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Privacy notice for The Addressable Platform

Your privacy is our priority

Your data is important. It’s important to us, and we understand that it’s important to you. We are committed to safeguarding your information in line with the latest data protection and privacy laws. We also want to be transparent about what information we collect about you, how we use it, and how you can control what we do with this information.

About this notice

This privacy notice covers the advertising technology platform and services offered by The AddressablePlatform Limited (“we”, “us” or “our” in this notice).

This privacy notice was last updated on 28 June 2019.

What information do we collect and how?

We provide an advertising technology platform and associated services which enable publishers or media owners and advertisers to manage and deliver their premium video advertising inventory and campaigns. To do this, we work with publishers and advertisers and, if you interact with one of the sites or services we work with (including by watching adverts on one of those sites or services), then we will collect data about you.

The data we collect includes the following information:

  • the device used and its IP address;

  • the browser or application used;

  • browser or device-specific identifiers (such as mobile device advertising identifiers or your browser’s user agent string);

  • data provided by the publishers we work with which may include data provided on registration (such as name, age, gender, postcode) and demographic, behavioural, interest or other profile data;

  • data relating to viewing of advertisements across the services that we work with, including the date and time an advertisement was viewed and other data about your interaction with that advert;

  • geolocation data from third parties;

  • location data;

  • data (including identifiers and data provided for matching purposes) provided by trusted third parties (such as publishers of the website,app or other service with which you interact, Amobee Inc and our advertiser clients) who have confirmed they are lawfully able to provide your data for the purposes of targeted advertising and/or provision of our services;

  • information from surveys and research, and information which is available publicly or from other reputable sources (which include trusted publishers or data providers).

We also offer data management services to our business partners via our data management platform (“DMP”). TheDMP enables us and our business partners (including without limitation publishers, advertising clients and agencies) to collect, store and analyse data about audiences. The data in the DMP is the data set out above, as well as any data uploaded by our business partners for their use (for example, where an advertising agency or client has uploaded data which they have confirmed that they are lawfully able to provide for the relevant purposes). We associate enduser data with unique identifiers and use ID syncing to associate our identifiers and data with those from business partners and trusted third party data providers to help us to display more relevant advertisements to end users.

How will we use your information?

When you interact with sites or services we work with we may process your data in a variety of ways, for several different reasons generally on the basis of legitimate interests or in order to comply with our legal obligations (for example, where we have to retain records for the purposes of complying with tax or financial regulation). We have set out more detail on our processing based on legitimate interests in the table below.

Where any of the activities set out below involve the use of cookies or similar technologies, additional information (including about how you can disable them) is displayed to you before such cookies are installed. Cookies may be set by the relevant publisher,website provider or media owner in which case please check their cookie policy or notice and/or on some sites you visit, our partner, Amobee Inc may also set cookies - you can find more information about those cookies here and you can opt out of Amobee’s use of cookies to serve advertising which is more relevant to you via their Consumer Opt-Out page.

Please see below.


Purpose of processing: Understanding use of our services and reviewing effectivenessWe have a legitimate interest in understanding how people are interacting with our services for ad delivery and reporting purposes and to help us serve advertising more effectively and improve our services.We may use your personal information to understand and analyse use of our services. We combine the information which we receive from reputable sources (which include trusted publishers or data or service providers) with information we collect from that product and service and may also combine that information with:

(i) information we collect from our other products and services, (ii) information from surveys and research, and (iii) information which is available publicly.We apply modelling techniques to the information we hold to model audiences for advertising based on certain attributes, understand consumers better and to analyse use across all of our products and services.We and our business partners also have an interest in understanding effectiveness of our services and we also work with trusted third parties (including advertising clients and research providers) to understand effectiveness of advertising (for example, what actions result from viewing advertising) and of our services.


Purpose of processing: Making advertising more relevant to end-users

Our business is related to making advertising more relevant to end users. We receive information from our partners (including publishers, media owners and data providers) and combine that information with information we collect.We have a legitimate interest in using the information we hold to help us serve advertising which is more relevant to you. For example, if you live in Leeds then we would be more likely to show an ad for an event in Yorkshire - and less likely to see an ad for an event in London.We also work with trusted third party partners (such as Amobee Inc and GroupM UK Limited (who also work with Finecast Limited) and other media agencies or advertising clients) to enable them to match against other data they may legally hold and use that combined information to serve ads of particular relevance to you.We work with publishers and other business partners to respect the choices you make not to receive more relevant adverts on that site or service. In these cases, you’ll still see adverts, but they will be generic (which includes advertising served against content being watched) and less relevant to you.


Purpose of processing: Managing serving of advertising

We and our business partners have a legitimate interest in serving and measuring advertising efficiently and to continue to improve our services. This is to ensure that viewers have a good user experience, (for example, don’t see the same advertising over and over again) and to allow our business partners to reach more viewers and know when ads have been served and to measure the efficiency and/or effectiveness of our advertising. We may therefore use data and share data with trusted business partners (including advertising verification partners) for these purposes.If you interact with any apps we work with on a mobile device with a Google Android or Apple iOS operating system then you will be given an advertising identifier by that operating system. We use and pass this identifier to permitted third parties for frequency capping to limit repetitive advertising, for analytics purposes, or to enable us to serve you advertisements of particular relevance to you. You can reset your advertising ID at any time using the settings on your mobile device.


Purpose of processing: Geo-blocking content

Our services are only available in certain parts of the world (the United Kingdom, Channel Islands, Isle of Man and Republic of Ireland) and we have a legitimate interest in limiting our services to these areas to comply with our legal obligations. To ensure we only show you content when you’re in the appropriate territories we detect the IP address of your device to work out your location.


Service providers based outside of Europe

We use third party companies to perform or enable us to provide some of the functions of our services. These third parties are only allowed access to your information as needed to perform such functions or to provide such services. They’re not allowed to use it for any other purpose.

Some of these companies may be located, or have servers that are located, outside the UK and European EconomicArea. Where we share your information with such companies, we take all steps reasonably necessary to ensure your information is treated securely and in accordance with this privacy notice.

However, please note that the data protection and other laws of such countries may not be as comprehensive as those in the UK orEuropean Economic Area. We’ll only transfer your personal information to a territory outside of the UK or European Economic Area under the following circumstances:

  • the European Commission or UK government has determined that an adequate level of protection for personal information is in place in the country to which we transfer your data;

  • standard data protection clauses as adopted by the European Commission or UK government are in place governing the transfer (you can view the standard clauses on theEuropean Union’s legal website at eur-lex.europa.eu);

  • for transfers to the USA, the recipient organisation is a participant in the EU-USPrivacy Shield programme (or equivalent with the UK as and when created); or

  • other appropriate safeguards have been put in place, as described in the privacy notice for the applicable product/service

How long do we keep your information?

We keep your personal information for only as long as necessary, which is longer in some cases than in others. The length of this retention period depends on the purpose for which the data was obtained and its nature. For example:

  • we need to keep some personal information about you so we can deal with any complaints you might make about our products and services;

  • if you ask us to stop processing your personal information for direct marketing, we need to retain enough information about you to enable us to ensure we stop including you in those direct marketing activities;

  • we need to keep personal information so we can defend possible future legal claims.Unless there’s some other reason for keeping it, personal information will be deleted when such a claim could no longer arise or it is no longer required in order to defend legal claims that have arisen; and

  • we have a legal or regulatory duty to retain particular personal information for a certain minimum period (for example under HMRC tax rules).

In what circumstances do we share your information?

We do need to share your personal data with third parties in some circumstances. We pass information about you to other parties as follows:

  • to third parties authorised by us and acting on our behalf, such as our employees, contractors, partners, suppliers, auditors and/or agents, to administer the products and services we provide and/or to help us review and improve these products and services (including reviewing the accuracy of our data and checking how effective we are at making advertising relevant to end users).These third parties are only allowed access to your information as needed to perform functions of the products and services or to provide services to us.They’re not allowed to use it for any other purpose;

  • to reputable third parties such as publishers we work with to enable you to have abetter cross-platform advertising experience (see “Making advertising more relevant to end users” above);

  • to conduct analytics in relation to our products and services, including with regard to our user base, sales patterns, traffic volumes and related matters.This could include comparing the information we hold about you against third party datasets;

  • to the police, regulatory bodies or legal advisers in connection with any alleged criminal offence, unlawful activity or suspected breach of the Terms of Use and/or the breach of other terms and conditions or otherwise where required bylaw or where we suspect harm or potential harm to others. We will cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity or location of or any other information about anyone breaching any relevant terms and conditions or otherwise for the prevention or detection of crime or the apprehension or prosecution of offenders; and

  • to any other third party where you have provided your consent.

We also share your personal information with other parts of our group of companies (the ITV group). We do this to:

  • provide a more personalised experience across our different products and services;

  • provide and/or manage cross or intergroup products and services; and/or

  • provide other services and products you request or to promote those which might be of interest to you.

For privacy notices of other ITV group companies (including for ITV’s Direct to Consumer businesses such as the ITV Hub), please see https://www.itv.com/groupprivacy.

Changes to our business

If we decide to change or restructure our business we may need to pass your personal information to one of our group companies so we can continue to effectively deliver our products and services.However, if we become involved in a merger, acquisition, restructuring, reorganisation or other transaction involving the sale of some or all of our group companies’ assets, then your information may be included in the assets that are transferred to the new owner and may be provided to the entities and advisors involved. Such a transaction could involve us: (i) retaining the right to continue to use transferred personal information in addition to the right of the new owner to use such information; and (ii) engaging in additional transfers of personal information (including new personal information) with the new owner from time to time following such a transaction.

If there are changes to our business(such as a re-organisation or restructuring), your personal information will remain subject to this privacy notice (as amended from time to time). However, where your personal information is transferred to a new owner following a merger or acquisition it may be subject to a different privacy notice. We, or the new owner, will provide notice to you before any of your personal information becomes subject to a different privacy notice.

What are your rights?

Any personal information you supply will be treated in accordance with applicable data protection laws including the Data Protection Act 2018, the General Data Protection Regulation and any other applicable or superseding legislation. We are committed to delivering the rights that individuals are entitled to under data protection laws in the UK. These are:

  • the right to request a copy of the personal information we hold about you. To do this, please contact us at privacy@tapl.tv making clear that you are requesting a copy of your personal information and including full details of what you require. You may also be required to submit proof of your identity;

  • the right to object to your personal information being processed where the legal basis for the processing is our own legitimate interests as a business (see ‘How will we use your information?’ section above). In some circumstances (for example, where we are using cookies or in respect of personalising editorial content or advertising or marketing) we have specific mechanisms to enable this objection. In all cases, we will comply with such a request unless there is a lawful reason for not doing so, such as when we need to continue to process your information to defend a legal claim or if this information is necessary for the ongoing provision of our services;

  • the right to rectification. You may request that we correct any inaccurate and/or complete any incomplete personal information;

  • the right to withdraw consent. Where we are processing your personal information on the basis that you have given us your consent to do so, you may withdraw your consent at any time;

  • the right of erasure. You may request that we erase your personal information and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for retaining your personal information;

  • the right to data portability. In certain circumstances, you may request that we provide your personal information to you in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services to us. Where this right is applicable, we will comply with such transfer as far as it is technically feasible; and

  • the right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your personal information. However, you do have the right to contact the relevant supervisory authority directly. To contact the Information Commissioner’s Office in the United Kingdom, please visit the ICO website (https://ico.org.uk/) for instructions.

Data Controller

The Addressable Platform Limited is a company registered in England and Wales (registered number 11423826) with registered office at 2 Waterhouse Square, 140 Holborn, London EC1N 2AE. Our VAT registration number is 197 0041 67.

The Information Commissioner’s Office(ICO) regulates our processing of your personal information. You have the right to lodge a complaint with the ICO. Details of how to contact the ICO can be found on their website at ico.org.uk.

If you wish to contact us about our privacy notice, please email us at privacy@tapl.tv

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