1. PRIVACY NOTICE
Captify is committed to ensuring that your privacy is protected. This Notice sets out how Captify uses and protects any personal data that we process using our technology platform. Any data we collect will only be used in accordance with all applicable laws, including the GDPR, and this Notice. Captify may change this Notice at any time by updating this page. You should check this page from time to time to ensure that you are up to date with any changes. Captify does not collect any data that makes you contactable, such as names, addresses (physical or e-mail), payment or similar information.
Si vous préférez lire cette Politique de Confidentialité en français, veuillez cliquer ici.
Si prefiere leer la presente Declaración de Privacidad en castellano, haga clic aquí.
2. WHO IS CAPTIFY?
Captify refers to Captify Technologies Limited, (registered in England with company number 07620174) and its other group companies in the EU.
In accordance with the GDPR, we have appointed a Data Protection Officer whose contact details are as follows:
c/o Captify Technologies Ltd.
5 Langley Street
London WC2H 9JA, UK
3. WHY DO WE COLLECT DATA?
3A. END USER DATA
Captify is a specialist in displaying advertisements that are relevant to you. Our aim is to enhance your online advertising experience by showing you adverts for products we think you might like based on your preferences or interests. By way of a practical example, you search for a product online, explore various options and continue to surf the web. As you later surf the web, Captify shows you adverts that are related to the product you searched for. With Captify’s service, the digital advertisements you see online or in apps will be more relevant to you than the ads you will see without Captify.
In order for us to process your data, you normally will have already consented to data processing and accepting cookies or similar technologies from one of the publishers that participates in our programmes. You can change your preferences at any time as set out in Section 10 below.
In addition, we and our publisher partners and advertising clients have a legitimate interest, which does not conflict with your legal rights as no further personal data is processed and there is no effect on your web or app experience, in processing data for the following business purposes:
- Counting the number of times ads are seen
- Knowing whether ads have had a chance to be seen (“viewability measurement”)
- Counting the clicks made on ads
- Counting purchases made through ads (“conversion counting”)
- Verifying whether you make a purchase at or visit an advertiser’s online or offline store at a later date after having seen the relevant advertisement (“view-through measurement”)
- Limiting the number of times you see particular ads (“frequency capping”)
- Analysing trends and browsing behaviour
- Detecting and combating fraud
- Testing and analysing the effectiveness of different ads
- Optimizing website and mobile app experiences.
3B. BUSINESS CONTACTS DATA
We also need to process your personal data if we have or are considering a business relationship with you. This may include data relating to your work with the following, for the following purposes:
- a Captify client (e.g. an agency or advertiser) in order to manage our contracts and campaigns, issue invoices and collect payments, and keep records;
- a web or mobile publisher or other data provider in order to manage data, make payments, and manage technical issues;
- a supplier, potential supplier and other business contacts in order to collaborate, evaluate and negotiate the purchase of goods and services;
- potential clients, potential data suppliers or publishers, in order to expand Captify’s business and resources.
Processing this data is necessary where we have a contract with your company or for our legitimate interests in managing and growing our business.
As this data always relates to your professional life (work email, work telephone, information about contracts etc.) and/or is obtained from sources where it is voluntarily offered (e.g. websites, trade shows, professional networking) there will be no negative impact on your privacy or rights, and our use is within what a professional data subject would reasonably expect.
Although applicable laws do not require us to obtain your consent for such data processing, you may still be entitled to exercise your statutory rights in relation to such processing where applicable (see Section 12 below).
We regularly review and update the need for retaining such data and delete such data after the later of:
- two years from the last time we were in direct contact;
- six years from the end of any contractual relationship.
3C. EMPLOYEE, STAFF AND CANDIDATE DATA
If you are an employee or other staff member working at any Captify group company, then this Notice does not apply to data processing in that context. A different Privacy Notice setting out what employee and staff data we process, why and how, is available from Captify’s People Team.
Where you are a candidate applying for any type of position with us, please review the specific Privacy Notice for candidates available here.
4. WHAT TYPES OF DATA DO WE PROCESS?
Captify collects data via anonymous “cookies” or similar identification technologies placed on your device via our partners’ websites or apps, that record:
- Events related to your activity on the partner’s website/app (such as the number of pages/products viewed or your searches made on the partner’s website/app). These may include activities over time and across different web sites, mobile applications, or online services, and across different devices that you use.
- Events related to the Captify ad serving activity such as the number of ads displayed to you or whether you interacted with those ads (as further described in Section 3A above).
This allows us to show you advertising that is more relevant and interesting to you on one or more devices that you use. We do not at any point collect contact information such as your name, address, phone number, email, address, credit card information, or anything else that can allow us or our clients to contact you directly. There is no way for Captify to know who you are. We only collect data from our trusted data partners and do not collect data from public sources.
5. CAPTIFY COMMITMENTS
Captify and its group of companies have partnered with the following organisations to ensure that all information is properly regulated and that you have the greatest amount of choice and control over what information you are providing:
Captify adheres to the IAB Europe OBA Framework. Please see the section below headed “HOW CAN YOU MANAGE COOKIES AND OTHER TECHNOLOGIES?” which explains how you can make choices and control the collection and use of your data for online behavioural advertising.
In addition, Captify participates in the IAB Europe Transparency & Consent Framework and complies with the Framework Policies applicable to different areas of Captify’s business (please see http://www.iabeurope.eu/tcfdocuments/documents/legal/currenttcfpolicyFINAL.pdf or as updated or replaced from time to time).
A cookie is a small text file stored on a user’s device for record-keeping purposes. There are two types of cookies:
- Session cookies are used to make it easier for you to navigate on websites. A session ID cookie expires when you close your browser.
- Persistent cookies are used to run our technology as they enable us to track and target the interests of our users to enhance the experience on our partners’ websites. Persistent cookies remain on your device for an extended period of time. You can remove persistent cookies by following the directions provided in your browser’s help section.
Our partners’ advertisements are displayed on many websites and apps of our partner network. These publishers may also place cookies on your device (or use similar identification methods). This is so that our technologies can recognise that Captify has a personalised advertisement available for your device.
You can find out more information about cookies here.
To manage cookies from Captify, please see Section 10 below.
7. HOW DOES CAPTIFY USE DATA?
The information collected aims to increase the relevance of the ads being displayed to you, to give our clients and partners more information about the performance of their advertising campaigns and websites, and to improve performance over time. In compliance with the best industry standards, we also use IP addresses for purposes such as fraud detection to help alert us to situations which could not have been caused by human behaviour, such as a massive amount of clicking in a limited period of time.
We do not process any information which could be used by Captify, directly or indirectly, with the help of a third party or otherwise, to determine the identity of users. We do not know who you are. We do not know your address, your place of work, your date of birth, your email address or any other personally identifiable information about you. We do not process special categories of data (such as your religion, your political opinions, your health etc.), although if you search for related terms, then that information could be sent to our systems.
8. HOW LONG DOES CAPTIFY KEEP DATA?
We never retain data longer than necessary for the purpose for which it was collected, i.e. to serve relevant ads and help with website and app optimisation and to report back to and check campaign performance with our advertiser and agency clients and publisher partners. We delete/de-identify all data that is more than 13 months old.
9. WHO RECEIVES YOUR DATA?
For our clients, we provide insights in the form of aggregated data, which does not include any individual personal data.
We provide data to other companies in our corporate group and technical service providers inside and outside the EU that require access to data in order to assist us in providing our services. In each case we have in place safeguards that enable these transfers to happen in a way that ensures that data is handled in accordance with similar standards to those applicable in the EU which include: the EU-US Privacy Shield for transfers to business partners in the US; and European Commission approved standard contract clauses for other transfers outside the EU. A copy of these documents can be provided upon request.
In particular, we work with reputable external data processors, to which we provide certain data which may include personal data, in order to provide our technology platform and services, including those listed in the Annex.
In addition, third-party service providers with whom we work (please see Part B of the Annex to this Notice) may set and/or access cookies or other data collection technologies which collect information about visits to websites, mobile websites and/or mobile applications across your various devices, in order to enable our and their advertising clients to provide content and advertisements about goods and services of interest to you. If you would like more information about this practice and your choices with respect to it, please refer to the relevant third parties’ privacy policies.
Finally, if any authority, police force or regulator requested data from us, then we would normally comply with such request without having to notify you or other users.
10. HOW CAN YOU MANAGE COOKIES AND OTHER TECHNOLOGIES?
If you no longer want to receive Captify personalised ads, you can manage this directly as explained here. Please note that this procedure will block ads that are displayed by Captify.
Manage your choices here: Your ad choices
This does not affect email, telephone, direct mail or any other type of marketing, and if you wish to stop receiving those types of materials then you should contact the providers or any official “do not contact” lists separately.
Please note that managing cookie preferences will not block ads that are displayed on the websites you visit, it will simply stop you receiving advertising that has been tailored to your interests. You can also block Captify’s service by visiting the IAB choices platform. Please note that these platforms allow you to choose not to receive interest-based advertising delivered by registered members. You may still see personalised ads from other providers and should also contact them as needed.
Your online choices: More info
You can configure your web browser to remove cookies by following the directions provided in your browser’s “help” section.
PLEASE NOTE: when you manage choices in these ways, a cookie will be set in your browser. You must maintain the cookie on your browser in order for advertising providers to recognise you as a visitor that has made this choice. You will need to repeat this process if you clear that cookie (or all cookies) from your browser, use a different web browser, or use a new device. If you have any questions, please feel free to contact us as set out in Section 2 above. If you decide not to accept cookies from a site, it is possible that in addition to not receiving personalised ads, some other functionalities and content on that site might not work as intended.
You can opt out from receiving targeted advertising based on data collected via applications on mobile devices by following the instructions from the device maker, e.g. (at the time this Notice was published):
- Android: Open the Google Settings app > Ads
- iOS 7 or higher: Choose Settings > Privacy > Advertising
- iOS 6: Choose Settings > General > About > Advertising
11. CHILDREN’S DATA
Captify does not create segments that specifically target people below the age of 13.
It is not our intention even to collect or process data from anyone under 13 years of age. If you are a parent or guardian and believe that Captify may be processing data from someone that you have parental responsibility for, then please contact us at the addresses set out in Section 2 above.
12. WHAT ARE YOUR OTHER RIGHTS?
In accordance with the EU’s GDPR and equivalent UK legislation, you have additional rights in relation to data that we process about you e.g.:
- To ask for access to it;
- To ask for errors in it to be corrected;
- To ask for it to be erased (the “right to be forgotten”);
- If not erased, then to ask us to restrict its processing;
- To object to its processing for specific purposes;
- To ask for a copy to take to another service provider.
Further information on how you can exercise your legal rights is set out here.
Where we process any data based on consent that you have given in the past, then you are always allowed to withdraw your consent at any time (though the processing that took place before withdrawal will still be legal). The main ways to do this are (1) to manage online choices as set out above; or (2) by contacting the publisher sites where you have previously given your consent.
Where we are processing your personal data, the main method of meeting the requirement for erasure is by deleting all personally identifying elements so that the data is permanently anonymised and cannot be traced back to you or any other identifiable person (sometimes called “de-identifiying”).
As indicated above, Captify does not process contact or ID data such as names or emails and so, while we will always investigate any request thoroughly, often it will be impossible for us to know whether or not we are processing any data relating to you, or we may not technically be able to locate it. In such cases, given the safeguards in place that enable you to manage directly your online choices and cookie settings, we believe it would be contrary to the intention of the law and to good data protection practices for us to ask you for (and then to process) additional data about you in order to investigate the request. However, this also means that you can be reassured that you cannot be personally identified or contacted using the data that we hold.
We are always available through the contacts in Section 2 above to help resolve any issues or doubts you may have in relation to processing of your data. If you believe that your rights have not been respected at any time then you also have a right to complain to the Supervisory Authority in your country (also known as Data Protection Authorities or, in the UK, the Information Commissioner’s Office) to ask them for a resolution.
Last updated: 21 January 2019
Annex: Key Data Partners:
A: Data Processors
- Captify Technologies, Inc. of 151 West 25th. Floor 2, NYC, 10001, USA. Processes data, including of EU residents, for the purposes of running advertising campaigns for US-based clients;
- Amazon Web Services, Inc. and its affiliates (primary location in Ireland). AWS provides secure hosting and storage of all Captify data;
- Innovecs LLC, 400 Federal Boulevard, Carteret, NJ 07008, USA (primary location Kiev, Ukraine). Innovecs provides engineering and development expertise and data analytics;
- AppNexus Inc., 28 W 23rd Street, 4th floor, New York, NY, 10010, USA. Appnexus provides processing and delivery of targeted advertising services;
- Google LLC, Google Ireland Limited or any other Affiliate of Google LLC. Google provides processing and delivery of targeted advertising services;
- Avocet Systems Limited, 96-100 Clifton Street, London, EC2A 4TP, UK. Avocet provides technology for the purchasing of ad placements.
- The Trade Desk Inc., 42 N. Chestnut Street, Ventura, CA 93001, USA. The Trade Desk provides technology for the purchasing of ad placements;
- Amobee, Inc., 901 Marshall Street, Suite 200, Redwood City, CA 94063, USA. Amobee provides technology for the purchasing of ad placements.
B: Other Data Partners