End user policy
End user policy
Who are we?
Illuma Technology (the “Organisation”, “we”, “us” and “our”) based at 6-8 Long Lane, London, EC1A 9HF (tel: 0207 490 7713; email firstname.lastname@example.org) provides expertise to our clients (“Clients”) on media and advertising campaigns to advertise their products or services online. To do this, we use our in-house technology platform (the “Platform”).
We respect your privacy and are committed to protecting your personal data and being transparent about how we collect and use the data and to meeting our data protection obligations.
For the purposes of what we do and our interactions with you, we are a ‘processor’ of your personal data, and we are appointed as a processor, by our Client. Our Client is the ‘controller’, who is ultimately responsible for your personal data and deciding how it is used.
What do we do?
We use our Platform to help our Clients place online display advertising on websites (“Websites”) that are typically owned by publishers or online service providers (“Website Owners”). Tailoring which advertisements are displayed is known as “targeted advertising”.
By providing targeted online advertising, it is more likely to: (a) make the advertising you see more relevant and useful to you; (b) make the advertising more effective for our Clients; and (c) allow the Website Owner to sell the advertising space for a higher price and increase the flow of funding from advertisements that it receives.
In order to try to ‘target’ the most appropriate advert, we typically employ “Contextual Targeting”. This is where we recommend that our Clients show advertisements on a specific page.
This type of targeting does not specifically target you or your device and all visitors to the page could receive the same advertisement.
What information do we collect?
We process limited data when employing targeted advertising for our Clients. The data we collect is related to the advertising campaign and the URL that ads have run on. No personal data such as online identifiers, geo-location information, is collected.
We do not know your name, address, phone number, email address or other contact information. We do not knowingly collect any “Special Categories” of personal data 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.
We do not knowingly use or collect data to target advertising to children under the age of 13.
We may create, use and share aggregated data. Aggregated data is not considered personal data in law as this data does not directly or indirectly reveal your identity.
How do we collect personal data?
We do not collect any personal data.
How do we use your personal information?
We do not collect or use any personal information.
As a data subject, you have a number of rights. You can:
access and obtain a copy of your data on request;
require the organisation to change incorrect or incomplete data;
require the organisation to delete or stop processing your data, in certain circumstances, for example where the data is no longer necessary for the purposes of processing;
withdraw your consent to our using your data;
ask the organisation to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation’s legitimate grounds for processing data; and
right to data portability, in certain circumstances.
However, given we don’t process any personal data, it is unlikely that we would be able to link you as an individual. You are more likely to be able to control, restrict or amend your personal data by opting out of advertising.
If you would still like to exercise any of these rights, please contact us using the details below. This may mean that you will have to provide us with further personal data about yourself so that we can identify the device connected with you.
Can I delete my data?
Under data protection laws (such as the GDPR), you may have the right to ask us to suspend the processing of your personal data. However, as explained above, we are unlikely to have any personal data about you and therefore, you would need to provide further personal data to allow us to identify you as the individual using a specific device.
You can also manage your opt out on the OBA User Choice Site (www.youronlinechoices.com).
Changes to this Notice
We reserve the right to update this Privacy Notice at any time, and we will post a new version of this Privacy Notice on our website when we make any substantial updates.
Illuma Technology contact information
To get in touch with us with regards to privacy and your personal data or in connection with the advertising services we manage for our Clients, you may contact us by email on email@example.com
The websites www.weareilluma.com and www.illuma-tech.com are both owned by Illuma Technology.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The GDPR also gives you right to lodge a complaint with a data protection supervisory authority, in particular in the European Union state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
The wording in this document reflects the requirements of the General Data Protection Regulation (GDPR), which will come into effect in the UK on 25 May 2018. illuma technology adheres to the IAB Europe OBA Framework.