Blis Online Privacy Policy For Online Advertising and Related Uses

 
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Blis Privacy Policy For Online Advertising and Related Uses

This Privacy Policy explains in detail what personal data Blis collects and processes about you, how we use that personal data, who we may share it with, how we protect your personal data, and the choices and the rights you have regarding how we collect and process your personal data. For simplicity we refer to personal data consistently throughout this document, however, the words personal information may also be substituted.

This Privacy Policy covers the personal data we collect and process about you which originates from your use of other companies’ websites and your use of other companies’ apps on your tablets, mobile phones and other handheld devices. This Privacy Policy does not describe the collection and use of personal data by Blis from its own website, which can instead be found here

We hope the following sections will answer any questions you have but if not, please do get in touch with us by emailing privacy@blis.com or visit our privacy centre for more information here.

We are Blis, a digital advertising company. We provide services to companies including media agencies and their clients – global advertisers – who want to place advertisements or content, [or purchase data] by using our technologies. Our services include, for instance, presenting you with personalised ads, verifying location data, measuring footfall attribution, facilitating advertising based on audience segments and inferred interests, cross-device retargeting and other attribution and location analytics.

 

You can find out more about our business in the privacy centre. This video simplifies the process of real-time bidding within which our technologies are utilised.

 

Our parent company is Blis Global Ltd, a company registered in England and Wales with company number 06455773 and with a registered office at 85 Great Portland Street, London W1W 7LT.

 

The companies which form the Blis Group, and their locations, are listed in our privacy centre as Blis official trading companies.

 

Blis Global Ltd, the parent company, is the controller of any personal data held about you by the Blis Group. 

 

Blis is an active member of the industry associations that govern policies around user privacy in the context of digital advertising, including at the time this Policy was last updated: 

 

  • IAB (UK, Netherlands, US and Australia)
  • IMAA (Australia and India)  

Through our membership of the IAB, Blis participates in and complies with the policies and technical specifications of the IAB Europe Transparency and Consent Framework and IAB CCPA Framework. We also have an IAB UK Gold Standard certification.

 

The personal data we may hold about you is associated with one or more pseudonymous identifiers linked to your device, such as cookies or Mobile Advertising IDs.  We do not associate that identifier with your name, email, address, or phone number, because we don’t collect that type of directly identifying information about consumers.

 

  • Mobile Advertising ID
    The Mobile Advertising ID, also referred to as a MAID, is a string of digits associated with a mobile device assigned by operating systems like Android and Apple IOS. This is unique to your device and can be reset by the user.
  • IDFV
    The ID for Vendors (IDFV) is a code assigned to all apps by one developer and is shared across all apps by that developer on your Apple IOS device.
  • Cookie ID 
    This is a unique identifier made up of a string of characters that websites and servers associate with the browser on which the cookie is stored. It is used for purposes including frequency capping and measurement. We may also receive anonymised IDs based on, e.g., SSP-deployed cookies, which may have been synced with other third-party cookies, and that are de-identified and shared with us.
  • Cross-Device ID
    This ID is a user ID created by using statistical, deterministic and probabilistic algorithms in an attempt to link devices and identifiers belonging to the same user. This is often a Cookie-based ID.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

 

  • Location related data
    This includes precise GPS-sourced latitude/longitude data and geolocation data derived from IP addresses. We may also create historic location data profiles from this data. For IP addresses that we have identified as residential, we may link devices seen at the IP address as being potentially in the same household.
  • Online usage data or “log” data
    This includes some data which would be defined as personal data and some which is not. The following is a non-exhaustive list: the name of the publisher or app in use, the category of the site, the general nature of the content being viewed e.g. sports, other information from advertising bid requests relating to a particular device ID, such as hashed cookie IDs or proprietary client/partner IDs, user agent information, device make, model and operating system, ads clicked on, frequency of exposure to ads served, IP address and timezone. 
  • Inferred data
    We might infer some data about you based on your demographics (e.g., age or gender), browsing behaviour or your location data.  For example, if you regularly go to a sports stadium, we might predict that you are interested in sports, and then show you an ad from one of our clients that sells sporting fashion goods.  To be more precise, we would predict that your device might belong to a person interested in sports.

 

Children

We do not knowingly collect, store, share or use the personal data of children under 16 years. Our platform and services are intended for a general audience and are not directed at minors. Advertisers may not use the Blis services to collect data from, target or re-target users under the age of 16. In the USA, as directed by COPPA regulations this is lowered to the age of 13. 

 

If you are under the age of 16 years and you believe that we process personal data about you, please ask your parent(s) or guardian(s) to notify us and we will delete your personal data.

We use cookies, mobile identifiers and data derived from tags, pixels, beacons, SDKs and other tracking technology to associate your usage data with you – or more accurately, with your device. Personal data processed under this policy is received by us as a result of your visiting a website or using an app. 

This data comes to us either from our own Cookie or from third parties such as data partners, supply side platforms (SSPs), exchanges and clients, but only where those parties are lawfully entitled to make available the data for our use.  

We use these tracking technologies and combined data sources so that we and our clients can infer your interests, deliver more relevant advertising to you, measure the impact of that advertising, and better understand your digital media usage patterns.

If you want to understand what these terms mean, want to know more about tracking technology or to understand how you can disable tracking technology, please visit our privacy centre.

Blis uses personal data to provide advertising services, to deliver more relevant advertising on behalf of our clients, to improve our products and services and to create new products. 

 

The purposes include:

 

  • Delivering ads onto your device including technically delivering, selecting the right ad for you, sequencing ads, capping the number of ads shown to you and predicting the likelihood of you interacting with the ad
  • Analysing, measuring and reporting on advertising campaigns so that user actions and interactions can be attributed to campaigns, publishers, apps, clients and specific advertisements
  • Using IDs for cross-device mapping (linking your different devices) in order to limit advertising exposure for consumers and facilitate more relevant advertising
  • Creating and delivering personalised advertising campaigns including campaigns targeted and tailored to your interests, relevant to you and based on your activity, interests, visits to sites or apps, demographic information, or location
  • Using Cookies and IDs to facilitate your user opt-out requests or rights (under GDPR or CCPA)
  • Detecting fraudulent activities and when traffic is not “real” traffic, such as the use of robots, malware and other suspicious activities
  • Synchronising our services with other online advertising services. This process is a core function of the digital advertising ecosystem, as it enables our clients to link up data from multiple advertising services providers. Please see this video to explain more
  • Conducting product research and development, i.e. to analyse the use of our services; to design new, and improve existing, features and functionality of our services; and to develop and train the computer algorithms which form part of our services

 

Profiling and automated decision-making

 

Provided that you have given consent, we will use the personal data we hold about you to deliver ads which we believe match your interests or the interests which we have inferred about you (see Inferred Data). This matching of ads and content to people (or more correctly, to their devices), is carried out automatically by our algorithms and is a category of automated decision-making.

 

Ads and content are served to you because the client or algorithms involved estimate that, based on the data we hold about you (or infer about you), there is a reasonable prospect that you are likely to be interested in the relevant product or service. If you would like more information about the logic involved, or to express your point of view or to contest how the algorithm works, please contact us as set out below.

 

The automated processes that we use do not affect your legal rights (such as your right to vote, take legal action, or freely associate with others) or your ability to receive social benefits or obtain citizenship, nor do they have legal effects on you. Also, we do not knowingly process or make automated decisions about EEA users based on any data that falls into special categories in the EEA. For further details please see our Content and Advertising Standards Policy.

 

 

Health data and special categories of data

 

We do not knowingly collect, store, share or use health data or data which reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, or data concerning a natural person’s sex life or sexual orientation.  For further details please see our Content and Advertising Standards Policy. If you believe you have provided that kind of personal data to us, please contact us at privacy@blis.com

Under UK and EU GDPR (General Data Protection Regulation), our legal basis for collecting and using your personal data will depend on the type of personal data and how it was collected. 

 

For the purposes of this Privacy Policy we will only be processing your personal data where we have your consent or where we have a legitimate interest to do so. If we process your personal data based on a legitimate interest we will ensure that this processing is not overridden by your rights, such as your right to opt-out, and that we have carried out a balancing test. An example of where we rely on our legitimate interests to process your personal data is to prevent fraudulent advertising and to deliver an advertisement to your device. 

 

If you wish to learn more about the legal basis on which we collect and use your personal data please contact us at privacy@blis.com.

Blis is a global business firm and any information that we collect or that you provide to us may be shared and processed by any Blis company or reseller. You can find out more about Blis companies and locations here

 

We may also share your personal data with third parties so that they can help us to provide our advertising services. Some of these third parties are companies in relation to which you have previously given your consent, others are third parties that provide services to Blis. Their services include ad serving, brand safety, viewability, ad fraud, insights, measurement, data, location-based attribution, targeting, optimisation, infrastructure and storage.  Whenever we share your personal data with a third party, we ensure we do this in a manner compliant with the relevant data protection regulations.



For a list of all third parties, together with explanatory information about the different types of third party, please see Blis third parties and partners in our privacy centre

Where legally required we may your share personal data with:

  • Our professional advisers, such as lawyers and accountants
  • Government, police forces, and/or regulatory authorities
  • As part of actual or potential business sale of Blis or its assets, to prevent suspected fraud, to respond to claims asserted against us, or to comply with legal processes such as court order

Blis is a global company. We may transfer personal data to countries other than the country in which it was collected.  Where the destination country does not provide an adequate level of protection for personal data, we will only do so with an appropriate transfer mechanism and apply appropriate safeguards.  

 

If we receive personal data and transfer it on to a third party, we will take appropriate measures to ensure an adequate level of data protection in accordance with this Privacy Policy and data protection regulations.   

 

For more information please contact privacy@blis.com

As described in this Privacy Policy, we process your personal data for a number of purposes, and the length of time that we retain your personal data depends on the processing purpose, the category of personal data and certain external factors, 

 

We will delete or anonymise the personal data we hold about you within 13 months of receiving it.

We use a range of measures to keep your personal data safe and secure. This includes protection against unauthorised access to or unauthorised alteration, disclosure, or destruction of data we collect and store. We require our staff and any third parties who carry out any work for us to comply with appropriate security standards including obligations to protect data and apply appropriate measures for the use and transfer of data.

Data collected and used by our services is held securely by Google Cloud. Data protection is a priority for Google and they are certified against recognised international standards such as ISO/IEC 27001, ISO/IEC 27018 and ISO/IEC 27017. You can read more on Google’s website.

If you have any questions about your data protection rights, please contact us at privacy@blis.com or for other methods please see “How to contact us”.

 

UK and EU GDPR (General Data Protection Regulation)

 

If you are located in the UK or EEA, you may have certain rights under UK and European privacy law, principally the General Data Protection Regulation (GDPR).   This section of the Privacy Policy is intended solely for such consumers, i.e., “data subjects”.  You have a number of rights in relation to the personal data that we hold about you including:

 

  • The right to access personal data we hold about you and to obtain information about how we process it
  • The right to request that we rectify (correct) your personal data if it is inaccurate or incomplete
  • The right to ask us to delete your personal data. We may continue to keep your personal data if we are entitled or required to
  • The right to object to, and to request that we restrict, our processing of your personal data in some circumstances
  • The right to receive certain personal data you’ve provided to us in an electronic format and/or request that we send it to a third party
  • The right to withdraw your consent to us processing your personal data
  • The right not to receive marketing communications from Blis

If you wish to exercise any of the above rights, please contact us at privacy@blis.com.

 

If we are unable to action your request, we will explain the reasons for our refusal.

 

California privacy rights

 

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Policy applies if you are a resident of California and your “personal information” (referred to elsewhere in this document as “personal data” is collected or disclosed by us. This notice supplements the information already provided in this Privacy Policy. 

 

As some of the data we process may be considered “personal information” under CCPA, we are required to make certain disclosures to California consumers. Please see this key to guide you through the Privacy Policy 

 

 

CCPA

Blis Privacy Policy Section

Categories of Personal Information collected in the previous 12 months

What data do we collect and use

Categories of sources from which we collected Personal Information

What data do we collect and use

The business or commercial purposes for collecting or selling Personal Information

How your personal data will be used by us

Categories of Personal Information shared or disclosed to third parties in the preceding 12 months and the categories of third parties with whom the information was disclosed or sold

Who we share or disclose your personal data to

 

California consumers have the following rights:

 

  • To request that we disclose what information we collect, use, disclose or sell about you (twice in a 12-month period)
  • To access the specific pieces of information we hold about you (twice in a 12-month period)
  • To request the deletion of any of your personal information we collect or maintain, subject to certain exceptions (twice in a 12-month period)
  • To non-discrimination – we will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights
  • To opt out of the sale of your personal information

 

Do not sell my personal information. 

Under CCPA, California consumers have the right to opt-out of the sale of their personal information. CCPA broadly defines sale such that it may include, for example, allowing third parties to receive and use certain information, such as cookies, mobile advertising IDs, IP address and/or browsing behaviour, to deliver tailored or personalised advertising.  When you opt-out of the sale of your personal information, you will still receive ads, but we will not be able to use this data to personalise them to you and therefore they may be less useful.

 

How to exercise your rights under CCPA

 

California residents may exercise their California access or deletion rights by calling our toll-free number 1-866-I-OPT-OUT (1-866-467-8688) and enter code 1191#. or by emailing us at privacy@blis.com.

For security purposes, we will verify your identity when you request to exercise your California privacy rights.   Once we have verified your identity (and your agent, as applicable), we will respond to your request as appropriate and except where not permitted under applicable law or otherwise exempted by the CCPA.

If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request.

 

 

Authorised agents

You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights, and to verify that your agent has been authorised to make a request on your behalf through providing us with a signed written authorisation or a copy of a power of attorney.

 

 

We use your personal data to present you with ads which (we hope) are relevant and interesting to you.  We think that this is a win-win for consumers, advertisers, and publishers because advertising revenue is one of the main reasons that the internet is mainly free.

 

If you don’t want to receive personalised or interest-based ads from us then you can opt-out, but please bear in mind that you may still receive ads from us.  The only difference is that they won’t be personalised and therefore – we think – they will be less interesting and relevant to you.

 

How to opt-out

 

There are a number of different ways for you to opt-out of personalised or interest-based advertising:

 

  1. In-ad opt-out

You may opt-out of Blis-delivered interest-based advertisements within a mobile website or mobile App by clicking on the enhanced notice/OBA icon included within that advertisement, and then selecting “opt-out” within the page to which you are redirected.

 

       2. Using the TRUSTe app

 

You may download the TRUSTe mobile app on your iOS or Android device in order to exercise choice regarding the use of mobile app-collected data for interest-based advertising by us and other companies that participate in that choice tool. Links to those applications are below:

TRUSTe mobile appMobile applications opt-out iOS

TRUSTe mobile app Android

 

       3. In your mobile device settings

 

To opt-out of the collection and use of data for interest-based advertising on your mobile device, you can modify the settings on your mobile device. For example:

 

For Apple iOS Devices: 

 

On iOS version 14 and later only:

 

You may withdraw your consent by disabling the “Allow Apps to Request to Track” setting in your iOS settings (precise directions may be different on different iOS versions).

 

On iOS version 13 and earlier only:

 

Go to Settings, select Privacy, select Advertising, and enable the “Limit Ad Tracking” setting.

 

To reset your Advertising Identifier on iOS, open “Settings”, tap “Privacy”, tap “Advertising”, and tap “Reset Advertising Identifier”. 

 

For Android Devices: 

 

Open the Settings app, then Google Settings app, select Ads then “Reset advertising ID” and choose “Opt-out of Ads Personalisation”. 

 

Note: The actual opt-out instructions for each device may differ slightly depending on the operating system and updates. Also, after choosing to opt-out via any of the mechanisms described, if you use a different device or a different browser, or if you delete browser cookies, you may need to repeat the opt-out steps for that particular device or browser. In addition, if you block cookies on your browser or if third-party cookies are blocked by default, some of the opt-out tools above may not function.

 

        4. Other methods

 

You may also opt-out of the collection of data across unaffiliated sites over time for interest-based advertising and other purposes from companies participating in the Digital Advertising Alliance Consumer Choice Page at www.aboutads.info/choices and from members of the Network Advertising Initiative via www.networkadvertising.org/choices 

 

If you have any questions about your internet choices, please contact us at privacy@blis.com or for other methods please see “How to contact us”.

 

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us:

 

By letter: Blis Privacy Team, Blis Global Ltd, 85 Great Portland Street, London W1W 7LT, UK.

 

By email: privacy@blis.com 

 

You can also contact our DPO (data protection officer) directly at dpo@blis.com.

You have the right to lodge any complaints you have regarding our processing of your personal data with a regulatory authority such as the Information Commissioner’s Office (the UK data protection regulator) or you can contact your local data protection regulator. 

 

You can contact the ICO as follows:

 

Phone: 0303 123 1113

 

Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow SK9 5AF

Website: www.ico.org.uk

  

Updates to this policy

This Privacy Policy may be updated from time to time.  We will post a prominent notice on our website notifying users when it is updated. 

 

Effective date of the recent update of this Privacy Notice

 

25 March 2021

 

Blis’s previous Privacy Policies can be found here:

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