Privacy Notice

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PRIVACY NOTICE
Screen6 B.V. is an advertising technology company that offers a cross-device advertising service. We have a data platform (the “Platform”) that allows ad-tech companies to manage cross-device campaigns in real-time. This privacy notice explains how information is collected and used pursuant to offering our Platform.
This privacy notice also explains how information is collected and used in connection with our delivery of service to our corporate advertising clients (our “Clients”). This includes information collected via our website located at https://s6.io (the “Website”).
We are headquartered in Amsterdam (The Netherlands) at Jozef Israëlskade 46-1H, 1072 SB and we have built our Platform and services with privacy-by-design principles in mind.

PRIVACY PRACTICES FOR THE PLATFORM
Screen6 is a cross-device advertising technology provider. We receive certain information about Internet users (“Users”) from our Clients and process that information on the Platform to help our Clients conduct cross-device advertising. In other words, we process information to help Clients infer that a particular computer or device is the same User or household of another computer or device. The type of information we receive is generally pseudonymous information related to the digital advertising campaigns of our Clients and includes a User’s IP address (which is sometimes received in hashed and/or salted form), user agent, browser type, computer (or mobile device’s) operating system, mobile o/s advertising ID or other pseudonymous identifiers. In certain places like the European Union, this type of pseudonymous data is considered personal data. We also receive other information about Client advertising campaigns such as the time/date that an ad was served. While we don’t read or write our own advertising cookies, we receive information collected via cookies by our Clients. The specific information we receive varies by Client. Screen6 operates as a “processor” of data in that we process data on Platform solely as directed by our Clients and for no other purpose.

PRIVACY PRACTICES FOR DATA FROM CLIENTS
We collect personal data from employees of Clients when provided to us. Typically: full name, email and telephone number. This information can be provided via email, phone, or the Website (when someone uses the contact form). We, and our service providers, use this information to deliver our services and invoice for our services, or in case of a general query to answer questions about our services to potential clients.
On our Website, we do not collect analytics data, although our webhosting service does automatically collect log-data about your use of the Website, such as IP address, referrer, browser type, pages requested and operating system. Log data is kept for 14 days in order to troubleshoot the Website in case of a malfunction. We do not use cookies or tags (web beacons) on the Website and we do not allow other parties to place cookies on the Website.

LEGAL BASIS
We process data from employees of Clients on the basis of our and our Clients’ legitimate interest to deliver our services in a regular manner.
We process data from Website visitors and people that send us messages on the basis of our legitimate interest to provide information about our business.

DATA RETENTION
We store data of employees of our Clients for the duration of our legal relationship with that Client, and for up to 7 years thereafter to meet record-keeping obligations.
We store data from visitors of our Website for 14 days, and of people that send us messages until they request us to remove it.

SECURITY
We take all reasonably necessary steps to protect all information we hold from misuse, loss, from unauthorized access, modification or disclosure. All information is kept on secure servers and protected by firewall security systems to keep information secure and safe. No method of transmission over the Internet or method of electronic storage is 100% secure; therefore, while the company strives to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

TRANSFER OF YOUR PERSONAL DATA
You should know that your personal data may be transferred from your home country to third parties. If you are an EU resident, this could imply that we also transfer data to countries that do not offer an adequate level of protection for your personal data. When we transfer this data, we will do so only when we have put in place appropriate safeguards to protect your personal data. Please contact us to get a copy of the safeguards that we have put in place. Our contact details are at the bottom of this text.

YOUR RIGHTS
As mentioned above, for our Platform, Screen6 acts as an agent and “processor” for the data provided by Clients and only uses that data as directed by Clients. Sometimes our Clients will pass us information which indicates that a particular User has opted out tracking and/or ad targeting. For example, some Users may enact the privacy settings of their Android or iOS device and select “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android). When we see that type of choice indicator, we don’t process information collected about that User’s computer or device. If we receive a subject access requests pertaining to data processed on our Platform, and we are able to identify that the data provided pertains to a particular Client, we will pass your request on to that Client and await further instructions from that Client.
For the data of employees of Clients, you have the right to request access to your personal data that we process. You also have the right to:
• Rectify incorrect personal data or erase it in certain circumstances.
• Restrict or object to the processing of your personal data.
• Receive your data so that you can use it elsewhere (data portability).

If you wish to exercise any of the above rights, please write us at privacy@s6.io. We will respond to all requests within a reasonable timeframe, but four weeks at the latest, unless your request is complicated. You also have the right to lodge a complaint with your local EU data protection authority for unresolved complaints.

INFORMATION RELATING TO CHILDREN
Screen6’s Website and Platform is designed for those 18 years of age and older. Screen6 does not knowingly collect personal data from anyone under the age of 16. If the company is made aware that it has received personal data from someone under 16, it will use reasonable efforts to remove that information from its records.

DATA INTEGRITY, PURPOSE LIMITATION
We process information in a way that is compatible with and relevant for the purpose for which it was collected as described above. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.

DISCLOSURE OF INFORMATION TO THIRD PARTIES
Screen6 may share personal data with trusted third-party partners such as client billing and payment processing vendors and hosting providers for our Website and Platform. These third-party contractors are prohibited from using the information for purposes other than performing services for Screen6.
Screen6 will transfer pseudonymous data back to our Clients after processing. Typically, the information transferred is a subset of the information we’ve received. Screen6 may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. Screen6 may also disclose your information to third parties when obligated to do so by law and in order to investigate, prevent, or take action regarding suspected, or actual prohibited activities, including but not limited to fraud and situations involving potential threats to the physical safety of any person.
Finally, Screen6 may transfer information, including any personal data, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. If Screen6 is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via a notice on our Website of any change in ownership or uses of your person personal data, as well as any choices you may have regarding your personal data.

QUESTIONS AND CHANGES TO THIS PRIVACY NOTICE
We may change this privacy notice at any time. We will post all changes to this privacy notice on this page and will indicate at the bottom of the page when we have last modified the notice. If you have any questions or suggestions regarding this privacy notice, please contact us at:
Privacy Officer, Screen6
Jozef Israëlskade 46-1H, 1072 SB Amsterdam
The Netherlands

privacy@screen6.io

Our Data Protection Officer can be contacted at privacy@screen6.io or by writing to the above address.

This privacy notice was last updated on 27 November 2019