Privacy policy

What we do

At Affectv, we're dedicated to the highest standards of consumer privacy. Our technology and processes are regularly audited by ABC and EDAA to ensure we meet industry best practices of consumer data privacy and any data we collect will only be used in accordance with all applicable laws and GDPR. 

Our Technology & Service

Affectv provides technology services to advertisers that enable them to serve relevant online advertising to consumers who are browsing the World Wide Web. Through this, we process pseudonymous data regarding the relationships between people, the website pages they visit and/or the actions they take on a website, with the purpose of facilitating advertising to consumers that is more relevant and tailored to their particular interests. We achieve this through creating segmented profiles based on users’ browsing history that allows our clients to clients categorize users with similar characteristics or interests, improving their ability to deliver more relevant advertising. In doing so, we make all efforts to ensure that we only process personal data where we have a suitable legal basis to do so and only process personal data in a pseudonymous form to the greatest degree possible.


A.  IMPORTANT INFORMATION AND WHO WE ARE 

Affectv is the data controller, either jointly or solely and responsible for processing your personal data. You may contact our Data Protection Officer using the details below.


B.  THE DATA WE COLLECT ABOUT YOU 

We may collect, use, store and transfer different kinds of personal data about you as follows:

This data may be collected through information you submit directly to our website or cookies operated by Affectv or our third party partners or collected through our website or as you otherwise provide to us. We explain these categories of data further below (section 3. How Is Your Personal Data Collected?). 

We use different methods to collect data about you, which are explained below (section 5. Disclosures Of Your Personal Data).


C.  HOW WE USE YOUR PERSONAL DATA 

We will only use your personal data for the purpose for which we obtained it which include the following:  

More detail on how we create profiles and use your personal data can be found below (section 4. How We Use Your Personal Data).


D. HOW WE SHARE YOUR PERSONAL DATA

We may share your personal data with our trusted third-party partners, including organisations we use for data storage and real-time bidding platforms that allow our clients to present suitable, targeted advertising to you. More detail can be found below (section 5 subheading, Third-party Partners).

 

E.  INTERNATIONAL TRANSFERS   

In addition to on our systems, the information that you provide to us may be stored in secure servers which are located in the European Economic Area (EEA). However, our third-party providers may transfer, store and process your personal data outside the European Economic Area (EEA). More details can be found below (section 9. Your Legal Rights).

 

F.  YOUR LEGAL RIGHTS 

Under certain circumstances, you have rights under data protection laws in relation to your personal data that we collect, which we are committed to respecting. In particular, you have the right to:

You may also make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

These rights may be limited where we process personal data about you in an anonymous form, in which case you should contact the website publisher that originally collected the information from you. Additionally, we may require additional information from you, such as CookieIDs, in order to comply with a request for the exercise of your legal rights. More details can be found below (section 10: Cookies).


Opt-out  

You have the right to opt-out from having advertisements tailored to our interests. To exercise this, please click here.  

You can opt out from Affectv’s use of cookies here.  

More details on opting-out from further use of cookies can be found here (section 10: Cookies).


G.  FURTHER DETAILS 

If you are looking for more information on how we process your personal data including details on data security, data retention and lawful processing bases, please see our full privacy policy below.


Privacy Policy

INTRODUCTION 

Welcome to Affectv’s privacy policy.  

Affectv respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 

1.  IMPORTANT INFORMATION AND WHO WE ARE   

PURPOSE OF THIS PRIVACY POLICY   

This Privacy Policy aims to give you information on how Affectv collects and processes your personal data obtained directly from yourself or from third parties, including any data you may provide through this website.  

Our services are not designed for, or intentionally targeted at, children 13 years of age or younger. We do not intentionally collect or maintain data about anyone under the age of 13.

 

CONTACT DETAILS   

Affectv is the data controller, either jointly or solely and responsible for the legality of processing your personal data (collectively referred to as ”Affectv”, “we”, “us” or “our” in this privacy policy).  

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise [your legal rights], please contact the Data Protection Officer using the details set out below.  

If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Officer (DPO) in the following ways:

Full name of legal entity: Affectv

Email address: privacy@affectv.com

Postal address: Affectv, 1 Mark Square, London, EC2A 4EG.

Telephone number: +44 (0) 20 3934 2174  

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.  

ICO contact details

Email address: casework@ico.org.uk

Postal address: Information Commissioner’s Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Telephone number: +44 (0) 303 123 1113

 

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES   

We keep our Privacy Policy under regular review. This version was last updated on November 2018. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

THIRD-PARTY LINKS 

This website includes links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

2.  THE DATA WE COLLECT ABOUT YOU   

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:  

We may also collect, use and share such data, including Behavioural Data, as Aggregated Data, such as for statistical purposes. This may involve aggregating users’ behavioural interests, where the Aggregated Data is completely anonymous. We may also aggregate data on usage of a website’s functionalities to calculate the percentage of users accessing a specific website feature.

We may incidentally collect Behavioural Data related to Special Categories Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual life, sexual orientation, political opinions, trade union membership or information about your health,), although we explicitly exclude any form of profiling or advertising based on these types of data. We do not collect any information about criminal convictions and other offences.

 

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including the following:  

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

Automated technologies or interactions. As you interact with our website or websites hosted by our third party partners, with cookies embedded, Technical Data will automatically be collected, which may also translate into Behavioural Data, about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy below (section 10: Cookies) for further details.  

Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

1. Technical Data and Behavioural Data from the following parties:

(a)  Analytics providers, such as Google Analytics; and

(b) Third party providers, such as AddThis, and ShareThis;.  

2. Identity Data, Technical Data and Behavioural Data from data brokers or aggregators such as AddThis and ShareThis;

3. Identity and Contact Data from publicly available sources, such as Companies House and the Electoral Register.   

                                                                                                                                                                                                    

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:  


Consent

Where you have given us consent to the processing. Typically, this will include where you have consented to the installation of Cookies for the collection and sharing of other Technical Data and/or Behavioural Data. However, this may also include where you sign up to receive marketing offers from us or our partners. You have the right to withdraw consent to marketing at any time by contacting us or opting-out. For more information, see the section on Your Legal Rights.

 

Legitimate Interests  

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Typically, this will include where we contact you in the course of our business activities, or in relation to marketing where you have bought a product or service from us.  

We may also rely on our legitimate interests for the use of Inferred Data for targeted advertising purposes, where this does not include Special Category data.

 

Legal Obligation

We may also stored your personal data where we need to comply with a legal obligation, including to pass information to government and supervisory authorities.           

 

Performance of a Contract

We may also stored your personal data where we need it to process a contract with you, for example, for the provision of goods and services you have requested.   

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA   

Profiling

Affectv may use data we receive in the form of Behavioural Data from the sources listed above in order to create a profile of specific users’ interests and behavioural information, and allow us to target them with useful advertising later on. We may also compile Inferred Data into “segmented profiles” or “model audiences” based around categories of interests, which can later be associated with different users.

This is performed using an automated technological process and is passed on to our third-party partners to ensure that this information is used to target appropriate advertisements to you. However, we do not use any Special Category Personal Data to generate such profiles.  

We have set out below, in a table format, a description of all the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.  

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

Purpose/activity

Type of data

Lawful basis for processing, including basis of legitimate interest

To register you as a new customer

  • Identity
  • Contact
  • Performance of a contract

Sending you marketing communications

  • Identity
  • Contact
  • Marketing and Communications
  • Performance of a contract
  •  Legal Obligation
  • Legitimate interests (for business development and sales purposes)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  • Identity
  • Contact
  • Technical
  • Legitimate interests (for the provision of administration and IT services, network security, to prevent fraud)

To monitor your behaviour on websites and collect information about your interests

  • Identity
  • Aggregated/Usage
  • Technical
  • Behavioural
  • Consent (as received through our website or the websites of our third party partners )

To create a profile of your interests

  • Identity
  • Aggregated/Usage
  • Technical
  • Behavioural
  • Consent (as received through our website or the websites of our third party partners )
  • Legitimate interests (to allow customers to be targeted/to generate sales for clients)

To deliver relevant website content and advertisements to you

  • Identity
  • Aggregated/Usage
  • Technical
  • Behavioural
  • Consent (as received through our website or the websites of our third party partners )

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

  • Aggregated/Usage
  • Technical
  • Legitimate interests (to define types of customers for our products and services and inform our marketing strategy)


THIRD-PARTY MARKETING 

We will make sure to collect opt-in consent before we share your personal data with any third party for marketing purposes. This will be achieved through the use of opt-in click or button functionalities through our website or requiring you to perform another affirmative action, such as replying to an email or text, to confirm your consent.

 

CHANGE OF PURPOSE 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

 

5.  DISCLOSURES OF YOUR PERSONAL DATA 

We may share your personal data with the parties set out below for the purposes set out in the table above. These may include:  

 

THIRD-PARTY PARTNERS

With any website that you visit that has Affectv cookies, the publisher of that website will potentially be a joint data controller of the data collected through such cookies. In particular, several of our clients may use Affectv’s cookies, in order to allow us to personalise the advertisements that you receive.  

Data content providers and aggregators, such as Addthis and Sharethis, as joint data controllers with Affectv, may install cookies on a variety of publishers’ websites, which collect your personal data. Addthis and Sharethis may then provide this data in a live data feed to Affectv.  Addthis and Sharethis act as joint data controllers of this data.                                           

Another of our third-party partners, Appnexus also may receive your personal data from Affectv, which consists of Behavioural Data (including potentially Inferred Data) and personal data such as Technical Data and Identity Data associated with it. Appnexus then uses such data in order to organise targeted advertising to you on various websites that you may visit. Appnexus acts as a data processor of this data, on behalf of Affectv.                                             

 

6.  INTERNATIONAL TRANSFERS 

Data may be shared with our trusted third-party partners, which may result in data being transferred out of the European Economic Area (EEA).  

Our third party partners include Appnexus, which may process data identifiable to you for ensuring that you only receive relevant advertisements on servers operated in the USA. Appnexus have certified under the EU-U.S. Privacy Shield certification and have agreed EU-approved Standard Contractual Clauses with us, which allows us to legally transfer your personal data to them.  

We may also use cloud providers such as Salesforce that use servers based in the United States of America, with the safeguards of the EU-U.S. Privacy Shield certification, which allows us to legally transfer your personal data to them. 

   

7.  DATA SECURITY 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Moreover, we ensure that any Identity Data that we process will be internally pseudonymised – i.e. cookie IDs converted to an Affectv ID, where possible.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.  

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

8.  DATA RETENTION 

HOW LONG WILL YOU USE MY PERSONAL DATA FOR? 

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of providing you any services, carrying out targeted advertising, and satisfying any legal, regulatory, tax, accounting or reporting requirements.

 

With regard to the use of personal data collected from Cookies, the retention period is set by the original website that placed such a Cookie, rather than Affectv.



Type of data

Retention period

Justification

Identity Data

Unique/device identifiers: 13 months

Personally Identifiable Data: 2 years maximum

To ensure we keep up to date with users’ interests

Personally Identifiable Data: To keep in contact with our customers/suppliers

Contact Data

Duration of the business relationship + 2 years

To keep in contact with our customers/suppliers

Technical Data

13 months maximum

To ensure the operation of our website and to keep up to date with users’ interests

Behavioural Data (including Inferred Data)

90 days maximum

To allow advertisements to be tailored to users and to keep up to date with users’ interests


We may store certain data, including Identity, Behavioural and Technical Data for longer than the periods specified, but only in an aggregated and anonymous format, to which the GDPR no longer applies. Such anonymous data will be used for research and statistics reporting on an aggregated basis for as long as this data is relevant.

 

9.  YOUR LEGAL RIGHTS 

Under certain circumstances, you have rights under the GDPR in relation to your personal data, upon request. In most cases, the website publisher or third-party partners that originally collected the information from you, such as through a Cookie, will be better placed to help you comply with such rights.  

OPTING OUT   

You have the right to opt-out from having advertisements tailored to our interests. To exercise this, please click here.  

You also have the right to opt-out to any Identity Data or Behavioural Data collected through cookies that Affectv or our Third Party Partners may carry out, as well as to your tracking through such cookies. Obn opting out, arrangements will also be made so that the user is no longer tracked by Affectv and that data is no longer received from Addthis and Sharethis in relation to the user.  

You can ask us or third parties to stop sending you marketing messages at any time by accessing our website and selecting your preference (https://affectv.com/opt-out). 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of [a product/service purchase, warranty registration, product/service experience or other transactions].  

You can also opt-out from our third-party partners that engage in behavioural advertising (such as AddThis and ShareThis) by selecting your country of residence in this page (http://www.youronlinechoices.eu/) and clicking on ‘Your Ad choices’. You will be presented with a list of the companies that collect data from you for behavioural advertising that adhere to the European Interactive Digital Advertising Alliance (EDAA) that you can opt-out from.

 

 COOKIES   

You can also opt-out of all Affectv cookies, including targeting that we and third-party partners we pass this information to (such as Appnexus).

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see below (section 10. Cookies).      

WHAT WE MAY NEED FROM YOU 

In order to allow you to exercise these rights, we must be in a position to be able to identify any personal data, including Identity, Behavioural and potentially Inferred Data that relates to you, for which we may require you to provide us with specific identifiers, such as CookieIDs. We are not obliged to comply with any data subject rights in relation to personal data that we cannot identify.

 

TIME LIMIT TO RESPOND 

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

NO FEE USUALLY REQUIRED 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

   

10.  COOKIES

At Affectv, we use cookies to collect, aggregate and process mainly analytical and interactive data so we can understand which computer browsers have viewed which content on a website; which websites are most visited from which geographical location and which other browsers and users you may have interacted with.

A cookie is a small text file that is downloaded onto your computer when you visit our website and allows us to recognise you as a user. Typically, these contain two pieces of information: a site name and unique user ID. All information these cookies collect is aggregated and anonymous. Cookies are essential to the effective operation of our website. Cookies make the interaction between you and the website faster and easier. Cookies may also be set by the website you are visiting (first party cookies) or they may be set by other websites who run content on the page you are viewing (third party cookies).

Affectv uses cookies on its website and/or the websites of our third-party partners:

We require you to accept or decline certain cookies by accepting or declining our Cookie Consent Notice when first accessing our website. By accepting and using our websites you consent to our use of cookies as updated from time to time and the cookies we use will be stored on your device (unless this functionality is rejected or disabled by your browser).

Opting out of Affectv cookies does not mean you will no longer receive online advertising. It does mean that Affectv will no longer deliver ads tailored to your Web preferences and usage patterns. The Affectv Opt-out Tool is cookie-based. In order for the tool to work on your computer, your browser must be set to accept cookies. Be advised that if you change computers or upgrade or change browsers, clear or delete this opt out cookie either separately or by clearing all cookies of your browser or if you use multiple computers or browsers, you will need to repeat this opt-out process for each computer and each browser.

Non-Essential Cookies: A list of the non-essential cookies we use on the website are detailed below:

Affectv Cookies:

Google Analytics: analytics.js (__ga, _gat), used by Google to generate web analytics and for tracking how you use the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.. The information generated by the cookie will be forwarded to Google servers in the U.S. for statistical analysis purposes only.

Google Adwords: Using Google Adwords code we are able to see which pages helped to lead to contact form submissions. This allows us to make better use of our paid search budget.

Storage Time

The cookies are stored for a period of 13 months maximum unless you clear their cache and the cookies themselves.

Opting Out of Cookies

You can also choose to opt-out of Affectv’s cookies through the IAB Consent Framework operated on the websites of our third-party partners as well as through initiatives such as the Network Advertising Initiative.

You can also opt-out from the cookies of our third-party partners Addthis here, Sharethis here and Affectv here.

You can manage the cookies stored on your device as well as stop cookies from being installed on your browser. For more information on how to manage cookies usage on your device, please let us refer you to information found on these topics on allaboutcookies.org, more specifically by clicking on the links below:

Please note that if you prefer to block some or all of the cookies Affectv uses, you might lose some of our website’s functionality.