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.

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:

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.

Cookie-less environments

For browsers set up 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.

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.

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.

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 encoding 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.

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 measurements 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 that provide non-precise geolocation 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.

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:

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

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

A 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 the 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.

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.

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.

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.

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