What does ReklamStore’s Platform do?
ReklamStore owns and operates a technology platform (the “Platform”) which collects, organizes, maintains and distributes pseudonymized profile information (the “Platform Data”). Platform Data is collected from a variety of online sources, such as website publishers, and also offline data sources such as market research companies.
What is the purpose of ReklamStore’s Platform?
ReklamStore’s Platform allows ReklamStore’s clients to buy, sell & distribute Platform Data for the specific purposes of:
- Facilitating targeted advertising
- Facilitating the delivery of targeted or customized content to website visitors
- Supporting an advertising funded internet
- Providing aggregated reporting to data providers and advertisers
- Using aggregated data for internal reporting, reporting industry trends & market research
ReklamStore’s clients and partners are contractually obliged to have adequate privacy policies which also facilitate these purposes.
What information does ReklamStore Platform hold?
The Platform Data that is sent to us by our partners includes aggregated pseudonymized profile information, and data that is sent via the HTTP header including IP address, cookie information, date and time, URLs, operating system, and browser version.
The pseudonymized profile information is aggregated and then organized in to audience segments that fall into the categories of interest data (e.g., interest in sports, news, fashion and associated sub-categories etc.), demographic data (e.g., age, gender, employment sector, income band etc.) and purchase intent data (e.g. in-market for electronics, financial products, online fashion etc.).
ReklamStore’s Platform is not designed to collect any Personal Data such as full name, email address, physical address or sensitive Personal Data such as social security number etc. In addition, our clients and partners are contractually prohibited from transmitting any data which can directly identify an individual to ReklamStore. We do not intentionally collect data that we consider to be sensitive.
The definition of Sensitive Data within the EU (as defined by Article 9.1 of the General Data protection Regulation or “GDPR”) includes:
- Racial or ethnic origin
- Political opinions
- Religious or philosophical beliefs
- Trade union membership
- Genetic or biometric data
- Personal health data
- Information concerning a person’s sex life or sexual orientation·
In the US and Asia, ReklamStore does receive the following data from some of our data providers:
- Inferred racial or ethnic origin
- Inferred political opinions
- Inferred religious or philosophical beliefs
- ReklamStore does hold some non-sensitive data that is related to health or financial positions; lists of these segments can be found here and here.
- ReklamStore does not collect any data related to adult-oriented products or services such as alcohol, tobacco or firearms.
For information relating to our age data policies, please refer to the Protecting Children’s Data section of this policy under 4. Personal Rights for EU Data Subjects below.
What is ReklamStore Platform Data used for?
ReklamStore’s Platform is designed to enable manufacturers and brands to discover audiences who may have a preference for their advertising. The platform helps advertisers discover new audiences who have traits, preferences and interests which are similar to their existing customers or their desired audiences. ReklamStore’s Platform Data is useful to a number of different groups
- Internet Users will experience more relevant online advertising as a result of the services provided by the Platform. In addition, the operation of the Platform helps to support an advertising funded internet where many online publishers offer content free of charge to users. All Platform Data held by ReklamStore is in a pseudonymized form and includes no data that can identify specific individuals, e.g., no full name, address, email address, phone number, social security number, etc.
- Online Advertisers use the Platform to help them deliver advertising to relevant online audiences; discover new potential customers who have a preference for their products and services and to increase the efficiency of their advertising campaigns. Online advertisers can also use ReklamStore’s Platform to better understand their customers, and the recipients of their ad campaigns. For example, a beauty manufacturer may use ReklamStore data to discover new audiences who have similar interests and preferences to their existing audience base. Because the new aggregated audiences are similar to the Beauty Manufacturer’s existing customers, it increases the likelihood that any advertising shown to the new audiences may be of interest to them,
- Online Data Providers
- who deliver the Platform Data to ReklamStore find the Platform useful as they are able to gain greater insights in to their audiences, helping them to make more informed commercial decisions and to improve the value of the content and/or advertising on their own online properties. For example, a publisher in the auto vertical may discover, via the Platform, that these audiences are also interested in eating out and fitness. These insights may help the publisher decide what advertising to run on their website, or what additional content to create for their audiences.
- who are able to sell aggregated pseudonymized data to advertisers to better inform their advertising campaigns (see 1. above). This data is aggregated by groups of interest, preference or relevance on the ReklamStore Platform, e.g. males with a preference for organic food and sold in this form to advertisers who are looking to target people with this preference. The revenue earned from the sale of this data is provided to the Online Data Providers who typically use the funds to support the production of content and services on these online properties, many of which provide content and services free of charge to internet users.
- Market Research Agencies and other Offline Data Providers use their customer and survey data for traditional offline marketing campaigns (such as advertising through direct mail, printed media, outdoor advertising, TV & radio). These offline data providers find the Platform useful as it enables them to transfer the pseudonymized data in to the online environment so that their advertising clients can also use this interest and preference information when discovering new audiences for their advertising campaigns.
If, at any time, you would like to opt-out of participating in this type of online interest-based advertising where the adverts you see can be based on your pseudonymized profile information, please go to the opt-out section of this policy.
The Platform is operated by ReklamStore Pte Ltd, a Singapore registered company with company number 201223893Z and with the registered address of
ReklamStore Pte Ltd
12a Upper Circular Road
How does ReklamStore collect Platform Data?
We use online technologies such as Cookies, Pixel Tags, Server-to-Server Connections and Secure Data Transfers with our partners to collect and store Platform Data. We do not use “flash cookies” or any other embedded tracking mechanisms.
What is ReklamStore’s legal basis for collecting and processing Platform Data in the EEA?
For data from EU data subjects processed via the Platform, ReklamStore operates under the legitimate interest provisions of the GDPR.
For example, as you use the internet to discover content, products and services or to use a digital service for your daily life, advertising may be served to you that is relevant to your interests or lifestyle. Brands and Advertisers use data companies like ReklamStore to identify groups of people with particular interests or preferences so that they can serve advertising that is more relevant to them than other groups of people.
This legal basis of legitimate interest is founded on the position that the advertising funded internet delivers significant value to internet users as well as wider economies. The types of data segments utilized by ReklamStore (e.g., pseudonymous Personal Data) and the profiling activities are not generally considered high risk. ReklamStore adopts controls to ensure that the data collected is secured and won’t fall into the hands of an entity that might be in position to harm the human rights of data subjects. Thus, the balance of interests leans towards benefits generated for data subjects, publishers and advertisers outweigh the risks to the fundamental human rights of data subjects.
The only data that ReklamStore interacts with which are directly classified as Personal Data under the GDPR are IP addresses and cookie IDs. However, as all profile information is attached to pseudonymous Personal Data such as a cookie ID, all profile information is also considered to be Personal Data.
For ReklamStore to process your data, you may have consented to accept a cookie or to processing of your data from one of our partner data providers, thus, we also expect to handle data that has been collected and provided on the basis of consent.
If you have any further questions relating to ReklamStore’s legal basis for collecting and processing data in the European Economic Area, please contact us here.
How long does ReklamStore store Platform Data for?
- ReklamStore limits the number of days which aggregated information is available for targeted advertising to 120 days.
- All user level data is deleted after 13-months.
- The only data that ReklamStore retains for longer than 13-months is in aggregated form and to support Statistical Data Modelling and Analysis: (e.g., how many profiles of males were active in the ReklamStore Platform in the UK in December 2015) We hold these reports indefinitely to help us understand the evolution of the business, to conduct commercial analysis and make business decisions, although we take care to ensure that none of the information within the reports may be used to identify an actual person.
What Platform Data information is shared with third parties?
ReklamStore shares Platform Data with technology platform partners who provide online advertising services to marketers, advertisers and online publishers. For a full list of the organizations that receive Platform Data from ReklamStore directly, please refer to ReklamStore’s demand side integration list here. We will endeavor to keep this list updated on a regular basis as our partners may change from time to time.
Reporting is also an integral part of ReklamStore’s business. Under contract, our clients and data providers receive periodic operational reports for performance tracking and billing and auditing. We also generate reports that provide insights on the popularity and usage of the aggregated data, such as the number of data subjects that appear in a segment, in aggregate. The reports are prepared using aggregated Platform Data and contain only pseudonymized data.
The aggregated Platform Data may be shared with authorized employees, independent contractors, consultants and subsidiaries. User level Platform Data is only made available to full time employees in our technology team, who need access to execute their job requirements, on a limited access basis, and in line with our Data Minimization Policy (ReklamStore Company Policy designed to protect the individual rights of data subjects or users and to ensure that employees understand their obligations with respect to user level data).
We may also use the services of third-party service providers for cloud data storage, analysis, and processing facilities and to provide operational or other support services. The Platform Data is shared only to enable these entities to perform professional and technical functions in relation to ReklamStore’s business. These entities are subject to confidentiality restrictions and are not authorized to use, access or transform the Platform Data for any purpose other than providing their services to ReklamStore.
We may be required to share Platform Data and information with regulatory authorities, government agencies, and law enforcement officials, as permitted or enforced by law. Additionally we may share data and information to defend or protect our legal rights, our intellectual and physical property, our employees and service providers, the safety and security of our business partners and their online users, and to protect us against fraud.