IVO Media Ltd, herein referred to as “IVO” (“we”, “us” or “our”) is a creative management platform providing advertising technology that enables the design, production and delivery (“Services”) of advertisements on behalf of digital publishers and advertisers who buy media inventory for digital advertising campaigns, purchased directly or via their appointed media buying representative. Once an advert has been bought, our Services allow the advertiser to serve ads to users browsing the internet, using mobile apps and similar placements of digital advertising media, for example outdoor digital display screens. IVO, the digital publishers and the advertisers we work with are fully committed to preserving the privacy of users who see advertisements delivered by IVO.
Data held by IVO is in accordance with the requirements of the Data Protection Act 2018. IVO is compliant with the EU General Data Protection Regulation (GDPR), details for Data Subject Access Requests (DSARs) are provided within this policy.
To meet the standards for transparency and accountability for personal data uses under the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) our administrative, technical and operational controls are designed to comply with regulatory requirements. This includes safeguarding the data under our care using secure encryption technologies and ensuring Privacy by Design in our products on an ongoing basis. A Data Privacy Officer (DPO) oversees our privacy and security compliance and can be contacted at firstname.lastname@example.org.
The IVO platform uses various technologies including web beacons (also known as “tracking pixels”), web storage and similar technologies to provide anonymous aggregated measurement information in the context of an advertising campaign, including for example the number of viewings and clicks on an advert. This helps indicate if an advert is effective for the advertiser.
Non-cookie technologies can also be used to recognise your device in order to show you ads that are tailored to your context. The technologies IVO uses do not identify you as an individual. For example, to show you an advert with the weather in your current non-specific location, your device might be identified, where permitted, through the IP address broadcast by your browser or device. This information is not stored by IVO or used to identify you as an individual in any way.
Collection of Information
In order to serve advertisements to your web browser and to help advertisers provide adverts that are relevant to your context, we automatically collect certain information when you access websites that incorporate our Services or otherwise interact with our Services. This information does not identify you individually.
Collection of Personal Information
IVO does not collect or use data for advertising purposes which directly identifies an individual or is tied to “sensitive information” such as name, postal address, social security numbers or other government issued identifiers, insurance plan numbers, financial account numbers, sexual orientation, or precise information about past, present, or potential future health or medical conditions.
Grounds for Using Personal Data
The advertising campaign data IVO collects and processes on behalf of advertisers is anonymous and aggregated data, consequently IVO Services do not control or process any personal data on behalf of advertisers and digital publishers. When administering the IVO website (https://www.ivo.io), we act as a data controller, relying on the following lawful grounds to collect and process your personal data:
Use of Information
We use the anonymous aggregated information we collect to help our clients understand how their ads are performing, to serve ads that are best suited to your browser and device, and to understand, measure, and report on how users interact with the Services. We may use the information we collect from the Service to maintain and constantly improve upon the Services.
INFORMATION WE COLLECT AUTOMATICALLY ON THE SITE
In order to serve advertisements to your web browser we automatically collect certain information when you access the Site. This information does not identify you individually, but it does reflect information about your visit(s) to the Site and how you interact with the content.
Information Collected on Our Website
Visitors may provide contact information through our website to find out more about IVO, be contacted by an IVO representative, or to start working with IVO. IVO may use this information to respond to your request, to send you marketing communications, and for business purposes such as marketing and research. We will also use the information we collect from advertisers and publishers for invoicing and billing purposes. You may opt out of receiving promotional emails from IVO by following the instructions in those emails or by emailing us at email@example.com. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations, if applicable.
IVO may also work with third parties that collect data on our website and on other websites to serve you targeted ads. You can opt out of interest-based ads by companies that participate in the Digital Advertising Alliance opt out program here.
Information we collect from other sources
We may also obtain other information that does not identify you personally (directly identify a natural person or individual or tied to “sensitive information” under GDPR) from other sources and combine that with information we collect through our Services. For example, we may collect information about you from third parties, including our business partners, other advertising companies, and publicly available sources. Please be aware that the information we receive from other parties is usually voluntarily given through use of their Services.
Grounds for using Personal Data
When administering the website, IVO acts a data controller and relies on the following lawful grounds to collect and process your personal data:
Use of Information
We use the information we collect through the Site to measure and improve user experience. We may also use personal information you provide to us for sales and direct marketing-related communications.
Request Removal of Personal Data for Marketing Communications
Whether we received your information through a form submission on the website, through an email, provided to us directly, or through a partner service, you may opt out of marketing communications through the opt out process provided in our marketing messages. Please note that while the opt out is being processed, you may receive additional marketing communications.
Data Subject Rights (EU)
This section addresses the Article 12 requirement for Transparent information, communication and modalities for the exercise of the rights of the data subject. An individual who seeks access to personal data concerning them, or who seeks to correct, amend, request processing restrictions, object to processing, or delete personal data or exercise a right of portability can direct his or her Data Subject Access Requests (DSAR) query to IVO at firstname.lastname@example.org.
IVO abides by the Data Subject Rights requests referenced within GDPR Articles 13-22 with respect to:
IVO and its subsidiaries and partners have put into place operational processes to comply with all Data Subject Rights requests within 30 days when received, however we may need to verify certain Personal data fields to ensure we act upon the correct data.
RIGHT TO BE INFORMED ABOUT PROCESSING (ARTICLES 13 AND 14):
An individual who seeks access, or who seeks to correct, amend, or delete data collected for sales or direct marketing purposes can contact IVO at email@example.com. We will respond/act within 30 days. You may also Opt Out of marketing communications through the mechanism provided in the message, in which case, we will no longer use your Personal information for direct marketing.
RIGHT TO ACCESS DATA (OR OBTAIN DATA BEING PROCESSED) (ARTICLE 15):
We will release the information upon verification of personal data. If such information cannot be verified, we reserve the right to withhold fulfillment the request.
RIGHT TO RECTIFY INFORMATION (WHEN OUTDATED OR INCORRECT) (ARTICLE 16):
Once data access is given, as per Article 15, the user has the right to rectify. Please submit such requests to firstname.lastname@example.org.
RIGHT TO ERASURE (AND TO BE PUBLICLY FORGOTTEN) (ARTICLE 17):
Personal data held for sales and marketing purposes may be overwritten/deleted upon request.
RIGHT TO RESTRICT PROCESSING (WHEN PROCESSING IS DEEMED TO BE UNLAWFUL) (ARTICLE 18):
IVO will suppress use of personal data for sales and direct marketing following the actions in Article 17. Users can also accomplish this through the Opt Out mechanism provided in marketing communications.
RIGHT TO DATA PORTABILITY (BETWEEN PROPRIETARY SYSTEMS IN A COMMON FORMAT) (ARTICLE 20):
If requested to, we will act in accordance of Article 15 provided that as per Article 20, a common format is available.
RIGHT TO OBJECT TO PROCESSING (PARTICULARLY ACTIVITIES BASED ON CONSENT) (ARTICLE 21):
Similar to Article 17, users may object to use of their personal data for sales or direct marketing communications by either requesting from IVO or via the Opt Out mechanism provided in communications. IVO will comply with all such requests.
RIGHTS RELATED TO AUTOMATED DECISION MAKING (INCLUDING DECISIONS BASED ON PROFILING ACTIVITIES) (ARTICLE 22):
IVO does not rely on any fully automated decision making with respect to sales and marketing communications.
IVO is fully committed to preserving the privacy of users who see advertisements delivered by IVO, and requires the same commitment from all users of the Services including IVO employees, its clients, and anyone authorised to access and use the Platform and related Services (“Platform Users,” “you,” or “your”).
Collection of Information
We automatically collect certain information when Platform Users access and interact with the Services. This information reflects the parts of the platform you visit, and how you interact with the Services.
Grounds for Using Personal Data
When administering the website through which you access the Services, IVO acts a data controller. We rely on the following lawful grounds to collect and process your personal data:
We use the information we collect to grant you access to the Services, to understand, measure, and report on how you interact with the Services. We use the information we collect from the Service to maintain and constantly improve upon the Services, and to periodically send platform and marketing communications.
Request Removal of your Personal Data for Marketing Communications
Whether we received your information through our contractual relationship or through a partner service, you may opt out of marketing communications through the opt out process provided in our marketing messages. Please note that while the opt out is being processed, you may receive additional marketing communications.
Last update 1 October 2019
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