End-User
Privacy Policy
Effective date: May 25, 2018
Last updated: May 22, 2018
This document provides information about our
advertising technology platform, Archer Media Network. Archer Media
Network (Central Lofts, 5 Waterloo square, Newcastle Upon Tyne, NE1-4DR) enables
advertisements to appear within desktop and mobile websites. The intention of
this document is to provide you transparent information how the Archer Media
Network platform runs and how the data is processed, collected, and stored in
the platform. We realize that some technical terms might sound complicated to
you, so this document presents those terms in simple words as well as explains
what the goal of data processing is.
Archer Media is firmly committed to protecting the
privacy of Internet users and fostering users’ confidence in online advertising
and marketing. Accordingly, we are committed to observing applicable industry
guidelines including those established by the Interactive Advertising Bureau
and the General Data Protection Regulation (“GDPR”) by the European Union. We
continue to evaluate enhanced ways to protect Internet users’ privacy while seeking
to deliver relevant advertising and custom online experiences to those users on
behalf of our customers.
This document outlines Archer Media’s End User
Policy and provides you a clear notice about the user information we may
collect and process online in connection with our services.
Our customers use our technology (Archer Media
Network available at http://network.archermedia.co.uk) to
execute advertising campaigns. Such operations result in you having
indirect (when advertisements are displayed within sites and apps) and direct
(when you click any of these advertisements) interactions with our servers.
I. Glossary
- Applicable
laws: All
the laws and regulations relevant to the collection, processing, and
storage of data, especially all the data protection laws and the General
Data Protection Regulation (EU) 2016/679(GDPR).
- Ad
exchange:
This is a platform where people who can offer unsold ad placements meet
people who want to buy those placements for their online advertisements.
You can think about it as a digital marketplace with a sort of an auction
called real-time bidding. However, a buyer can be anybody including other
ad exchanges or platforms that sale advertisements to other companies / buyers.
- Ad
server: By
and large, a server where advertisements are stored and managed, and
delivered to you as a website end user. It might also provide a
reporting module to check how the advertisements perform.
- Customer: The party who submits an
application on one of the registration pages: http://network.archermedia.co.uk
and uses the Archer Media Network
platform.
- Domain
name: It
is a character string that helps you to easily go to a website without the
necessity of remembering IP addresses. A domain name must be unique for
all domain names available on the Internet. It allows you to navigate to a
website and discover an online advertisement.
- End
user (visitor):
This is a user of an Internet connected device, such as a visitor to a
website, a user of a mobile app, or a user of an IoT device, or a visitor
on an advertisement, landing page, or campaign.
- Geographic
location:
This is a piece of information where you are located based on an IP
address. Precisely, this is a location of your device that is connected to
the Internet and based on that we are able to define a country, region,
city, and Internet Service Provider (ISP) your device is connected to.
- HTTP
request header:
The request header of HyperText Transfer
Protocol. The HTTP protocol is used all around the world. Almost
all content that shows up in the browser you see is transmitted to your
computer (or other device connected to the Internet) over HTTP. For
example, when you opened this policy in the browser, many HTTP
requests have been sent. Each request contains an HTTP header in which
there is information about the browser you use, the requested page, the
server and much more.
- IP
address: An
Internet Protocol (IP) address is a set of numbers that each device
has assigned to connect with other device over the Internet network. The
IP address allows addressing and delivering the information to the right
receiver. Every time a piece of information is sent, a device needs to
communicate with other devices in a computer network to be able to deliver
the message. Sending information in that context means every kind of
activity such as surfing, exchanging emails, or downloading an
application. The IP address is used to identify the device to which
the message is supposed to be sent and find the best way to deliver it.
- Personal
information / personal data: Any information relating to an
identified or identifiable person as defined in article 4.1 of GDPR.
- Processing: Any operation or set
of operations which is performed upon personal data, whether or not
by automatic means, such as collection, recording, organization, storage,
adaptation or alteration, retrieval, consultation, use, disclosure by
transmission, dissemination or otherwise making available, alignment or
combination, blocking, erasure or destruction (process, processes
and processed shall have the same meaning).
- Real-time
bidding: Archer
Media Network’s customers are able to bid in real time to get the
opportunity of showing an online advertisement offered by a certain ad
exchange. The winner of the auction is treated as the best candidate to
display the advertisement on a website.
- Referrer
domain: In
simple words, this is the address of a website that led you, as a
visitor, to another page.
- Targeting: A strategy of online
advertising when information is gathered to address visitor’s preferences
based on the collected data. When you as a visitor go to websites in one
particular language, then the advertisement is displayed in front of you
in the same language you were browsing and relates to the region you are
located.
- User
agent:
Information about a device, operating system, web browser is being used to
access a website.
- You
(visitor): A
person who can visit digital advertising campaigns on the Internet.
II. What is Archer Media Network?
Archer Media Network is a real-time bidding pop and
domain traffic network. This means that Archer Media Network connects one group
of customers (publishers) looking to monetize their websites with other group
(advertisers) that want to sell items or services to the visitors of these
websites. Archer Media Network enables the advertisers to get traffic from
publishers’ parked domain redirects to advertisers’ landing pages or via new
browser windows popping-up on publishers’ websites and displaying an
advertisement.
There is a number of advertisers willing to score
each display of an advertisement. To determine whose ad gets displayed, an
auction is held. It takes place as a visitor loads the page, so it usually
takes about milliseconds. In that time all interested advertisers automatically
put their predetermined bids, the highest of which wins the bidding, resulting
in displaying an ad.
In the next sections you can find out what
information is stored in Archer Media Network and how it relates to your
activities as a visitor.
III. Archer Media’s Role in
Processing Personal Information
While our customers use Archer Media Network, we
act as a customer’s data processor meaning that we process end user’s personal
data on behalf of our customer under customer’s instructions.
IV. What Kind of Data Do We
Collect and For What Purposes?
In order to perform our services
we are intent to collect and process certain information about you and your
device. Some of this information, for example your IP addresses, may identify a
particular computer or device and be considered as “personal data” in some
jurisdictions, including the European Union. This kind of data enables us to
provide aggregated reporting and analysis of the performance of our customer’s
advertising campaigns.
The Archer Media Network platform does not collect
any data which by itself identifies an individual such as name, address, phone
number, email address.
We also do not collect any “sensitive” or “special
categories of personal data” as defined under European data protection laws as
well as personal data of children.
IP Address
An IP address is used to identify the device’s
location as well as, to some extent, user’s location. Based on the IP
address visitor’s country, region, or city can be characterized and stored in
the Archer Media Network platform. Moreover, some more technical specifications
are processed such as Internet Service Provider (ISP). This data is stored to
adjust the online advertisements that are displayed on websites and
identify automatic computer programs that might affect our customers’
reporting.
In addition, the IP address is used to limit the
number of times a visitor is exposed to a single advertisement.
User Agent
A user agent helps us to identify what kind of a
device a visitor uses (TV, desktop, table, mobile phone) and which model it is.
Even more, this piece of information is stored to establish device’s
parameters such as browser and browser version, operating system, and operating
system version. It also allows us to detect the automatic computer programs and
fraud attempts.
Additionally, the user agent is used to limit the
number of times a visitor is exposed to a single advertisement.
HTTP Request Header
The HTTP request header is used for troubleshooting
purposes to fix customer’s issues with campaign’s settings.
Device ID
A device ID is a unique identifier used to
accurately measure actions taken by a specific device. It plays a role in
personalization, distribution, and performance of the traffic sent to a
visitor.
Domain
Information about a domain is stored to be able to
determine whether a domain is fake or not. Moreover, it helps to find
a specific category of a website that is related to a customer’s
advertisement. This allows displaying advertisements where their topics are
very close to the topic of the website visitors see in front of them. The
domain information is also used for reporting and troubleshooting purposes.
Referrer Domain
The referrer domain data is stored for
troubleshooting purposes as well as used to define whether a website is
addressed to an adult audience. This helps to display the advertisement always
to a proper audience.
Keywords
Defining keywords and targeting by them is a
popular form of online advertising when customers want to address their
advertisements to people who are looking for such keywords on the Internet. Archer
Media Network helps them to define those keywords and, once defined, store them
in the platform. Keywords are also used when it comes to troubleshooting to
sort out issues with campaign’s settings.
Note that our publisher partners may share with us
additional demographic information, such as age or gender, in order to enable
more accurate targeting. We do not use this information to maintain any kind of
persistent user profile database.
V. How Do We Collect Data?
The Archer Media Network platform uses non-cookie
technologies to collect data associated with particular web browsers or devices
that you as a visitor use. The Archer Media Network platform does not use
cookies to collect data about visitors of advertisements.
Archer Media Network collects end user’s data being
sent either by a publisher or through third-party partners. This data consists
of an IP Address, User Agent, Referrer, Accept Language, all HTTP Headers, and
Keywords.
Whenever Archer Media Network wins an auction and
customer displays an ad from Archer Media Network, the IP Address, User Agent,
Referrer, Accept Language, all HTTP Headers are also retrieved from end user’s
browser request sent to Archer Media Network.
VI. For What Purposes We Use End
User Data?
The data collected and stored in the Archer Media
Network platform is used by Archer Media Network’s customers to increase the ad
relevance and target different kinds of audiences. Particularly, our customers
use Archer Media Network for:
Adult Visit Detection
To check a type of an audience (adult or non-adult)
and display an advertisement only to the proper one.
Fake and Duplicated Traffic
Detection
To monitor the quality of traffic for our customers
and blacklist those sources that generate fake or duplicated visits / clicks.
Fake Domain Detection
To detect domains that might look like an
original domain of the customer and abuse the domain’s reputation for different
sorts of benefits.
Frequency Capping
To limit the number of times a visitor is
exposed to a single advertisement.
Geo Targeting
To allow the Archer Media Network’s customers to
address visitor’s preferences that refer to a geographic location. The
targeting is mainly based on a country, Internet Service Provider, or
demographic data.
Optimization
To measure the effectiveness of online ad campaigns
what helps to address the advertisements to right audiences and based on the
collected data improve the performance of the campaigns. Briefly, to determine
how visitors respond to advertisements they see on the Internet. The goal of
the optimization is helping advertisers predicting the cost of a particular
campaign and find an optimal value.
Reporting
Reporting aggregates data for troubleshooting,
analysis, improve our customers’ experience, provides custom reporting for both
publishers and advertisers.
Targeting by Keywords
To choose words that are relevant or
important to a displayed advertisement to be able to target end users searching
for the same terms.
Troubleshooting
To fix technical issues that Archer Media Network’s
customer experience while running their online campaigns and identify faulty
settings of the configuration.
VII. Legal Basis for
Processing User Information
For our customers, meaning both advertisers and
publishers, we collect and process end users’ personal data as their data
processor. If you are a European Union End user or GDPR applies to you under
Applicable Law, our customers need to have a legal basis for collecting and
using the end user information described above. The kind of legal basis used by
our customers will depend on the user information concerned and the specific
context in which we collect it. Mainly, this legal basis is end users’ consent
in particular when end users’ personal data is collected and processed in order
to deliver targeted advertising to the end user.
Sometimes, end user’s data can also be processed
under legitimate interests of our customers, in particular to:
- Operate
and improve our technology
- Enable
standard advertising controls
- Prepare
reports that summarize visitor’s activity
- Analyze and report on the advertisement’s performance
(such as tracking views of ad as well as click-through rates on ads),
campaign reporting, and campaign forecasting
- Protect,
investigate, and deter against fraudulent, unauthorized, or illegal
activity.
VIII. How Long Do We Store Data?
The collected data is stored using generally
accepted security standards. The data retention of visitor’s activities in the Archer
Media Network platform is 3 months starting from the day of the customer’s
account registration. This data is used for reporting and analysis. After 3
months, all collected data regarding visitors is removed.
IX. Your Choices and Opt Out Option
The opt out option is applicable for end users who
see an online advertisement set by a customer.
If you wish to opt out of being tracked
with desktop and mobile website environments from Archer Media
Network, please email dpo@archermedia.co.uk.
Opting out of being tracked with desktop and
mobile website environments from the Archer Media Network platform is
valid for 10 years for a web browser where the opt out option has been set. The
option can be enabled only for a particular web browser meaning that if you
switch to start using other web browser, make an update for the current version
of the web browser, clear cookies, or use a browser’s incognito mode, you need
to go through the opt out procedure once more. When the opt out option expires,
you need to repeat the same procedure to turn it on again.
X. European Data Subject
Rights
If you are a European Union end user or GDPR
applies to you under Applicable Law, you have certain rights and protections
under the law regarding the collection, processing, and use of information
about you. In particular, you have the right to:
- To
request access and obtain a copy of your data.
- To
request rectification (correct or complete information about you) or
erasure (it is sometimes called ‘the right to be forgotten’ that applies
in some circumstances).
- To
restrict the processing end user information.
- If
applicable, to the data portability.
In certain circumstances, you may also have the
right to object to the processing of end user’s information when personal data
is processed on the basis of legitimate interests and there is no overriding
legitimate interest for us to continue to process your personal data, or if
your data is being processed for direct marketing purposes.
If you have given us your consent to process your
data, you have the right to withdraw your consent. The withdrawal of consent
does not affect the compliance of the processing which was made on its basis
before the withdrawal of consent.
You have also the right to lodge a complaint with
the Supervisory Authority in particular if you feel that Archer Media has not
responded to your requests to solve a problem.
As we act as a processor of end users’ personal
data on behalf of our customer, according to GDPR, taking into account the
nature of the processing, we are obliged to assists the controller by
appropriate technical and organisational measures, insofar as this is possible,
for the fulfilment of the controller’s obligation to respond to requests for
exercising the data subject’s rights laid down in GDPR.
In aforementioned matters, please contact our data
protection officer: dpo@ArcherMedia.co.uk.
Please include information that will enable us to verify your identity within
your request.
XI. Transfer of Personal
Data Outside EEA
We work with customers and partners throughout the
world, including in the European Economic Area (EEA) as well as countries
outside of the European Economic Area (EEA).
In order to ensure that your personal data is
adequately protected when transferred outside of the EEA, Archer Media:
- relies on
EU-U.S. Privacy Shield Program – Privacy Shield is a “partial” adequacy
decision, as, in the absence of a general data protection law in the U.S.,
only the companies committing to abiding by the binding Privacy Shield
principles benefit from easier data transfer. In such cases, your personal
data will be transferred to the territory of USA in accordance with applicable
laws, with appropriate safeguards in place, only to Privacy Shield
certified vendors (according to the EU Commission Decision 2016/1250), or
by using standard contractual clauses adopted by the European Commission
(EU Commission Decision on standard contractual clauses for the transfer
of Personal Data to processors established in third countries under
Directive 95/46/EC (the “Model Contract Clauses”), or based on other
applicable transborder data transfer mechanisms,
or
- has
entered into inter-company EU “model clause” agreements.
You may contact us if you require a copy of the
safeguards which we have put in place to protect your data transferred outside
of the EEA and your privacy rights in these circumstances.
You may also learn more about:
XII. Security
Archer Media uses various security technologies and
procedures that help protect your personal information from unauthorized
access, use, disclosure, alteration, or destruction.
For example:
- Personnel: Only qualified and
authorized employees are permitted to access personal information, and
they may do so only for permitted business functions.
- Data
Protection Officer: We appointed a Data Protection Officer
who in particular watches over the security of your data, monitors our
compliance with GDPR, and is a point of contact for you in all matters
regarding data protection; here you have contact to our Data Protection
Officer: enquiries@archermedia.co.uk.
- Security
Measures: We
use encryption in the transmission of your personal information between
your system and ours, and we use firewalls to help prevent unauthorized
persons from gaining access to your personal information.
- Payments: All supplied
sensitive/credit information is transmitted via Secure Socket Layer (SSL)
technology and then encrypted into our payment gateway providers database
only to be accessible by those authorized with special access rights to
such systems, and are required to keep the
Information confidential. After a transaction, your private information
(credit cards, social security numbers, financials, etc.) will not be
stored on our servers.
- Additional
Safeguards: We
maintain physical, electronic and procedural safeguards in connection with
the collection, storage and disclosure of your information. Our security
procedures mean that we may request proof of your identity before we
disclose personal information to you.
- Trusted
Vendors:We rely only on vendors who ensure an
appropriate level of security of your Data. In this context, we use only
secure cloud servers, including AWS cloud – a secure, private cloud
platform. AWS participates in the EU-US Privacy
Shield framework. Amazon Web Services is our processor. AWS Amazon
cloud platform uses various security technologies and procedures to
protect personal data and is compliant with third-party assurance
frameworks such as ISO 27017 for cloud security, ISO 27018 for cloud
privacy, PCI DSS Level 1, and SOC 1, SOC 2, and SOC 3. For more
details please see AWS Amazon security and privacy policy at www.aws.amazon.com.
XIV. Children
Protecting children’s privacy is very important to Archer
Media. Our platform is not intended for, designed to be used by, or targeted at
children. We do not allow our partners and customers to send to us personal
data of children as defined under GDPR.
XV. Contact Us
If there are any questions regarding this End User
Privacy Policy, you may contact us using the information below:
Archer Media UK Ltd
Central Lofts
5 Waterloo square
NE1-4DR
Email: enquiries@archermedia.co.uk