Vizury provides the following offerings to its clients (“Advertisers”):
a. Retargeting services wherein Vizury uses User’s behavioral data collected through Advertiser’s desktop or mobile website or mobile application to display personalized ads on its publishers’ desktop or mobile website or mobile application (“Partners”)
b. Push notification services wherein Vizury uses User’s behavioral data collected through Advertiser’s desktop or mobile website or mobile application to display personalized notifications on such Advertiser’s desktop or mobile website or mobile application
Together Retargeting services and Push notification services shall be referred to as the (“Services”)
Vizury considers the privacy and security of Users as critical and is committed to protecting the same. (“User”) means a visitor to the Advertiser’s desktop or mobile website or mobile application.
2. Nature of data collected
Vizury collects the following types of “Performance Data” pertaining to the Users:
a. The type of browser and its settings
b. Information about the device’s operating system and type of device including pseudonymous identifiers assigned with the device, such as Apple’s Identifier for Advertisers (IDFA) and Google’s Advertising ID for Android devices (AAID)
c. Cookie information
d. The IP address from which the device accesses Advertisers’ websites or apps
e. In connection with receiving requests to show ads to a device or requests initiated by Advertisers to track activity or place users into interest-based segments, information about the user’s activity on that device, including web pages and apps visited or used and the time those web pages and apps were visited or used
f. Information about the geographic location of the device when it accesses a website or app (only if Advertisers have informed a User that this information will be shared with Vizury or another third party and the user hasn’t disabled the location services settings and/or consented to this information being shared)
g. Inferences or information about users’ interests that are used by Advertisers (commonly known as “interest-based segments” or “segment data”) to target ads/impressions to users.
B. Push Notification
a. In addition to Performance Data, Vizury also collects username of Users (only if Advertisers share the same with Vizury) (“Push Notification Data”)
Together, Performance Data and Push Notification Data shall be referred to as “Data”
b. Vizury may also receive Data of Users from its third party Adexchanges.
Vizury uses the Data to provide Services to Advertisers by showing Users product recommendations by doing the below:
a. Interest-based advertising/notifications
b. Limiting the frequency a user sees a particular ads/notifications
c. Displaying ads/notifications in a specific sequence
d. Customizing ads/notifications to a specific location
e. Determining how users respond or may respond to ads/notifications
f. Reporting aggregated statistics regarding, for example, the effectiveness of online advertising campaigns
g. Our platform may use Data for cross-device mapping in order to serve or measure advertising on related devices on behalf of Advertisers.
5. Duration, location of storage and security of Data
a. Vizury keeps the Data for up to 750 days
b. The Data is stored in a Vizury owned AWS account located across US/Singapore/India/Japan
c. Vizury has a robust business continuity policy in place which covers its backup practices
d. Vizury has secure systems to encrypt the transmission of Performance Data from the websites or mobile applications to Vizury servers where supported by Advertisers or Partners with whom Performance Data is exchanged.
e. Vizury has commercially reasonable safeguards in place to ensure that all the Data collected and stored by Vizury is safe from unauthorized access, use or disclosure.
f. Vizury works towards continually improving its security practices in order to secure the Data.
6. Third Party Transfer and Access
In case of Facebook DPA based retargeting- Vizury shares information about the User’s activity on that device, including web pages and mobile apps that are visited or used. Vizury also shares the Device ID and cookie with some of its Partners to provide the Services.
The Data will also pass through our infrastructure provider systems – AWS and in case of Retargeting Services, Performance Data will be accessed by Partners to enable the provision of Retargeting Services
Apart from the above Service related transfer and access; Vizury will not share Data with organizations or individuals external to Vizury unless it is essential to meet:
a. Applicable laws, regulations, legal processes or enforceable governmental request.
b. Enforce applicable terms of service, including investigation of potential violations.
c. Detect, prevent or address fraud, security or technical issues.
d. Protect against harm to the rights, property or safety of Vizury, users or the public as required or permitted by law.
7. Legal Basis
With respect to Retargeting Services, Vizury acts as an intermediary between Advertisers and Partners and with respect to Push Notification Services, Vizury acts as a vendor. Hence, in both cases, Vizury is not facing the User. Therefore, Vizury considers unambiguous consent as the most applicable basis for its’ Advertisers and Partners who collect Data, including technical identifiers.
Under GDPR, with respect to Performance Data, Vizury acts as a co-data controller with Advertisers and Publishers.
Under GDPR, with respect to Push Notification Data, Vizury acts as a processor and the Advertiser acts as the controller.
8. Rights of User
a. Correction and Deletion
With respect to Retargeting Services, because Performance Data processed is pseudonymized data, it is generally not feasible for Vizury to provide Users information that is associated with their identities.
In relation to the Services, if the User believes that Vizury holds information that would allow Vizury to correct, amend or delete inaccurate information about the User, User may contact Vizury as mentioned below. Vizury will undertake reasonable efforts to provide access to such data within a reasonable time.
b. Limit usage
The User may also have the right to restrict the processing of the User’s Data. To make a request, or if the User needs assistance with this process, User may write to email@example.com .
For desktop and mobile web browser, the User may CLICK HERE to opt out of (disable) re-targeting ads displayed by Vizury through his computer or mobile device.
Opting out of Vizury services through this link from User’s browser inserts a cookie on the User’s browser. Vizury relies on this cookie to identify an opted-out user. Vizury will not be able to identify an opted out User, if the User
a. Clears the cookie from his/her browser,
b. Uses a different browser
c. Uses a different computer
For mobile applications, the User may disable re-targeting ads by activating the “opt-out” options through the settings on their mobile devices or by sending a mail to firstname.lastname@example.org with a request for opting out and mentioning the device identifier of their mobile device.
Opting out of Vizury services from User’s mobile device enables Vizury to identify an opted-out user. Vizury will not be able to identify an opted out User, if the User
a. Resets the device identifier of User’s mobile device,
b. Uses a different mobile device
Vizury will discontinue re-targeting activities for an opted out User within a reasonable time after opt-out. This means that Vizury will not track an opted out User’s behaviour or display customized ads to the User. However, an opted out User may be able to view generic Vizury ads which are not customized based on the User behaviour.
B. Push Notification
To opt out of push notification, User needs to disable the notification setting on his/her browser and mobile application.
Additionally, User may write to email@example.com for any such requests.
Once disabled, User will stop receiving notifications immediately.
To enable the Retargeting Services, CLICK HERE (if a User had Opted-out earlier).
To enable the Push Notification Services, User needs to re-enable the notification setting on his/her browser and/or mobile application.
11. Contact Information
In case of any requests, queries, complaints, please contact Vizury by writing to firstname.lastname@example.org.
13. Third parties
Vizury does not control the privacy policies, content or cookies of the Advertisers or Partners.