We take the privacy of your data seriously. This policy is designed to help you learn about Vibrant’s data practices. Please do read it carefully.
References to “Vibrant/we/us” means Vibrant Media Limited. The terms “you” and “your” means you as a user of our Website and our Network.
If you have any questions or queries, please contact us using the details set out at the end of this policy.
- Collection and Use of Information on this Website
- Collection and Use of Information through Our Technology
- Who else may use your information
- Cookies and other technologies
- Participation in self-regulatory programs
- Information access
- Contact details for additional questions and/or to issue a complaint
1. COLLECTION AND USE OF INFORMATION ON THIS WEBSITE
1.1 Our Website is directed at our clients who we intend to do business with. It is not directed at consumers. We use this business contact information primarily in order to make our technology available to our customers and clients, contact customers and potential customers who have provided information to us about our technology, administer accounts, and respond to questions and issues you might have.
1.2 The following personal and identifiable information may be provided by you when you visit our Website:
1.2.1 when you register or complete our enquiry form, you may provide us your name, address, e-mail address and/or telephone number etc. This information allows us to contact you with the information/services you may request from us. We may also ask you to give us other optional contact information, for example your mobile phone number.
1.2.2 if you contact us via our Website, we may keep a record of that email, form or comment.
1.2.3 if you agree to provide a testimonial about your experience with us, we will collect your name and comments and may display them on our Website.
1.2.4 we may also ask you to complete surveys for research purposes from time to time.
1.3 Your personal and identifiable information may be used in the following ways:
1.3.1 to register you as a user of our Website;
1.3.2 to identify you when you visit our Website, including to assist with logging you in;
1.3.3 to provide service(s) and information to you as an actual or potential user of our technology and to carry out our obligations arising from any contracts entered into between you and us;
1.3.4 to notify you about changes to services and/or our Website.
1.3.5 your IP address may be used to help diagnose problems with servers and to administer the Website;
1.3.6 to ensure that content from our Website is presented in the most effective manner;
1.3.7 to help administer our Website generally; and as otherwise described at the time of collection
1.4 In addition, under European privacy law, some information that is collected automatically through the Website is considered personal data. Such information includes information such as your IP host address, pages viewed, browser type, Internet browsing and usage habits, Internet Service Provider, domain name, the time/date of your visit to this Website, the referring URL and your computer’s operating system. This information is typically collected in log files on the Website’s servers. The purpose of this collection is as follows:
1.4.1 your IP address may be used to help diagnose problems with servers and to administer the Website;
1.4.2 to ensure that content from our Website is presented in the most effective manner;
1.4.3 to help administer our Website generally; and as otherwise described at the time of collection
1.8 Updating / Deleting your Personal Data If you’d like us to update, correct, or delete any personal data that you have provided to us on this Website, please send your request to us by clicking here and we will process your request.
1.9 Where you have given us your contact details on a form on the Website or have emailed us in order to request additional information from us, we will rely on your consent to use your information for such purpose. You may revoke that consent at any time. Please see the How To Object and Opt Out section below for information as to how you may withdraw your consent. We use the information collected from you through this Website as necessary for our legitimate interests. These legitimate interests include our interests in providing, maintaining, operating and improving this Website and ultimately the services we provide to our customers and clients.
2. COLLECTION AND USE OF INFORMATION THROUGH OUR TECHNOLOGY
2.1 We place advertisements on websites operated by our client publishers (i.e. through our Network). Our products include Vibrant In-Text Ads, Vibrant In-Image Ads and Vibrant Display Ads. For more information about our products, click here. Other than serving advertisements as referred to above, we do not modify, control or influence any content on our client publishers’ websites.
2.2 Our technology is designed primarily to facilitate the delivery of contextual advertising. For example, we may place advertisements triggered from highlighted keywords within the text of web content on a client publisher’s website so that when you move your mouse over a word or phrase of interest, a relevant advertisement will appear (for example, an advertisement for cars which appears when you move your mouse over the word ‘car’ while reading an automotive news article).
2.3 We may collect information about a visitor’s interactions with the advertising we place on the Network, which we may use to provide more relevant advertisements aligned with your current interests. This process is called “Interest Matching”, and examples of how we may carry out Interest Matching are set out below:
2.3.1 One example is that, if you interact with one of our advertisements (for example, by hovering your mouse over one of the keywords we have underscored), we may use information about your interaction using cookies and other technologies (please see our Cookie Statement for more details) and draw inferences from your visit in order to provide you with an advertisement that is more relevant, interesting, and useful for you.
2.3.2 As another example, we may use our technology to identify a visitor’s interests by gathering web viewing data (e.g. web pages visited, browser type, referring URL, Internet service provider, a computer’s or device’s operating system, and date and time of visits) using cookies and other technologies (please see our Cookie Statement for more details).
2.3.3 We may also engage in behavioural retargeting that allows us and some of our advertising partners to display advertising to you when you are on a website in our Network, based on your browsing patterns and interactions with a website (which may or may not be part of our Network). For example, if you have visited the website of an online retailer, you may see ads on websites in our Network from that same retailer displaying the products that you were viewing on the retailer’s website.
2.3.4 In the case of all the examples above, the information collected and used does not include such personally identifiable information as your name, street address, e-mail address or telephone number.
2.4 Aggregate and non-personally identifiable web viewing and computer data is also collected and used for other purposes including advertisement delivery and reporting, measuring the effectiveness of a campaign, optimizing a campaign, and for operational purposes. We may also combine web viewing data with information (e.g. demographic data) provided by other entities to help make our advertiser clients’ advertising more relevant.
2.6 Our legal bases for collecting and using this personal data are as follows: (a) consent – we will not place cookies on your browser if you do not give us consent to do so. You will continue to receive advertising through our technology but such advertising will be only contextual which means that it is being placed where you can see it based only on the words or images on the page of the website you are viewing. (b) legitimate interests including our interests in providing, improving, and customizing our technology for our clients and customers and providing you with relevant advertising and content, unless those interests are overridden by your interests or fundamental rights requiring protection of personal information.
2.7 We process data primarily in the European Economic Area. However, we are a global company and occasionally will transfer data outside the EEA. In such instances, the data is pseudo-anonymised so that no data can be tied back to any user.
In addition, we use standard contractual clauses approved by the European Commission and may rely on the European Commission’s decisions about the adequacy of safeguards in certain countries, as applicable, including for data transfers from the EEA to the United States and other countries. You can contact us to request a copy of our Standard Contractual Clauses.
3. WHO ELSE MAY USE YOUR INFORMATION
3.1.1 to other members of our group, our partners and service providers (for example people who provide technical services to the Website) for the purpose of managing or administering certain aspects of our Website, or to help us develop new services;
3.1.2 to a third party or successor entity in connection with a corporate merger, consolidation, sale of all or substantially all of Vibrant’s assets, bankruptcy, or other corporate change.
3.1.3 if we are under a duty to disclose or share your personal information in order to comply with any legal obligation and/or in order to enforce or apply any other agreements between you and Vibrant; or
3.1.4 to protect the rights, property or safety of us or our users.
3.2 In addition to the information that we collect, a number of third parties may collect certain data when you visit websites using our technology. These third parties include:
3.2.1 our website publisher clients that operate websites that use our technology, who may use their own cookies and other technologies to collect information about the content of the sites that you visit and the advertising that appears on those sites; and
4. COOKIES AND OTHER TECHNOLOGIES
We have in place administrative, physical, and technical measures designed to protect the confidentiality and integrity of your data that we hold. These measures may include encryption and employment of information storage security technologies to restrict access to our network. In spite of these efforts, you should be aware that no method of transmitting information via the internet is completely secure.
6. PARTICIPATION IN SELF-REGULATORY PROGRAMS
We support the cross industry, Self-Regulatory Principles for Online Behavioural Advertising as managed by the European Digital Advertising Alliance (“EDAA”) (for more information click here) as well as the EDAA’s Self-Regulatory Principles for Multi-Site Data, and, in particular, the use of the Ad Choices icon. In support of the EDAA and to provide consumers with enhanced transparency, we display the Ad Choices Icon advertisements delivered across our network to help consumers understand how their data is being used and provides choices for consumers who want more control. The Ad Choices icon is customarily displayed within the frame of our advertisement. The Ad Choices icon provides information (and links to other information) on online ads, who may be collecting and using online data, and how you can exercise choice with respect to those companies participating in the EDAA program. Vibrant Media also (1) is a member of the Internet Advertising Bureau and abides by IAB’s Member Code of Conduct which you can review by clicking here and (2) is an NAI member and adheres to the NAI Code of Conduct (“NAI”) opt-out tool for behavioural advertising, which you can review at https://www.networkadvertising.org/choices.
7. INFORMATION ACCESS
7.1 Vibrant Media Limited is registered with the UK Information Commissioner’s office as a Data Controller in accordance with the Data Protection Act 1998 (DPA) with registration number Z526181X. The DPA provides a framework to ensure that personal information is collected and handled properly and gives individuals certain rights to know what information is held about them. More information can be found at www.ico.gov.uk.
7.3 If you are located in the EEA and we can properly identify you, you have a number of rights with regard to your personal information. For example, you have the right to access your information and to have inaccuracies in your personal information corrected.
8. CONTACT DETAILS FOR ADDITIONAL QUESTIONS AND/OR TO ISSUE A COMPLAINT
If you have any questions or comments, or complaints about our Website (www.vibrantmedia.com/en/) or about this privacy statement, please contact us by one of the methods below:
Via mail: Vibrant Media, Ltd. 33 Queen Street, London, EC4R 1BR
Via email: firstname.lastname@example.org
Via telephone: 020 740 0000