Overview

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.

The delivery and measurement of IVO adverts does not use cookies and does not provide user level targeting or reporting, we do not sell or buy media inventory and do not create or broker consumer profiles or audiences.

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.

The latest version of our Privacy Policy will be kept on this page and may be updated from time to time. Changes are notified by revision of the date at the top of the policy. We encourage you to check back regularly to stay informed about our information practices.


IVO’s Approach to Regulatory Compliance

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 privacy@ivo.io.


Measurement Technologies used by the IVO Platform

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. Occasionally IVO adverts may include Google cookies on behalf of an advertiser. Please refer to the Google privacy policy page for more details. IVO may also work with third parties that collect data on other websites to serve you interest based ads. You can opt out of interest-based ads by companies that participate in the Digital Advertising Alliance opt out program here.

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.


Privacy Policies Relating to Consumers

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.

  • Browser and Device Information: We collect information at the time of the ad being served about your browser and device, including your browser type, device type, IP address, user agent string, operating system, mobile carrier (if applicable), connection type and identifiers assigned to your browser or device, such as the advertising identifiers assigned by platform providers.  This information does not directly identify a natural person or individual, nor is tied to “sensitive information” under GDPR.

  • Usage Data: We collect information about the websites and mobile apps you visit, including the date and time your browser or device accesses such websites or apps and the specific pages accessed;

  • Click Data: We collect information about the adverts that you click on.

  • Location Information: If permitted by your browser or device, we may collect information about the geo-location of your device for the purposes of serving ads that may be more relevant to you.


Collection of Personal Information


Although our Services are designed to avoid collecting information that identifies you personally, in certain cases, at the request of an advertiser or publisher, an IVO advert ad may occasionally be designed to enable the collection of data such as your town or post code, for example if you interact with an ad that includes the function to search for the advertiser’s nearest shop. This information is provided to the advertiser or publisher who sponsored the ad or its authorised service provider and is not used by IVO for and other purpose. The advertiser or publisher’s collection and use of personal information is governed by such advertiser or publisher’s privacy policy.

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:

  • Legitimate business interests. We may use your personal data for our legitimate business interests to improve our websites and content, and to optimize your experience. Consistent with our legitimate business interests and any choices that we offer or consents that may be required under applicable laws and regulations, we may use personal data and technical information for direct marketing.


  • User Consent. We may use personal data described in this Privacy Policy subject to your consent. Notably and where required by applicable laws and regulations, we will rely on your consent for electronic marketing and Personalisation of message content, which may include collecting information from your mobile device or computer. You may withdraw your consent at any time using the opt-out and preference management mechanisms provided within the message or by contacting us as described in this Privacy Policy. Withdrawing consent will not affect the lawfulness of consent-based processing before consent was withdrawn.


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.


Privacy Policies Relating to Commercial Visitors to our Website

Overview


This section of the Privacy Policy describes how IVO collects, uses, and discloses information when you visit this website (“the Site”) and applies to all websites and mobile applications from which IVO collects marketing data including https://www.ivo.io and any/all related service URLs.

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.

  • Browser and Device Information: We collect information at the time of your visit to the Site about your browser and device, including your browser type, device type, IP address, user agent string, operating system, mobile carrier (if applicable), connection type and identifiers assigned to your browser or device, such as the advertising identifiers assigned by platform providers. This information does not directly identify a natural person or individual, nor is tied to “sensitive information” under GDPR.

  • Usage Data: We collect information about your visit(s) to the Site, including the date and time your browser or device accesses the Site and the specific pages accessed;

  • Click and Search Data: We collect information about the links that you click on and the search terms you employ within the Site.
  • Location Information: If permitted by your browser or device, we may collect information about the geo-location of your device for the purposes of serving you ads.

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 privacy@ivo.io. 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:

  • Legitimate business interests. We may use your personal data for our legitimate business interests to improve our websites and content, and to optimise your experience. Consistent with our legitimate business interests and any choices that we offer or consents that may be required under applicable laws and regulations, we may use personal data and technical information for direct marketing.

  • User Consent. We may use personal data described in this Privacy Policy subject to your consent. Notably and where required by applicable laws and regulations, we will rely on your consent for electronic marketing and Personalisation of message content, which may include collecting information from your mobile device or computer. You may withdraw your consent at any time using the opt-out and preference management mechanisms provided within the message or by contacting us as described in this Privacy Policy. Withdrawing consent will not affect the lawfulness of consent-based processing before consent was withdrawn.


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 privacy@ivo.io.

IVO abides by the Data Subject Rights requests referenced within GDPR Articles 13-22 with respect to:

  • Right to be informed (about processing activities and applicable rights)

  • Right to access data (or obtain data being processed)

  • Right to rectify information (when outdated or incorrect)

  • Right to erasure (and to be publicly forgotten)

  • Right to object to processing (particularly activities based on consent)

  • Right to restrict processing (when processing is deemed to be unlawful)

  • Right to data portability (between proprietary systems in a common format)

  • Rights related to automated decision making (including decisions based on profiling activities)


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 privacy@ivo.io. 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 privacy@ivo.io.

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.


Privacy Policies Relating to Authorised Users of our Creative Management Platform

Overview


This section of the Privacy Policy describes how IVO collects, uses, and discloses information when you use our Services and applies to all websites and mobile applications from which IVO collects data including https://builder.ivo.io, https://trafficker.ivo.io , and any/all related service URLs.

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.

  • Browser and Device Information: We collect information at the time of accessing the about your browser and device, including your browser type, device type, IP address, user agent string, operating system, mobile carrier (if applicable), connection type and identifiers assigned to your browser or device, such as the advertising identifiers assigned by platform providers.

  • Right to access data (or obtain data being processed)

  • Usage Data: We collect information about the date and time your browser or device accesses the Services, and the specific pages accessed;

  • Click and Search Data: We collect information about the buttons and links that you click on and the search terms you employ within the Services.

  • Location Information: If permitted by your browser or device, we may collect information about the location of your device for the purposes of tailoring the Services to your locality. We also infer information about your general (non-specific) location based on your IP address.

  • Use of our Platform: We will use your email address for login authentication, Platform update communications, and marketing communications.


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:

  • Legitimate business interests. We may use your personal data for our legitimate business interests to improve our websites and content, and to optimize your experience. Consistent with our legitimate business interests and any choices that we offer or consents that may be required under applicable laws and regulations, we may use personal data and technical information for direct marketing.

  • Performance of contract. If you are our client, we need to collect and use your personal data to fulfill our contract with you and provide access to the Services.

  • User Consent. We may use personal data described in this Privacy Policy subject to your consent. Notably and where required by applicable laws and regulations, we will rely on your consent for electronic marketing and personalisation of message content, which may include collecting information from your mobile device or computer. You may withdraw your consent at any time using the opt-out and preference management mechanisms provided within the message or by contacting us as described in this Privacy Policy. Withdrawing consent will not affect the lawfulness of consent-based processing before consent was withdrawn.


Use of Information

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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