Improve Media Ltd. is a Finnish ad network that includes over 100 media and media entities. Protecting the privacy of our clients and website users is crucial to us. In this clause we describe how we handle the personal data of our clients and site users.
Additionally, we process personal data of the publishers in our network as well as data of the advertisers purchasing advertising space to maintain a partnership or client relationship.
If the user continues to browse the site after she or he has been given the information about cookies and how to have an effect on them, the user accepts the cookie settings. The user can block or remove the cookies in the browser settings. The user may block targeted advertising and data collection related to it with the choices listed below.
- What kind of information is collected about the site users and in what ways the data is used
- What kind of information is collected about our clients and in what ways the data is used
- How long the data is stored
- What opportunities to effect the client and the site users have
- Where the data is given
- Where the data is transferred
- How the data is protected
- How you can contact
Data collected about the site users and how the data is used
With the help of server logs and cookies we automatically collect data, which helps us understand how many users Improve Media and sites on its network has, which content or ads are popular and how long the user views the content or the ads. The data includes:
- Site usage and browsing information
- The page from which the user has moved to the site
- Device model
- Browser and browser version
- IP address
- Session time and duration
- Screen resolution and operating system
- Unique device and/or cookie tag
When setting the cookies, the user is given the opportunity to influence the setting of cookies by using the browser settings or by using the options described in the cookie clause.
Additionally, we may create various target groups of the site users with the help of our partners. The target groups consist of information about a set of people who are estimated to behave similarly or have similar features, like interests, age, intents or geographic location. The target group information can be combined with a numeric identifier, such as a cookie or a mobile tag, but we cannot identify the user personally. The target groups may be shared with third parties who want to provide the user with advertising that is likely to be of interest to the user. These third parties may combine our target group information to their own data in order to buy advertising space precisely from the sites where the users interested in the advertiser’s products or services visit.
To the extent that the data collected with cookies can be considered as personal data according to the data protection law, we consider that the processing of the data described above is in the legitimate interest of both Improve Media and the sites within its the network. Websites in our network are ad-funded, so processing the data makes maintaining the sites possible. Site users can reasonably expect to be processed through the information provided and the affecting opportunities offered.
Data collected about the advertiser clients and publishers’ contact persons and how the data is used
Information provided by the clients or data from which the client can otherwise be personally identified includes:
- Contact details such as name, title, address, phone number, email address
- Publisher’s site details, such as URL address, subject, number of visitors, page views
- Advertiser’s campaign details, such as the name of the advertiser and the campaign, date, and impressions
- Company name and business ID
- Client relationship details such as billing, payment, and debt collection information, feedback, and contacts
- Direct marketing bans
- Other data collected with the client’s consent
This data is mainly gathered from the site publishers with the publisher application, from the advertiser and media agency clients the data is gathered during the delivery of the campaign materials and otherwise during the related contractual relationship.
We may also collect information from external sources, such as from company websites. From these potential clients we typically collect name, email address, title, and company name.
We process the information to give an offer of our services or to fill the contract for the service the client has ordered.
Without the information mentioned above, we cannot provide our services, handle orders, contact the clients, provide technical support, bill our services, do commissions or develop our business. We will process the information as long as necessary to maintain the contractual relationship and after the cooperation has ended, to do marketing as described below.
We use the information to market our services. Marketing is essential to our business and therefore of our legitimate interest. A registered person can oppose the processing by contacting us.
We need to keep some personal information in order to comply with accounting or other compelling legislation. In this case, the processing is based on compliance with a legal obligation and we do not use the data for other purposes.
Time period for keeping the data
We retain customer information for as long as is necessary to achieve the purposes stated above, in accordance with the legislation in force.
For marketing purposes, the data is typically stored as long as the person has not refused to receive marketing communications, and the information is otherwise not outdated. If a person refuses marketing, we will keep a record of the ban and contact information so that we can ensure that the ban is complied with.
We may be required to retain some of the client’s personal details in order to comply with accounting or other compelling legislation even after the termination of the client relationship or other basis for processing personal data.
Cookies-related online behavior data are typically retained from a few months to a few years, as data of this time period is assumed to represent the site user’s interests.
Clients and site users can themselves influence the retention time of the information through the opportunities described in the next section.
Rights of a registered person
Data collection and processing can be affected in many different ways. To the extent that we can personally identify our clients, the client has the following options:
- Checking, correcting and deleting the information: The client has the right to check the personal data stored of him or her. At the client’s request, we correct, delete or supplement the personal information that is inaccurate, unnecessary, incomplete or out of date.
- Transferring data from one system to another: By contacting us, the client may receive the personal data he or she has provided us. In this case, the client must have provided the information and it is automatically processed on consent or agreement.
- Prohibition of direct marketing and related profiling: The client may, at any time, deny the forwarding of his of her personal information related to direct marketing by clicking on the link at the end of the message or by contacting our customer service.
- Right of object and limit the processing: On the basis of the client’s personal situation, the client may object to the processing, which is based on a legitimate interest. For example, the processing can be limited for the time when the objection is evaluated.
- Withdrawal of consent: The client may also withdraw his or her consent at any time by contacting us or by any other means provided, for example, via the opt-out link in the e-mail.
Improve Media cannot identify the site users personally. Users can influence the processing as described in the cookie clause.
Disclosing the data
We may disclose personal information about clients and users to third parties in the following cases:
- With consent: We may disclose client’s information to third parties with the consent of the client.
- Target groups: We can share the target groups of the site to third parties. Advertiser customers and their partners use this information when making decisions about buying ad space and analysing the effectiveness of the campaigns. Typically, buying and selling ad space is done by using an automatic software. With these softwares, the advertiser clients or their partners can combine target group information, which describes the site users in our network, with their own data to buy ad space from the site the consumers interested in their products visit.
- Authorities: If required, we may disclose personal information to authorities in accordance with the legislation in effect.
City Digital Group: Improve Media Ltd. is part of the City Digital Group. We can process the client’’s personal information within the group.
- Mergers: In case we sell, merge or otherwise organise our business, personal information may be disclosed to buyers and their advisers.
- Direct marketing and opinion and market research: We can disclose personal information to direct marketing and opinion and market research unless the client has separately denied this.
- Legal claims and debt collection: We may disclose personal information to third parties if we believe it is necessary for the implementation of the agreement, collection of claims, investigation of possible violations, or legal action.
Transferring the data
We use subcontractors to process the data, and by contractual arrangements we guarantee that the data will be processed in accordance with both the legislation in force as well as this privacy statement. Subcontractors process the data on our behalf and may not process it for their own purposes.
Some of our partners may be located outside the EU or the EEA areas. If we transfer data outside the EU or the EEA, we ensure an adequate level of protection of personal data by agreeing on matters relating to the confidentiality and processing of personal data, such as using standard contract clauses approved by the European Commission, and otherwise by processing the personal data in accordance with this privacy statement. Transferring the data outside the EU or EEA may also be based on the client’s consent.
We use the necessary technical and organizational security tools to protect personal data against unauthorized access, disclosure, destruction or other unauthorized processing. Access to the registry is restricted to persons employed by the registry holder and other specified persons, who need the information in their work assignments. Individuals processing personal data are bound by a confidentiality obligation. The data is collected in a database, which requires a username and password, and the data is technically protected with a firewall.
Inquiries about this privacy statement can be sent to: firstname.lastname@example.org.