Effective as of 26 July, 2018
Welcome to Attribution Digital (ATTD)
2. Personal Data We Collect
3. How We Use Personal Data
4. How We Disclose Personal Data
5. Your Rights and Choices
6. Security and Retention
7. International Data Transfers
9. Jurisdiction-specific Provisions
10. Contact Us
ATTD obtains Personal Data about you from various sources to provide our Services and to manage our Sites. “You” may be a visitor to one of our websites, or the recipient of one or more of our Services (‘Client’ or ‘ATTD Client’).
If you visit or use our Sites, we may collect Personal Data. For example, we collect Personal Data that you submit to us via online forms and surveys, and when you contact us by email.
2. Personal Data We Collect
a. Personal Data that we collect about you.
Personal Data is any information that relates to an identified or identifiable individual. The Personal Data that you provide directly to us through our Sites will be apparent from the context in which you provide the data. In particular:
When you fill-in our online form to contact our sales team, we collect your full name, work email, country, and anything else you tell us about your project, needs and timeline.
When you respond to ATTD emails or surveys we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call ATTD.
If you are a Client, when you make payments or conduct transactions through ATTD’s website, we will receive your transaction information. The information that we collect will include payment method information (such as credit or debit card number, or bank account information), purchase amount, date of purchase, and payment method. Different payment methods may require the collection of different categories of information.
You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details at trade shows or other events.
b. Information that we collect automatically on our Sites.
Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Sites you are visiting;
Usage data, such as time spent on the Sites, pages visited, links clicked, language preferences, and the pages that led or referred you to our Sites.
We also may collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services. We use Google Analytics on our Sites to help us analyze Your use of our Sites and diagnose technical issues.
3. How We Use Personal Data
a. Legitimate business interests.
We rely on our legitimate business interests to process Personal Data about you. The following list sets out the business purposes that we have identified as legitimate. In determining the content of this list, we balanced our interests against the legitimate interests and rights of the individuals whose Personal Data we process. We:
Respond to inquiries, send service notices and provide customer support;
Manage, operate and improve the performance of our Sites and Services by understanding their effectiveness and optimizing our digital assets;
Analyze and advertise our products and services;
Conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business;
Share Personal Data with third party service providers that provide services on our behalf and business partners which help us operate and improve our business;
Ensure network and information security throughout ATTD and our Services; and
Transmit Personal Data within our affiliates for internal administrative purposes.
b. Marketing and events-related communications.
We may send you email marketing communications about ATTD products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable law. When we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and, with your permission, include you on our marketing information campaigns.
c. Interest-based advertising.
When you visit our Sites or online services, both we and certain third parties collect information about your online activities over time and across different sites to provide you with advertising about products and services tailored to your individual interests (this type of advertising is called “interest-based advertising”). These third parties may place or recognize a unique cookie or other technology on your browser (including the use of pixel tags). Where required by applicable law, we will obtain your consent prior to processing of your information for the purpose of interest-based advertising.
You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users based on a range of factors, including demographic data, users’ inferred interests and browsing context (for example, the time and date of your visit to our Sites, the pages that you viewed, and the links that you clicked on). This technology also helps us track the effectiveness of our marketing efforts and understand if you have seen one of our advertisements.
We work with Google AdWords, Doubleclick, AdRoll and other advertising networks. To learn how to opt out of behavioral advertising delivered by Network Advertising Initiative member companies, please visit the Network Advertising Initative (http://www.networkadvertising.org/managing/opt_out.asp) and Digital Advertising Alliance (http://www.aboutads.info/). You may download the AppChoices app (http://youradchoices.com/appchoices) to opt out in mobile apps. If you opt out from interest-based advertising, you may see advertising that is not relevant to you. At present, there is no industry standard for recognizing Do Not Track browser signals, but we respond to them accordingly.
4. How We Disclose Personal Data.
ATTD does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below.
a. ATTD. We share Personal Data with other ATTD entities in order to provide our Services and for internal administration purposes.
b. Service providers. We share Personal Data with a limited number of our service providers. We have service providers that provide services on our behalf, such as website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union and the United States of America.
c. Corporate transactions. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties for the purpose of facilitating and completing the transaction.
d. Compliance and harm prevention. We share Personal Data as we believe necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of ATTD, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
5. Your Rights and Choices.
You have choices regarding our use and disclosure of your Personal Data:
a. Opting out of receiving electronic communications from us. If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our Services.
b. How you can see or change your account Personal Data. If You would like to review, correct, or update Personal Data that You have previously disclosed to us, You may do so by contacting us (link to contact page / form).
c. Your data protection rights. Depending on your location and subject to applicable law, you may have the following rights with regard to the Personal Data we control about you:
– The right to request confirmation of whether ATTD processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
– The right to request that ATTD rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;
– The right to request that ATTD erase your Personal Data in certain circumstances provided by law;
– The right to request that ATTD restrict the use of your Personal Data in certain circumstances, such as while ATTD considers another request that you have submitted (including a request that ATTD make an update to your Personal Data); and
– The right to request that we export to another company, where technically feasible, your Personal Data that we hold in order to provide Services to you.
Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time. You may also have the right to object to the processing of your Personal Data on grounds relating to your particular situation.
d. Process for exercising data protection rights. In order to exercise your data protection rights, you may contact ATTD as described in the Contact Us (link to contact page / form) section below. We take each request seriously. We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may consult with the data protection authority in your country.
For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.
6. Security and Retention.
We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data within our organization against unauthorized access, destruction, loss, alteration or misuse. Your Personal Data is only accessible to a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us (link to contact us form / page) immediately.
If you are an ATTD Client, we retain your Personal Data as long as we are providing the Services to you. We retain Personal Data after we cease providing Services to you to the extent necessary to comply with our legal and regulatory obligations. We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.
7. International Data Transfers.
9. Jurisdiction-specific Provisions.
10. Contact Us
Ahtri 12 Tallinn,
Harju County, 10151