Our ADVERTISING PRIVACY policy

 Please do read and contact us if anything not understood - your privacy is actually important to us!!

Last updated: 14th February, 2020

Brand Advance LTD (known as Brand Advance) offers an advertising marketplace that proposes innovative advertising solutions to under-represented publishers of diversity and advertisers in the UK, Europe, the United States, Latin America and Asia.

Publishers use Brand Advance’s advertising solutions to monetize their ad spaces either directly or through advertising demand including other advertising buyer partners.

Advertisers or their intermediaries (e.g. media agencies and advertising technology vendors) display their advertising campaigns through Brand Advance advertising solutions on the websites or apps of our publisher partners.

Brand Advance’s advertising technology collects and uses data to help make online advertising more relevant as well as for ad delivery and reporting purposes.

SCOPE OF THIS PRIVACY POLICY

Brand Advance LTD., together with its affiliates (“Brand Advance”, “we”, “us”, or “our”) recognizes the importance of privacy and is committed to providing transparency and control over the use of the data in online advertising.

This privacy policy details Brand Advance’ data practices on how we collect, use, process and share the data we may collect through our advertising services (collectively, the “Services”) as well as the ways in which individuals may exercise control over the use of information collected by us. This privacy policy does not describe Brand Advance’s data practices relating to information Brand Advance collects through its website www.wearebrandadvance.com, and only pertains to Brand Advance’s Services.  Your use of the Services is also governed by the Terms of Use.

As used herein, “personal data” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Brand Advance customer or consumer or his or her household.

Please note that we may update or change this privacy policy.  If we make any material changes we will notify you by means of a notice on our website prior to the change becoming effective.

  1. USER IDENTIFICATION

We do not collect or process information related to (i) name, user address, place of work, date of birth, email address, or phone number, (ii) hardware-based identifiers such as UDID or MAC Address or (iii) sensitive targeting categories as defined by the European Interactive Digital Advertising Alliance (EDAA) in the European Economic Area (EEA) and under other applicable law (e.g. religion, political opinion, health).

In order to deliver personalized ads as well as non-personalized ads, Brand Advance uses the following 3 methods to identify users depending on the device they use, whether they access our Services on web or mobile, and operating system:

  1. Cookie-based identification

Brand Advance places a cookie on the user web and/or mobile browser. Cookies are alphanumeric identifiers that are created on your device through your web browser for record-keeping purposes. Cookies are used to identify a user and store a randomly generated identifier to identify his or her browser across visits.

  1. Cookie-less environments

For browsers setup to not allow cookies to be placed, Brand Advance uses an identification methodology based on IP address non-reversible encryption, browser, and device characteristics. This method allows Brand Advance to identify a user in order to provide the same level of services, such as reporting and targeting information to users, segmenting users, and capping the number of times the same ad is shown to the same user.

  1. Advertising ID

Brand Advance uses its software development kit (“SDK”) technology to identify your advertising ID for mobile applications. For Google Android operating system, we use the Google Advertising ID and for Apple iOS the IDFA

You can opt-out of the use of these technologies as described in Section 9.

  1. INFORMATION WE COLLECT

We do not collect information about you, directly, but we collect data through our web tags on publisher web pages, or through our SDK within publisher mobile apps. We also automatically collect the information listed below about your use of our Services through tracking technologies such as cookies, pixel tags, beacons, and embedded scripts. These tools help us collect and measure session information, time spent on certain pages, and page interaction information.

Automatically Collected Information. 

  • Identifiers: IP address, advertising ID for inApp.

  • Internet or other electronic network activity information:

    • Page URL

    • Browser Information (e.g. Browser name and version)

    • Device Information (e.g. Device type, OS)

    • Network carrier information (e.g. Wifi, 4G or Wired connection)

    • Mobile application information (e.g. Application name or IDFA)

    • User Interactions with Ads displayed by Brand Advance

  • Geological Information:

    • Non-Precise Geolocation data: On web and web mobile, we collect non-precise location information at the country and/or city level that are derived from user IP Address.

    • Precise Geolocation data: On mobile apps, when a user opts-in for Geo Location on the publisher’s app, precise user geolocation (latitude / longitude) might be transferred to Brand Advance’s SDK by the mobile app, but this data is neither stored nor used by Brand Advance.

Information We Infer.

We may derive information or draw inferences from you based on the information we or our partners collect. For example, we may use data drawn from trusted providers in order to infer general users’ interests (e.g. socio-demographic, brand affinity) and improve advertising relevance for users. 

  1. DATA USE

We use the information we collect for various business and commercial purposes, including those described below: 

  • Target advertising: We use the data to filter ad delivery according to the user profile, such as his interests, location, device used or page content;

  • User frequency Capping: We use data to prevent displaying the same ad to the same user too many times;

  • Analyzing traffic and user interactions:  We use data for monitoring and reporting the campaign delivery for advertisers and publishers and for internal business analysis;

  • Delivering ads:  We may transmit part of the user profile using encoded methods to programmatic buyers so that they can deliver their advertising campaigns;

  • Providing, maintaining, and improving our Services: We use data to improve our Services and technology, including training our ad delivery algorithms;

  • Cross device experience: We use data to provide a consolidated experience through a user’s different device or browser environments, and we may link the Brand Advance identifiers on the different browsers and environments the user is using;

  • Providing customer service: We may use data to resolve disputes, feedback, or other issues related to our Services;

  • Debugging, identifying, and repairing errors: We may use data to fix issues that impair the functionality of our Services;

  • Protecting the rights and property of Brand Advance and Complying with Law: We may use data to protect our rights and property and comply with our legal obligations, including to detect, investigate, and prevent fraud and other illegal activities and to enforce our agreements; and

  • Carry out certain short-term activities: We may use data for other short-term, reasonable internal purposes related to our Services or your ongoing relationship with us.  

  • Insights: We may use the data to deliver aggregated insights to our customers, at advertising campaign or market levels.

  1. DATA DISCLOSURE

Data shared with Third Parties.

In order to provide the Services, we need to share data (including personal information) with third party vendors, service providers, contractors or agents who perform functions on our behalf, including the ones listed below. Our service providers are authorized to use the information we provide only as necessary to provide these services to us.

  • Programmatic Buyers: We may send part of the user profile to programmatic buyers using demand side platforms such as The TradeDesk Inc., or Google Display & Video 360, who buy our ad placements through programmatic ad auctions. Those companies are responsible as independent controllers of the data used to deliver their ads on Brand Advance’s network.

  • Viewability measurement. We transmit data to companies specialized in campaign measurement such as Integral Ad Science or MOAT or in order to verify that our ads are viewable.

  • Fraud detection. We transmit data to companies such as DoubleVerify in order to prevent delivering our ads on fraudulent traffic, such as non-human traffic.

  • Geo-location. We transmit the IP address of the user to companies such as digital elements which provide non-precise geo-location services.

  • Analytics and Audience measurement. We transmit data to companies such as Nielsen or ComScore in order to validate the accuracy of our targeting or measure the demographic reach of our network.

  • Affiliates. We may disclose the information we collect through the Services to our affiliates or subsidiaries for the purposes described in this privacy policy; however, if we do so, their use and disclosure of your personal information will be subject to this privacy policy.

  • Hosting. We utilize third party hosting and data-center providers to store data.

  • Data sharing agreement: We may process data sharing with selected premium brands.

Other Disclosures.

We also may disclose information in the following circumstances.

  • Business Transfers. If we are or may be acquired by or merged with another company, if any of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.

  • In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal processes, such as in response to a court order or a subpoena.

  • To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which Brand Advance is involved.

  • Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.

Sale of Personal Information. 

Brand Advance uses data for its business to serve clients and combines such data with other information to help enhance its products and services. Such use may be considered a “sale” under the California Consumer Privacy Act (the “CCPA”). As Brand Advance uses and combines data it receives with other information to help enhance its products and services, Brand Advance considers itself a third party for CCPA purposes. 

Advertisers (and their intermediaries) and publishers that work with Brand Advance should include a “Do Not Sell” link on their website(s) to comply with the CCPA as interpreted by the California Attorney General.

  1. ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

If you are located in the European Economic Area or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data.

Legal Basis for Processing.

When we process your personal data, we will do so, e.g., in the following situations:

  • We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the products or services you have requested).

  • We have a legitimate interest in processing your personal data.  For example, we may process your personal data to send you marketing communications, to communicate with you about changes to our products and Services, and to provide, secure, and improve our products and Services.

  • We find such processing is necessary to comply with our legal obligations.

Data Subject Requests.

You have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred.  You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us as indicated below.

Email us at:  privacy@brandadvance.co.uk

Call us:  +44 (0) 203 962 7179

Or write to us at:

DPO, Brand Advance LTD,

The Dock, Tobacco Quay,

Wapping Lane,

London,

E1W 2SF

  1. DATA RETENTION AND SECURITY

  • We retain the data linked to a user up to 12 months from the date of collection.

  • We may also store aggregated and non-personal data for a longer period than 12 months for financial and statistical reasons.

  • For security reasons, user’s IP address is stored in a private security log for a period of 4 months.

  • Brand Advance cookie is kept up to 365 days after the last user interaction with our services.

  • Brand Advance uses generally accepted industry security standards to protect data.

Your personal information will be retained in accordance with our data retention policy which is designed to retain data for as long as needed for us to comply with our contractual obligations, employment obligations, and other business purposes, including global legal obligations to retain data. We may retain some information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze or troubleshoot programs, enforce our Terms of Use, or take other actions permitted by law. 

We have implemented reasonable security measures to protect the information we collect from unauthorized access, exfiltration, theft, loss, misuse, disclosure, alteration, or destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

  1.  TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES

Brand Advance is based in the United Kingdom and we process and store information throughout the United States, Europe, Latin America, and Asia. Therefore, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.

  1. PRIVACY POLICIES OF THIRD PARTIES

This privacy policy only addresses the use and disclosure of information and data by Brand Advance. Publishers, advertisers and other websites that may be accessible through our Services have their own privacy policies and practices that govern the collection, use, and disclosure of your personal information when you interact with their services and use their products. We encourage you to familiarize yourself with the privacy policies provided by all third parties prior to giving them information or taking advantage of an offer or promotion.

  1. CHOICES FOR ACCESS, DELETION, OPT-OUT OF SALE, AND RIGHT TO NON-DISCRIMINATION FOR CALIFORNIA.

If you are a California resident, you have the right to know what personal information we collect, disclose, and “sell” about you (as that term is used in the CCPA). Additionally, you have the right to access, delete and opt-out from the “sale” of your personal information.

To exercise these rights, please follow the instructions below:

  • How to Request Access to Personal Information: You may request access to your personal information twice in a 12-month period. To do so, please, email us at dpo@brandadvance.co.uk. US residents can as well call us at the number above, requesting to speak with ‘The DPO’. Account holders can request access to their personal information at any time by logging into their accounts on the Services. In response, we will produce an Access Report detailing the personal information we have collected, disclosed, and/or sold about you. This Access Report will be delivered by mail or electronically at your request.  

  • How to Request Deletion of Personal Information: You may request that Brand Advance delete the personal information it has collected and/or maintained about you. To do so, please email us at dpo@brandadvance.co.uk.  US residents can as well call us at the number above requesting to speak with ‘The DPO’. Note, we may need to retain certain personal information as permitted by law, such as to complete the transaction for which the personal information was collected, provide a requested good or service, detect security incidents, protect against malicious, deceptive, fraudulent or illegal activities, comply with legal obligations or to enable solely internal uses that are reasonably aligned with your expectations or lawful within the context in which you provided the information.

  • How to Opt-Out of the Sale of Personal Information: We offer an opt-out from the use of cookies and other tracking technologies in connection with our Services, which may in some cases constitute the sale of your personal information under the CCPA or other privacy laws.  To opt-out of the sale of your personal information, please click Do Not Sell My Personal Information or follow the browser setting instructions below. This will cause information to cease to be added to any cookies or other tracking technologies that have been set on our Services or block them entirely.  It will also inhibit targeted advertising. Please note that you will need to opt out again if you visit one of our Services from a different device or browser or if you clear your cookies.     

Verification

Please note, we will take steps to verify your identity before fulfilling any consumer request. If you maintain an account with us, we will verify your identity through existing authentication practices for the account (e.g., login and password). If you are not a registered member, we will request to verify your identity by matching two or three data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification (e.g., browser and device ID). 

Authorized Agents

You can use an authorized agent to make such requests on your behalf. But we may require the agent to provide a written permission and verify his/her identity or demonstrate that he or she has power of attorney. 

Anti-Discrimination Right

You have the right to be free from discrimination in product quality, goods or services if you choose to exercise your privacy rights under the CCPA. 

Do Not Track Signals

Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we stop running targeted advertising when we receive a “do not track” signal. For information about Do Not Track, visit www.allaboutdnt.org.

  1. OPT-OUT FROM BRAND ADVANCE PERSONALIZED ADVERTISING

If you do not want us to show you personalized ads (based on your inferred interests) please follow the below instructions:

To opt-out from your web browser in any devices:

If you opt-out, you will still see ads, including contextually tailored ads (i.e., ads tailored to the current website or app you are viewing) and ads based on your current location; they just may not be relevant to your interests.

The opt-out mechanism will only opt you out of personalized advertising delivered by Brand Advance in this browser or in mobile applications on this device (e.g., phones, tablets). It will not opt you out on other devices or in other browsers you use.

Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove or reject browser cookies.   Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. Opt-out information is stored in a cookie for 5 years. If you delete your cookies, this information will also be deleted, and you will need to renew your opt-out choices.

For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.youronlinechoices.com, www.aboutads.info/choices, and other similar sites.  

To opt-out from an in an app environment:

If you opt-out, you will still see ads, including contextually tailored ads (i.e., ads tailored to the current website or app you are viewing) and ads based on your current location, they just may not be relevant to your interests.

If you want to disable Brand Advance personalized ads, please refer to your operating system settings.

Mobile device system software are providing mechanisms that allow users to opt-out of the use of information about their usage of mobile apps to deliver targeted ads to their mobile device. For more information, or to opt-out using these mechanisms, consult your device settings (e.g. “Opt-out of Interest-Based Ads” on Android devices and “Limit Ad Tracking” on iOS devices).

Please note that this is a device setting which will disable personalized ads from all providers, and not just for Brand Advance.

If your device’s advertising identifier is reset, you will need to renew your opt-out choice for that device.

  1. CHILDREN’S PRIVACY

Our Services are not directed to children under the age of sixteen (16) in the United States or children under the age of legal majority in jurisdictions outside the United States, nor do we market products or services to such children. 

  1. BRAND ADVANCE SELF-REGULATION COMMITMENTS

Brand Advance is committed to initiatives that intend to provide greater transparency and control for users and as such has made application to the IAB Trust and Consent 2.0 Framework self-regulation initiative.


CONTACT US

For any questions about this privacy policy or our data practices, you can contact Brand Advance:

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