1. INTRODUCTION

Klever provides trading desk services to support our customers in buying, managing, and optimizing data-driven digital advertising campaigns across multiple platforms, devices and formats. In providing these services we may process your data if you are a user or potential user of our customers’ products, services, websites or media, or if you are or work for one of our customers or other business contacts.

This Privacy Notice explains how Klever uses and protects personal data and information. Klever is committed to respecting all applicable privacy laws and ensuring your data is secure. This Notice does not apply to our processing of data of Klever employees or employment candidates, which will be communicated separately.

Klever may change this Notice from time to time by updating this page. You should check back to ensure that you are up to date with any changes.

 

2. WHO WE ARE

The entity that takes decisions regarding why and how your personal information is processed (also referred to as a “Data Controller”) is:

Klever Programmatic, Inc. (“Klever”) (incorporated in Canada)
6000 Boulevard Rome, Suite 410
Brossard, Québec J4Y 0B6
Canada
[email protected]

We have appointed our Chief Operating Officer as our Privacy Officer to oversee our data processing compliance and to be a point of contact for inquiries, who may be reached at the above addresses.

 

3. CATEGORIES OF DATA THAT WE PROCESS

A. Internet and media users: In providing our advertising-related services we may have access to data generated by publishers or advertisers from viewers of their websites, apps, connected televisions, or other media. We ourselves do not collect this data, but this data may be disclosed to us by customers or advertising technology partners who work with us on advertising campaigns.

In general, this information relates to online behavior and does not contain real life names or addresses or any other information that could allow anyone directly to identify or contact a particular person. Information we receive may include the following:

• cookie IDs
• device IDs
• advertising IDs (such as mobile advertising IDs)
• mobile device usage data (such as apps used)
• browser and device type, version and settings (“user agent”)
• IP addresses that reveal approximate location of the device
• webpage browsing information e.g. urls visited or searched
• interactions with ads (e.g. views, clicks, purchases)
• advertising bid requests
• profile data, including likely characteristics, interests or intentions, which either we infer from the above information or is provided to us by customers and partners.

B. Business contacts: If you or your employer is a Klever customer (or potential customer), or one of our suppliers (or potential suppliers), an investor or potential investor, or other business contact, then we will need to collect certain personal contact information in connection with our relationship with you. This information may also come from our third party marketing partners. This may include:

• your name
• company name
• position
• professional qualifications or interests
• mailing address
• web address
• telephone numbers
• e-mail addresses
• details of products and services, and
• information provided to us in the course of correspondence with you (e.g. by email, phone, or online messaging).

4. PURPOSES FOR WHICH WE PROCESS DATA

We collect and use personal data for the following purposes:

A. Internet and media users

• personalizing, targeting and delivering ads
• limiting the number of times ads are seen
• measuring effectiveness and viewability of ads
• measuring clicks, purchases or other actions
• keeping records, reporting to customers and billing for ad campaigns
• making links between devices that might relate to the same users
• preventing fraud or invalid activities.

In Canada, the EU/EEA and UK our legal basis for this data use is your consent, which the relevant publisher or brand needs to have obtained from you in accordance with local laws. You can manage your consents as set out in Section 9.

B. Business contacts

• setting up, renewing, updating, and managing your or your organization’s contract or account with us
• billing and collections for services we provide
• making payments for products and services supplied to us
• evaluating new services and products
• investor relations
• recordkeeping, accounting and meeting other legal requirements
• managing, improving and expanding our business and resources
• communicating with you and managing our relationship with you
• answering inquiries including email, telephone, and chat conversations with sales and customer support staff
• responding to customer services requests
• organizing events such as webinars
• sending promotional communications and offers
• sending PR or company information (e.g. if you are a journalist or influencer)
• asking for feedback on our products and services
• understanding visitors’ navigation on our websites to understand trends and user interests and requirements.

In the EU/EEA and UK our legal basis for this data use is compliance with our legal obligations, performance of our contracts, or our legitimate interests which are compatible with your interests and rights. In Canada our legal basis for this data use is where possible your consent, which may be express or implied in accordance with local laws.

5. MEANS OF DATA COLLECTION AND DATA SOURCES

A. Internet and media users: This data may be disclosed to us by our customers in connection with their ad campaigns, or by or through demand-side platforms (DSPs) or ad exchanges through whom we buy online advertising or receive information in relation to pricing and performance of advertising.

B. Business contacts: We obtain this information directly from you or your employer, for example through exchanging emails or business cards, industry events, online or offline networking, business directories, publicly available information such as your organisation’s website and online channels, requests for proposals, or in-person meetings. In addition, if you visit our website, we may collect data using cookies and similar technologies.

6. RECIPIENTS AND INTERNATIONAL TRANSFERS

Our corporate headquarters is located in Brossard, Québec, Canada. Your personal information may be stored and processed in any country where we have facilities or service providers that we work with, e.g. for audience measurement, secure hosting, data storage, ad exchanges and DSPs.

We also provide data to our customers in relation to their campaigns and contracts with us in order to ensure proper billing and improve future campaigns.

 Where we send data originating from the EU/EEA, the UK, or Switzerland internationally (other than to Canada or other places that are officially regarded as having adequate data protection laws), we put in place safeguards designed to ensure that data is processed in a way equivalent to the rules applicable under the EU and UK General Data Protection Regulations. These may include standard contract clauses for data transfers as approved by the European Commission or other supervisory authorities. A copy of these safeguards may be made available if we receive a valid request. When transferring data outside Québec or Canada, we will do so where we have assessed any privacy impact and concluded that the data will receive adequate protection.

Occasionally we may receive a request from a government, law enforcement agency or regulator requesting data from us, and we would normally comply with such request without having to notify you.

7. DATA RETENTION PERIODS

We only retain data for as long as necessary for the purpose for which the data was collected. So we will retain your account data for at least the time that you or your organization has an account or contract with us. If you have subscribed to a newsletter or other communications, we will keep your contact details until you unsubscribe.

 We retain device IDs and related data for up to eighteen months for billing and service management purposes. Aggregated and anonymized or statistical data may be retained for a longer period for reporting, testing, tax or legal reasons.

8. SECURITY

Once the retention periods are reached and data is no longer required, such data is anonymized so that it does not relate to any identifiable person and is not used for our services.

We implement and require our third party suppliers to implement security measures, including physical, logical, contractual, and organizational safeguards, to prevent unauthorized access to, loss, misuse, or alteration of the information that we process in connection with our services. We consider these measures to be appropriate given the low levels of sensitivity of the data that we access, and in line with all applicable laws and good industry standards.

9. PRIVACY TRAINING AND GOVERNANCE

We ensure that our personnel in roles that have a need to access personal information have appropriate and recent training regarding provincial, national and international personal information protection laws and practices. We also have in place internal policies which set out our framework for the keeping and destruction of personal information, limiting its collection, use, disclosure and retention, the roles and responsibilities of staff throughout all stages of its processing, including dealing with requests and complaints from individuals, data incident response plans, and all other aspects addressed by this Privacy Notice.

10. COOKIES

A cookie is a small piece of data sent from a website and stored in a user’s web browser or device. Every time the user loads the website, the browser sends cookie information back to the server to notify the website that it recognizes the user. You can find more information about different types of cookies here.

We use cookies when you visit our websites, for the purposes of analyzing use of our websites, and improving and optimizing our websites and services.

You can remove cookies from your web browser by following the directions provided in your browser’s “help” or “settings” sections. Some cookies may be essential for using different features of certain websites, so if you clear all cookies then those features may not work as expected, or you may need to accept some cookies on your next visit. For mobile devices please review the privacy controls within your mobile operating system.

11. YOUR RIGHTS

In relation to online advertising data, there are various methods that enable you to manage consents and data use directly, without contacting publishers or media owners:

• for the USA: www.aboutads.info/choices and www.networkadvertising.org/choices
• for Europe www.youronlinechoices.com
• for Canada: youradchoices.ca/choices
• for mobile devices: http://www.networkadvertising.org/mobile-choice
• for connected TVs: https://www.networkadvertising.org/internet-connected-tv-choices/

Some of these methods may place a cookie on your device to identify you as not wanting to receive targeted ads so, if you change devices or delete cookies, you may need to repeat this process.

In addition, under international data protection laws, including the GDPR in the EU/EEA or the UK and PIPEDA in Canada, you may have various additional rights such as the following:

• to access your personal data
• to require us to correct mistakes in your personal data
• to have personal data concerning you erased (“the right to be forgotten”)
• to receive personal data which you have provided to us (“portability”)
• to object to processing of your personal data for direct marketing or for certain other purposes
• to restrict our processing of your personal data in certain circumstances

Consumers who are resident in US states such as California, Colorado, Virginia, Connecticut, or Utah (and others in the future) may have additional rights under state privacy legislation. Depending on the particular provisions of such local laws, you may have some or all of the following rights:

• to have inaccurate data corrected
• to access and know what personal information we collect and hold, from which types of sources it was obtained, for what purposes, and the types of third parties it is shared with
• to opt out of sales or sharing of personal information
• to request deletion of personal information that we collected from you
• to limit use of sensitive information
• to not be discriminated against for exercising your rights (e.g. we would not deny you goods or services, charge you a different price, or provide you a different level of quality).

Where our use or communication of your data is based on your consent, then you can always withdraw that consent (but any processing that took place before withdrawal will still be legal).

If you wish to exercise any of your legal rights, or have another issue or inquiry, it may be easiest to contact the publisher or media provider to whom you originally gave your consent. In other cases, please contact us using the details in this Notice and we will help as far as possible. Please note that we may ask you to verify your identity before acting on your request. If you believe that we have not respected your rights then you may also have a right to challenge our compliance before the supervisory authority in your country.

Last updated: 26 January