Effective date: May 23, 2018
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 may 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 THE WEBSITE AND HOW WE TREAT INFORMATION COLLECTED FROM CLIENTS
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.
We may store information about your visit to our Website for up to 13 months. We collect personal data such as email address or billing details so long as you continue to have a business relationship with Screen6. You may ask us to delete that information by following the instructions below. We store pseudonymous information collected via our Platform for up to 180 days in order to ensure that our Platform functions properly after which time such information is de-identified.
As stated above, 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 and remove it from our systems. Screen6 does not currently take action on the Website in response to a browser’s Do Not Track signal.
Some of our Clients are third-party advertisers and may collect information about your visits to the Website and also collect information about your visits to other websites in order to help them deliver more relevant advertising messages to you and other consumers. This process is sometimes referred to as online behavioral advertising. If you want more information about online behavioral advertising and information on how to opt-out, please visit the ad industry choice mechanism at http://www.aboutads.info/choices/.
ACCESS AND DELETING YOUR PERSONAL DATA
Screen6 acknowledges that individuals have a right to access their data. If you’d like us to provide access to, update, correct, delete, or deactivate any personal data that you have provided on the Website (including any online interface we provide to Clients), please send your request to firstname.lastname@example.org and the company will process your request within a reasonable period of time after receipt. If you’re an EU data subject and wish to make an access request with respect to data processed via the Website or the Platform, please send an email to email@example.com. Please note that the Website is mostly for information purposes for our Clients and prospective clients and we don’t collect profiles via the Website other than an inference that by visiting the Website you might be interested in our services. Moreover, we operate the Platform as a data processor and therefore only process data as requested by Clients. 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.
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, ONWARD TRANSFER
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.
EU DATA SUBJECTS
In addition to the above referenced privacy practices, EU Data subjects are granted additional privacy rights under the General Data Privacy Regulation (“GDPR”). For example, Pseudonymous data such as an IP address, a mobile advertising ID or a cookie ID are considered personal data under the GDPR. Moreover, an EU individual who seeks to access, correct, amend, port over and/or delete inaccurate data, or who wishes to limit the use and disclosure of their personal data should visit our EU Subject Access process above.
Screen6 operates the Platform and provides our services as a “data processor” under the GDPR. That means that Screen6 processes data via the Platform and services as directed by each of our Clients. Screen6 does not create profiles of Internet Users via the Platform. We may create a profile titled “Interested in S6 services” of those who visit the Website.
We process certain EU personal data provided by Clients and vendors under contractual necessity. For example, we require the billing details of our Clients located in the EU to process payment for the use of the Platform and services and we need email addresses from Clients to enable them to login to our systems. We collect contact details from EU data subjects via our Website with consent and ask for consent to place cookies onto EU desktops. Click here to see information about the cookies placed via the Website. Our sales and marketing team may obtain additional contact details for current and prospective Clients via our legitimate interest where we ascertain that our rights to process such data is not overridden by the fundamental rights of the data subject.
Screen6 data protection officer is Olivier Oosterbaan from LMO Advocaten and he may be contacted at firstname.lastname@example.org.
We may change this Policy at any time. We will post all changes to this Policy on this page and will indicate at the top of the page the modified policy’s effective date. If you have any questions or suggestions regarding this Policy, please contact us at:
Privacy Officer, Screen6
Weteringschans 165 1017 XD, Amsterdam