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                Email: 

                contact@switchconcepts.com

                 

                Tel:

                +44 (0)333 200 1230

                ​

                Address:

                Switch Concepts Ltd

                Hounsdown House

                Hounsdown Business Park

                Southampton

                SO40 9LX

                ​

                ​

                © SWITCH 2017

                Privacy Policy

                Brand Safety Policy

                Number 2 in the Sunday Times Hiscox Tech Track 100. 2013 & 2014

                Number 1 Fast50 2014

                Switch Concepts Ltd is a company registered in England and Wales. Number 06706037, Registered address 37 Commercial Road, Poole, BH14 OHU

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                  PRIVACY POLICY

                  ​Switch Concepts Ltd (Switch) is a company registered in England and Wales under Company No. 06706037 with a registered address at First Floor, 1-3 Chapel Street, Guildford, Surrey, GU1 3UH, UNITED KINGDOM.  VAT Number 942295413.

                  Switch’s trading address is Hounsdown House, Hounsdown Business Park, Southampton, SO40 9LX, UNITED KINGDOM.

                  You can contact us in relation to this Privacy Policy via post to the address given in the Contact Us section of this Privacy Policy, via email using dpo@switchconcepts.com, or by telephone using +44 (0) 333 200 1230.

                   

                   

                  Introduction

                   

                  Switch is committed to protecting personal data.  This Privacy Policy explains how Switch and its partners collect, use, and disclose information; and choices for managing information preferences where applicable.  This Privacy Policy is intended for:

                  • publishers using Switch technology for advertising and analytics;

                  • individual users of websites where Switch technology is used for advertising and analytics; and

                  • individual users of the Switch website.

                  This Privacy Policy also includes details about data related to Switch’s marketing activities.

                   

                  There is a section for each type of activity, which explains:

                  • what data is collected and processed;

                  • the purpose for collecting the data - how it is used;

                  • the lawful basis for processing; and

                  • how to review and update information and preferences.

                   

                  ​

                  Online Advertising

                   

                  Switch is a technology company.  We provide services to publishers which enable advertisers to place adverts on websites to reach their audience.  When a user visits a page, the website requests an advert to be displayed using Switch technology.  When this request is made, it is possible to include Personal Data so that advertisers can tailor the response.  The data is also used to protect against fraud.

                  Sometimes the publisher will be the Data Controller and Switch will be the Data Processor.  For example, when the publisher has a direct contractual relationship with an advertiser partner, decisions about data will be made by them, and Switch will just process the data as a technology provider, pursuant to the Controllers’ instructions.  

                  Sometimes Switch will also be a Data Controller.  This is the case when Switch has our own relationship with advertiser partners, and our own independent uses of the data.

                  Understanding and managing the collection and processing of Personal Data differs depending on which party is the Data Controller, but as the touch point with the Data Subject, every website that collects Personal Data, should have a Privacy Notice that covers all scenarios.

                  Personal Data when Switch and the Publisher are each a Data Controller

                  The data Switch collects for its own uses are below.  The website from which the request for an advert originated, may collect additional personal data for their purposes, and the user should also refer to the website Privacy Policy to fully understand data engagement.

                  The information that Switch may collect and process:

                  • Page URL

                  • Device information

                  • Location information as found in the IP address (and the IP address itself)

                  • Pseudonymised identifier


                  How the data is used:
                  With consent, this data can be used for targeting advertising.  For example, the IP address may disclose that a user is in a London borough, and an advert for a London attraction may be picked as an advert which might be of interest.  With consent, this data may also be used for analytics.  In other words, the publisher may want to find out how many of their website visitors access the site whilst in the UK, and therefore change their content appropriately.  The pseudonymised identifier is used to recognise the user’s browser, and to encode user preferences in relation to Personal Data so that they can be shared and interpreted in the advertising ecosystem.  It is also used to manage the frequency with which one advert is shown to a user.  The data is also used for fraud prevention.  Activity is assessed to see if it might be non-human activity that is claiming to have viewed adverts with the intention of fraudulently claiming revenue from advertisers.  If it appears that a website page-load was not generated by a human, we simply take the decision not to request an advert.

                  The lawful basis for processing when Switch is the Data Controller:  
                  Collecting this data must be lawful and transparent.  Where Switch is the Controller and data is collected for targeted advertising and analytics, the lawful basis is consent.  Users can set consent preferences per vendor via a prominent tool on the website page.  Where consent either is not granted by proactive selection, or was not sought, personal data will not be used for these purposes.  When this data is collected for fraud prevention, the lawful basis is legitimate interest.  Forensiq are our partners for fraud prevention and their privacy policy can be viewed for more details.

                  Duration:
                  This data is kept securely in unaggregated form for 7 days.  After 7 days unaggregated data is deleted.

                  Third parties:
                  These are the third parties that Switch works with, with links to their privacy policies where you can find out about any additional personal data collection and usage:

                  • AppNexus

                  • BidTheatre

                  • BidSwitch

                  • bRealTime

                  • Engage BDR

                  • PubMatic

                  • PulsePoint

                  • Quantcast

                  • Rubicon Project

                  • RhythmOne

                  • Smart RTB

                  • Sovrn

                  • Taboola

                  • The Agency

                  • The Trade Desk

                  • Forensiq

                  Switch has a contract with each of these vendors, covering data protection.  All the above are advertising partners except for Forensiq, which provide fraud prevention services.

                  Updating Consent Preferences:
                  Where consent is the lawful basis for processing, website users will be able to update their preferences via tools on websites.  Users can toggle consent on and off globally, or by vendor and purpose.  This preference is encoded in a string which is passed through the ecosystem and tells vendors that are relying on consent, whether they have permission to use the data.  User consent will be renewed periodically by the tool used to record preferences, being shown to users again.  To access the tool at other times, the user can clear cookies, which gives the impression that the user is new and has not yet set preferences.


                  Personal Data when a Publisher using Switch technology is the Data Controller

                  When the publisher uses Switch technology to deliver on its own contracts and collect Personal Data for its own uses, the publisher is the Data Controller and Switch is the Data Processor.  Switch processes the data pursuant to the Controller’s instructions.  The Data Controller will decide what is collected and the lawful basis for collection, and the publisher will manage Data Subjects’ individual rights.  To find out what is collected, the lawful basis for processing, and how Personal Data is used, the website user should refer to the Privacy Policy on the website.

                   

                  ​

                  Website

                  ​

                  Cookies
                  Switch uses cookies on its website.  Cookies are small text files that are stored on your device, which can be used to recognise you as a unique user.  The cookies used are essential to the correct functioning of the website.  These are the cookies used:

                  ​

                  XSRF-TOKEN, Wix cookie, expires at end of session

                  PHPSESSID, Wix cookie, expires at end of session

                  hs, Wix cookie, expires at end of session

                  svSession, Wix cookie, persists

                  IDE, Google cookie, persists

                  test_cookie, Google cookie, persists

                  NID, Google cookie, persists

                  1P_JAR, Google cookie, persists

                  CONSENT, Google cookie, persists

                  ​

                  These are third party cookies.  You can find out more about Google cookies here.  You can find out more about Wix cookies here.  Switch uses Wix to create and manage the website.  You can disable cookies via your browser.  The following explains how: www.aboutcookies.org.uk/managing-cookies.  Please note that this is not a Switch resource and we do not control the content. 
                   

                  Contact Form

                  ​By submitting your details, you are requesting that Switch contact you about products and services.  Your details will be processed by the web-hosting company (with which we have a contract covering data protection) and e-mailed to Switch.  We will add your details to our customer database for the purpose of contacting you as requested, and will not use your details for any other purpose.  If you wish to remove or amend your details, or no longer wish us to follow up on your request, you can contact us using a method listed below.

                  ​

                  ​

                  Supplier, Customer and Prospect Data

                   

                  If you are a customer of or supplier to Switch, data needed for the performance of the contract to which you are party, or data processed in order to takes steps at your request prior to entering into, or during the term of the contract, will be processed and stored.  More information is given within your contract where applicable. For further details, or to access, amend, or exercise any of your rights, please use the contact details listed in the Contact Us section of this policy.

                  ​

                  ​

                  International Transfers


                  Where Switch is the Data Controller, for information transferred outside of the EEA, Switch ensures that the transfer is governed by a contract which provides adequate protection for personal data in accordance with applicable data protection laws.
                   

                  ​

                  Security

                   

                  ​Information that we collect is stored using procedures and practices designed to help protect information from unauthorized access, destruction, use, modification, or disclosure.  Our employees are aware of and accountable for compliance with these procedures.

                   

                  ​

                  Policy Updates

                   

                  This Privacy Policy may be updated from time to time so you may wish to check it each time you visit the Switch Concepts website. The date of the most recent revisions will appear on this page. If material changes are made to the Privacy Policy, we will notify you using an appropriate method such as a prominent notice on the website or an e-mail.

                   

                  ​

                  Contact Us

                   

                  If you have any questions relating to this Switch Privacy Policy, please contact us using one of the following methods:

                   

                  E-mail: dpo@switchconcepts.com

                  Telephone: +44 (0) 333 200 1230

                  Post: Hounsdown House, Hounsdown Business Park, Southampton, SO40 9LX

                  ​

                  ​

                  Supervisory Authority

                  You have the right to contact the Information Commissioner’s Office (supervisory authority) if you wish to make a complaint.

                  ​

                  ​

                  Effective Date

                  ​

                  25th May 2018
                   

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