DIANOMI PRIVACY NOTICE

Effective date of this Privacy Policy:

If you would like to go directly to Dianomi’s opt-out status options, please click here.

 

If you would like to learn more about Dianomi’s region-specific processing of Information, you can go directly to the applicable notices for individuals in the European Economic Area (“EEA”) and in California by clicking here.

 

Introduction

Welcome to Dianomi’s privacy notice.

Dianomi is dedicated to providing Internet users the highest level of transparency and control over the use of their data in online advertising. We adhere to the Interactive Advertising Bureau’s (IAB) Self-Regulatory Principles for Online Behavioural Advertising.

When you visit www.dianomi.com, and any Dianomi website displaying this privacy notice, or use or interact with any of our services or are a visitor to one of our customers’ websites and digital properties who interacts with our services (collectively the “Sites”), we may collect information from or about you or your device, which may include personal information or personal data as defined by applicable privacy laws (“Personal Information” or “Personal Data“) (collectively, the “Information”), and this Information will be handled as described in this privacy notice.

Dianomi respects your privacy and is committed to protecting your Information. This privacy notice will inform you about how we collect, process, use, disclose and look after your Information that we may obtain when you visit our Sites and when we provide our native advertising platform services for digital publishers and advertisers (collectively the “Services”) to you (regardless of where you visit from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR INFORMATION COLLECTED
  4. HOW WE USE YOUR INFORMATION
  5. TRACKING AND RETARGETING
  6. COOKIE POLICY
  7. DISCLOSURES OF YOUR INFORMATION
  8. DATA SECURITY
  9. DATA RETENTION
  10. YOUR LEGAL RIGHTS
  11. ADDITIONAL REGIONAL PRIVACY DISCLOSURES
  12. CHANGES TO THE PRIVACY NOTICE

The data we collect about you

If you do not fill in one of our forms, we do not know who you are, your address, your date of birth, your email address or your phone number.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Information about you (as a user, advertiser or publisher) which we have grouped together follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, date of birth and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Sites and our Services.

Profile Data includes your username and password, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our websites or Services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Information but is not considered Information in law as this data doesnot directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website, content. However, if we combine or connect Aggregated Data with your Information so that it can directly or indirectly identify you, we treat the combined data as Information which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide Information

Where we need to collect Information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your Information collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Information you provide when you:

  • Apply for our products or services as an advertiser or publisher
  • Create an account on our Sites
  • Subscribe to our service or publications
  • Visit a web page with our ad units
  • Click on a link in our ad units
  • Request marketing to be sent to you
  • Enter a competition, promotion or survey
  • Give us some feedback.

 

Automated technologies or interactions. As you interact with our Sites or Services, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Information by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other Sites employing our cookies and similar technologies. Please see our cookie policy for further details. We may record your browsing behaviour when you visit Sites on which our ads are displayed including which pages are visited. This can be used to target you with personalised advertising and for analytics purposes.

Third parties or publicly available sources. We may receive Information (including analytics data, demographic data, IP addresses) about you when you visit our sites via third parties that collect information on our behalf through your use of the Sites or via our third party customers’ websites and digital properties who interact with our Services or via our data partners and other public sources.

How we use your Information

Most commonly, we may use your Information in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with our publisher and advertiser clients and others.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to perform the contract we are about to enter into or have entered into with our publisher and advertiser clients and others.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Providing our Service. To provide and manage our Sites and Services.
  • For analytical and insight purposes.
  • To register you as a new customer, advertiser, publisher
  • To process and deliver your order campaigns including:
    • Manage payments, fees and charges
    • Collect and recover money owed to us
  • To manage our relationship with you which will include:
    • Notifying you about changes to our terms or privacy policy
  • To enable you to partake in a prize draw, competition or complete a survey
  • To administer and protect our business and our Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  • To use data analytics to improve our Sites, products/Services, marketing, customer relationships and experiences
  • To make suggestions and recommendations to you about goods or services that may be of interest to you
  • To check the reputation of that IP Address (both then and later)
  • We need to use your IP address so we can geotarget our ads
  • We may disclose user Information to other unaffiliated third parties, specifically with our data partners, so that we can connect you with relevant content by allowing our advertisers to target specific audience segments
  • For robot detection
  • For audit purposes
  • Legal compliance. To comply with applicable legal obligations, including requests from law enforcement or other governmental entities.

Tracking and retargeting

Dianomi Limited participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Dianomi Limited’s identification number within the framework is 885.

Purposes for which we will use your Information

Marketing / Targeting

We strive to provide you with choices regarding certain Information uses, particularly around marketing and advertising. We have established the following Information control mechanisms:

Promotional offers from us -

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). In most cases we will show you recommendations based on the context of the page and not on your Information profile.

You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered your details in one of our form.

Third-party marketing

Dianomi may also use third parties to serve ads and see list of data partners for this purpose. These third parties may collect information about your visits to our Sites and other websites, your IP address, your ISP, the browser you use to visit our Sites (but not personal information such as your name, address, email address or telephone number). They do this using their own cookies, clear gifs or other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Sites and the other sites tracked by these third parties. This policy does not apply to, and we are not responsible for, cookies or clear gifs in third party ads, and we encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here 

 

User Choices and Opting Out

Dianomi supports initiatives to offer our users greater transparency and control over the uses of their Information. Therefore, we offer the following options for controlling the interest-based content and ads you receive.

  • If you do not want to receive interest-based ads from Dianomi, you can disable the display of such ads by clicking on the opt-out button below.

You are opted in
You are opted out

Opting out - Tracking

If you have:

Opted Out: you have opted out of tracking (behavioural targeting), Dianomi will no longer serve you with personalized content recommendations based on your Internet history. Please note that an opt out will not prevent you from seeing Dianomi’s content recommendations. Rather, the opt out will prevent Dianomi from using your information to tailor these recommendations to your interests. You will continue to receive recommendations that are selected based on the particular website that you are viewing (i.e. contextually based ads).

Not Opted Out: in some cases Dianomi will serve you personalized recommendations (behavioural targeting) based on your history, however Dianomi serves mostly contextual recommendations.

Tracking mechanisms operate at the device and browser level, so if you would like to opt-out across all devices, you will need to do so on each device and browser individually.

 

Cookie Policy

To enhance your online experience, we use "cookies." Cookies are small text files placed by the Sites in your computer's browser to make a user’s experience more efficient. Cookies, by themselves, do not tell us your e-mail address or other personal information. However, once you choose to furnish the Sites with personal information (such as signing up to receive one of the offers made by our third party advertising partners), this information may be linked to the data stored in the cookie. We use cookies to understand Internet usage, enhance the performance of the Sites, activate special web features and security mechanisms. In addition, we may use cookies to offer you products, programs or services which may be part of client retargeting campaigns.

You always have the option of setting your browser to warn you when a cookie is being accessed on your computer, to delete cookies that are currently on your computer or to decline cookies altogether. However, to take full advantage of the Sites and its features, your browser will need to accept cookies.

Web beacons (also known as clear gifs) are small, invisible graphic images that may be used on the Sites and in e-mails to collect certain information about your use of and activity with the Sites and emails. If we combine cookies or clear gifs with or link them to any of the personally identifying information, we would treat this information in the same way we treat other personal information.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Sites may become inaccessible or not function properly.

The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission.

To understand your interests and deliver advertisements that are tailored to your interests, we may work with service providers or third parties that use their own cookies, web beacons, and other technologies to collect Information about your online activities, either on our Sites and/or other websites across the Internet. This may include advertisers and ad networks that may collect Information about when you view or interact with one of their advertisements and may collect information regarding your activities on our Sites and your online activities over time and across different websites. Dianomi works to place our advertisements where we think they will be most interesting and relevant to the recipient.

Dianomi uses different types of cookies which are listed in the below table. Some cookies are placed by third parties.

Change of purpose

We will only use your Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

Please note that we may process your Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your Information

We may share data or aggregated data with affiliates, subsidiaries, or our third party data partners for the purpose of delivering our Services. We may disclose your Information to our customers where relevant to the Services we provide. For example, we may provide third parties with information about the viewing and click-through patterns of the advertisements and/or content they publish and may provide advertisers with information about conversion rates for analytics purposes.

We may disclose your Information to vendors, service providers, agents, contractors, sub-processors or others who perform functions (e.g., maintenance, data analysis, customer relationship management, email marketing, surveys, credit card processing, data hosting, fraud detection) on our behalf.

We may disclose your Information to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Information in the same way as set out in this privacy notice.

We require all third parties to respect the security of your Information and to treat it in accordance with the law.

We may transfer your Information outside the country in which it is collected, including to a country that may not offer the same level of protection for Information as the country in which you reside. Rest assured however, that Dianomi has contractual safeguards to ensure your Information is processed in a way that offers an adequate level of protection when it is shared between or among the Dianomi Group. If you would like to learn more about EEA Data Transfers, specifically, see Section 11.1 below.

Data security

We have put in place appropriate security measures to prevent your Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

We retain your Information for the period necessary to fulfil the purposes outlined in this Privacy Notice unless a longer retention period is required or allowed by law.

Additional Regional Privacy Disclosures

11.1 Individuals within the European Economic Area (EEA)

Data Controller

If you reside in the EEA, Dianomi Limited will be the controller of your Personal Data provided to, collected by or for, or processed by Dianomi in connection with our Services.

Legal Basis for Processing Personal Data

If you are a customer, Site visitor, or user from the EEA, our legal basis for collecting and using the [Personal Data] described above (also referred to in this Section 5.1 as “EEA Data”) will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only (i) where we have your consent to do so, (ii) where we need the Personal Data to perform a contract with you, or (iii) where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you or may otherwise need the Personal Data to protect your vital interests or those of another person.

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).

Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us at: [email protected]

Your Rights to Your Information

You have the right to request that Dianomi (i) provide you with access to the Personal Data we hold about you, (ii) correct your Personal Data, (iii) Export your Personal Data, (iv) delete your Personal Data, and (v) cease or restrict processing of your Personal Data. If you are a user and would like to understand what Personal Data and behavioural information Dianomi holds about you, specifically, and how you can exercise any of your rights with respect to your Personal Data, please contact us at: [email protected]. You may also submit a data subject access request by emailing us at [email protected] so that Dianomi may either respond with the relevant information. You have the right to complain to a data protection authority about our collection and use of your Personal Data. To learn more, please contact your local data protection authority. However, if you have any questions about our collection and use of your Personal Data, please first contact us at: [email protected].

EEA Data Transfers

We share your personal data within the Dianomi Group. This will involve transferring your data outside the European Economic Area (EEA) and Dianomi has in place an Inter Group Data Transfer Agreement across its international entities, which is based on the European Commission’s approved Standard Contractual Clauses, which are contractual privacy and security commitments between companies that transfer personal data. We may also share your personal data with our external data partners who may be based outside of the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA, and such transfers will rely on adequacy determinations and/or be based on the European Commission’s approved Standard Contractual Clauses.

11.2. Individuals in the State of California

California law requires us to disclose the categories of personal information we collect and how we use them, the categories of sources from which we collect personal information, and the third parties with whom we share personal information, which we have explained in this Privacy Notice. You also have the right to request what information we collect and how we use and disclose it. Additionally, you have the right to access and delete your personal information. Please note that we must take steps to verify your identity before we can fulfil any consumer request. If we are not able to verify you by matching two data points, we may need to ask you for further information about you for verification purposes (e.g. browser and/or device ID) so that we can fulfil your request.

In addition, we are required to provide you with certain information about the business and commercial purposes for which we collect and share your personal information. We use and disclose the information we collect for the business purposes described in the how we use your Information section of this policy, including: to allow our clients to select and display advertisements, to understand how users interact with our Services, for auditing purposes, to detect security incidents, to prevent fraud, debug, and repair errors, and for other purposes described above.

Dianomi does not use cookies for the purpose of behavioural targeting in California. Dianomi will serve ads to Californian users contextually and therefore will not require users’ consent for targeting purposes. Dianomi does not sell User Information and does not participate in the “sale” of data in California in relation to the California Consumer Privacy Act of 2018 (CCPA) (Cal. Civ. Code § 1798.100-§ 1798.198).


 

Changes to This Privacy Policy

This Privacy Notice is current as of the Effective Date set above at the beginning of this Privacy Notice.

We may change this Privacy Notice from time to time, so please make sure to check it on a regular basis.

If we make any changes to this Privacy Notice that materially affect our practices with regard to the Information we have previously collected from you, we will endeavour to provide you with notice in advance of such change by highlighting the change on our Sites. We will seek your prior consent to any material changes, if and where this is required by applicable data protection laws.