The Top 10 Myths in Programmatic Advertising
Before we close out the year, we had to put an end to these myths about programmatic advertising by circling back to a conversation with our founders. Marc Poirier, our CEO, sat down to debunk all the lies with our COO, Vincent Potier. If anyone has deep insights into the programmatic advertising industry, it’s him – he formerly established Captify as one of the leading ad tech companies in the UK, Europe and the US. In the interview below, Marc asked the tough questions, and Vincent shared his expert insights. See all of Vincent’s entertaining answers below in our top ten list of programmatic advertising myths (plot twist: one myth is partially true!!).
Myth #1 Programmatic Is Dead
While there will be turbulence, growth will continue on the back of important trends such as the continued rise of Connected TV (CTV).
“False of course. (…). No programmatic is not dead. Programmatic is going to go through turbulence but positive turbulence. It’s going to shake but it’s still going to grow and there is absolutely no doubt. I’ll just give you. You know. I’ll just give you two points. One is what scares people is they cannot say exactly how the programmatic spend is going to be structured in 2022, which is only a year away. So that is what is scaring people. Number two, the biggest trend in programmatic spend I would say in the last 18 months in the United States or in the North American market has been the rise of CTV. When you think about the rise of CTV, you need to parallel it to what powered internet advertising at the very beginning like 15 years ago – and it is a migration of spend dollars away from print to performance advertising on display. You’re getting exactly the same phenomenon now with TV money… traditional TV money being migrated into CTV and it is only the beginning. The prize is gigantic and you know what? CTV doesn’t rely on third-party cookies.”
Myth #2 – Walled Gardens Will Take All The Money
Facebook and Google both are struggling to maintain their growth pace.
“Of course not! The walled gardens are going to do everything they can not to lose money. Look at what’s been happening – which is unrelated to chrome and third-party cookies – but what we were talking about earlier… IOS 14. Facebook is actually suffering right now to keep the advertising spend, which basically they’re used to. So the walled gardens are obviously way more powerful because they represent, you know probably 80 percent of the programmatic spend in the market, today – Facebook, Google and to an extent Amazon. But I mean they could crumble at any time. So, I’m not worried at all for the independent money.”
Myth #3 – Advertisers Will Revert To Traditional Media
As they say, you can’t stop progress, and in this case, there is definitely no turning back now.
“It never happens. You know. It’s like saying that when you had the 1973 oil shock, people decided to park their cars in the garage and get back on bicycles. Humanity doesn’t progress like that, so of course not.”
Myth #4 – Contextual Advertising Will Rule The Day
While it will definitely become more important than it ever was, contextual advertising will likely not be the most important targeting method available to advertisers, far from it.
“Contextual advertising has a big problem, and the problem they have is the word contextual. Contextual has always been seen as a poor parent of advertising technology. Now, that said, many of the solutions, which are being thought about rely on contextual technology (which basically is a nice word for saying: analyzing the page on which you want to serve an ad). – and therefore, it is page targeting rather than user-level targeting. And contextual will have a big play in the new world post third-party cookie, but is it going to rule it? No, it’s not.”
#5 – Ad Tech Will Be Privacy-Free
Privacy is not only about capturing personal data, but it’s also about compliance. Ad Tech companies need to pay close attention to privacy legislation, even if they don’t collect personal data.
“Yeah, that’s one of the illusions that I hear a lot, today. So, it goes like this: okay, the third-party cookies are going away and new technologies, which do not use personal data – cookie IDs, device IDs, IP addresses – this is all considered to be personal data or personal information, according to all the new legislations about privacy and personal data. So, the reasoning goes like this: If I don’t deal with personal data in order to do targeting, therefore I don’t have to care about privacy anymore. Obviously, this is absolutely bonkers. Privacy is not only about capturing and collecting personal data. It is also about the privacy, and compliance of the publishers you work with, and also remember that personal data collection can happen before you target, but it can happen after you target also. What is true though, is if you stop using the equivalent of cookie IDs or IP addresses in order to do targeting, you could put yourself out of scope. So, it’s partially true.”
#6 – Y2K Of Cookies Is Coming
Google will not kill itself – it controls the market and needs to comply with legislation, advertisers should pay close attention to what Google is doing as they will definitely control the timing of cookie deprecation.
“Yeah! So, obviously, you know it’s wrong and for a very simple reason, there is a big guy who’s in control of the speed at which it goes. Remember the legislation here. They’ve existed for three years already, so it’s simply that Google just wants to make sure the market moves with the times. But they are always in control. You know, when you are a market maker of an ecosystem, you have no interest in having the ecosystem basically going through two troubled times.”
#7 – All The Money Will Go Back To Search Or Social
Social advertising is facing major issues currently as advertisers see their audiences dwindle to ever smaller numbers, and search growth has been slowing down for years. Growth will be in programmatic.
“Yeah, I mean social… I think we spoke enough about Facebook, so it’s not going to happen. And search is a more-than-mature market, so it’s obviously not going to be the case.”
#8 – The Silver Bullet Solution is Coming
We need a new currency, many solutions will emerge, and the market will select several, which will be the dominant solutions.
“Now, I think every time there is a transformation, people imagine there will be a silver bullet and that’s not the way the market works. The way the market works is when you’ve got a main commodity of the market or a currency (…) what happens is you’ve got plenty of solutions, which are going to compete with each other and then that diversity of solutions is actually going to diminish with time and then the market is basically going to chase a few solutions, which are going to be the dominant solutions of the market. But there’s not going to be a silver bullet, especially not in the short term.”
#9 We Will Revert to Data-less Advertising – True or False?
Advertisers will still use data, just different data solutions, less reliant on user-level targeting.
“It’s false. It’s just not going to be the same data, and I believe between now and the next 24 months, everyone and their brother is going to be a solution. But past 24 months, what we will see is a different data environment, which is probably not going to be as reliant on user-level targeting.”
#10 Does Anybody Know The Future?
The problem is every time we try to predict the future, we’re wrong. Winners are those who are ready to adapt by design.
“(…) The problem especially in technology, and the reality is, every single time you try to predict the future you’re wrong. In the future, there is such a range of possibilities that it is extremely hard. The true winners are not the ones who predict the future for sure. They are the ones who structure and shape their companies in such a way that at the core of the company, you’ve got not only privacy (of course you know privacy by design), but you’ve got something, I would call agility by design. That means the company is shaped in such a way that it can deal and cope with any kind of emerging future. These are the winners of tomorrow.”
Transcript
Marc Poirier: “In today’s episode, we’re going to talk about the top 10 myths surrounding the changes to the privacy landscape and the data world in advertising – let’s go!
Okay, we’re gonna play a little game… I’m gonna say 10 big bold statements that at Klever we think these are myths and you’re gonna say why they’re myths, okay?”
Vincent Potier: “Okay so they’re all myths so I can’t say true or false”
Marc Poirier: “Oh you can say it’s true, but we’ve had these discussions before (laughs).”
Vincent Potier: “Okay okay okay cool, so I’ll take the liberty then I’m listening.”
Marc Poirier: “All right number one, programmatic is dead.”
Vincent Potier: “False of course. Why would we be recording beautiful videos if we were afraid for our revenue? (Laughs). No programmatic is not dead. Programmatic is going to go through turbulence but positive turbulence. It’s going to shake but it’s still going to grow and there is absolutely no doubt. I’ll just give you. You know. I’ll just give you two points. One is what scares people is they cannot say exactly how the programmatic spend is going to be structured in 2022, which is only a year away. So that is what is scaring people. Number two, the biggest trend in programmatic spend I would say in the last 18 months in the United States or in the North American market has been the rise of CTV. When you think about the rise of CTV, you need to parallel it to what powered the internet advertising at the very beginning like 15 years ago – and it is a migration of spend dollars away from print to performance advertising on display. You’re getting exactly the same phenomenon now with TV money… traditional TV money being migrated into CTV and it is only the beginning. The prize is gigantic and you know what? CTV doesn’t rely on third-party cookies.”
Marc Poirier: “Second, the walled gardens of Google and Facebook and all these platforms with logged-in users will take all the money.”
Vincent Potier: “Of course not! The walled gardens are going to do everything they can not to lose money. Look at what’s been happening – which is unrelated to chrome and third-party cookies – but what we were talking about earlier… IOS 14. Facebook is actually suffering right now to keep the advertising spend, which basically they’re used to. So, the walled gardens are obviously way more powerful because they represent, you know, probably 80 percent of the programmatic spend in the market today – Facebook, Google and to an extent Amazon. But I mean they could crumble at any time. So, I’m not worried at all for the independent money.”
Marc Poirier: “Number three, advertisers will shift their money from digital to traditional media.”
Vincent Potier: “It never happens. You know it’s like saying that when you had the 1973 oil shock, people decided to park their cars in the garage and get back on bicycles. Humanity doesn’t progress like that, so of course not.”
Marc Poirier: “Number four – contextual advertising will rule the day.”
Vincent Potier: “Contextual advertising has a big problem, and the problem they have is the word contextual. Contextual has always been seen as a poor parent of advertising technology. Now, that said, many of the solutions, which are being thought about rely on contextual technology (which basically is a nice word for saying: analyzing the page on which you want to serve an ad). – and therefore, it is page targeting rather than user-level targeting. And contextual will have a big play in the new world post third-party cookie, but is it going to rule it? No, it’s not.”
Marc Poirier: “Number five, ad tech will be privacy free.”
Vincent Potier: “Yeah, that’s one of the illusions that I hear a lot today. So, it goes like this okay: the third-party cookies are going away and new technologies, which do not use personal data – cookie IDs, device IDs, IP addresses – this is all considered to be personal data or personal information, according to all the new legislations about privacy and personal data. So, the reasoning goes like this: If I don’t deal with personal data in order to do targeting, therefore I don’t have to care about privacy anymore. Obviously, this is absolutely bonkers. Privacy is not only about capturing and collecting personal data. It is also privacy, compliance of the publishers you work with, and also remember that personal data collection can happen before you target, but it can happen after you target also. What is true though, is if you stop using the equivalent of cookie IDs or IP addresses in order to do targeting, you could put yourself out of scope. So, it’s partially true.”
Marc Poirier: “Number six, there will be a Y2K of cookies.”
Vincent Potier: “Yeah! So, obviously you know it’s wrong and for a very simple reason, there is a big guy who’s in control of the speed at which it goes. Remember the legislation here. They’ve existed for three years already, so it’s simply Google just wants to make sure the market moves with the times, but they are always in control. You know, when you are a market maker of an ecosystem, you have no interest in having the ecosystem basically going through two troubled times.”
Marc Poirier: “Number seven, all the money will go back to search and social.”
Vincent Potier: “Yeah, I mean social… I think we spoke enough about Facebook, so it’s not going to happen. And search is a more than mature market, so it’s obviously not going to be the case.”
Marc Poirier: “Number eight, someone’s going to design like a silver bullet solution to all this.”
Vincent Potier: “Now, I think every time there is a transformation, people imagine there will be a silver bullet and that’s not the way the market works. The way the market works is when you’ve got a main commodity of the market or a currency (that’s what I’m looking for – a currency of the market). The third-party cookie was the currency of the market. Well, what happens is you’ve got plenty of solutions, which are going to compete with each other and then that diversity of solution is actually going to diminish with time and then the market is basically going to chase a few solutions, which are going to be the dominant solutions of the market. But there’s not going to be a silver bullet, especially not in the short term.”
Marc Poirier: “Number nine, we will revert to our 1990s style dataless-advertising, true or false?”
Vincent Potier: “It’s false. It’s just not going to be the same data, and I believe between now and the next 24 months, everyone and their brother is going to be a solution. But past 24 months, what we will see is a different data environment, which is probably not going to be as reliant on user-level targeting.”
Marc Poirier: “Number ten, does anybody know the future?”
Vincent Potier: “Of course, we don’t. I’ve got a theory about this, which is, hopefully, one day people will have the courage to tell that to their investors. The problem especially in technology, and the reality is, every single time you try to predict the future you’re wrong. In the future, there is such a range of possibilities that it is extremely hard. The true winners are not the ones who predict the future for sure. They are the ones who structure and shape their companies in such a way that at the core of the company, you’ve got not only privacy (of course you know privacy by design), but you’ve got something I would call agility by design. That means the company is shaped in such a way that it can deal and cope with any kind of emerging future. These are the winners of tomorrow.”
Image Credits
Feature Image: Screenshot taken November 2022 via Tenor.
Video via YouTube.
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Klever Programmatic, Inc- Privacy Notice
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 explain show 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, Suite410
Brossard, Québec J4Y 0B6
Canada
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 orany 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
- 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 orintentions, which either we infer from the above information or is provided tous 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 adcampaigns
- 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 chatconversations 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 net working, 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 ourcustomers in relation to their campaigns and contracts with us in order toensure 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 are quest 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:
https://cookieinformation.com/what-is-a-cookie/.
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 beforgotten”)
- to receive personal data which you have provided to us (“portability”)
- to object to processing of your personal data for direct marketingor for certain other purposes
- to restrict our processing of your personal data in certaincircumstances
Consumers who are resident in US states such as California, Colorado, Virginia, Connecticut, Utah, Texas, Florida, Oregon, and Montana (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 optout 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.
12. Additional Information For California Consumers
12.1 Personal Information Collected in the past 12 months
Category
Examples
Source
Business or Commercial Purpose
Categories of third parties disclosed to
Identifiers
Unique personal identifier, online identifier, Internet Protocol address (e.g. device and cookie IDs)
From ads
From our customers From third party data providers
Providing and improving our services which include ad targeting and performance measurement
Providing and improving our services which include ad targeting and performance measurement
Providing and improving our services which include ad targeting and performance measurement
Providing and improving our services which include ad targeting and performance measurement
Providing and improving our services which include ad targeting and performance measurement
Providing and improving our services which include ad targeting and performance measurement
- Our customers
- Our data hosting and storage providers
- Our providers of advertising technology and services such as demand side providers,
data management platforms, and ad networks
- Our data processing service providers (for purposes such as analytics, database management, customer support)
Commercial information
Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies (e.g. sites visited, apps used, searches, views, clicks, and purchases)
As above
As above
As above
Internet or other electronic network activity information
Information regarding interactions with ads, websites and applications (e.g. sites visited, apps used, searches, views, clicks, and purchases)
As above
As above
As above
Geolocation Data
Approximate geolocation from information provided by a device (e.g. IP address)
As above
As above
As above
Sensitive personal information
Information concerning a consumer’s health (where permitted); precise geolocation
As above
As above
As above
Professional or employment-related information
Contact information used for managing and transacting with business contacts (e.g. customers and suppliers)
From individuals directly, e.g. via correspondence, chat, telephone, or web forms. From events and online and offline networking. From private and public sources such as websites and trade directories.
Promoting and managing our business
- Our data processing service providers (for purposes such as analytics, database management, email management, customer support)
- Our other group companies
12.2. Personal Information Sold or Shared in the past 12 months
We have sold and/or shared (with our customers) the following categories of personal information in the past 12 months: (a) Identifiers; (b) Commercial information; (c) Internet or other electronic network activity information; (d) Geolocation Data; (e) Inferences; and (f) Sensitive Personal Data.
12.3. Personal Information disclosed for a business purpose in the past 12 months
We have disclosed the following categories of personal information for a business purpose in the past 12 months: (a) Identifiers; (b) Commercial information; (c) Internet or other electronic network activity information; (d) Geolocation Data; (e) Inferences; (f) Sensitive Personal Data; and (g) Professional or employment-related information.
These business purposes comprise:
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Helping to ensure security and integrity.
- Debugging to identify and repair errors that impair existing intended functionality.
- Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf.
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of our Services, and to improve, upgrade, or enhance our Services.
Last updated: July 2024
Privacy - Privacy Notice
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 explain show 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, Suite410
Brossard, Québec J4Y 0B6
Canada
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 orany 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 net working, 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 ourcustomers in relation to their campaigns and contracts with us in order toensure 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 are quest 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 2023