This Website and the services eventually offered through the Website are reserved to subjects over the age of 18 years old. Hereby, the Controller does not collect personal data pertaining to subjects under the age of 18 years old. At request of the Users, the Controller will promptly delete all the personal data, involuntary collected, pertaining to subjects under the age of 18 years old.
The Users’ personal data will be processed by the Controller lawfully pursuant to art. 6 of the Regulation for the following processing purposes:
The Controller will carry out the processing of Users’ personal data by manual and IT instruments, applying logics strictly connected to the purposes and, in any case, so that the safety and confidentiality of the relevant data is guaranteed.
Users’ personal data will be retained for the time strictly necessary to carry out the relevant purposes described in the previous paragraph 1, and in any case for the time necessary for the protection of the civil interests of the Users and of the Controller.
Controller’s employees and/or workers appointed to manage personal data may become aware of any Users’ personal data. Such subjects, who are formally appointed by the Controller as persons in charge for the processing, will process the relevant User’s data exclusively for the purposes specified under this policy and in compliance with the provisions of the Applicable Law.
Furthermore, third parties which may process personal data for the account of the Controller may become aware of any Users’ personal data in their capacity as “external data processor”, such as, including, but not limited to, providers of logistics and IT services functional for the Website operational, outsourcing or cloud computing services providers, professionals and advisors, companies entrusted with the sending of marketing e-mails for the account of the Controller.
Users have the right to obtain a list of the data processor (if any) appointed by the Controller upon a specific request to be made to the Controller following the modalities specified under the following paragraph 4.
Users may exercise the rights granted to them by the Applicable Law, contacting the Controller with the following modalities:
Pursuant to the Applicable Law, the Controller hereby informs that any Users has the right to obtain the indication of (i) the source of the personal data; (ii) the purposes and methods of the processing; (iii) the logic applied to the processing, if the latter is carried out with the help of electronic means; (iv) the identification data concerning data controller and data processors; (v) the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated data processor(s) or person(s) in charge of the processing.
Furthermore, data subjects have the right to obtain:
a) access, updating, rectification or, where interested therein, integration of the data;
b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
Furthermore, Users have:
a) the right to withdraw the consent at any time, when the processing is based on consent;
b) the right to data portability (if applicable), that is the right to receive all the personal data concerning the User, in a structured, commonly used and machine-readable format; the right to restriction of processing of the personal data; the right to erasure (right to be forgotten).
c) the right to object:
i) in whole or in part, on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
ii) in whole or in part, to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys;
iii) if personal data are processed for direct marketing purposes, to object at any time to the processing for such marketing, which includes profiling to the extent that is related to such direct marketing.
d) the right to lodge a complaint with a supervisory authority (in the Member State of him or her habitual residence, place of work or place of the alleged infringement) if the User considers that the processing of personal data relating to him/her infringes the Regulation. The Italian Data Protection Authority is the Garante per la protezione dei dati personali, with registered office in Piazza di Monte Citorio, n. 121, 00186 – Rome (http://www.garanteprivacy.it)
1. GENERAL INFORMATION
PRECISO SRL is advertising technology company that provides online advertisement services to advertisers (such as e-commerce stores or online stores) in the programmatic advertising environment. Our role is to give advertisers a precise platform to show display ads of their products on various publishers’ websites which is both in desktop and mobile environments. The ads we show are personalized according to the information on user previous online activity. We will display to the ads of those advertisers whose websites or apps they had visited in the past or ads that we believe otherwise match their current shopping interests.
In order to serve personalized ads, we process certain information related to their online activity that helps us understand what users current shopping interests might be and allows us to display an ad and analyze how it performs. While doing so, we aim at ensuring the highest level of privacy protection and transparency. We comply with the European General Data Protection Regulation (GDPR).
2. HOW DO WE COLLECT DATA
3. WHAT DATA WE PROCESS
We process the following groups of data:
(a) Information related to user browsing activity on advertisers’ websites or apps — it helps us understand what sorts of products and services they are interested in and, consequently, determine which ads should be displayed to them match their current shopping interests. We process this data on behalf of the advertisers for whom we conduct advertising campaigns (as a data processor), specifically for the purpose of creating their user profile.
(b) Information that users are currently entering a publisher’s website or app, where we may display an ad to you — it comes within a so called bid request, which is an offer to buy an advertising space on the publisher’s website or app in order to display an ad (for details, see Section 4 below). We process this information as a data controller for the purposes of displaying ads, ad measurement, brand safety, product development, and fraud detection.
(c) Information regarding the delivery of our ads, i.e., impressions of an ad (e.g., whether we displayed an ad to users and, if so, which ad we selected) and their interactions with an ad (e.g., whether they clicked on it). We process this information as a data controller for the purposes of displaying ads (in particular for frequency capping and ad rotation), ad measurement, and product development.
Users may find a full list of categories of data we process as a data controller in our GDPR privacy notice (see Section 5 below).
While providing our services, we do not collect personally identifiable information (PII), such as names, e-mail addresses, postal addresses, telephone numbers, or financial data, such as credit card details.
We do not receive any additional data from advertisers or partners, which, along with the data collected by our technology, would enable us to directly identify users.
4. HOW WE USE DATA
While users are visiting an advertiser’s website or app, we collect certain information related to their activity there, such as which items they viewed, put in the basket, and bought. Those browsing patterns on the advertiser’s website or app help us understand what sorts of products and services they are currently interested in and thus display to them, on publishers’ digital properties (e.g., news portals), only ads compatible with these interests.
We display our personalized ads with the use of a programmatic auction system known as real-time bidding. Real-time bidding procedure happens at the moment users enter a publisher’s website or app that offers an advertising space for sale. While such website is loading, a bid request is sent to us by the publisher or our business partner cooperating with the publisher (supply-side platform) inviting us to buy a certain ad space. After receiving such bid request, our technology uses information about your previous browsing activity on advertisers’ websites or apps to decide whether to buy the auctioned ad space and, if so, which ad to display.
For instance, if users had recently visited our client’s website looking for a pair of pants, we may display to them an ad of those same pants they had viewed there and similar pair of pants or complementary products, such as belt or shirt offered by that same advertiser.
We may also use information on the content of the website where the ad is to be displayed for the additional personalization of this particular ad. However, we never use such website content to personalize future ads, in particular we do not assign this information to their user profile in order to categorize them such as grouping them to a particular segment) or try to determine their shopping interests on the basis of their browsing history on publishers’ websites or apps.
Moreover, we do not use their browsing data across advertisers, which means that a browsing activity from one advertiser’s website or app does not affect other advertisers’ ads we display. For instance, the fact that they looked for a pair of pants in our 123 Client website, it will not result in us displaying them a pair of pants from our XYZ Client website except when they had previously browsed similar products on that a XYZ Client website too.
After we display an ad to users, we collect information regarding ad impressions, that we actually displayed an ad to the users, which ad was selected, and when and on what type of device it was displayed) and users interactions with the ad (mainly whether they clicked on it or not). We use this information for the analysis of how our ads perform, for the creation of statistical reports for advertisers regarding the delivery of their ads, and subsequently for attribution and billing purposes. We also process this data for the control of the frequency of ads we display to users under frequency capping and for campaign improvement purposes.
Preciso bidder is integrated with the real time bidding environment through matching of our technical identifiers, e.g., cookie IDs or mobile advertising IDs (“cookie matching”) with those used by our technology partners. It enables us to (a) receive a bid request and eventually serve an ad on a publisher’s website or app that uses our business partners’ digital advertising technology and (b) collect information related to our ad serving activities.
Upon an advertiser’s specific request and on the basis of the information provided by such advertiser, we may perform cross-device tracking that consists of displaying the same categories of ads of this particular advertiser’s products or services on different devices you use (e.g. laptops and smartphones). We do not, however, perform specific data analyses in order to link the devices that users use on the basis of the patterns of their online behavior. Preciso does not do probabilistic cross-device tracking.
We also utilize user personal data for the detection of frauds and other potential dangers to privacy security, for the calculation of the usage levels of our technology, and for brand safety purposes, i.e., to analyze whether publishers’ websites are a suitable environment for our ads to be displayed and to develop and improve our products.
We do not purchase any third-party data from data providers for service optimization purposes or sell data we process to any third parties.
Advertisers and publishers whose websites or apps that users visit may independently collect and use their data for different purposes. Please consult their privacy policies for more information in this regard.
5. PERSONAL DATA PROCESSING (GDPR)
Although, as described above, we do not collect personally identifiable information (PII), the data we do process is tied to unique online identification numbers that, under the GDPR, are considered “online identifiers” that allow us to “single out” a specific user from other users. According to the GDPR, such information may be considered personal data (this type of non-personally identifiable data is referred to as “pseudonymous data”). Consequently, in cases where the GDPR applies to our services, we assure compliance with all the requirements established by this regulation.
In these California Consumer Privacy Act Disclosures (“CCPA Disclosures”), we, PRECISO SRL. (“PRECISO”, “we”) disclosure information about our data processing practices as required by the California Consumer Privacy Act of 2018 (“CCPA). These CCPA Disclosures are effective January 1, 2020.
I. Who and what information is subject to these CCPA Disclosures?
California residents are protected as “consumers” by the California Consumer Privacy Act of 2018 (“CCPA”) with respect to personal information.
II. How can a consumer with a disability access these CCPA Disclosures?
Consumers who have a visual disability may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this notice.
We are providing the disclosures about consumer rights and our personal information handling practices in the preceding twelve months, as required by the CCPA and regulations of the California Attorney General.
7. DATA SECURITY MEASURES
We have implemented organizational and technical measures to assure an appropriate level of security of user data. We have deployed procedures regarding every aspect of data processing, and we carefully select technologies used for such processing and any data recipients.
User data is protected against human interactions, equipment malfunctions, internal or external attacks, losses, or misuses. In order to ensure the ongoing confidentiality and availability of user data, we use encryption and a back-up mechanism. We constantly monitor the implemented security measures and develop the awareness and knowledge about privacy and personal data protection at our company on an ongoing basis.
If you have any further questions related to your privacy, please do not hesitate to contact our Chief technology Officer:
If users have any concerns about their privacy after having been acquainted with the extent, purpose and how Preciso process the data collected, they may opt out to disable Preciso from collecting information from their browser which will also result in the deletion or effective anonymization of all data previously collected. In order to opt out from Preciso, please, visit Preciso Opt-Out Link.