedoubler by opting-out. To do so please follow the instructions above in section “Tradedoubler’s targeting technologies”..
In addition, note that you are always able to prevent cookies from any website from being installed on your computer by readjusting your browser settings. For more information about cookies and how to disable them, you should consult the help section of your browser.
If the cookie is deleted by the User, all profile data is removed.
For avoidance of doubt, please note that the foregoing requirement of notification does not limit any of your obligations according to applicable law. You are yourself as a publisher responsible for providing relevant and accurate information required by law, including applicable privacy laws.
Part 3 - Contact information
Contact details for inquiries and requests:
• For: (i) a withdrawal of a consent to process your personal data previously provided by you to Tradedoubler; (ii) a request that Tradedoubler shall not process your personal data for direct marketing purposes; (iii) a requirement that Tradedoubler shall rectify certain personal data held on you, or; (iv) a Subject Access Request, please send an e-mail to the following address: privacy@Tradedoubler.com;
Please provide relevant details in your e-mail in order for Tradedoubler to be able to process your request or inquiry.
You also have the right to lodge a complaint to the Data Protection Authority if you do not think that Tradedoubler has respected your data privacy rights.