Welcome to the VendorCloud(“VendorCloud,” “we”) web site at http://www.VendorCloud.com (the “Site”). VendorCloudis a digital advertising company and values the privacy of consumers who visitthe Site as well as web and mobile sites and applications where our technologyis enabled (“Users,” “you”). VendorCloud uses technology to gather informationand optimize the delivery of digital advertising (the “Technology”).
1. IMPORTANTINFORMATION AND WHO WE ARE
PURPOSE OF THISPRIVACY NOTICE
This privacynotice aims to give you information on how VendorCloud collects and processesyour personal data through your use of this website, including any data you mayprovide through this website when you apply for a product demo.
This website isnot intended for children and we do not knowingly collect data relating tochildren.
It is importantthat you read this privacy notice together with any other privacy notice orfair processing notice we may provide on specific occasions when we arecollecting or processing personal data about you so that you are fully aware ofhow and why we are using your data. This privacy notice supplements the othernotices and is not intended to override them.
VendorCloud isthe controller and responsible for your personal data (collectively referred toas “VendorCloud”, “we”, “us” or “our” in this privacy notice).
We haveappointed a data protection officer (DPO) who is responsible for overseeingquestions in relation to this privacy notice. If you have any questions aboutthis privacy notice, including any requests to exercise your legal rights,please contact the DPO using the details set out below.
Our fulldetails are: VendorCloud 20 North Audley, Street, #201, London, W1K6LX, UK.
Data PrivacyOfficer (DPO)
Name or titleof DPO: VendorCloud DPO
Postal address:VendorCloud 20 North Audley, Street, #201, London, W1K 6LX, UK.
You have theright to make a complaint at any time the Data Protection Authority. You canfind contact details of your National Data Protection Authority online at:http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.html
We would,however, appreciate the chance to deal with your concerns before you approachthe ICO so please contact us or our DPO in the first instance.
CHANGES TO THEPRIVACY NOTICE AND OUR DUTY TO INFORM YOU OF CHANGES
This versionwas last updated on May 25, 2018 and historic versions can be obtained bycontacting us.
The dataprotection law in the EU will change on May 25, 2018. Although this privacynotice sets out most of your rights under the new laws. We are stillformalizing processes for responding to certain types of request under the newGDPR. You can contact the VendorCloud DPO in the first instance for anyqueries. We will be updating our systems and processes as an ongoing projectand this privacy notice may be updated with these changes at any time
It is importantthat the personal data we hold about you is accurate and current. Please keepus informed if your personal data changes during your relationship with us.
This websitemay include links to third-party websites, plug-ins and applications. Clickingon those links or enabling those connections may allow third parties to collector share data about you. We do not control these third-party websites and arenot responsible for their privacy statements. When you leave our website, weencourage you to read the privacy notice of every website you visit.
2. OURADVERTISING SERVICES & DATA WE COLLECT ABOUT YOU
VendorCloud isnot an ad network or a data broker. It is a digital advertising technologyplatform. By “Platform,” we mean a technology that provides tools foradvertisers, or buyers, to purchase ad space and for website and mobileapplication publishers, or sellers, to sell their ad space in the mostefficient way possible. Users benefit from targeted advertising by receivingmore interesting and relevant advertisements, while advertisers benefit throughthe more efficient delivery of advertising to interested Users.
Our targetingoptions are based on non-personally identifiable data that is collected overtime and may range from sending an advertisement to a User based on suchfactors as a User’s interests, similarities to other Users, or generalgeographic location. This data may be used to identify and predict the sitesand groups of Users that are most likely to create a response to anadvertiser’s campaign.
If you prefernot to have VendorCloud tailor online advertising to your interests, you mayopt out at any time by one of the following methods: Opt out of VendorClouduser interest targeting cookie by clicking “OPT OUT HERE”.Please note that if you delete your cookies, change browsers, or use adifferent computer, you will need to opt out again. Read more at: https://VendorCloud.com/privacy-policy/
Personallyidentifiable data, personal data, or personal information, means anyinformation about an individual from which that person can be identified. Itdoes not include data where the identity has been removed (anonymous data). Wemay collect, use, store and transfer different kinds of personal data about youwhich we have grouped together follows:
Identity Dataincludes first name, maiden name, last name, username or similar identifier,marital status, title, nationality, date of birth, place of birth, gender,passport or ID document number, photo, issue date, expiry date and otherinformation provided in passport or ID document scan copy.
Contact Dataincludes residence address, email address and telephone numbers.
Technical Dataincludes internet protocol (IP) address, your login data, browser type andversion, browser plug-in types and versions, device type, operating system andplatform and other technology on the devices you use to access this website.
Usage Dataincludes information about how you use our website, products and services.
We alsocollect, use and share Aggregated Datasuch as statistical or demographic data for any purpose. Aggregated Data may bederived from your personal data but is not considered personal data in law asthis data does not directly or indirectly reveal your identity. For example, wemay aggregate your Usage Data to calculate the percentage of users accessing aspecific website feature. However, if we combine or connect Aggregated Datawith your personal data so that it can directly or indirectly identify you, wetreat the combined data as personal data which will be used in accordance withthis privacy notice.
We do notcollect any SpecialCategories of Personal Data about you (this includes details aboutyour race or ethnicity, religious or philosophical beliefs, sex life, sexualorientation, political opinions, trade union membership, information about yourhealth and genetic and biometric data). Nor do we collect any information aboutcriminal convictions and offenses.
The VendorCloudSite is generally intended for use by businesses, advertisers, and potentialpartners interested in learning more about VendorCloud. You may provide to VendorCloudIdentity Data (such as your name or email address) when using the Site. Forexample, if you are an advertiser or web publisher and use the Site to requesta contact from our sales or business development department, we will ask foryour name, email address and other contact information so that a VendorCloudrepresentative can respond to your inquiry. We do not use your Identity Datafor any other purpose other than responding to your request. We do not shareyour personally identifiable information with other organizations for theirmarketing or promotional uses without your express consent. Notwithstanding theabove, VendorCloud reserves the right to disclose Identity Data if: (i)required by law or in the good-faith belief that such action is necessary tocomply with state and federal laws; (ii) we believe, in good faith, that suchaction is appropriate or necessary to take precautions against liability; or(iii) such action is necessary to protect our rights or those of our Users andothers.
We adhere toDigital Advertising Alliance Principles with regard to data collection andinterest-based advertising. Visitors to the VendorCloud site may experience athird party engaging in data collection for such purpose, based on yourbrowsing behavior across many sites. If you wish to control such datacollection, you may visit the DAA Consumer Choice Page, where you can learnmore about the value of interest-based ads, and express your preferences there.The Site is hosted in the United States. If you choose to use the Site from theEuropean Union or other regions of the world with laws governing datacollection and use that may differ from U.S. law, then please note that you maybe transferring your personally identifiable information outside of thoseregions to the United States and by providing your personally identifiableinformation on the Site you consent to that transfer. Read more at: http://grvty.fr/1BzXR
IF YOU FAIL TOPROVIDE PERSONAL DATA
We need tocollect personal data under the terms of a contract we have with you and if youfail to provide that data when requested, we may not be able to perform thecontract we have or are trying to enter into with you (e.g., to provide youidentity verification services). In this case, we may have to cancel a serviceyou have with us but we will notify you if this is the case at the time.
3. HOW IS YOURPERSONAL DATA COLLECTED?
We usedifferent methods to collect data from and about you including through:
Directinteractions. You may give us your Identity and Contact Data byfilling in online forms provided on our website. This includes personal datayou provide when you:
create anaccount on our website;
submit yourinformation for identity verification
AutomaticallyCollected Information. We may also collect a variety of informationfrom your browser or computer using the Technology, including “pixel tags,”“clear gifs,” or “web beacons.” This “automatically collected information” mayalso include request-based information which is passed to us by the User’scomputer browser with every request and is stored without any personallyidentifiable information. Examples of this include your web browser type, theweb sites that you visit just before or just after visiting a web site, and thedates and times that you visit a web site. We may also collect sessioninformation relating to Users and specific ad campaigns, which is used forfrequency capping, or limiting the number of times a User sees a specific ad;and the targeting of Users based on their specific interests. If you are usinga mobile device and viewing a website that utilizes our Technology, we may alsouse the Apple IFA, Android Advertiser ID, or other non-personally identifiabledevice information that uniquely identifies individual smartphones or mobiledevices (collectively, “IDFA and Android ID”) in order to authenticate the usersession. This IDFA and Android ID functions similarly to a persistent cookie tomake it possible to authenticate the user without the need for a password. Readmore at: https://VendorCloud.com/privacy-policy/
ClickInformation. We may receive non-personally identifiable informationwhen you click on or otherwise interact with ads deployed using our Technology,including when you indicate a “like” or “share” the ad by clicking on a buttonnear the ad. The information received by us may include information about thead that was clicked on, the web page, or other session-based and request-basedinformation as described above. We may also receive information regarding anylinks that you may click on that are associated with ads deployed using theTechnology or any links that you share or receive from third parties related tothose ads. Read more at: https://VendorCloud.com/privacy-policy/
Informationfrom Tr.im. We may receive non-personally identifiable informationwhen you click on or use our sharing tools on websites that use our Tr.imsharing service. When a user accesses a webpage that contains our sharing toolsor utilizes our link shortening or video embedding services, we may add acookie to the user’s browser to record information on websites that the userhas visited, search terms that they have entered, or connections between non-personallyidentifiable cookies, but strictly in a non-personally identifiable profile.For our video embedding services, we may also track information related to thevideos that you share, including social statistics and information relating tothe parties accessing the video, but only as a non-personally identifiableprofile. We may also collect the IP address and ZIP Code of any devices thataccess URLs shortened by our services, information about how the shortened URLshave been shared, and the date and time of the website access using theshortened URL. We may use this information to customize and send more relevantadvertisements to that user, based upon the collected information, as describedbelow in the section entitled, “How We Use and Disclose Information.” We do notscan the title or the content of any messages you send through our services.Read more at:https://VendorCloud.com/privacy-policy/
InformationAcquired from Other Sources. We may acquire non-personallyidentifiable data from third party sources, including through websites that useour Technology. This data may be used for a variety of purposes, including toupdate existing User profiles, to provide our clients and others with aggregateinformation about traffic and site usage in our advertising network, and otheruses as described below in the section entitled, “How We Use and DiscloseInformation.” We do not share, rent or sell any of this non-personallyidentifiable data and require these third party sources to comply withapplicable industry and legal standards. Read more at: https://VendorCloud.com/privacy-policy/
4.HOW WE USEYOUR PERSONAL DATA
We will onlyuse your personal data when the law allows us to. Most commonly, we will use yourpersonal data in the following circumstances:
Where we needto perform the contract we have entered into with you.
Where it isnecessary for our legitimate interests (or those of a third party) and yourinterests and fundamental rights do not override those interests. Where we needto comply with a legal or regulatory obligation.
Please seeinformation below to find out more about the types of lawful basis that we willrely on to process your personal data.
Generally we donot rely on consent as a legal basis for processing your personal data.
5. PURPOSES FORWHICH WE WILL USE YOUR PERSONAL DATA
We have set outbelow, a description of all the ways we plan to use your personal data, andwhich of the legal bases we rely on to do so. We have also identified what ourlegitimate interests are where appropriate.
Customers.VendorCloud will collect customer identifying information for contractualreasons. This is so we can contact you and communicate with you and yourcompany efficiently.
General. VendorClouduses the information collected by the Technology to tailor advertising to youmore effectively. The aim is for you to see ads which you are more likely to beinterested in. We do this by comparing the information in a non-personallyidentifiable profile against our selection of ad campaigns and choosing themost suitable advertisement. In general, VendorCloud can only create theseprofiles and display ads to you when you visit a web site within our network.This data is collected for a lawful and legitimate reason so we can perform ourcontracts with our customers and also customize advertising to you.
ActionAttribution. To gain a greater understanding of a web site’sperformance or a User’s general interests, we use a variety of technologies todetermine which web sites in our network the User has visited previously and/orwhere the User clicked on an advertisement. By using this information, we cancalculate which web sites and/or which broad interest characteristics of Usersare most likely to respond to a particular campaign. This may be performed twoways – Performance Attribution and User Interest Profiling. This data iscollected for a lawful and legitimate reason so we can perform our contractswith our customers and also customize advertising to you.
User InterestProfiling. To create a User interest profile, we observe which websites within our network Users have visited and determine what topics arecovered by these web sites. This information is combined to generate anon-personally identifiable interest profile for specific browsers to bettertarget our ads to Users. For example, if a User visits a sports site within ournetwork, we may classify them as broadly interested in that sport and potentiallyinterested in purchasing sports gear. That information may be provided to ouradvertising partners to allow them to better tailor their ads to specificUsers. This data is collected for a lawful and legitimate reason so we canperform our contracts with our customers and also customize advertising to you.
Tr.im. Ifyou use our Tr.im sharing service, we may provide our third party partners withnon-personally identifiable metrics and analytics about information andwebsites that you access. For example, if you click on a curated link hosted byone of our partners, our partner may receive non-personally identifiableinformation about the fact that you have accessed that website, including butnot limited to the date and time of such access, the website visited, and theIP address and ZIP Code of the device used to access the link, but strictly ina non-personally identifiable profile. This data is collected for a lawful andlegitimate reason so we can perform our contracts with our customers and alsocustomize advertising to you.
ServiceProviders. VendorCloud works with authorized service providers toprovide website hosting, maintenance, and other services for us. To the extentit is necessary for these service providers to complete their obligations to us,these service providers may have access to User information. However, wecontractually require these service providers to safeguard User information andgenerally limit their use of User information to the purpose for which it wasshared. This data is collected for a lawful and legitimate reason so we canperform our contracts with our customers and third parties and helps us betterprovide services
Note that wemay process your personal data for more than one lawful ground depending on thespecific purpose for which we are using your data. Please contact us if youneed details about the specific legal ground we are relying on to process yourpersonal data where more than one ground has been set out above.
We will getyour express opt-in consent before and if we share your personal data with anycompany outside the VendorCloud group of companies for marketing purposes.
We will onlyuse your personal data for the purposes for which we collected it, unless wereasonably consider that we need to use it for another reason and that reasonis compatible with the original purpose. If you wish to get an explanation asto how the processing for the new purpose is compatible with the originalpurpose, please contact us.
If we need touse your personal data for an unrelated purpose, we will notify you and we willexplain the legal basis which allows us to do so.
Please notethat we may process your personal data without your knowledge or consent, incompliance with the above rules, where this is required or permitted by law.
9.WHERE WESTORE YOUR INFORMATION
10.DISCLOSURES OFYOUR PERSONAL DATA
We may have toshare your personal data with the parties set out below for the purposes setout in the table in section 5.
Internal ThirdParties as set out in the Glossary.
External ThirdParties as set out in the Glossary only after your explicit consent to suchdisclosure.
Specific thirdparties such as service providers acting as processors based in the EU whoprovide identity verification services.
Third partiesto whom we may choose to sell, transfer, or merge parts of our business or ourassets. Alternatively, we may seek to acquire other businesses or merge withthem. If a change happens to our business, then the new owners may use yourpersonal data in the same way as set out in this privacy notice.
We require allthird parties to respect the security of your personal data and to treat it inaccordance with the law. We do not allow our third-party service providers touse your personal data for their own purposes and only permit them to processyour personal data for specified purposes and in accordance with ourinstructions.
We have put inplace appropriate security measures to prevent your personal data from beingaccidentally lost, used or accessed in an unauthorised way, altered ordisclosed. In addition, we limit access to your personal data to thoseemployees, agents, contractors and other third parties who have a business needto know. They will only process your personal data on our instructions and theyare subject to a duty of confidentiality.
We have put inplace procedures to deal with any suspected personal data breach and willnotify you and any applicable regulator of a breach where we are legallyrequired to do so.
Numerousstudies have established that data stored in the cloud is less likely to be lost,deleted or leaked than data stored on a personal computer. All our data isfully encrypted at rest and in transit, and we employ state-of-the-art firewalland back-up technology. All our data is continuously backed up in several highsecurity access-controlled data centers in different locations.
HOW LONG WILLYOU USE MY PERSONAL DATA FOR?
Platform Datais stored using generally accepted security standards. It is usually aggregatedor deleted within 30-60 days, but may be retained in the Platform for up to 18months from the date of collection before aggregation or deletion. Aggregateddata is used for reporting and analysis, and may be stored in the Platform forup to 2 additional years. When clients remove their data from the Platform,their own privacy policies and applicable laws, rules, or regulations governtheir storage and retention of data. VendorCloud maintains all server log dataand stored data for a period of 24 months to comply with audits, court order orlaw enforcement inquiries. After 24 months all of the stored data is destroyed.Summarized data is kept indefinitely. Summarized data is aggregated statisticaldata (impressions, clicks, and conversions) used for financial reportingpurposes. Read more at:http://grvty.fr/1BzXR
Under certaincircumstances, you have rights under data protection laws in relation to yourpersonal data.
Request accessto your personal data
Requestcorrection of your personal data
Request erasureof your personal data
Object toprocessing of your personal data
Requestrestriction of processing your personal data
Requesttransfer of your personal data
Right towithdraw consent
If you wish toexercise any of the rights set out above, please Contact us.
14.NO FEEUSUALLY REQUIRED
You will nothave to pay a fee to access your personal data (or to exercise any of the otherrights). However, we may charge a reasonable fee if your request is clearlyunfounded, repetitive or excessive. Alternatively, we may refuse to comply withyour request in these circumstances.
15.WHAT WE MAYNEED FROM YOU
We may need torequest specific information from you to help us confirm your identity and ensureyour right to access your personal data (or to exercise any of your otherrights). This is a security measure to ensure that personal data is notdisclosed to any person who has no right to receive it. We may also contact youto ask you for further information in relation to your request to speed up ourresponse.
16.TIME LIMITTO RESPOND
We try torespond to all legitimate requests within one month. Occasionally it may takeus longer than a month if your request is particularly complex or you have madea number of requests. In this case, we will notify you and keep you updated.
LegitimateInterest means the interest of our business in conducting and managingour business to enable us to give you the best service/product and the best andmost secure experience. We make sure we consider and balance any potentialimpact on you (both positive and negative) and your rights before we processyour personal data for our legitimate interests. We do not use your personaldata for activities where our interests are overridden by the impact on you(unless we have your consent or are otherwise required or permitted to by law).You can obtain further information about how we assess our legitimate interestsagainst any potential impact on you in respect of specific activities byContacting us
Performance ofContract means processing your data where it is necessary for theperformance of a contract to which you are a party or to take steps at yourrequest before entering into such a contract.
Comply with alegal or regulatory obligation means processing your personal datawhere it is necessary for compliance with a legal or regulatory obligation thatwe are subject to.
Other companiesin the VendorCloud Group acting as processors and provide IT and systemadministration services.
Other companiesacting as processors based in the EU or outside EU, or our customers who usenon-personal identifying data to provide customized advertising services.
You have theright to:
Request accessto your personal data (commonly known as a “data subject access request”). Thisenables you to receive a copy of the personal data we hold about you and tocheck that we are lawfully processing it.
Requestcorrection of the personal data that we hold about you. This enablesyou to have any incomplete or inaccurate data we hold about you corrected,though we may need to verify the accuracy of the new data you provide to us.
Request erasureof your personal data. This enables you to ask us to delete or removepersonal data where there is no good reason for us continuing to process it.You also have the right to ask us to delete or remove your personal data whereyou have successfully exercised your right to object to processing (see below),where we may have processed your information unlawfully or where we arerequired to erase your personal data to comply with local law. Note, however,that we may not always be able to comply with your request of erasure forspecific legal reasons which will be notified to you, if applicable, at thetime of your request.
Object toprocessing of your personal data where we are relying on a legitimateinterest (or those of a third party) and there is something about your particularsituation which makes you want to object to processing on this ground as youfeel it impacts on your fundamental rights and freedoms. You also have theright to object where we are processing your personal data for direct marketingpurposes. In some cases, we may demonstrate that we have compelling legitimategrounds to process your information which override your rights and freedoms.
Requestrestriction of processing of your personal data. This enables you toask us to suspend the processing of your personal data in the followingscenarios: (a) if you want us to establish the data’s accuracy; (b) where ouruse of the data is unlawful but you do not want us to erase it; (c) where youneed us to hold the data even if we no longer require it as you need it toestablish, exercise or defend legal claims; or (d) you have objected to our useof your data but we need to verify whether we have overriding legitimategrounds to use it.
Request thetransfer of your personal data to you or to a third party. We willprovide to you, or a third party you have chosen, your personal data in astructured, commonly used, machine-readable format. Note that this right onlyapplies to automated information which you initially provided consent for us touse or where we used the information to perform a contract with you.
Withdrawconsent at any timewhere we are relying on consent to process yourpersonal data. However, this will not affect the lawfulness of any processingcarried out before you withdraw your consent. If you withdraw your consent, wemay not be able to provide certain products or services to you. We will adviseyou if this is the case at the time you withdraw your consent.