Privacy Policy

About us

We are Bidstack Ltd and its group companies (Bidstack).

We are a cross-platform in-game advertising provider, whose technology enables video game companies and advertisers to create advertising opportunities in-game (the “Platform”).

Game developers and publishers can integrate adverts into the game environment using our SDK and advertisers can use our technology to buy space and run targeted campaigns within video games.

We use information provided to it by game publishers and developers to create user profiles and audiences. This means that we tailor advertising to users based on this information and may use certain information to enable it to identify where the same user is playing different video games which use our services.

Similar to many organisations, our website may include links to third-party websites, plug-ins and applications provided by the likes of LinkedIn, Twitter, Facebook and Instagram. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy practices. When you leave our website, we encourage you to read the policies of those websites you visit.

As part of our commitment to upholding high privacy standards and quality advertising, we are a member of several key industry groups; this includes the Interactive Advertising Bureau (iAB), the IAB Europe Transparency and Consent Framework (TCF), the Trustworthy Accountability Group (TAG) and we are accredited by JICWEBS for complying with the DTSG Brand Safety standards.

The purpose of this policy is to set out clearly to you how we protect your data and respect your privacy.

About you

Whether you are a customer, client or partner of Bidstack, a consumer of video games, or are just a visitor to our website, this Policy applies to you. We take your privacy very seriously.

Our obligations

Where you are a customer, client or partner of Bidstack or a user of our website, we are the data controller and as such we determine the ‘how’ and the ‘why’ in respect of the processing of your data. We are registered as a data controller at the UK’s Data Protection Authority, the ICO, under registration number ZA370854.

Where you are a consumer of video games, we act as the data processor of the developer or publisher of the game(s) you are playing. This means we only process your data (i) to enable us to provide our services to our customer, (ii) in accordance with their instructions, or (iii) otherwise as may be required by law. Our customer is responsible for making sure that your personal data is treated in accordance with the applicable data protection laws which includes informing you how their service providers (including Bidstack) collect and use your data on their behalf.

Your obligations

Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

Where you provide Bidstack with personal information about other individuals, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. By submitting the information, you confirm that you have the right to authorise us to process it on your behalf in accordance with this Policy.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals and our wider operations in the European Economic Area (EEA).

When and how we collect data

From your initial interaction with Bidstack, we are collecting data. Some of this will be collected automatically, sometimes you provide us and sometimes third parties provide us with the data.

* Third Parties may include games publishers/developers and audience partners, social media platforms such as Facebook or LinkedIn, and/or analytics providers such as Google.

Types of data collected

From your initial interaction with Bidstack, we are collecting data. Some of this will be collected automatically.

Contact details
Name, address, telephone number, email address.

Financial Data
Bank account number, sort code number, BIC, and.or other account details in respect of our suppliers, vendors and clients.

Identity Data
Age, gender, country, region, city, and your Steam, PlayStation, Xbox or other similar gaming platform user identification name, alias or tag. Where the data relates to Steam, PlayStation, Xbox, (or other similar gaming platform), this is received from game publishers in a hashed form.

Technical Data
Your internet protocol (IP) address, device type, operating system and platform and versions, connection type, user agent string, mobile carrier, identifiers assigned to your device including advertising identifiers and other technology on the devices you use to access or to otherwise interact with our Platform, browser type and version, time zone setting, browser plug-in types, geolocation information about where you might be.

Usage Data
Your URL clickstreams (the pathways you take through our site), products/services viewed, page response times, download errors, how long you stay on our pages, what you do on those pages, how often, and other actions. Game session data including session length, success markers of session, selection choices, and other information about how you use our Platform and the games that our technology sits within.

Marketing and Communications Data
Your preferences in receiving marketing from us and our third parties and your communication preferences

Aggregated Data
We also process aggregated data for business and commercial purposes. For example, we may aggregate your Usage Data to calculate the percentage of users seeing a specific advertisement. We take measures to ensure this data is not personal

Sensitive Data?
We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences except when we have your specific consent, or when we have to in order to comply with the law.

What about children’s data?
Our services, Platform and website are not intended for children and we do not knowingly collect personal information relating to children. We have stringent processes in place to ensure that where a game user identifies as a child their personal information is not passed to us.

How and why we use your data

The result of data protection laws means that we are only able to use your data for certain reasons and where we have a legal basis to do so.

Keeping Bidstack running
Managing our relationship with and providing our services to our customers, login and authentication, remembering your settings, processing payments, hosting and back-end infrastructure.
Legal bases for this data usage: (i) Contract; (ii) Legitimate Interests.

Improving Bidstack
Testing features, interacting with feedback platforms and questionnaires, managing landing pages, heat mapping our site, traffic optimization and data analysis and research, including profiling and the use of machine learning and other techniques over your data and in some cases using third parties to do this.
Legal bases for this data usage: (i) Contract; (ii) Legitimate Interests.

Providing our Services
Delivering appropriate tailored advertising and other content into native gaming spaces to see delivers.
Legal basis for this data usage: (i) Consent; (ii) Legitimate Interests; the precise basis will depend on the specific processing purpose and the context in which data is processed. If we rely on legitimate interests, these interests will typically be to run the Platform and serve advertising on behalf of our game publisher clients. We, or our clients, may have other legitimate interests and, if appropriate, will explain these to you at the relevant time.

Customer support
Notifying you of any changes to our services, resolving queries via a communications platform, phone or email including any bug fixing.
Legal basis for this data usage: (i) Contract.

Marketing purposes (with your consent)
Sending you emails and messages about new features, products and services, and content.
Legal basis for this data usage: (i) Consent.

Here is what is meant by each of these “legal bases”:

Consent
You have given clear consent for you to process your personal data for a specific purpose.
You can change your mind!

If you have previously given consent to our processing your data you can freely withdraw such consent at any time. You can do this by emailing us at DPO@bidstack.com.

If you do withdraw your consent, and if we do not have another legal basis for processing your information, then we will stop processing your personal data. If we do have another legal basis for processing your information, then we may continue to do so subject to your legal rights.

Contract
Processing your data is necessary for a contract you have with us, or because we have asked you to take specific steps before entering into that contract.

Legitimate interests
Processing your data is necessary for our legitimate interests and/or the legitimate interests of a third party, provided those interests are not outweighed by your individual rights and interests.

These legitimate interests are:

• gaining insights from your behaviour on our Platform or website or interaction with our services
• delivering, developing and improving Bidstack’s services
• enabling Bidstack to enhance, customise or modify our services and comply with all applicable laws
• determining whether marketing campaigns are effective
• enhancing data security

In each case, these legitimate interests are only valid if they are not outweighed by your rights and interests

Your choices and rights

Choices

You can choose not to provide us with personal data
If you choose to do this, you can continue to use the website and browse its pages, but we will not be able to process transactions without personal data.

You can turn off cookies in your browser by changing its settings
You can block cookies by activating a setting on your browser allowing you to refuse cookies. You can also delete cookies through your browser settings. If you turn off cookies, you can continue to use the website and browse its pages, but certain services will not work effectively.

You can ask us not to use your data for marketing
We will inform you (before collecting your data) if we intend to use your data for marketing and if third parties are involved. You can opt out from marketing by emailing us at DPO@Bidstack.com.

Rights

You can exercise your rights by sending us an email at DPO@Bidstack.com.

I. The right to access information we hold about you

This includes the right to ask us supplementary information about:

• the categories of data we’re processing
• the purposes of data processing
• the categories of third parties to whom the data may be disclosed
• how long the data will be stored (or the criteria used to determine that period)
• your other rights regarding our use of your data

We will provide you with the information within one month of your request, unless doing so would adversely affect the rights and freedoms of others (including another person’s confidentiality or intellectual property rights). We will let you know if we would be unable to meet your request for that reason.

II. The right to make us correct any inaccurate personal data about you

III. The right to object to us using your data for profiling you or making automated decisions about you

We may use your data to determine whether we should let you know information that might be relevant to you (for example, tailoring emails to you based on your behaviour).

IV. The right to port your data to another service

If you ask us and it is technically possible, we will directly transfer the data to the other service for you. We will not do so to the extent that this involves disclosing data about any other individual.

V. The right to be ‘forgotten’ by us

You can do this by asking us to erase any personal data we hold about you, if it is no longer necessary for us to hold the data for purposes of your use of Bidstack.

VI. The right to lodge a complaint regarding our use of your data

Please let us know first, so we have a chance to address your concerns. If we fail in this, you can address any complaint to the ICO, either by calling their helpline or as directed on their website at www.ico.org.uk.

VII. As a consumer of video games?

If you wish to exercise your rights, please contact the relevant game publisher/developer. If you prefer, you can contact us at DPO@Bidstack.com, and we will pass the request on to our client or customer (please provide their name).

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We have put in place procedures to deal with any security incident involving personal information and will notify you and any applicable regulator of a breach where we are legally required to do so

Data storage

Where?
The personal data we collect is processed at our offices in London and Riga and in any data processing facilities operated by the third parties identified below.

By submitting your personal data, you agree to this transfer, storing or processing by us. If we transfer or store your information outside the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected as outlined in this Privacy Policy.

How Long?
We will only retain your personal information for no longer than is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or regulatory requirements, complaints or contemplated / actual litigation.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your personal information: see above for further information.

In some circumstances we will anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that we do not receive any advertising requests in relation to your profile for a period of 12 months then we will treat your profile as expired and the data connected to your profile may be deleted.

Data sharing – Third parties

We partner with third parties who we believe are the best in their field at what they do.

When we do this, sometimes it is necessary for us to share your data with them in order to get these services to work well. Your data is shared only when strictly necessary and according to the safeguards and good practices detailed in this Policy. We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions

We may share your information, with the parties set out below for the purposes set out above.
 

 
Connected Third Parties

Bidstack Group PLC
Minimised Medial Limited (t/a Pubguard)
Bidstack SIA

Service providers acting as processors who provide:
IT Infrastructure and Analytics, including:

• Amazon Web Services Inc.
• Google Cloud
• Google Analytics
• Looker Data Sciences, Inc.

 
Integrations

• Slack Technologies Inc.

 
Marketing and Communications

• Hubspot Inc.
• Mailchimp (The Rocket Science Group LLP)
• WordPress
• Google G-suite

 
Advertisers:
Advertisers who have entered into an agreement with Bidstack and who have purchased advertising through the Platform or via Advertising Demand Partners.

Advertising Demand Partners (including Demand-Side Platforms (DSPs)):
Parties that purchase advertising inventory or manage and/or facilitate this process for advertisers. These include:

• Google DV360
• The Trade Desk Inc
• xAndr, an AT&T Company (AppNexus)
• iPonweb GMBH
• BidSwitch GmbH
• Google Ad Manager
• InMobi
• Yahoo (Verizon Media)
• Magnite (Rubicon Project)
• Unruly
• SpotX
• Pubmatic
• Comcast (Beeswax)
• Improve Digital

 
Advertising Measurement and/or Fraud Partners:
Third parties that we provide data to in order to verify the user traffic and demonstrate the effectiveness of our services. These include:

• MOAT by Oracle (Oracle Corporation)
• Nielsen
• Comscore
• Flashtalking
• Google Ad Manager
• Sizmek Inc

 
The iAB Global Vendor List
https://iabeurope.eu/vendor-list/

Professional advisers
acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

Tax bodies, regulators and other authorities
acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

External Third Parties

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy policy.

To any other third parties with your consent to the disclosure.
 

 
We recommend that you read our advertising partners’ privacy policies for more information as to how they will handle your information.

Updates and changes

We keep our privacy policy under regular review. Any changes will be posted to this page, and where appropriate may be notified to you when you next start an app or game that engages with our Platform.