Last update: 19 May 2022
Introduction
The integrity of individuals is an important factor of Tradedoubler’s business success. Tradedoubler’s advertisers, publishers, media agencies and other customers (hereafter the “Client/Clients”) that from time to time provide Tradedoubler with personal data, as well as web surfers whose digital data is processed by Tradedoubler as part of its provision of services to its Clients (hereafter the “User/Users”), must be able to trust that data is processed by Tradedoubler in accordance with applicable privacy laws and regulations. This Privacy Policy was created in order for Clients and Users to better understand how information relating to them is processed by Tradedoubler. The Privacy Policy is not exhaustive, but contains certain fundamental privacy principles applied by Tradedoubler which Tradedoubler considers to be of particular importance for Clients and Users to be aware of. If you do not agree to this Privacy Policy and/or other terms and conditions stated in connection with the collection, please do not provide personal data to Tradedoubler. Tradedoubler reserves the rights not to provide you certain products or services should you choose not to provide required personal data.
Part 1 of the Privacy Policy contains Tradedoubler’s general privacy principles with regard to its processing of personal data provided by individuals on our website contact card and to Tradedoubler´s web visitors.
Part 2 of the Privacy Policy contains information regarding Tradedoubler’s processing of digital information about Users on behalf of our advertisers for the sole purpose of letting them advertise through Tradedoubler’s Publisher network. It also contains requirements on publishers with whom we have contracted to serve marketing services, to inform Users about Tradedoubler’s data processing on their websites and obtain User´s consent as required by applicable data protection laws.
Part 3 of the Privacy Policy contains contact information for different kinds of inquiries and requests relating to Tradedoubler’s processing of personal data and this Privacy Policy.
Tradedoubler may at any time and without notice change the Privacy Policy, e.g. to keep it compliant with applicable laws. You should therefore read this Privacy Policy each time you intend to provide Tradedoubler with personal data.
Part 1 – General privacy principles
Personal data and controller of personal data
Personal data comprises all information that directly or indirectly can be referred to a natural person who is alive, e.g. name, postal address, e-mail address and phone number. A controller of personal data is the natural or legal person who processes personal data and who decides why and how such data shall be processed.
Collection of personal data via our website contact card
Personal data that you submit to Tradedoubler on our contact card on our websites for which Tradedoubler is controller may be provided by you to us e.g. in the following situations:
- As part of our sales efforts, we may collect and store data through online forms for contact purposes;
- If you are a prospect Client, you may provide us with personal data through this Site when applying to join our network;
- You may provide us with personal data when you send us inquiries relating to our services or in relation to this Privacy Policy. The collection of personal data is based on legitimate interest according to the above and for the performance of a contract to which you and Tradedoubler are the parties.
Use of personal data
Tradedoubler is committed to protect any personal data you provide to us and to process your personal data in accordance with this Privacy Policy and applicable laws.
Personal data provided to Tradedoubler may be used for the following purpose: direct marketing. The legal ground for Tradedoubler to process and store your personal data is legitimate interest. The personal data is stored as long as the data subject is considered to be a prospect and deleted when not needed anymore. The personal data provided by you on our contact card is currently stored in the UK.
Disclosure and transfer of personal data
Personal data may be transferred to other companies within the Tradedoubler group of companies. Tradedoubler may as a consequence of service agreements with third parties, also transfer personal data to such third parties who process personal data on behalf of Tradedoubler. Such service agreements including data processing agreements shall contain obligations for third parties to process data only in accordance with applicable data protection laws and to take appropriate measures to secure that the processing of the personal data is secure.
For any of the purposes described herein, personal data may be transferred to Tradedoubler’s business partners within or outside the EU/EEA or in a third country declared as offering an adequate level of 3 protection through a European Commission decision (‘Adequacy Decision’), meaning that data can be transferred with another company in that third country without the data exporter being required to provide further safeguards or being subject to additional conditions. In other words, the transfers to an ‘adequate’ third country will be comparable to a transmission of data within the EU, like the UK for example. Should any of the recipients reside in a country without adequate legal protection for personal data, Tradedoubler will make sure the recipient adopt appropriate safeguards and enter contractual arrangements with the recipient of the personal data, using, for example, the standard contractual clauses approved by the European Commission.
Right to information and rectification of personal data
Tradedoubler will take reasonable measures to rectify incorrect information, block or erase personal data without undue delay. You also have the right to contact Tradedoubler in order to object the processing. Part 3 of this Privacy Policy contains information about who you should contact if you would like us to correct or delete personal data that we hold on you.
To the extent required by law, we will inform you about Tradedoubler’s processing of your personal data in connection with the initial collection or registration of your personal data.
You may request a copy of the personal data that Tradedoubler holds about you (“Subject Access Request”). This information will include information regarding what personal data Tradedoubler processes about you, where such information has been collected, for which purpose the information is being processed, and to whom, or to which categories of persons, the information is being disclosed. Contact information for Subject Access Request is set out in Part 3 of this Privacy Policy.
Destruction of personal data
Any personal data that we hold on you is only stored as long as it is required for us to keep them in order to fulfill the purposes for which they were collected.
Security
Tradedoubler is dedicated to maintain the security of personal data and preventing unauthorized access through the implementation of appropriate technical and organizational measures, as far as is reasonably possible. Such security measures also include that personal data may be accessed only by a limited number of persons within Tradedoubler.
Our employees are made aware of and must comply with Tradedoubler’s security standards. When we occasionally use third-party contractors to perform tasks that might otherwise be performed by our employees, these contractors are contractually bound to similar restrictions as our employees.
Cookies
The Site contains cookies. This Site sends your browser a cookie – a small piece of data stored on your computer’s hard drive. The purpose of the cookie is to improve your reading of and your search possibilities on our Site. This cookie is not personal data since neither Tradedoubler or any other party can identify you by this cookie number. It is just a unique randomly generated number by Tradedoubler. If you are a registered Client (Advertiser or Publisher), the cookie will also manage and control your login and session on those part of our Site that are only available to registered Clients. These session cookies are automatically deleted when you close your browser.
If you do not want to accept that your computer receives and stores cookies, you can alter your security settings on your web browser (Google Chrome, Microsoft Edge, Safari etc.). However, note that certain parts of our Site may only be used fully if your browser allows cookies. Thus, your reading experience of our Site may be affected negatively by removing and not allowing cookies.
The table below explains the cookies we use and why.
Signup/Login cookies
| Cookie name | Description |
|---|---|
| JSESSIONID | For security reasons when logging in a session cookie is needed. It is a unique id to this session and encrypts this in a cookie. This cookie is set when logging in and will be deleted when logging out. |
| test | To check if cookies are disabled or not in the browser. To inform the user that cookies has to be enabled for the signup and be able to login. |
Tracking cookies
| Cookie name | Description of how it works (what kind of data is collected, what is the purpose, what kind of activity is allowed due this process) |
|---|---|
| UI | The Unique Impression Cookie contains programs of viewed ads together with the time of the ad-view. This information is used to be able to identify unique ad-views. |
| TD_POOL | Ad-pools have the feature of ad-rotation. To support this, pool based ad-views are stored in a cookie. |
| PI | The Post Impression Cookie holds information about ad-views for those organizations that have post impression tracking activated. |
| TD_EH | The Event History Cookie contains information about the tree latest tracks (clicks) and the ten latest closures per program. This information is used to be able to connect clicks with closures. |
| TradedoublerGUID | The GUID Cookie holds an identifier to support server side storage of the user event history. |
| OPT_OUT | Allows a user to disable cookie based tracking or targeting for the browser that the user is using. |
Part 2 – Tradedoubler's processing of digital information about Users
Introduction
Tradedoubler processes digital information about Users (web surfers) who visit websites belonging to Publishers with whom Tradedoubler has contracted to serve advertisements (the “Advertising Network”). This part of the Privacy Policy lets you know what information we collect and process about you as a User on behalf of our Advertisers, why we collect it through Publishers and how it is used in relation to our services to our Advertisers. Further, the Policy contains instructions to our publishers on how to inform Users about Tradedoubler’s services on their websites.
The fundamental integrity principle underlying all Tradedoubler’s processing of digital data relating to Users, is that such data shall be anonymous. Therefore, we only store a unique randomly generated ID that does not allow Tradedoubler to identify the User; we do not have, and will not initiate, any co-operation with Internet Service Providers in order to identify Users. The data stored is limited to information collected at the User’s visits to websites belonging to Tradedoubler’s Publisher Network, your cookie id and/or IP number. Cookie id and/or IP number are deleted automatically after six weeks unless shorter retention period is required by our Advertisers. Cookie id and IP numbers are stored by our cloud hosting partners within EU. The legal ground for Tradedoubler and our Advertisers to process your personal data is consent collected by our Publishers on their websites.The overall purpose to collect your personal data is to provide our Affiliate marketing services to our Advertisers and to enable them to advertise through Tradedoubler’s Publisher network. Tradedoubler does not collect any personal data for any own or other purposes, such as profiling or retargeting etc.
Opt-out
Note that you are always able to prevent cookies from any website from being installed on your computer by readjusting your browser settings. For more information about cookies and how to disable them, you should consult the help section of your browser.
Publisher notification
If you are a publisher, please note that you are obligated to inform visitors of your website about third parties who are serving advertisements on your website by way of use of cookies and/or IP numbers. You are required to inform visitors to your website of this personal data processing, gain their consent for passing data to Tradedoubler and to hash the data in accordance with Tradeoubler´s instructions before sending it to Tradedoubler. The consent needs to be in line with GDPR and the ePrivacy directive . As a party to the publisher agreement with Tradedoubler, you agree to provide clear and unambiguous information about this.
To comply with the regulations governing personal data processing under the GDPR and the ePrivacy Directive you must:
- Receive users’ consent before you use any cookies except strictly necessary cookies.
- Provide accurate and specific information about the data each cookie tracks and its purpose in plain language before consent is received.
- Document and store consent received from users.
- Allow users to access your service even if they refuse to allow the use of certain cookies.
- Make it as easy for users to withdraw their consent as it was for them to give their consent in the first place.
For avoidance of doubt, please note that the foregoing requirement of information and gaining visitors´consent does not limit any of your obligations according to applicable law. You are yourself as a publisher responsible for providing relevant and accurate information required by law, including applicable privacy laws.
Part 3 - Contact Information
Contact details for inquiries and requests:
- For general inquiries concerning this Privacy Policy or Tradedoubler’s processing of data, please send an e-mail to the following address: privacy@tradedoubler.com;
- For: (i) a request that Tradedoubler shall not process your personal data for direct marketing
purposes; (ii) a requirement that Tradedoubler shall rectify certain personal data held on you, or;
(iii) a Subject Access Request, (iv) delete your personal data, please send an e-mail to the following
address: privacy@tradedoubler.com;
Please provide relevant details including country you signed up with in your e-mail in order for Tradedoubler to be able to process your request or inquiry.
You also have the right to lodge a complaint to the Data Protection Authority if you do not think that
Tradedoubler has respected your data privacy rights.