May 24, 2018
At Mediasmart, we take fundamental rights of end-users (data subjects) seriously and we are committed to protecting and respecting your privacy and your privacy rights. This document explains when and how we collect personal information about people who a) visit our website and/or use our services through website and on-line servers and b) are exposed to the advertisements (“Ads”) in which technical serving process we are involved, how we use such personal information, the conditions under which we may disclose it to others and how we intend to keep it secure. Mediasmart participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Mediasmart’s identification number within the framework is 193.
Any questions regarding this Policy and our privacy practices should be sent by email to: firstname.lastname@example.org.
Who we are
We are Mediasmart Mobile, S.L. (“Mediasmart”) a software as a service platform for advertisers, agencies and companies seeking to dramatically improve their on-line advertising strategies. We are a Spanish limited liability company, with tax ID number B-86329638 and our registered address on: Calle Garcia de Paredes 12, 1ºB, 28010, Madrid.
How do we collect information from you?
We process very limited information about you (your “Personal Information”).
Such Personal Information is collected in the following ways:
- On our website and servers, when you visit and browse through it and/or use any of the services we provide through it such as accessing “bsmart”) our advertising biding platform.
- On behalf of our clients: We collect Personal Information when you use any of our providers products or services which use Ads within them. What this means is that when you for instance use an App or visit a web page from a mobile device that shows Ads, chances are that such advertisement impressions have been “purchased” by companies using our software as a service platform in order to serve you such Ads. Our advertisement serving software collects Personal Information to the extent and in the way explained in this policy (please see next section).
What type of information is collected from you?
The Personal Information we collect through our website/servers and/or on behalf of our clients include cookies and on-line identifiers from the mobile device used to run the App or browse the web pages in which the Ad impression was served and might include as well the IP address being used at the time the Ad was served and other ancillary information such as: the size of the ad space, the operating system and version running in your mobile device, the category of the app or website where it was served, or the approximate location of the device.
‘Cookies’ are small text files containing pieces of information (often including a unique identifier), sent to your computer and stored on your hard drive to allow a website to recognise you each time you visit. They collect statistical data about your browsing actions and patterns and do not generally identify you as an individual. Mobile devices identifiers have been likened to cookies.
Please note that while these cookies and device identifiers are regarded as Personal Information and while we process and protect them as such, they do not specifically and automatically identify you as an individual. While it would be extremely difficult for us or for any third Party to know about your specific identity using this information, at any time you might choose to: erase or remove your browser cookies as well as reset the on-line identifier of your mobile devices rendering all and any personal data linked to such devices obsolete.
Which is the legal basis for this processing of your Personal Information
We rely on the following separate bases to lawfully process your information:
i. Usage of the bsmart platform: We need to process your Personal Information in order to be able to provide you to access to the bsmart in accordance with its Terms of Service. This processing is necessary to perform the contract between you and us. ii. We may process Personal Information where necessary for the purposes of our legitimate interests or the legitimate interests of third parties, where those legitimate interests are not overridden by your rights or interests.
How is your Personal Information used?
Website and server cookies ared used internally to measure how the different sections from our website work, track your browsing through it and also in order to find out where is the traffic coming from at any moment in time.
Bsmart cookies are used to identify you within the platform and in order to provide you with our Services, including information about how you interact with the platform and those of our third-party partners and information that allows us to recognise and associate your activity across devices and Services. This information may include information such as IP address, cookie information, browser version, operating system type and version, mobile network information, device settings and software data.
With regard to device identifiers collected on behalf of our customers, we use them to:
allow our customers to target their advertisement campaigns, for example, the product an advertiser is promoting may work only in a given country and a certain operating system, and in order to properly manage the campaign our system needs to read the IP address (to understand in which country the Ad will be served in) and the operating system; allow our customers to generate user segments (what we call “audiences”) based your previous interactions with their advertising campaigns; allow our customers to target identifiers based on them being part of certain user segments (those segments may have been created with our platform or a different one); allow our customers to track whether or not you have engaged with their Ads
Our clients may analyse your personal information to create a profile of your interests and preferences so that Ads can be better targeted to you. We may also use your Personal Information to detect and prevent fraud.
Allowing our customers to target user segments is what we call “Interest Based Advertising”.
We will hold your personal information on our systems for as long as is necessary for the relevant activity (we have set a general maximum limit of six (6) months).
Who has access to your Personal Information?
We do not share any Personal Information obtained by way of the cookie usage of our website. With regards to information obtained through your usage of bsmart, we may share your information with third-party partners used to provide you with add-on services to bsmart if and when you request them.
With regard to device identifiers obtained on behalf of our customers, we may need to share your Personal Information with certain partners at the very moment our system has to decide whether or not to buy some specific ad space as programmed or instructed by our clients. For example, if the App or website where you are about to see an ad does not tell us which country you are in, we will need to send your IP address to one of our partners to find out about the country based on your IP address (all of our campaigns have to be targeted to one or several specific countries). Or, if our customer is working with a Data Provider, and targets a campaign to user segments created by that Data Provider, we will need to check with said Data Provider whether your identifier is in the targeted user segment before we decide to try and buy the Ad slot.
Our customers will have access to your information when they have purchased that impression and thus have served you an Ad.
Third Party Service Providers we work with:
- AdSquare (www.adsquare.com), a mobile data exchange who can work as a Data Provider for our customers
However, when we use third party service providers, we disclose only the Personal Information that is necessary to deliver the service and we have arrangements in place that requires them to keep your information secure and not to use it for any other purposes. Please be reassured that we will not release your information to third parties beyond the Ads serving process we’ve described, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
How you can opt-out of processing and access or update your Personal Information
a. Website browsing and/or server cookies
You may refuse or accept cookies from websites at any time by choosing the appropriate settings on your browser. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Please we aware that should you choose to decline all cookies, you may not be able to sign in or use other features of our website that depend on cookies.
Information about the procedure to follow in order to enable or disable Cookies can be found at:
- Chrome: https://support.google.com/chrome/answer/95647?hl=en
- Safari: https://support.apple.com/kb/ph21411?locale=en_US & https://support.apple.com/en-us/HT201265
- Firefox: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
- Microsoft Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
For more information about other commonly used browsers, please refer to http://www.allaboutcookies.org/manage-cookies/.
To opt-out of participating in Google Analytics data follow the instructions: https://tools.google.com/dlpage/gaoptout.
In order to access to a detailed list of cookies used by Mediasmart, please refer to this page.
b. Interest-based advertising Personal Information
You may opt-out of this interest based advertising process altogether
Please note that you have the choice to opt-out from all Interest Based Advertising activities by changing the settings on your Android or iOS phone or tablet (we never use your identifiers if you use mobile devices with any other operating system).
Your iOS or Android mobile device provides a “Limit Ad Tracking” or “Opt out of interest-based advertising” setting. When you have opted out using this setting on a device, we will not allow our clients to use personal information collected from that device for any targeting purposes, nor to create any user segments.
You can find the setting for your mobile device by following the directions below:
iOS Device iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting iOS 6 Go to your Settings >Select General > Select About > Select Advertising > Enable the “Limit Ads Tracking” setting More information about the iOS setting can be found here. Android Device.
Android devices with OS 2.2 and up and Google Play Services version 4.0 and up: Open your Google Settings app > Ads > Enable “Opt out of interest-based advertising” If you’ve turned on Limit Ad Tracking on your iOS device or the Opt out of interest-based ads on your Android device, you can restore interest-based ads by turning the settings off.
When you opt out, you may still see the same number of Ads on your mobile device; however, these ads may be less relevant because they won’t be based on your interests, neither Ads bought with our platform, nor with any other platform. We may continue to serve you Ads based on other non-personal information, such as ads related to the content of the application you are using.
What this means is that by opting out of from all Interest Based Advertising you will not remove advertising from the pages you visit; instead it means the ads you will see may not be matched to your interests.
Opting out of interest based advertising just from Ads managed by Meadiasmart:
You can opt-out of interest based advertising coming ONLY from our clients by providing us your advertising identifier (IDFA if you have an iPhone or GAID if you have an Android phone). In order to do this, please use the tool we have developed for this purpose by visiting this link.
By providing us with these identifiers, we can also tell you what user segments in our system your identifiers are currently part of. You may request us to be deleted from certain user segments and we shall communicate your request to the corresponding client.
Security precautions in place to protect the loss, misuse or alteration of your information
We take this matter seriously and we’re continuously evolving our platform to make sure data integrity and data security are always a priority. Our platform and servers use encryption techniques for storage and transmission of data.
We are concerned to protect the privacy of children. If you are aged 16 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.
Transferring your information outside of Europe
If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.
IMPORTANT: If you do not agree with this transfer of Personal Information outside of Europe, you may opt-out of our processing of you Perrsonal Infiormation by using the procedures explained in section 9 above: “How you can opt-out of processing and access or update your Personal Information”.