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Privacy Policy

Updated 1 October 2019

Introduction

Bidstack Limited (“Bidstack“, “we“, “us” or “our“) is 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 the video game.

Bidstack uses information provided to it by game publishers and developers to create user profiles and audiences. This means that Bidstack tailors 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 Bidstack’s services.

Bidstack respects your privacy and is committed to protecting the personal information we receive.

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 information. It also explains your rights in relation to your personal information, how you can opt out of targeted advertising served by Bidstack and how to contact us.

1. Important information and who we are

This privacy policy aims to give you information on how Bidstack collects and processes personal information about the users and customers of Bidstack’s clients, together with any personal information that you may provide to us when you use our Platform directly or use https://www.bidstack.com/ and its sub-domains (“Website“).

Our 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.

In addition, 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 Internet Advertising Bureau (“IAB“), the IAB Europe Transparency and Consent Framework, the Trustworthy Accountability Group (“TAG“) and we are accredited by JICWEBS for complying with the DTSG Brand Safety standards.

Bidstack is the controller and responsible for your personal information set out in this privacy policy. We are registered with the UK Information Commissioner’s Office under registration number: ZA370854.

2. The information we collect about you

We may collect, use, store and disclose different categories of personal information about you.  As set out below, the information collected depends on whether you are an end user receiving advertising via the Platform, a Website visitor or a customer / partner representative:

End user

Website visitor

Customer / partner representative

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.

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.

3. How do we collect your personal information?

We use different methods to collect personal information including via the following:

Direct interactions. You may give us your Identity Data and/or Contact Data by filling in forms or by corresponding with us by post, phone, e-mail or otherwise, such as where you submit a request to us to exercise a data protection right. This includes personal information you provide when you directly register with us, contact us by post, email, telephone, through our website or social media or where you request that marketing be sent to you.

Automated technologies or interactions. As you interact with our Website and/or Platform, we will automatically collect Technical Data about your equipment and usage of the Website and/or Platform such as frequency of visits and pages accessed.  We collect this personal information on the Website by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources. We will receive personal information about you from various third parties and public sources as set out below:

4. How do we use your personal information?

We have set out below how we use your personal information, and our lawful basis for doing so where we act as controller.  Where we act as a processor, it is for our customers as controllers to establish the appropriate lawful basis.  We have also identified what our or our customers’ legitimate interests are where necessary.

Purpose/Activity

Type of information

Lawful basis for processing including basis of legitimate interest

To provide our services to game publishers, including the provision of  targeted adverts to users on behalf of our game publisher clients.

This purpose includes profiling users, creating segments, making decisions about the opportunity to place an advert, measuring the performance of adverts, fraud prevention and detection.

(a) Identity

(b) Technical

(c) Usage

Consent OR 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.

To comply with our professional, legal and regulatory obligations that apply to our business.

(a) Identity

(b) Contact

Necessary to comply with a legal obligation.

To gather and provide information required by or relating to audits. enquiries or investigations by regulatory bodies.

(a) Identity

(b) Contact

(c) Technical

Necessary to comply with a legal obligation.

To enable you to provide feedback or to communicate with us.

(a) Identity

(b) Contact

(c) Usage

Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

(a) Identity

(b) Contact

(c) Technical

(d) Usage

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).

Necessary to comply with a legal obligation.

To deliver relevant website content to you.

(a) Identity

(b) Contact

(c) Usage

(d) Technical

(e) Marketing and Communications

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

To make suggestions and recommendations to you about goods or services that may be of interest to you.

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business).


We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

5. Sharing of Information

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

Category

Explanation

Connected Third Parties

Bidstack Group PLC

Pubguard

External Third Parties

Service providers acting as processors based within the European Economic Area (EEA) who provide:

  • IT and system administration services (e.g. Amazon Web Services, Microsoft.
  • Our third party advertising partners including:
    • Flashtalking
    • DV360
    • The Trade Desk Inc
    • xAndr
    • iPonweb GNBH
    • BidSwitch
    • Google Ad Manager
    • Sizmek Inc

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.

Other 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.

6. International transfers

We will not transfer your personal information outside the European Economic Area except to a country offering a similar level of protection for your personal information by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information outside of the EEA.

7. 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.

8. Retention

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 below 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.

9. Data protection rights

You have the following data protection rights:

In order to respond to your request, we may need to engage with our publisher clients, for example, for them to consider what information to provide or delete.  We respond to requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

10. 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.

11. How to contact us

If you have any questions or concerns regarding this privacy policy or our privacy practices, please contact our Data Protection Officer via DPO@bidstack.com.

1 October 2019