Audience Trading Platform Limited (“atp”)

This privacy policy sets out how “audience trading platform ltd.” (‘atp’, ‘company’, ‘we’, ‘us’ ‘our’) uses and protects any information provided when individuals (“users”, “you“, “your“) interacts with our platform. Our analytics platform allows advertisers to better understand what messages people like you want to see and when you want to see them. In short, our tracking helps to make your ad experience better.

You can opt out of our tracking anytime you like by clicking the button below. It will be sad, and we will miss you. Our Internet will be a colder, darker place.

Now, if you will, please allow us to geek out by providing the following in depth information, which will essentially say the same thing as the previous statements.

With our ongoing commitment to transparency and progress, it remains our honor to fully disclose this information. Our policy also sets out our practices regarding our use of such data, the steps we take to protect it, the parties with whom we share it, and the choices and rights that you have regarding how we collect and process personal data about you. If you are interested in further conversation, please contact us at privacy@atp.io

Last updated February 1st, 2018

Data

While atp collects certain categories of personal data in the course of measuring ad effectiveness via the platform, we do not intentionally collect data that reveals your real-world identity, such as your name, address, phone number, or any government identifiers. Instead, atp collects certain data about your computer or device through the use of cookies and other similar technologies. We may assign a unique identifier called a atp ID to your browser, mobile device or any supported internet enabled device when we serve an ad to it or you use it to access a client’s digital properties. This includes their websites, emails and apps where their ads appear. We do this to measure with reasonable confidence that a computer or device is the same one with which we had previously interacted. Well, how does that work? This atp ID may be a cookie ID (small text files that can be stored on your browser), a mobile advertising ID a unique ID assigned by the mobile operating system, e.g. Apple ID for Advertising or Android Advertising ID) or a statistical ID (an ID generated by atp which is an amalgamation of information from your computer such as operating system, user agent string and fonts which in concert creates a probabilistic distinct user profile). In some cases, a client may provide us hashed personal data which we may use to recognise multiple atp IDs are in fact interactions by the same individual. This helps the atp product and people analyze behavior data and improve consumer experiences. Who doesn’t like personalized attention?

Your atp ID is associated with other categories of personal data that we collect about you. These categories include the following:

Pixel Data: atp clients may use the platform to collect data regarding your interactions with them when you visit their digital properties such as their website and apps. We also may collect the same data when you visit our website. This includes information such as the time you visited the site, the page URL, your IP address, your browser type (e.g., Chrome or Internet Explorer), the operating system (e.g., Mac OS or Windows), the type of device you use (e.g. laptop or desktop), and data regarding your activities. Our clients also may use the platform to collect hashed personal data that (if unhashed) would reveal your real-world identity, such as hashed email addresses.

Third-Party Data: atp clients may receive data from third-party sources for the purposes of analytics and segmentation. A segment is a grouping of users who share one or more common attributes and provides further detail to what makes individuals special to our clients.

Cookie Syncing: atp receives personal data from third-party sources that allows us to associate their identifiers with our atp ID in a process called cookie synching. This allows us to translate a third party's recollection of interactions with an individual into a merged atp understanding.

Sensitive Categories of Personal Data: We do not knowingly collect any special categories of personal data about individuals in the EEA, including: personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; personal data concerning your health, sex life, or sexual orientation; and genetic or biometric data. atp also does not knowingly collect any data about other sensitive categories such as personal data about children, financial account numbers, insurance plan numbers, and criminal convictions or offenses.

How our platform uses data

Purpose/Activity
Personal Data Type
  • Setting, reading and modifying a atp cookie, reading a mobile advertising identifier, or generating a statistical ID;
  • Measuring the effectiveness of ads and attributing your activities to our clients’ campaigns;
  • Generating and providing to clients reports and user-level data related to their advertising activity;
  • Associating multiple browsers and devices with each other; and
  • Honouring opt-out requests for users who have opted out.
  • atp ID
  • Pixel Data
  • Synchronising atp cookie ID with third-party partners.
  • atp ID
  • Pixel Data
  • Cookie Syncing
  • Measuring the affinity of segments with clients' advertising and digital properties
  • atp ID
  • Pixel Data
  • Third-Party Data
  • Cookie Syncing

Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we process it. However, we will normally collect personal data from you only where the processing is in our (or a third-party's, such as our clients’) legitimate interests and not overridden by your rights, such as your right to opt out. We primarily use this to track the performance of our clients' advertising (how many ads delivered, how many users delivered to, how many ads per user, which users clicks, which users went on to purchase...etc.). We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are.

As described above, we process your personal data for different purposes, and the length of time that we retain your personal data varies depending on the processing purpose, the category of personal data and certain external factors. We will retain any personal data, where applicable, for as long as it is necessary for our legitimate business purposes. Our retention policy is to retain personal data for no longer than thirteen months, and we typically retain much of this data for shorter periods of time.

International transfers

The information that we collect from you and about you may be transferred to and stored in a country other than your country of residence, such as the USA, which may not offer the same level of protection of personal data as your country of residence. However, we will take contractual and/or other measures to ensure your personal data is protected.

As some of our partners are based outside the EEA, whenever we transfer your personal data outside of the EEA we ensure it receives a similar degree of protection by ensuring either: (1) Reliance on our or our applicable partners’ or vendors’ Privacy Shield certification if the transfer is to the United States or (2) Entering into contracts approved by the European Commission with our group companies and applicable partners or vendors.

Security

atp takes steps to protect the security of information that we collect. To that end, we have designed and deployed hardware, software, and networking solutions in an effort to reasonably secure and protect access to our systems and data. No transmission of data over the Internet, however, is guaranteed to be completely secure. It may be possible for third parties not under the control of atp to intercept or access transmissions or communications unlawfully. While we strive to protect your personal data, we cannot ensure or warrant the security of any data you transmit to us or that we collect about you.

Contact

If you have read this far and have any further questions or concerns about our privacy policies, feel free drop us a line at privacy@atp.io. If you wish to submit a formal Data Subject Access Request, you can do so by submitting a email request via the below link. This will send us an email containing your device identifier which can then be used to compile a report that provides all personal data stored by our system (as defined by Article 4 of the General Data Protection Regulation).



Updates to this policy

Our privacy policy may change from time to time. If we make any material changes to our policies, we will place a prominent notice on our website or application.

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