Service Privacy Notice
Effective as of May 16, 2019
We have prepared this Privacy Notice to explain how, why, and when we collect data from you to provide targeted advertising services for our clients, and your rights in respect of this data. If you have additional questions, you can contact us (see the “Contact Us” section below). Please note that this Privacy Notice does not apply to data we collect when you visit a Frank website. To learn what data we collect when you visit our website, please visit the Frank Website Privacy Notice.
1. About Frank’s Services
Frank provides targeted advertising and marketing services for our advertiser clients (“Advertisers”).
Our products help show our customers’ ads to the people that are most likely to find them interesting. We aim to make advertising more useful and relevant to consumers by showing ads that are best tied to their specific interests. And we show these ads on websites which rely on advertising revenue to support the content we all consume each day, often for free.
To do this, when you visit a website or a mobile application operated by an Advertiser (collectively “Digital Properties”) or we serve you an ad on behalf of an Advertiser on a third party site, we may collect some or all of the data described in this Privacy Notice. Our platform uses that data, as well as other data described below, to help Advertisers provide ads to you that are more relevant to you.
For example, let’s say you browsed hansapost.ee for some products that you need but didn’t yet purchase anything. Then we may later show ads for hansapost.ee about the latest offers or sales that are available on their website to encourage you to come back and make a purchase. If you gave hansapost.ee your email address for marketing purposes, we may also serve their ads to you through other channels, such as by email.
2. What data we collect
We collect the following categories of information for the purposes explained below.
- Activity on Advertisers’ Digital Properties: This is data about your browsing activity on the Advertiser’s website or app. For example, which pages you visited and when, what items were clicked on a page, how much time was spent on a page, whether you downloaded a white paper on a business to business website, what items you placed into your online shopping cart, what products were purchased and how much was paid.
- Device and browser information: This is technical information about the device or browser you use to access the Advertiser’s website. For example, your device’s IP address, cookie string data, operating system, and (in the case of mobile devices) your device type and mobile device’s unique identifier such as the Apple IDFA or Android Advertising ID.
- Ad data: This is data about the online ads we have served (or attempted to serve) to you. It includes things like how many times an ad has been served to you, what page the ad appeared on, and whether you clicked on or otherwise interacted with the ad.
- Data from Advertising Partners: This is data that we lawfully receive from other digital advertising companies that we work with (“Advertising Partners”) to help us deliver ads to you and recognize you across browsers and devices. This may include pseudonymous advertiser identifiers (meaning identifiers that help identify your browser or device, but do not directly identify you as a person) which some Advertisers or other third party Advertising Platforms choose to share with us – for example, your “Customer ID” with an Advertiser, an identifier (such as a cookie) associated with a hashed version of your email address, or demographic data such as age range. We may work with our Advertisers and Advertising Partners to synchronize their unique, anonymous identifiers to our own to enable us to more accurately recognise a particular unique browser or device and the advertising interests associated with it.
- Email from Advertisers: Some Advertisers choose to share actual email addresses from their customers with us, so that (with the help of Advertising Partners) we can help the Advertiser serve targeted ads to customers. For example, if you have given ACME Soccer Ball Co. your email address, through our service, ACME Soccer Ball Co. may send you a promotional email for a soccer ball you looked at but did not purchase. Similarly if you provided your email to a software website when you downloaded a white paper, through our services the software company may send you a follow up email providing you with more information about the software company’s products or services. We use clear emails supplied by Advertisers only for the purpose of assisting that particular Advertiser with their own advertising efforts and, in some cases, so we can report performance data back to the Advertiser’s CRM / reporting system. – we do not share email addresses with other third parties for their advertising purposes.
- Hashed email addresses: If an Advertiser allows, we may collect hashed versions of the emails that are entered on that Advertiser’s site. Hashing is a “one-way function” that effectively pseudonymizes email addresses. For instance, when email@example.com is run through a typical hashing function, it becomes the following string of code: 0F0B7B1A1A7E8BDBBC6AA545F8CCD6F83671B32479271BFCB6CC8498912058D5.
- We take this step to de-identify data and protect email addresses, while being able to use an identifier to better connect devices and browsers. We describe how this helps us better provide our services in “How we use the data we collect” below.
3. How we use the data we collect
We use this data to help our Advertisers identify and serve ads to you that are more relevant to you. We also use this data to operate, improve and enhance our services including enhancing the data points we or our Advertising Partners have about a particular user, browser, or device to serve the most relevant ads to you and, in turn, improve performance of an Advertiser’s ad campaigns. Specifically, we use this data for:
- Targeting: Selecting ads that are more likely to be relevant to you based on the interests previously associated with your device and the time of day you may be most interested in viewing these specific ads. For example, we may show you ads for your favorite shopping site (or similar sites we think you may like) during lunch or commute hours.
- Frequency capping: Making sure that you don’t see the same ad too many times.
- Sequencing: If you are being served a sequence of ads, making sure we show you the right ad next in the sequence.
- Attribution: Monitoring when, where, and at what price we served certain ads on behalf of an Advertiser so that we can measure our influence on the marketing result of the Advertiser’s campaigns and overall marketing strategy. For example, being able to measure if a certain ad campaign (the ads shown and to whom they were shown) actually sold more soccer balls for ACME Soccer Ball Co.
- Reporting: Providing Advertisers insights into how their ads are performing and gain insights into their customers. Reporting may include ad metrics such as impressions, clicks, and conversions (however the Advertiser may define a “conversion,” for example, a sale or a white paper download). For example, if an ad is not performing well (customers aren’t clicking on it), the Advertiser will be able to see that data and update the ad (perhaps with a better deal!). With respect to specific cookie data, we limit reporting to cookie activity on the specific Advertiser’s website and which ads were shown whether there was engagement with those ads.
Data is reported in the aggregate for the campaign and, at times, at the cookie level. For some customers, ad metrics are reported at the domain level at the contact level. For some customers, ad metrics such as impressions, clicks, conversions etc. are aggregated at the domain level (the domain representing the company/account the Advertiser wanted to target) as well as at the contact level (the individual to whom the ad is being targeted) represented with an email address that was initially provided by the Advertiser.
4. Our legal basis for processing personal data
We provide the representations and information in this Section 4 in compliance with European privacy laws, in particular the European General Data Protection Regulation (GDPR). Our legal basis for collecting and using the personal data described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal data from you where the processing is in our legitimate business interests to, for example, administer our platforms and services and fulfil our contractual obligations as a service provider.
In some cases we may collect and process personal data based on consent. To the extent our clients and Advertising Partners need to collect and share, or allow us to facilitate collection and sharing of personal data to enable our services, it is the responsibility of these parties to provide necessary privacy notices and obtain required consent(s).
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, including if you would like to better understand how our legitimate interests to process your data are balanced against your data protection rights and freedoms, then please contact us using the contact details provided under the “Contact us” heading below.
Finally, please note that when an Advertiser sends us email addresses to be used for targeted advertising purposes, we process that data only on behalf of the relevant Advertiser as its processor. If you have any questions about the use of this data by an Advertiser for the purpose of serving targeted advertising to you, please contact the relevant Advertiser.
5. Data Sharing
We may disclose information about you:
- With an Advertiser whose Digital Properties you have visited: We may share information about how you have interacted with that Advertiser’s Digital Properties or its Ads.
- With our service providers: We contract with companies who help with parts of our business operations (e.g., for example, website and data hosting, fraud prevention, viewability reporting, data hygiene, marketing, and email delivery), as well as billing, collections, tech, customer and operational support.
- With service providers to our Advertisers: Our Advertisers may contract with companies who handle data (such as managing Advertisers’ customer lists) for them.
- With our subsidiaries and related companies: But they will only process your data for the purposes already explained in this Privacy Notice. We are a part of BITE Corporation and All Media Baltics and the following companies belong to our group: All Media Eesti AS, TV Play Baltics AS, All Media Digital OÜ, Mediainvest Holding AS, Buduaar Meedia OÜ.
- In connection with legal proceedings: When we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of Frank, our Advertisers or any other third party.
- To Comply with legal process: To satisfy in good faith any applicable law, legal process, or proper governmental request, such as to respond to a subpoena (whether civil or criminal) or similar process.
- To Investigate Wrongdoing and Protect Ourselves or Third Parties: To enforce our Terms of Service or other policies or investigate any potential violation of those Terms and policies, any potential violation of the law, or to protect ourselves, our customers, or any third party from any potential harm (whether tangible or intangible).
- In connection with a sale of our business: If a third party acquires some or all of our business or assets, we may disclose your information in connection with the sale (including during due diligence in preparation for the sale).
We also share hashed email addresses (or other pseudonymous identifiers associated with those hashes), technical data that we collect about your browsing habits and your device (such as data relating to our cookies, tracking pixels and similar technologies) with other advertising companies in the digital advertising ecosystem. This enables them and us to better target ads to you.
6. Cookies and related technologies
Tracking cookies enable us to identify your device when you move between different Digital Properties, so that we can serve targeted advertising to you.
We may also drop cookies from our Advertising Partners for the purposes described above. The Advertising Partner cookies dropped will vary depending on who the Advertisers are.
7. Your choices and opting-out
We recognize how important your online privacy is to you, so we offer the following options for controlling the targeted ads you receive and how we use your data:
- In some cases we may link multiple browsers or devices to you. If you opt out of on a browser or device and we have more linked to you, we will extend your opt out decision to the other linked browsers and devices. Since we only link users across browsers on devices in some conditions, there could be cases where you are still being tracked in a different browser or device we have not linked, and where we are treating you as a different user.
- How to delete cookies? You can choose whether you want to agree to accept cookies or not. If you want to know when your computer receives a cookie, you can set your browser to notify you about it. This way you have the opportunity to accept or reject a cookie. Visit http://aboutcookies.org/ if you would like to get know how to set this option. Please be aware that changes in your web browser, involving disabling the option for cookies, may prevent parts of our Website, like login and play, from functioning properly. For more detailed information about cookies, you can visit www.pts.se/cookies.
Please note that when using the ad industry opt-out tools described above:
- If you opt-out your browser may still send us data, for example your IP address. However, we isolate this data and do not use it other than for accounting and, in some cases, for fraud prevention. If you have opted-out on that browser, we do not use this data to personalize ads or to track you.
- If you use multiple browsers or devices we will additionally opt out those we have linked to you. Since we may not have all your browsers or devices connected back to your user, you may need to execute this opt out on each browser or device.
- Other ad companies’ opt-outs may function differently than our opt-out.
- To opt out of receiving targeted ads that are based on your behavior across different mobile applications follow the below instructions, for iOS and Android devices:
- iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting
- For Android devices with OS 2.2 or higher and Google Play Services version 4.0 or higher: Open your Google Settings app > Ads > Enable “Opt out of interest-based advertising”
Opting out will not prevent you from seeing ads, but those ads will likely be less relevant because they won’t be tailored to your interests. The ads might, for instance, be randomly generated or based on the web page you are visiting.
8. Data retention
We retain personal data we collect directly for targeting purposes for no more than 6 months, after which time we employ measures to delete it. However for identifiable data that we hold on behalf of an Advertiser such as their email address list, we will retain until the Advertiser asks us to delete it.
Personal data collected for other purposes is held no longer than necessary for our business purposes but is anonymized. For example, we retain anonymized impression and click data to ensure we can meet auditing requirements related to services provided or to meet legal requirements.
We apply technical, administrative and organizational security measures to protect the data we collect against accidental or unlawful destruction and loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against other unlawful forms of processing.
10. International transfers
11. Additional data protection rights
You have the following rights concerning your personal data:
- to access information held about you. You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed by us, and, where that is the case, access to the personal data and information provided by law;
- to rectification of inaccurate personal data concerning you;
- to erasure of personal data, for example if data are no longer necessary or if the processing of your data is based on your consent, but you have withdrawn your consent, and there is no other legal ground for the processing;
- to restriction of processing, for example, when we analyse, whether you have the right to the data erasure;
- to receive the personal data concerning you, which you have provided us and which we are processing under your consent or under contract and by automated means, in a commonly used and machine-readable format and you have the right to transmit those data to another controller (data portability);
- to object to processing of your personal information, which is based on legitimate interests, including profiling, unless we demonstrate compelling legitimate grounds for the processing; or right to object for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing;
- to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
- not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly affects you.
12. Changes to this Privacy Notice
All future changes that we make in our Privacy Notice will be announced on this page, see above. When appropriate, you will also be notified about the changes via email, in accordance with our General Terms and Conditions. All changes take effect immediately excluding already existing subscribers, for whom the changes apply 30 days after they are announced, unless stated otherwise.
13. Contact us about questions or concerns
You have the right to lodge a complaint with a supervisory authority (www.aki.ee) if you consider that the processing of your personal data infringes your rights or the law.
has appointed an internal data protection officer for you to contact if you have any questions or concerns about our personal data policies or practices. The data protection officer´s contact information are as follows:
Peterburi tee 81, 11415 Tallinn, Estonia, referred to “Data protection officer”, email: firstname.lastname@example.org.
14. The General Terms and Conditions
Visit our General Terms and Conditions.