Relevant Digital Oy (“Relevant” or “we”) is a Scandinavian company focused on developing online advertising and media in a transparent and trustworthy manner. We are committed to ensuring that your privacy is protected while delivering our services. This privacy and cookie policy provides information about the personal information that we collect, the ways in which we use that information and the choices are available to you.
We provide our business partners, such as advertisers and website and app publishers, with technologies that enable the display of relevant advertising to individuals who access a website, mobile application or other online content. Our technology collects information automatically and we process such information to create online audience segments. Segments include information regarding a cohort of users with like characteristics, such as people interested in sports (interest segment), people likely to buy a car or a new apartment (intent segment), people living in Helsinki metropolitan area (geographic segment) or people aged 20-30 years (demographic segment). Information may be associated with a unique numerical identifier, such as a cookie or a mobile identifier, but cannot be used to directly identify you personally as we do not know your name, email address or identity number. These segments may be shared with third parties who wish to show advertising that is likely to be of interest to you.
When processing information for the purposes of tailored advertising and delivering the services to our business partners, we conform to all applicable laws and self-regulatory standards such as Self-regulation Framework for Online Behavioural Advertising (OBA) released by IAB Europe. In accordance with the Framework, we do not create sensitive audience segments or segments specifically designed to target children.
If you do not wish that we collect information about your use of our or our business partners’ services for the purposes of creating advertising segments and share the segments with third parties to display advertising likely to be of interest to you, you may opt-out here. If you wish to opt-out of tailored advertising in general, you may opt-out at www.youronlinechoices.eu.
This privacy and cookie policy explains the following, amongst other things:
• Information we process about you
• How we use information
• How long we retain information
• What kind of choices you have
• How we share your information
• What kind of security measures we use
• How we use cookies and similar technologies
• How to contact us regarding privacy issues
We may process the following categories of personal information:
1) Information provided by our business partners or individuals using our services.
• When providing services to our business partners we store personal information, such as name, email address, telephone number of the contact person and billing information as well as customer communications to store with the customer account. Without this information we cannot provide or invoice the services as agreed.
• Individuals may also choose to send us their personal information in an email or by completing an online form on our website for the purpose of receiving more information about our products and services. We will use any such collected information to contact the individual in accordance with the individual’s stated preferences.
• We can also collect other information, such as testimonials or answers to marketing research questionnaires, if we have the individual’s permission to do so.
2) Information we collect automatically through cookies and similar technologies. We collect certain information automatically as described in our cookie policy below. This information includes but is not limited to:
• the Internet Protocol (IP) address of the device from which you access the service;
• the site that you visited immediately prior to visiting the service;
• the specific actions that you take on the service, including the pages that you visit, posting a comment, or performing a search;
• the time, frequency and duration of your visits to the service;
• your browser type and operating system;
• the nature of the device from which you are accessing the service, for example, whether you are accessing the service from a personal computer or from a mobile device and its device-ID;
• your location, such as IP address or latitude/longitude coordinates; and
• information regarding your interaction with email messages, for example, whether you clicked on the email message.
This information is collected automatically from the use of our services or the use of our business partners’ services. Information is collected e.g. when our business partner places one of our tags on a website that the individual visits or uses or an individual interacts with an app from which we collect information.
3) Information obtained from third party sources. We might supplement the information you provide us or information we collect automatically with information obtained from third parties. This information typically contains segment information which we can use to infer more accurately to which segment you belong to.
4) Derived information. We can derive from the information defined above using algorithms and data analytics, such as calculating possible interests of the user or otherwise segmenting the user to a specific group of users. You may be shown different advertising on third party websites on the basis of the profile we have created.
We use information collected from business partners and from visitors of our website for the following purposes:
• To operate and maintain the account, and to provide with access to the services that it is requested from time to time;
• To provide technical support;
• To respond to comments or enquirie submitted;
• To prevent or take action against activities that are, or may be, in breach of our terms of use or applicable law;
• To process purchases and to collect payment;
• To send marketing messages as well as service updates, newsletters and notifications regarding the account;
• To analyze the use of the service, and the people visiting the services, in order to improve and customize it;
• For statistical analysis and reporting;
• To ensure technical functionality of our service and develop new products and services;
• To analyse the use of our service, including your interaction with apps, advertising, products, and services that are made available, linked to, or offered through our services;
• To provide, personalise, and improve your experience with our services and advertising, for example by providing tailored or localised advertising.
We use information collected from our business partners’ website through our technology for the following purposes:
• To provide, personalise, and improve your experience with our or our business partners’ services and advertising, for example by providing tailored or localised advertising;
• To analyse your use of the service, including your interaction with apps, advertising, products, and services that are made available, linked to, or offered through the services;
• To assign you to an audience most likely to respond to a particular advertisement;
• To pass segment information to advertising exchanges and similar advertising platforms for buying and optimizing ads;
• To provide, personalise, and improve your experience with the services and advertising, for example by providing tailored or localised advertising across apps and devices; and
• To invite you to participate in market research surveys.
We process personal information in compliance with the applicable EU legislation, namely on the basis of:
• contract (or other relevant connection) between us, such as the use of our services;
• legitimate interest, such as marketing or development of our services;
• consent obtained by us or our business partners e.g. for electronic direct marketing to consumers or placement of cookies for tailored advertising purposes; and
• legal obligation, such as retaining transaction information to fulfill our tax and accounting obligations.
If we intend to further process the information for a purpose other than the one for which the information were collected, we shall provide you with information on that other purpose and request your consent, if necessary.
We store the information as long as necessary to fulfill the purposes set out above, for example:
• information provided by our business partners is usually retained for the duration of the customer relationship or newsletter subscription and as long as necessary thereafter to fulfill our legal obligations;
• names and email addresses of our business partners are retained for marketing purposes in accordance with their stated preferences or until they opt-out from receiving marketing messages;
• information collected automatically is typically retained for a period of 90 days .
We offer you with the following choices:
• Access, correction and deletion right: You have the right to access the personal information that has been collected. Upon your request, we will modify, remove or supplement any incorrect, unnecessary, incomplete or outdated personal information. Please note that if we only process information collected automatically we cannot identify you personally and might not be able to grant you access, correction or deletion right without additional information.
• Portability right: Upon your request, we provide you with the information you have provided us in a machine-readable format.
• Direct marketing and newsletters: You may unsubscribe from direct marketing or from receiving newsletters by clicking the unsubscribe link in the email.
• Profiling: You may manage your preferences regarding tailored advertising here. You may unsubscribe from tailored marketing messages by clicking the unsubscribe link the email.
• Cookies: You may block or reset cookies by changing your browser settings. Please note that blocking cookies may have an impact on the way internet services function.
• Mobile identifier: User may reset the mobile identifier on your device’s privacy settings.
• Withdrawal of consent: If the processing is based on your consent, you may withdraw such consent at any time by notifying us or our business partner which has obtained the consent.
• Complaint: You may lodge a complaint to a supervisory authority if you consider that your personal information has been processed in breach of applicable legislation or this privacy and cookie policy.
We do not share personal information with third parties, unless one of the following circumstances applies:
• Consent: We may share directly identifiable personal information about you with third parties when we have your consent to do so.
• Segments: We may share segments to third parties in order for them to show advertising that might be of interest to the audience. This information does not include anything that could be used to identify you personally.
• External processing: We may transfer personal information about you to our trusted business partners to process it for us, based on our instructions and in compliance with this privacy and cookie policy and any other appropriate confidentiality and security measures.
• Mergers and acquisitions: We may disclose personal information of our users and users of our business partners’ services in connection with a merger, acquisition or asset sale.
• Governmental requests: We may disclose personal information of our users to authorities if such disclosure is necessary to meet any applicable law.
• Social media and networks: If you choose to connect your account to other networks such as Facebook, you will be sharing certain information with these networks.
• Our interests: We may disclose personal information of our users if it is necessary in order to protect or defend our legitimate rights and interests, or those of our users, employees, directors or shareholders, and/or to ensure the safety and security of the service.
• Third party cookies: Third parties may collect data in accordance with the cookie policy below.
We typically store our user’s personal information in the EU or the EEA. If any information is transferred outside the EU or EEA, we ensure that the country or organization to which the information is transferred is approved as having a sufficient level of privacy protection by the European Commission. Third party suppliers processing data on our behalf must process personal data in compliance with this privacy and cookie policy and our written instructions.
We use technical and organizational measures to protect personal information against unauthorized access, transfer, deletion or other handling that may compromise information security. Such methods include but are not limited to:
• the use of firewalls, encryption technologies and safe server rooms;
• proper access control systems;
• the controlled provision of user rights and supervision of their use;
• providing instructions for data processors; and
• selection of competent subcontractors who comply with industry standards for information security management.
Like most websites we collect information about how our services are used by using cookies and other similar technologies, such as mobile identifiers and browser local storage. We also place cookies and use similar technologies on the services of our business partners.
Cookies are small text files that are placed on your computer by websites that you visit. These text files can be read by the party which have placed them and help to identify you when you return to a website. Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your computer when you have gone offline, while session cookies are deleted as soon as you close your web browser.
Cookies and similar technologies typically contain a unique numerical identifier. Users cannot be personally identified merely by using cookies or similar technologies, nor can our website know the user’s email address, unless the user has entered it.
For more information about cookies, visit http://www.allaboutcookies.org/cookies. Please note that if Internet browser settings are used to clear or delete cookies, this may inadvertently delete cookies that have been set by websites to honour an “opt-out” status.
Cookies on our services
We use cookies primarily to personalize our service, analyze the use of our service, target advertising and maintain your identity or session on the service. You may block or reset cookies by changing your browser settings. Please note that blocking cookies may have an impact on the way our services function.
In addition to our own cookies, we work with various reputable companies to help us analyze how the service is used and to optimize our service to deliver the best possible experience. These companies include but are not limited to:
• Google, privacy policy, opt-out page
• Cxense, privacy policy, opt-out page
• Adform, privacy and opt-out page
We use social media partners to generate interest in our services among members of your social networks and to allow you to share interests with friends in your network. Our service utilizes features such as the Facebook Like button functionality to share content. If a user clicks the Like button and logs into Facebook via our service, Facebook will leave a cookie on the user’s computer. This is the same process as if the user logs into Facebook directly or clicks Like on any other website. Please see:
• Facebook’s privacy policy
• Twitter’s privacy policy
• LinkeDin’s privacy policy
Cookies on our business partners’ services
We may place cookies or use similar technologies on the services of our business partners to analyze your use of the services and to assign you to an audience most likely to respond to a particular advertisement. This supports the app and website developers by funding the services through advertisements and consumers by delivering advertisements more relevant to their interests.
If you do not wish that we collect data about your use of our business partners’ services, assign you to a segment and enable advertisers to show advertising more likely to be of interest to you, you may opt-out here.
Children
Our service is not intended for use by children. Anyone under the age of 13 is not permitted to use the service and must not attempt to register an account or submit any personal information to us. We do not knowingly collect any personal information from any person who is under the age of 13 or allow them to register an account. If it comes to our attention that we have collected personal information from a person under the age of 13, we will delete this information as quickly as possible. If you have reason to believe that we may have collected any such personal information, please notify us immediately.
Changes
We are continuously developing our services and reserve the right to change this privacy and cookie policy by informing you of such changes in our services. We recommend that you read our privacy policy and cookie policy on a regular basis to keep track of changes.
Links to other websites
This service may contain links to other websites of interest. You should note that we do not have any control over those other websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy and cookie policy. You should exercise caution and look at the privacy and cookie policy applicable to the website in question.
This privacy and cookie policy was last amended: 5.4.2017. You will find a link to prior versions of our privacy policies and summary of the main changes below.
Should you have any queries regarding this privacy and cookie policy, please contact:
Relevant Digital Oy
Petri Kokkonen
Keilaranta 1, 02150 ESPOO, Finland
petri.kokkonen(a)relevant.fi
+358 40 833 5077
The contact details of the supervisory authority are:
Office of the Data Protection Ombudsman
P.O. Box 800
FIN-00521 HELSINKI
FINLAND
Tel: +358 29 56 66700
Email: tietosuoja(a)om.fi
