PLATFORM PRIVACY POLICY
Improve Digital Platform Privacy Notice
We at Azerion Technology B.V. (“Improve Digital SSP”, “Improve Digital”, “we”, “us” or “our”) respect your privacy and recognize the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process your personal data.
Improve Digital is an advertising technology company that provides a variety of online advertising-related services. Together, we call this technology our “Platform”. This Platform helps our clients to monetize their advertising spaces, buy and sell online ads through online programmatic auctions and classic deals together we call this “Platform Services or Services”. Throughout this Policy we refer to our clients that sell advertisement space as “Publishers.” Publishers own or operate the “Digital Properties” (websites, apps, Smart TVs etc.) you may use or visit. We refer to clients that buy advertisement spaces (e.g. advertisers) as Demand Side Platforms (“DSPs”). Our technology helps our clients to serve advertisements that you see online such as in web pages, apps, and video content.
The purpose of this privacy notice (“Privacy Notice”) is to inform individuals (“end users or “you”) about why and how we process your personal data (that is any information that can be linked or attributed to you, “Personal Data”) when you visit the digital properties of the publishers using our technology (“Platform”) (“Platform”) which helps our clients to monetize their advertising spaces, buy and sell online ads through online programmatic auctions and classic deals. This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing.
This Privacy Notice applies whenever you visit the Digital Properties using our Platform or any of other services, all of which together we refer to as “Services“.
GENERAL INFORMATION
In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you use our Services. For specific information with more details about our processing activities, please see the service specific information below.
1. Who is responsible for the processing of your Personal Data
We, Azerion Technology B.V., based at Beechavenue 182, 1119 PE Schiphol-Rijk, The Netherlands are responsible (“the data controller”) for the processing of your Personal Data when we show you ads when you visit Digital Properties. Therewithal, we carry out these Services on behalf of or jointly with our Publishers.
2. What types of Personal Data do we process and how do we collect it?
When you visit the Digital Properties of the publishers using our technology,, as further explained, we collect, use, store and transfer different kinds of Personal Data via cookies, beacons, pixels, tags, and other non-cookie technologies. For example, when you visit a website or app, the publisher sends us a request to show you an ad. As a general principle, we do not collect and do not ask you to provide any “special categories of Personal Data”, which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation.
The information we collect depends on which of our Services you use and how you use them. We process the following types of your Personal Data.
2.1. Personal Data we collect
When you visit the Digital Properties of the publishers using our technology, we collect certain information about your visit. For example, when you visit a website or app, the publisher sends us a request to show you an ad. We collect certain information about ad inventory, you and your device to help inform our Demand Side Partner’s decision to serve an ad. We also collect information through Demand Side Partners that use our Services as well as from other third parties.:
- Browser and device information: such as the type and version of the browser or device(screen dimensions, device brand and model), internet service information (e.g.internet service provider used by you), certain browser settings, like language, time, and time zone, and the IP address.
- Unique Online Identifiers: if available, identifiers that enable us to recognize a browser or device across different content, such as mobile ad identifiers, device IDs, and cookie IDs, Apple IDFA and Android Advertising ID.
- Location: precise geographic location, if available from the device,and provided by the publishers, and/or imprecise location as derived from IP address or provided by the publisher.
- Content information: information about activity on the digital content visited, such as pages loaded, searches, or links clicked.
- Ad information: information about the ads that were shown, such as what type of ad, where in the page they appeared, and whether you interacted with them.
2.3. Personal Data we collect from third parties
In certain scenarios, we will also obtain your Personal Data from third parties, in strict compliance with applicable data protection laws and regulations. Your Personal Data are provided by the following third parties, including:
- Key Values: If the publisher decide to share us, key values about you (e.g. age, gender)
- Interest Segments (e.g. interest information reflects your interests as may be derived from your behavior, such as your internet activity or your purchase history)
- Other information shared in connection with this data.
To learn more about which data is processed, please see the section with service specific information below.
3. Do we collect data from minors?
Our services are intended to be appropriate for general audiences. Therefore, we do not intentionally collect and/or categorize personal information from children. In the event that we learn that we have collected personal data from a user under 16 years of age within the scope of the Services explained in this Privacy Notice, we will delete that data as quickly as possible. If you believe that a user might be under the age of 16, please contact our support team.
Improve Digital does not engage in activities that require parental notice or consent under the Children’s Online Privacy Protection Act (COPPA). As mentioned above we rely on the data that we receive from publishers therefore if a publisher sent us the COPPA flag, we take all the necessary actions accordingly. If you believe that Improve Digital has inadvertently collected information from a child under 16 that is subject to parental notice and consent under COPPA, please contact Improve Digital using the contact information below to request deletion of the information. We will take all reasonable measures to promptly delete all personal data from our records.
4. For what purpose do we process your data?
When we use and allow our clients to use the information we collect for the following purposes,
4.1. Provision and improvement of our Services
- to provide our advertising services
- to enable the automated auction (bidding process) of ad inventory of our clients and to record views and clicks on ads and to show end users accurate advertisements in terms of technical details (size of the ad slot, type of the ad etc)
- to facilitate navigation, display information more effectively, and to personalize your experience while using the ad services, as well as auditing, researching, and analyzing information to provide, protect, manage, and improve our ad services, develop new services, and ensure that our technologies function properly
- To calculate usage levels of the ad services, help diagnose server problems, and administer the ad services
4.2. Personalization of your experience
- to infer end users’ likely commercial interests based on their activities across websites and devices over time, including to build interest-based advertising segments or audiences, as well as to supplement the information we collect with additional information we receive from third parties, such as third-party advertising segments or audiences, to allow us to customize and more effectively tailor the ads we display to end users and to optimize the display of ads (including limiting exposure to less relevant ads)
- to serve targeted ads to an end user on behalf of our clients based on the end user’s activity across websites, mobile apps, and other digital properties over time and information regarding an end user’s inferred commercial interests. We also deliver location-based advertising, services, and content in real-time through the detection of approximate geolocation
4.3. Marketing, analytics and reporting
- to analyze ad performance, such as tracking views of ads,click-through rates to websites or app stores and/or installs of apps that have been advertised as well as to understand usage of our services across all our group companies to support strategy and growth
- to provide information and reports to buyers about when and how end users have been exposed to their ads, clicked on their ads, or visited their digital property to account monetary transactions
4.4. Prevention of fraud and illegal activity
- to identify invalid ad impressions, clicks, installs, or ad queries
- to protect us and our publisher clients from fraudulent behavior, and protect the security of the ad Services
4.5. Compliance with our legal or regulatory obligations
- to comply with the applicable laws (such as obtaining your consent, if you are in a consent jurisdiction -EEA or US-), including laws outside an end user’s country of residence
- to comply with subpoenas, warrants, or other legal process
- to respond to requests from public and government authorities including public and government authorities outside an end user’s country of residence
- to enforce our terms and conditions
- to protect our operations or those of any of our affiliates
- to protect our rights, privacy, safety or property, and/or that of our affiliates, end users, or others
- to allow us to pursue available remedies or limit the damages that we may sustain
Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data.
5. Do we engage in profiling activities?
If you consent to this via the consent management platform of the Digital Property, with instruction of the publisher we allow our third party partners to conduct profiling activities to show you ads that are more relevant to you. You can also go to your privacy settings to review and amend your privacy choices related to this type of processing at any time.
6. On which legal basis do we process your Personal Data?
We process your Personal Data for the purposes described in this Privacy Notice, based on the following legal grounds:
- Your consent: We process your Personal Data if you have provided your consent via a consent management platform available in the publisher’s page for a specific purpose. For example, when you visit a Digital Property for the first time, your consent is asked for the data processing in the context of personalized advertising. You have the right to withdraw your consent at any time, for example by changing your privacy settings. Please note that this will not affect any processing carried out before you withdraw your consent.
- Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations. for example, for tax and accounting purposes or legal disputes.
- Legitimate interests: We also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we process your Personal Data for fraud protection and security or transfer of your personal data across all our group companies for administrative transfers as well as to determine the size of the user base of our services. We kindly remind you that you have the right to object to such processing of personal data.
Please see for additional information the section with service specific information below.
7. With whom do we share your Personal Data?
We will not disclose your Personal Data to any party who is not authorized to process them. To manage our Services, we will share your Personal Data internally with members of our responsible departments and technical support and in each case only if access to your Personal Data is necessary for the performance of their roles.
Moreover, and only when necessary to fulfill the purposes mentioned above, we disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our Services. Often, these are vendors working on behalf of the advertiser to measure ad performance or prevent ad fraud or other purposes. This Policy does not apply to those parties, and Improve Digital is not responsible for their collection or use of information.
- Customers and their service providers: We sometimes give our customers personal data in the form of logs and other types of records and reporting related to their use of our platform.
- Demand side partners: Demand partners are companies that integrate with our Platform in order to buy ad space from publishers working with us. To facilitate these ad transactions, we transmit personal data in accordance with publishers’ instructions to demand partners so that they have information about the ad unit to be filled, and can choose whether to bid for the ad space and how much.
- Vendors and service providers: We use a variety of vendors and service providers as part of, and for the purposes of, providing our platform. These could include cloud storage and cloud computing services, or anti-fraud and security vendors. These vendors and service providers are subject to security and confidentiality restrictions to ensure their processing of the data is consistent with this policy
- External service providers: We share your Personal Data with external service providers who perform services on our behalf, like IT services, hosting and content delivery services, analytics services, data management services, video hosting service, and user notification services. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.
- Law enforcement, government authorities or courts: We disclose your Personal Data in the event that we reasonably suspect malicious activity or fake traffic or in response to lawful requests to public authorities, including law enforcement, government authorities, or courts.
- Affiliates and group companies: We share information with our affiliated companies, i.e. companies within our corporate family, which are also subject to this policy. We also share your personal data with our group companies which are responsible for internal analytics for the purposes of cross-product audience measurement. Where we share your personal data with our group companies, we have appropriate agreements (an intra-company data sharing agreement) in place to ensure that your personal data is processed in compliance.
- Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).
Please see the section with service specific information below for more information about the third parties we may share your data with. For instance, Improve Digital processes bid requests from and to Google advertising platforms – read more about their platform policy here. Furthermore, you can find the full list of third parties your Personal Data may be shared with at the end of this document.
8. Where will my Personal Data be processed?
In general, if you are accessing our Services from the European Union (EU) / the European Economic Area (EEA) your data is stored on servers within the EU / EEA. However, with regard to certain activities described in this Privacy Notice, your data may also be shared outside the EU / EEA. We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission’s standard data protection clauses (also known as Model Clauses) to provide safeguards for your Personal Data.
For further information on, or to receive a copy of, the adequate safeguards adopted by us for the international transfer of your Personal Data, please contact us by email at dpo@azerion.com. We will process any request in line with any local laws and our policies and procedures.
9. How do we protect your Personal Data?
We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.
10. How long do we store your Personal Data?
We will not retain your Personal Data longer than necessary to fulfill the purposes for which the data was collected or to fulfill our legal obligations or necessary for the establishment, exercise of defence of legal claims or resolving disputes. Afterwards, we will delete or anonymize your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available above.
You may find our cookies retention period as below.
| Name | Placed by | Reason | How long |
| tuuid | Improve Digital | To enable bidding process | 90 days |
| tuuid_lu | Improve Digital | To enable bidding process | 90 days |
| pct | Improve Digital | Tracks clicks to measure conversions | 90 days |
| pvt | Improve Digital | Tracks views to measure conversions | 90 days |
| ih | Improve Digital | To limit number of advertisements you see (frequency capping) | 90 days |
| fh | Improve Digital | Impression counter | Till the end of day |
| pxl | Improve Digital | Division by client into groups. | 90 days |
| um | Improve Digital | To enable bidding process | 90 days |
| umeh | Improve Digital | To enable bidding process | 90 days |
| sh | Improve Digital | To limit number of advertisements you see (frequency capping) | Kept for 1 session – does not set expiry date |
| ad | Improve Digital | Track views and clicks to measure conversions. | 90 days |
11. What are your rights in respect of your Personal Data?
To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:
- Access the Personal Data we hold about you, including information such as, for example, the source and categories of data, the processing purposes, the recipients (or categories thereof) and the respective retention period.
- Request an update or correction of your Personal Data so that it is always accurate.
- Receive your Personal Data in a structured, commonly used and machine-readable format, including the right to transfer your Personal Data to another data controller.
- Request the deletion of your Personal Data if you believe that retention is no longer necessary for the purposes indicated above.
- Restrict the processing of your Personal Data for example, if you have contested the accuracy of your Personal Data, and for a period of time that is sufficient to allow us to verify its accuracy.
- Withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the lawfulness of data processing based on consent granted prior to its withdrawal.
- Object to the processing on specific grounds relating to your particular situation, in the event and to the extent that we process your Personal Data based on our legitimate interests. In such cases we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. You also have the right to object where we are processing your Personal Data for profiling. In that case, we will stop processing your Personal Data for such purposes.
You can exercise these rights by sending a request to the contact details set out below, providing your name, your email address as well as a description of your request.
If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example, the Autoriteit Persoonsgegevens in the Netherlands.
12. How can you contact us?
If you have any queries about this Privacy Notice or how we use your Personal Data, please contact our customer support via our Website or our Data Protection Officer via e-mail to dpo@azerion.com.
13. How often do we update this Privacy Notice?
We regularly review and update this Privacy Notice. When there is an important change that will have a relevant impact on the processing of your Personal Data, we will inform you by email if we have your email address. If we do not have your email address, for example because you did not create an account, we will inform you with a banner on our Website.
This Privacy Notice was last updated on 17 May 2023.
14. Additional Information for California Residents
This section for California residents supplements the information provided in this Privacy Notice and applies solely to players, and others who reside in the State of California. We provide this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and the regulations issued under it; accordingly, this section addresses the specific requirements of the CCPA and should be read together with this Privacy Notice.
We do not sell your Personal Data. However, we may share or provide access to each of the categories of Personal Data we collect as necessary for our business purposes. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. In particular, we have collected the following categories of personal information (envisaged by the CCPA) from consumers within the last twelve (12) months:
Category A – Identifiers (such as your device identifier, demographic information -such as your country, your username, email address, any information you may choose to provide -such as your age or your language-)
Category B- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D – Commercial information (such as purchase history)
Category F – Internet or other similar network activity (such as your interaction with our ads, your IP address)
Category G – Geolocation data
Category H – Audio, electronic, visual, thermal, olfactory, or similar information
The CCPA provides consumers (California residents) with specific rights regarding their personal information.
You have the right to access specific information i.e. you may request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.
You have the right to know. Under the CCPA you have the right to request that we disclose to you what Personal Data we process about you.
You have the right to deletion which means that you may request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Under the CCPA, you have the right to opt out of any sale of your personal data. Please note that your right to opt out does not apply to our sharing of personal data with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal data only for that function.
Finally, you have a right to not be discriminated against for exercising your rights under the CCPA.
You can exercise these rights by sending a request to the contact details set out above, providing your name, your email address as well as a description of your request.
Additional Information for Brazil Residents
Under the Brazilian General Data Protection Law (the “LGPD”), you have the right to access, rectify, port, erase, and confirm that we process your data. If you have given consent about processing your data, you have the right to withdraw consent anytime.
SERVICE SPECIFIC INFORMATION
In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed. For general information about data processes that apply, please see above.
Hosting
Improve Digital is hosted by external companies to provide its Services to its clients. For example, every time there is an ad request from a publisher, or you make a request, for example by clicking on a link on our platform, the information allowing this request (e.g., device information and information on requested content) as well as online identifiers (your IP address) will be sent to the external servers. This data is used to show you the content you requested in a faster way. We process this data on the basis of our legitimate interest, to provide and improve our service and ensure its functionality.
Customer service
If you contact us for customer support by using our email address, we will process your email address, and the content of your request in order to provide you with support. The request history helps us to solve a newer request and is stored to defend against possible future legal claims. We process this data on the basis of performance of contract to provide you with customer support, and store this data on the basis of our legitimate interest, to improve our services, and to be able to defend possible future legal claims.
Advertising
Our Platform helps our clients to monetize their advertising spaces, buy and sell online ads through programmatic advertising. In order to show you personalised ads and only if you have provided your consent at Publisher side, we will share your Personal Data (your IP address, advertising identifiers and the information that you have provided your consent for personalised ads) through our advertising platform provider with third-party advertisers and ad networks. You can adjust your preferences at any time in your privacy settings. If you choose not to receive personalised ads at all, we will still show you ads, but they may not reflect your interests as those ads will be content specific and not user specific. We also use this information to measure how effective our Services are.
Data management platform
Based on your consent, upon Publisher’s instruction we allow data management platforms to process your Personal Data to show you relevant ads, based on your preferences and interests. For this purpose, your device information and online identifiers are collected and sent to an external data management provider.
Third Parties List of Improve Digital
This list includes information about the third parties that your data may be shared with, in the way described in our Privacy Notice.
Under “Category”, you will find information about the group of recipient/activity your Personal Data is processed for, such as DSPs. The “Third party” indicates what third party specifically processes your data for the respective category. “Retention time” provides information about the amount of time your data is kept for by that party. The information that is included in this column is based on the information we have received from the third parties. For the most up to date information about the retention times, we refer to the privacy notice of the respective third party, which we have included in this list. In the third-party privacy notices, you will furthermore find information on how they collect and process your personal data.