Issued: May 2018
ReklamStore is the global leader in audience data, allowing brands to target their advertising campaigns with precision. With more than 3.5 billion unique global profiles, we offer data with scale and depth that enables advertisers to paint a fuller picture of audiences.
ReklamStore is committed to being transparent about its processes and the data it interacts with, and ensuring that the legal rights of individuals are respected and protected. If you want to contact us, please email firstname.lastname@example.org.
What does ReklamStore's Platform do?
ReklamStore provides a digital advertising technology platform. The platform provides tools for advertisers to buy advertising space on digital properties such as websites and mobile applications, and for publishers of websites and mobile applications to offer and sell their advertising space. We also provide tools to manage, buy, and sell data that can be used to ensure that advertisements are shown to users who are likely to have an interest in a particular ad, and we provide a technology that enables the delivery of advertising content to a website or mobile application. The Service is provided and operated by RS Internet Pazarlama A.Ş, Yeşilce Mh. Diken Sk. N:4 K:4 4. Levent Kağıthane, İstanbul Turkey.
What is the purpose of ReklamStore's Platform?
ReklamStore does not receive, collect or process information unless it is used for the following purposes: –to perform our Services to our Clients, including providing, operating, managing, maintaining and enhancing our Platform; -to improve our performance; -to perform interest-based advertising and increase the relevancy of the ads being displayed to you; -to perform optimization in respect to a campaign, including to limit the number of times you see a particular ad; -to customize ads to a particular location; -to show ads related to the content of the concerned web page; –to report aggregated statistics (for example, to understand the effectiveness of an online advertising campaign); -to secure, amend and improve our Services; In some cases, if our Client requests it, and if you gave your clear and informed consent during the course of our Services, we will analyze your information to build individual profiles. These profiles will be used to predict future interests and display targeted advertisements, with the aim of providing you with relevant and interesting offers. The profiling is based on your behavior on our Client’s website. As we do not collect information to directly identify you (your name, for example), we expect that our Services will have no further impact, other than providing you with a good user experience when visiting our Clients’ websites.
What information does ReklamStore Platform hold?
- Cookie ID
In order to link each single interaction to an individual device, ReklamStore generates a unique device ID for every new device which interacts with any form of ReklamStore advertisements or website tracking. The unique device ID is stored locally by using a Cookie in the user’s browser. The Cookie, by default, expires 60 days after the last interaction. The device ID is either generated as a truly random number or in some cases combined with an ID generated by static and dynamic variables from the browser and device configuration.
- Mobile Advertising ID
The Mobile Advertising ID is the technical ID in Mobile App Environments, e.g., on smartphone operating systems like Android and Apple IOS, that is under full control of the user and owner of that device and that can be reset by the user.
- Cross-Device IDs
This ID is a user ID generated by ReklamStore by using statistical and probabilistic algorithms in an attempt to link devices and identifiers belonging to the same user. ReklamStore generates and purchases 3rd party Cross-Device IDs for the purposes described in further detail below.
- Partner IDs
ReklamStore is connected to a large number of partners. ReklamStore automatically exchanges pseudonymous IDs with such partners. These IDs are strictly pseudonymous on both sides. ID synchronization is an essential prerequisite for the provision of the Service. ReklamStore also collects and stores certain Information for its clients related to the interaction that users have with ads and digital properties such as websites or mobile apps:
- The type of browser used by a user, and its settings.
- Information about the device operating system.
- Information about Cookie IDs and other IDs assigned to a device. IP addresses from which a device interacts with a client´s website or mobile application; IP addresses may be truncated or encrypted or both based on local legislation or other requirements. Information about a user's interaction and activity on web pages and mobile apps, including time of the interaction or activity, the internet addresses involved, and search terms entered into a search engine. Information about the approximate geographic location (city, region, zip code) of the device when it accesses a website or mobile app derived from truncated IP address information or truncated GPS data.
What does ReklamStore not collect?
ReklamStore does not collect, use, or allow its clients to transfer to or use on the Platform, data that, by itself, directly identifies an individual, such as name, address, phone number, email address, or government identifier. We also prohibit certain categories of sensitive data from being collected, used, or transferred on the Platform, and we use technical solutions to detect directly identifiable data in the Service and take appropriate action. To enforce this principle, we actively scan data for any breaches as such.
What is sensitive data?
- 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.
How do ReklamStore use Platform Data and with whom we share?
- Information to analyze and report on advertising performance.
- Information to improve online advertising experience and efficiency, f.e. to display ads in a sequence, display particular products in response to users’ interest, display ads based on statistical probabilities, or to decide what ad to show or whether to show it.
- IDs for cross-device mapping in order to limit advertising exposure for consumers and facilitate more relevant advertising.
- Cookies and IDs to satisfy end user opt-out requests.
- Cookie IDs and other IDs to synchronize our Service with other online advertising services.
- Information to facilitate the process of buying and selling online advertising.
- Information and IDs for internal 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. ReklamStore shares Platform Data:
To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
To any other person with your consent to the disclosure.
- With Clients
The Services allow clients to provide and share Information with each other. Clients have access to the Information they collect, upload or use within the Services, and may have access to Information generated through their use of the Service.
- With Third Parties
How ReklamStore Collect Information?
Does ReklamStore process data collected from consent signals?
ReklamStore has made application to become vendor of IAB, in the end of 2019, we will actively collecting consent signals from our Publishers and data partners.
How does ReklamStore collect and preserve Platform Data in the EAA?
If you are a visitor from the European Economic Area (EEA), our legal basis for collecting and processing the information described above will depend on the information concerned and the specific context in which we collect and process it. We collect and process Information only where we have your consent (Article 6, paragraph 1 of GDPR) or where we have a legitimate interest to do so. By way of example, we rely on our legitimate interests to process cookie IDs for advertising-related purposes, including the purposes mentioned in the section " How do ReklamStore use Platform Data and with whom we share?" above.
- Data Transfers outside of the EAA: Platform Data may be transferred to a partner located in a third country not providing adequate protection regarding data protection. With these partners, we sign standard contractual clauses adopted by the European Commission to ensure an adequate level of protection. When Platform Data may be transferred in the United States of America, we ensure that the other party is complying with the Privacy Shield Framework and/or that standard contractual clauses are signed, regarding the collection, use and retention of personal information transferred from the European Union to the United States, respectively.
How long does ReklamStore retain Platform Data for?
The Cookies ReklamStore sets in browsers expire 45 days after the last interaction. Mobile Advertising IDs are technical IDs in mobile application environments. Mobile Advertising IDs are resettable by the user; however ReklamStore does not have control of a Mobile Advertising ID. ReklamStore will see the same Mobile Advertising ID as long as it is not changed by the device user or updated by the device. ReklamStore does not keep any Cookie-based Information longer than 13 months. In other words, any data that can be related to your internet devices are deleted after maximum 13 months.
What is Business Data?
Business data refers to the information about people, places, things, business rules, and events in relation to operating a business.
How and in what purpose ReklamStore collect Business Data?
We need to process your personal data if we have or are considering a business relationship with you. This may include data relating to your work with the following, for the following purposes:
- client (f.e. an agency or advertiser) in order to manage our contracts and campaigns, issue invoices and collect payments, and keep records;
- a web or mobile publisher or other data provider in order to manage data, make payments, and manage technical issues;
- a supplier, potential supplier and other business contacts in order to collaborate, evaluate and negotiate the purchase of goods and services;
- potential clients, potential data suppliers or publishers, in order to expand ReklamStore’s business and resources. Processing this data is necessary where we have a contract with your company or for our legitimate interests in managing and growing our business. The Business Data is used for the purposes of marketing, communicating with our customers, responding to general inquiries, providing our services and recruitment.
Opt-out and withdrawing of consent
For the sake of transparency, ReklamStore has adopted a cookie opt-out policy, allowing each Internet user to opt out from our advertising network. This ensures that your browser will no longer be identified by our system. Please note that for us to acknowledge your desire to opt-out, one cookie will be placed on your device in order to ensure the performance of your opt-out. Moreover, this opt-out will only be available for the device on which it was created. ReklamStore allows Internet Users to Opt-out of:
- Cookie-based targeted advertisements using ReklamStore technology for online behavioral advertisements
- Tracking of visits across domains of different media or advertisers’ sites through ReklamStore technology
- Any type of cookie-based tracking by third-party technology through ReklamStore
- Mobile device-based targeted by changing settings/resetting advertising identifiers
The opt-out process erases the previously set cookie and places an alternate ReklamStore cookie into the Internet user’s browser with a special indication of an “opt-out” choice and with no other data. Since random identification numbers of those two cookies are different, no data attributed to the previously set cookie can be attributed to the new “opt-out” cookie. If you wish to opt-out, click OPT-OUT button below. A blank page will open, confirming the opt-out process has been completed and ReklamStore will no longer place cookies on your computer. You can withdraw your consent, as the case may be, at any time by sending us an email with your specific request at email@example.com If you receive any ReklamStore newsletters by email then you have the right to opt-out these at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the e-mails. If you have given any website your consent to use ReklamStore, then you should be able to withdraw your consent at any time on the same website where you have given it. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. For further opt-out requests and information, please send an e-mail to firstname.lastname@example.org
Personal Rights of European Union Subjects under GDPR
ReklamStore respects rights of users that are located within European Union under Chapter 3 of the GDPR.
- Right to Access Personal Data Under GDPR, data subjects have the right to access the data collected on them by a data controller. ReklamStore shall respond to that request within 30 days.
- Right to Rectification Data subjects have the right to request modification of their data, including the correction or errors and the updating of incomplete information (Article 16).
- Right to Erasure The right to erasure – also referred to as the right to deletion or the right to be forgotten – allows a data subject to stop all processing of their data and request their personal data be erased (Article 17).
- Right to Restrict Data Processing Data subjects, under certain circumstances, can request that all processing of their personal data be stopped (Article 18).
- Right to be Notified ReklamStore shall inform the data subject about those recipients if the data subject requests it.
- Right to Data Portability A data subject can request that their personal data file from ReklamStore.
- Right to Object If a request to stop data processing is rejected by ReklamStore, the data subject has the right to object to their Article 18 right being denied (according to Article 21).
How ReklamStore secure and protect it’s Platform Data?
ReklamStore implements high standard security measures to protect all data collected, used and processed by ReklamStore on behalf of its clients. Although no one can guarantee the security of the information collected and received, we do employ a number of safeguards intended to mitigate the risk of unauthorized access or disclosure of this information. At every step, ReklamStore adapts all relevant security and safety practices, and employs modern security hardware and software provided by recognized world-leading manufacturers. Security measures includes:
- Storing the data you provide in controlled facilities;
- Using HTTPS encryption when you authenticate (f.e., log into one of our Services), which helps prevent unauthorized access to your login credentials;
- Limiting access to personal information to employees who need that access to perform their jobs; and
- Providing company-wide training on privacy and data security.
Does ReklamStore collect Personal Information from minors?
No. ReklamStore does not knowingly collect Personal Information from individuals under the age of 18. In the event you become aware that an individual under the age of 13 has enrolled without parental permission, please advise us immediately via email@example.com
Glossary of Terms and Definitions
Cookies:are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information. Cookies set by the website owner are called "first party cookies". Cookies set by parties other than the website owner are called "third party cookies". Third party cookies enable third party features or functionality to be provided on or through the website(like advertising, interactive content, and analytics). The parties that set these third-party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.
Consent: any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Data controller: is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by the Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Data processor: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Data subject: a natural person whose personal data is processed by a data controller or processor.
Personal data: any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Platform Data: data which is processed on the Platform.
Principles: the fundamental principles imbedded within the GDPR which set out the main responsibilities for organisations.
Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Profiling: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Pseudonymised Data: the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, as long as such additional information is kept separately and technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
Restriction on processing: the marking of stored personal data with the aim of limiting their processing in the future.
Right of access: entitles the data subjects to have access to have access to and information about the personal data being processed by the data controller.
Special categories of personal data: personal data revealing a data subjects racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership or the processing of genetic data, biometric data for the purposes of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
Changes to this policy
If there are any questions, comments, concerns or complaints related to this policy, please contact us via privacy@reklamstore, or please write to us at the following address:
RS Internet Pazarlama A.Ş, Yeşilce Mh. Diken Sk. N:4 K:4 4. Levent Kağıthane, İstanbul/Turkey Attention: Data Protection Officer
No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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