Privacy Policy

Effective Date: May 05, 2018

This Privacy Policy explains how Steld SSP and its subsidiaries collect, use, and disclose information, and your choices for managing your information preferences.
The data protection declaration is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners.

Definitions

Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. If natural person could not be identified by particular data without additional information or reference this data in not Personal data.

Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by law, the controller or the specific criteria for its nomination may be provided for by law.

Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not.

Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

What This Policy Covers

This Privacy Policy describes Steld SSP ’s data practices associated with our corporate website (www.steld.com) and Steld SSP services (“Services”) such as CRM at stats.steld.com, and the choices that Steld SSP provides in connection with our collection and use of your information. This Privacy Policy is intended for both website publisher customers (“Publishers”) and individual users of websites. For Publishers, this Policy explains how Steld SSP may collect, use and disclose information associated with your company and with your company’s websites and Customers (DSPs and Exchanges) that use Steld SSP Services. For individual website users, this Privacy Policy explains how Steld SSP may collect, use, and disclose information when you visit our website or when you use any website that uses Steld SSP Services.

Steld SSP Services include our Ad Exchange, a Web-based Supply side Platform that enables publishers, advertisers, exchanges, DSPs and ad networks to efficiently market, buy and sell digital and mobile-web advertising and ad inventory. Steld SSP also offers services, such as our Ad Server, through which we act as a service provider to enable our Publishers, advertisers, exchanges, DSPs, ad networks, and other clients to manage their advertising inventory and to collect and use data to provide advertising on their digital and mobile properties and across the Internet. In this case, Publishers may use our services to process data, which they collect or source. Publishers and other clients may also have their own policies that govern how they collect, use, and share data. These policies may differ from Steld SSP ’s policies described in this Privacy Policy. Please consult the privacy policies of the websites you visit and apps you use to become familiar with their privacy practices and to learn about any choices that these companies may offer with respect to their information practices.

The Steld SSP website may contain links to websites or content operated and maintained by third parties, over which we have no control. We encourage you to review the privacy policy of a third-party website before disclosing any information to the website.

Information Collection and Use

Steld SSP collects contact information through our website when you choose to provide it, such as your name, username, or email address. You may be asked to provide us with contact information when you register with the Steld SSP website and when you purchase the Services. The decision to provide this information is optional; however, if you elect not to register or provide such information, you may not be able to access certain features, or services available on or through the Steld SSP website. In order to make payments owed to Publishers, Steld SSP may also request additional information from Publishers such as other contact information and billing account information.

Steld SSP uses this contact and billing information to operate and improve our website and Services, such as to provide notices about your Service, to fulfill your service requests, or to request your feedback or conduct research. Steld SSP also uses contact information to send you information about new products or Services; where Steld SSP needs your permission to do this, we only send such information in accordance with any permissions granted.

We may also collect additional information through our website and Services, such as the following:

Browser information (e.g. URL, browser type, ‘click through’ data, device type)
Ad reporting or delivery data (e.g. size/type of ad, ad impressions, data about interactions with the ad such click etc.)
Device-type information (e.g. mobile/desktop/tablet)
Unique identification numbers (e.g. IP address)
Location data (as derived from IP address)

With respect to data collected via the Steld SSP platform, behalf of our Publishers and Clients, we may combine information that does not directly identify an individual with data collected from other sources and disclose the combined information to participating publishers, advertisers and ad networks so that they can determine whether to bid on ad inventory and in order to improve the relevance of the advertising presented to users. We also use the information we collect to host, operate, maintain, secure, and further develop and improve our Services, such as to keep track of advertising delivery and to measure the effectiveness of advertising delivered through our Services, and investigate compliance with Steld SSP ’s policies and terms and conditions. Collected statistical information that does not directly or indirectly identify an individual natural person. Statistical data is Pseudonymised and Sampled so represent not a particular natural person but a mass of inventory grouped by one or several statistics-based terms.

Steld SSP does not engage in activities that require parental notice or consent under the Children’s Online Privacy Protection Act (COPPA). If you believe that Steld SSP has inadvertently collected information from a child under 13 that is subject to parental notice and consent under COPPA, please contact Steld SSP using the contact information below to request deletion of the information.

Cookies and Other Similar Technologies

We use cookies (a small file containing a string of characters that uniquely identifies your Web browser), Web beacons (an electronic file placed within a Web site that monitors usage), pixels, and similar technologies to operate and improve our website and Services, including for interest-based advertising as described below. Some of our Service Providers (defined below) may also use such technologies in connection with the services they perform on our behalf.

We use the following categories of cookies for our website and Services:

Strictly Necessary Cookies

These cookies are essential in order to enable you to navigate our website and use its features. Without these cookies, Services you have asked for such as remembering your login details cannot be provided.

Performance Cookies

These cookies collect anonymous information on how people use our website. For example, we use these cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve, such as navigation and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.

Functionality Cookies

These cookies remember choices you make such as the country from which you visit our website, language and search parameters such as size. These cookies can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and relevant. The information these cookies collect are anonymized and they cannot track your browsing activity on other websites.

Targeting Cookies or Advertising Cookies

These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The cookies remember the websites you visit and that information is shared with other parties such as advertisers.

Publishers, advertisers, DSPs, exchanges, and third-party ad networks that participate in the Steld SSP Ad Exchange may also utilize cookies or similar technologies to deliver ads and monitor the performance of such ads. The collection of information through cookies or similar technologies by such third parties will be governed by their own privacy policies and principles, which Steld SSP does not control.

Your browser may offer tools to enable or disable cookies by modifying the settings in your browser. How-ever, please note that certain features of the Steld SSP website may not work if you delete or disable cookies. Moreover, if you delete cookies after previously opting out of Steld SSP ’s Ad Exchange practices, you may need to renew your opt-out choice. To read about your choices with regard to Steld SSP ’s use of cookies in our services, please see below.

How to refuse or be warned of the installation of all “cookies” files? You may decline the saving of “cookies” by configuring your browser

• Chrome users: https://support.google.com/chrome/answer/95647
• FireFox users: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website- preferences
• Safari users: https://support.apple.com/kb/PH19214?locale=fr_FR&viewlocale=en_US
• Internet Explorer users: http://windows.microsoft.com/en-us/internet-explorer/delete-manage- cookies#ie=ie-11

Information Sharing

We will disclose contact and billing information to third parties only as described in this Privacy Policy:

with your express permission;
with our affiliates, which include entities controlling, controlled by, or under common control with Steld SSP ;
where we contract with third parties to provide certain services, such as advertising, analytics, data management services, web hosting, and web development (“Service Providers”). We ask Service Providers to confirm that their privacy and security practices are consistent with ours, we provide our Service Providers with only the information necessary for them to perform the services we re-quest, and Service Providers are prohibited from using such information for purposes other than as specified by Steld SSP ;
in the event that Steld SSP is merged, sold, or in the event of a transfer of some or all of our assets (including in bankruptcy), or in the event of another corporate change, we may disclose or transfer information in connection with such transaction; and
where we believe it is necessary to protect Steld SSP or our users; to enforce our terms or the legal rights of Steld SSP or others; or to comply with a request from governmental authorities, legal process, or other legal obligations.
We may also share and disclose other information that we collect, including aggregate information, as we consider necessary to develop and provide our Services, including in the ways described above.

Steld SSP may also be required to disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Legal Basis for Processing Personal Information of European Economic Area (“EEA”)

Individuals On certain occasions, Steld SSP relies on the consent of the individual to process personal information (for example, when the user inputs personal information into the Steld SSP website). On other occasions, Steld SSP may process personal information when Steld SSP needs to do this to fulfill a contract or where Steld SSP is required to do so by law.

Steld SSP may also process data when it is in Steld SSP ’s or its customer’s legitimate interests to do this and when these interests are not overridden by the individual’s data protection rights (which may vary based on an individual’s jurisdiction). Those legitimate interests include improving Steld SSP ’s Services.

Your rights as the Data Subject

Steld SSP s’ User Account Console is the preferred way of accessing your personal data. The console facilitates the possibility for you to exercise a number of your user rights in terms of personal data:

The right to object to processing – You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).

The right to be informed – You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.

The right of access – You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law.

The right to erasure – This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

The right to rectification – You are entitled to have your information corrected if it’s inaccurate or incomplete.

The right to restrict further processing – You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

The right to data portability – You have rights to obtain and reuse your personal information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.

Reviewing and Updating Information

Steld SSP takes reasonable steps to ensure that information is accurate, complete, current, and reliable for its intended use. For contact or billing information submitted through our website, you may review, correct, update, or change your information, request that we deactivate your account, or remove your information from our direct marketing efforts.

Retention of personal information of EEA individuals will be handled in accordance with Steld SSP ’s data retention policy. Where Steld SSP processes personal data of EEA individuals as a data controller, such individuals: (i) may have the right to request access to and rectification or erasure of personal information; (ii) may restrict the processing of personal information, object to processing, and/or exercise the right of data portability; and (iii) may have certain rights to withdraw consent without affecting the lawfulness of processing and the right to lodge a complaint with a supervisory authority.

International Information Transfers

Please be aware that the information we collect, including contact and billing information, may be transferred to and maintained on servers or databases located outside your location, or other jurisdiction, where the privacy laws may not be as protective as those in your location.

Security

Steld SSP employs appropriate measures to ensure the security of all Information and We routinely evaluate our practices to identify security threats or opportunities for the improvement of our services. No transmission of information is guaranteed to be completely secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. You acknowledge and agree to assume this risk when communicating with us.

Changes

As the standards governing Internet privacy continue to evolve, Steld SSP may find it appropriate or necessary to update this Privacy Policy from time to time. As a result, we reserve the right to change this privacy policy at any time and shall post such changes on the Website. Our Website will state the date the Privacy Policy was last updated. We encourage you to review the Privacy Policy whenever you use this Website to make sure you understand how your information will be used.

Your Representations

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND APPLICABLE SITE TERMS AND CONDITIONS.

You also agree that you have provided notice to, and obtained consent from, any third party individuals whose Information you supply to us with regard to:

• the purposes for which such third party’s Information has been collected;
• the intended recipients or categories of recipients of the third party’s Information;
• which of the third party’s data are obligatory and which data, if any, are voluntary;
• how the third party can access and, if necessary, rectify the data held about them.

It is the express wish of the parties that the Privacy Policy and all related documents have been drawn up in the English language.

Cookie Declaration