[Last Updated: September 5, 2019]
Display.io Ltd. (together with its subsidiaries, affiliates, officers and directors, as applicable – collectively “Display.io”, “Company”, “we” or “us”) is a global mobile ad-tech company that provides its mobile application developers, advertisers and publishers (“Business Partners”) with an advertising platform for the purpose of delivering advertising to individuals (“user(s)”) who download, use or otherwise interact with an app developers’ app, site or our services (“Digital Assets”), as defined below (collectively, “Advertising Service(s)“).
- Information we collect from visitors of our website available at: https://www.display.io (“Site”) and our Business Partners who register to our Services through our Site.
- Information we collect from users who interact with our Business Partners’ Digital Assets which are using our advertising platform.
- Our lawful basis for data processing (as required under the EU General Data Protection Regulation (“GDPR”), and applicable for European Economic Area ("EEA") residents).
- Types of data we collect
- How we collect data
- What are cookies and how we use them
- Sharing data with third parties
- Our data retention policy (meaning when will we delete the data we collect)
- How we protect data
- User choices and controls (including opt out information)
- User rights
- How do we transfer data
- Children Privacy Online
- “Do Not Track” disclosure
- How to contact us
As required under GDPR, the lawful basis for our data collection and processing is as follows:
- Where a Business Partner uses our Services, we process the Business Partner’s Personal Data in order to perform our contract with the Business Partner;
- Some Online Identifiers, such as third party cookies we use, are based on consent;
- For direct marketing of Business Partners, we will process such data under our legitimate interest.
Display.io acts as a Processor of certain Personal Data, as defined under the GDPR, such as the data processed from our users using our Business Partners’ Digital Assets. Display.io is also a Controller of certain Personal Data, such as our Business Partner’s registration data, or if individuals contact us via our Site.
Types of Data We Collect
If you are a visitor of our Site, Business Partner or a user of our Business Partner’s Digital Assets which use our Advertising Services, Display.io collect several types of data, which can be mainly classified as follows:
- “Non-Personal Data”: non-identifiable information which is not identifiable to a specific individual and as such we are not aware of your identity due to such information.
- “Personal Data”: individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual.
In the event we combine Personal Information with Non-Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
For your convenience, we have arranged the types of data we collect according to your interaction with us, meaning, the first table below will detail the data we collect from visitors of our Site including our Business Partners who register to our Advertising Services, and the second table will detail the data we collect from users who interact with our Advertising Services (e.g., a user who have downloaded our Business Partner’s app which serves ads through our Advertising Services). The tables below will also explain how we use each type of data.
Data we collect from Business Partners and visitors to our Site:
|Type of Data||How Do We Use It?|
|Business Partners’ Registration – if you are or wish to be our Business Partner, when you creates a developer account, you will be required to provide us with certain information such as: full name, email address and company name. Further, during the registration process you will be required to create a username and password.||We will use this data for the purpose of performing our contract with you, meaning provide the Advertising Services, and designate your account. Your contact details will be used in order to send you needed information related to our Advertising Services and our business engagement (e.g., send you a welcome message, notify you regarding any updates to our Advertising Services, send applicable invoices, etc.) and additional occasional communications and updates related to the Advertising Services, as well as provide you with tips related to our Advertising Service, promotional and marketing emails. We may also use the information in order to verify your identity.|
|Contact Information - in the event you contact us for support, feedback, meeting set up or other inquiries, by sending us an email or by other means of communications, including any online form available on our Site, you will be requested to provide us your contact details such as name and email address.||We will use this data for the purpose of performing our contract with you, meaning provide the Advertising Services, and designate your account. Your contact details will be used in order to send you needed information related to our Advertising Services and our business engagement (e.g., send you a welcome message, notify you regarding any updates to our Advertising Services, send applicable invoices, etc.) and additional occasional communications and updates related to the Advertising Services, as well as provide you with tips related to our Advertising Service, promotional and marketing emails. We may also use the information in order to verify your identity.|
|Newsletter Subscription - if you voluntarily subscribe to our Newsletter through the Site (or otherwise agree to receive our updates and content), you will be requested to provide us with email address and name. You can unsubscribe at any time using the unsubscribe option within the body of the applicable email or rather by contacting us (as detailed below).||We will use this data in order to send you the information related to our Advertising Services and to keep you up to date regarding new services, as well as provide you with tips related to our Advertising Service, promotional and marketing emails (offers, events and discounts).|
|IP and Technical Non-Personal Data - when you access our Site or interact with our Services, we will collect certain IDs (e.g. IP) as well as technical Non-Personal Data (e.g. viewing and usage information that relates to your interaction with the Site, the amount of time you spend viewing certain portions of the Site, etc.).||We use this data for our legitimate interests of (i) operating, providing, maintaining, protecting, managing, customizing and improving our Site and the way in which we offer it; (ii) enhancing your experience; (iii) our legitimate interests of auditing and tracking usage statistics and traffic flow; and (iv) protect the security of the Site, as well as our and third parties’ rights (subject to applicable law requirements).
If we use third party cookies on our Site we will obtain your consent.
Data we collect from users who interact with our Business Partners’ Digital Assets (meaning user who download our Business Partner’ mobile app which integrates our SDK to serve advertisements):
|Type of Data||How Do We Use It?|
This data will be used to: (i) enable the delivery of ads, including personalized ads; (ii) reporting and calculating payments with regards to our Business Partners’ use of our Advertising Services; (iii) detect fraud and other security issues related to our Advertising Services; (iv) our internal business needs such as Internal statistics and in order to further improve our Advertising Services (e.g., to control the number ads served to you while you use our Business Partner’s mobile app).
How We Collect Data
We may collect the data detailed above in two different ways:
- When you voluntarily provide us with such data – meaning, for example, if you are Business Partner and you register to our Advertising Services and create an account through our Site, or if you are a visitor of our Site and you contact us.
- Data collected automatically – meaning, if you are either visiting our Site or use our Business Partner’s Digital Assets (e.g., a mobile application which integrates our Advertising Services), we may use our SDK, Cookies and other similar tracking technologies (as detailed below) to gather information automatically, such as your Advertising ID, IP address, etc. We may also acquire information from other trusted sources to update or supplement the data that that we collect automatically.
Please note that, whenever required under applicable law, we will obtain your consent prior to collection of Personal Data, or obligate our Business Partners to obtain such consent, and you are always able to opt-out – see information in the “User Choices and Controls” section below.
What are cookies and how we use them
When you visit Display.io Site, we may use tracking technologies known as “cookies” and or similar technologies. Cookies are small text files that are placed on your hard drive by a web server when you access our Site or Services.
The cookies can be used for various purposes, such as to facilitate the use of the Site, to collect statistical information or customize the Site and our services offered therein. If you wish to block the cookies, you will have to modify settings in your browser and follow the necessary instructions to disable receipt of cookies – please review the “User Choices and Controls” section below for helpful information. However, bear in mind that disabling cookies may complicate or even prevent certain features of the Site and our services and your online experience may be limited. You can find more information about cookies at www.allaboutcookies.org.
|Google Analytics||Analytic purposes||https://www.google.com/policies/privacy/partners
|Umbraco||Enable the use of the Site and service||https://umbraco.com/about-us/privacy|
|Intercom||Enhance the use of the Site||https://www.intercom.com/terms-and-policies#cookie-policy
Sharing Data with Third Parties
We do not share any Personal Data collected from you with third parties or any of our partners except in the following events, and solely to the extent needed:
- If the Company is required, or reasonably believes that it is required by law or law enforcement agencies to share or disclose your information;
- In any case of dispute, or legal proceeding of any kind between you and the Company or between you and other users with respect to, or in relation with the Site or Advertising Services;
- We may disclose Personal Data to our trusted agents and service providers so that they can perform requested services on our behalf, for example for security, fraud detection, server and data storage providers, etc. (among others, as detailed in the “Cookies” Section above);
- We may share your information in order to prevent harm to the rights (including any legal rights), property (including intellectual property) or other or safety of us, our users or any applicable third party;
- We may share Advertising IDs or IP addresses collected by us (as detailed above), for the purpose of operating and improving our business, providing the Site or Advertising Services, as well as to detect fraud, security or technical issues in connection with the Site or Advertising Services.
Data Retention Policy
The table below details our data retention practices – meaning , when will we delete data we collect and process:
|Data Sets||Retention Period|
|Online Identifiers||Deleted immediately following to the completion of use.|
|Contact Details||Deleted Immediately following the completion of your request.|
|Business Partner Data||According to applicable laws.|
|Technical Information||For as long as needed to provide and improve our Advertising Services.|
Notwithstanding the above, in some circumstances we may retain the information we collect for longer periods, for example, when we are required to do so in accordance with legal, tax and accounting requirements. In addition, we may also retain your Personal Data for longer periods if we reasonably believe, at our discretion, that we need to obtain an accurate record of your correspondence or any dealing with us, for example, in the event of any complaints, all, in compliance with applicable laws.
How we Protect Data
Further, in the event of a security incident, in which we discover your Personal Data may be at risk, we will take reasonable efforts to notify you and the applicable authority (if required, subject to applicable laws).
User Choices and Controls
You may opt out of the data collection and sharing process related to our Site or Advertising Service, as shall be detailed below.
Options to opt out:
If you use an Android device please follow this link for instructions: https://support.google.com/ads/answer/2662922
If you use an iOS device please follow this link for instructions: https://support.apple.com/en-il/HT205223.
You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. Please refer to the support page of the browser you are using. In this regard, following are some links which you may find useful:
You may opt out of certain advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s (“NAI”) website - NAI consumer opt-out and the Digital Advertising Alliance’s (“DAA”) website - DAA opt-out page. If you wish to opt out of interest-based advertising, you may click here. Please note you will continue to receive generic ads.
Business Partners opt-out
You may also contact us at: email@example.com and we will be happy to assist you. Note that once you opt out, part of the Site or Services provided by us might no longer be available and some features may not work if you revoke the data transfer.
Data protection and privacy laws provide you with the ability to exercise some rights regarding your Personal Data that we hold (which might be different in each jurisdiction) such as; right to access your Personal Data; right of rectification; the right to erasure of your Personal Data; right to restrict processing of your Personal Data; the right to object to processing of your Personal Data; data portability; the right to file a complaint to a supervisory authority (in the event you are EEA resident); and, the right to withdraw consent.
If you wish to exercise any or all of the above rights, please fill out the Data Subject Request (“DSR”) form available here, and send it to our Data Protection Officer at: firstname.lastname@example.org and let us know that you wish to exercise your right of access and specify what Personal Data you would like to receive.
Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) in accordance with applicable law.
Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.
Transfer of Data
Do Not Track Disclosure
The Service does not respond to Do Not Track signals. For more information about Do Not Track signals, please see http://www.allaboutdnt.com.
Children Privacy Online
When applicable, Company implements measures to comply with applicable Children Online Privacy regulation, including the US Children’s Online Privacy Protection Act (“COPPA”). If we become knowledgeable of end user that is considered a Child under applicable laws, we make sure to not process their personal data and take steps to delete such data if existed.
If you become aware or have any reason to believe that a Child has shared any Personal Information with us, please contact us at: email@example.com.
Comments and Questions
display.io Inc., Suite 972, 511 Avenue Of The Americas, New York, NY 10011, USA
You can also contact us via email at: firstname.lastname@example.org.
Data Protection Officer
Please be sure to include your information in any correspondence to us so that we can respond to your inquiry in a timely manner.