Website Privacy Notice
Last updated May 16, 2019
We have prepared this Privacy Notice to explain how, why, and when we collect data from you on our website. Please note that this Privacy Notice only applies to data that we collect when you visit an Frank website. To learn what data we collect when you visit the websites of our advertiser clients, please visit the Frank Service Privacy Notice.
1. About Frank Services
Frank provides targeted advertising and marketing services for our advertiser clients (“Advertisers“). We use Frank website to describe our services to potential advertiser clients, to provide our advertising services to these clients, and to support clients and partners as they seek to deploy and manage their campaigns with us over time.
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 our Services 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 and how we use it
We may collect the following categories of information on our website and use them for the purposes explained below.
- Contact Information: You may provide us with your name, address, phone number and email when you set up an account with us and you may provide your name, title, company, email, address and/or phone number when you sign up for an event with us online or download content from our site.
- Account Information: If you open an account, we will collect your username and a password and other information necessary to open and access your account.
- Customer Service Information: Information you may provide to customer service including your email address for purposes of responding to your inquiries and survey responses.
- Financial Information: Credit card number or other payment account information. This information is collected directly by our payments processor and not stored at Frank.
- Activity on our Digital Properties: This is data about your browsing activity on our websites. For example, which pages you visited and when, what items were clicked on a page, how much time was spent on a page.
- Device and browser information: This is technical information about the device or browser you use to access our 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 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 third party Advertising Platforms choose to share with us – for example, 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 Advertising Partners to synchronize their unique, pseudonymous identifiers to our own to enable us to more accurately recognise a particular unique browser or device and the advertising interests associated with it.
- Third party information: We may collect additional information about you from other third party sources where they have the rights to share such information and we have the rights to use it, for example, demographic data or title and employer data. We use this data to better understand our customers and to better market our services to you.
3. How we use the data we collect
We use this data to operate our business and provide services to you as well to personalize Frank advertising and marketing materials we may serve to you:
- Providing our Frank Services and Customer Support: For example, to monitor usage of features, manage campaigns, and log data for audit purposes. We may contact you when you ask us for support or when it appears to us that you might need support, and to maintain records of our communications with you for future reference.
- Invoice you and collect fees for services we have provided.
Troubleshoot Problems: To monitor and fix our website performance, for example if the site is slow, not loading properly, or to investigate aberrations in performance of our services.
- Prevent potential fraud and enforce our Terms of Service. To prevent fraud on our site or through the use of our services; 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).
- Customize, measure and improve our website and services: To provide customized content and to measure which content is most helpful (or unhelpful) to our customers, which helps improve our website and our services. For example, if we notice higher visits to certain Help Center articles or receive higher Customer Support tickets for specific issues, we can improve our support materials or identify areas where we can make our product better for our customers.
- Contact you about your account or our services, including to market our services to you: We may use your contact information to contact you about your account, for example, in relation to performance of your campaigns, to follow up on billing issues, or to tell you about new services we are offering. When we can legally do so, we may augment the information you give us in order to contact you by phone or even snail mail. You can opt out of receiving emails by unsubscribing through the link at the bottom of our emails or by contacting us. You can let us know if you don’t want to receive phone calls or other marketing materials from us by contacting firstname.lastname@example.org.
- Deliver Targeted Marketing: We use our own Frank services to generate and route marketing leads for our business and to deliver targeted marketing to you. For more information about how our services work, please see our Services Privacy Notice.
- Targeting: Selecting ads that are more likely to be relevant to you on other sites around the net 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 an Frank product on another site related to a whitepaper you downloaded from one of our websites (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 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 led to a potential customer becoming a paying customer.
- Reporting: Analyze how our ads are performing and gain insights into our customers. Reporting may include ad metrics such as impressions, clicks, and conversions. This helps us identify ads that are useful to our customers and demonstrate Frank’s value, and relatedly, helps us identify an ad that is not performing well (customers aren’t clicking on it), we will be able to see that data and update our ad or ad campaign strategy.
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).
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.
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.
5. Data Sharing
We may disclose information about you:
- 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 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.
- With other advertising companies in the digital advertising ecosystem. We share 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.
- 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).
- Finally, we may disclose aggregated, anonymized information to third parties, for example, when we conduct industry wide surveys to publish benchmark reports, or to include statistics when collaborating with researchers or other companies on industry white papers.
6. Cookies and related technologies
We may also drop cookies from our Advertising Partners for the purposes described above. For example, we drop cookies for the exchanges through which we buy ads, which helps us measure viewability (meaning whether the ad was actually served and seen) and prevent fraud.
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:
- 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”
Please note: 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.
You can request that we stop email marketing to you. You can use the unsubscribe link in our marketing emails or contact email@example.com.
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.
Frank 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.