Readpeak Platform Privacy Policy
In this Privacy Policy you will find information on the processing of personal data that takes place in Readpeak platform and services. In this Privacy Policy, we explain how to track users’ interactions with client advertisements and websites to provide advertising services to our clients. To ensure your privacy, Readpeak complies with all applicable legislation such as the EU General Data Protection Regulation (GDPR), the ePrivacy Directive and the UK GDPR. We generally rely on consent obtained for us by the clients that use our platform and services. We are a registered vendor in the IAB Europe Transparency and Consent Framework (TCF) and rely on it to receive and honour your privacy choices. Our platform is designed to collect and use pseudonymous data, such as cookie IDs, mobile advertising identifiers and IP addresses. We do not collect directly identifiable data like your name or address, nor do we collect sensitive data.
For privacy information related to the Readpeak website, please visit Website Privacy Policy and Cookie Policy.
About Readpeak Services
Readpeak provides a digital advertising technology platform that is used by advertisers to buy advertising space on websites, mobile applications (browser and in-app) and similar online media sites. The buying is done via automated bidding on the platform. The platform and related online advertising technology services offered by Readpeak aim at helping advertisers deliver more relevant ads to customers and reduce the advertising pressure. This includes matching advertisers with audiences whose interests are relevant to the advertiser’s ad campaigns. The services also comprise other functionalities, such as capability to measure the effectiveness of ad campaigns by collecting and analyzing data of displayed ads, to prevent fraudulent activities and malware, and to predict the coverage of ads.
Data Collection
As part of the services, Readpeak tracks end users’ interactions with client advertisements and with client websites such as how many times advertisements are clicked or viewed. This tracking is carried out through Readpeak’s platform as well as on our clients’ website.
As part of the tracking process, Readpeak collects data such as IP addresses, cookie IDs, mobile advertising identifiers and other digital identifiers. In addition, Readpeak collects technical information related to your device, such as the name and version of your browser and your operating system. Readpeak does not collect data that identifies an actual person or could be directly connected to an identifiable individual. No sensitive data is collected either.
We collect data though our tracking technology which employs cookies and similar technologies. We may also receive data though our platform’s clients as well as through bid requests. Bid requests are sets of information that describe an ad space that is available to be filled. Bid request may also have an ID (or IDs) that enables us to match the request with information we may already have.
Readpeak’s tracking technology may employ tracking pixels on clients’ sites as well as data feeds from client or from third parties. A tracking pixel is a piece of code embedded on a web page of client sites that collects information about visitors’ behavior on that web page, such as the URLs the visitor has visited. The tracking pixel can either be provided by Readpeak or by our technology partners. The tracking pixel may include a command to create a Readpeak cookie or a third party cookie. When the tracking pixel of our advertising partners is placed on publishers’ sites, a third party cookie (or third party cookies of third parties acting on the advertiser’s behalf) may be placed on the users device. Such cookies are placed for the purposes of providing analytics to our advertising partners with regards to the campaign performance.
We always require our advertisers to disclose the use of third party pixels and/or cookies to end users via their website. We also verify that only pixels or cookies of partners that follow the IAB Europe Transpancy and Consent Framework (TCF) standards and are listed in the IAB Global Vendor List can be placed. As these cookies and/or pixels are added at the sole discretion of our advertising partners, users will be subject to their privacy notice and/or privacy policy. For clarity, Readpeak does not collect or gain access to this data, but only enables third parties to directly collect data via pixels and cookies in order to provide measurement information of the campaign to advertisers.
A cookie is a small text file that can be stored on a user’s browser and that enables tracking activity from a browser. Readpeak may serve ads based on the websites and apps a user has visited or based on ads a user has clicked. You can read more in our Cookie Policy.
Readpeak may also conduct cookie syncing with third-party platforms such as Google, Xandr, or Taboola. Cookie syncing means the process of matching the unique user ID across the third-party platforms. The purpose of cookie syncing is to serve targeted and tailored ads and to evaluate the performance of advertising campaigns run through the Readpeak platform.
Mobile device IDs, which are made available through the device operating systems, like Apple’s iOS and Google’s Android, for purposes of allowing mobile apps and their advertising partners to recognize a device over time. We use these IDs in a similar way to the way we use cookies.
In addition to Readpeak’s tracking technologies and Reapeak’s data collection described above, Readpeak’s clients (publishers and advertisers using our platform) may provide us with data, such as customer data or online behavioural data, via our platform (“client data”). Readpeak processes such client data on behalf of that client as a data processor.
Data Use
Readpeak uses the data to provide advertising services to its clients. This includes the following advertising-related purposes:
- Data is used to analyze and report on advertising performance. This includes processing data so that the actions of users can be matched with particular campaigns, targeting data, publishers, and specific advertisements.
- Data is used to improve online advertising experience and efficiency for example by displaying ads in a particular sequence, displaying particular content in response to users’ interests, displaying ads based on statistical probabilities, or by determining which ads to show or whether any ads should be displayed at all. Data can also be used for predicting the likelihood that users will engage with certain ads.
- IDs may be used to limit advertising exposure for browsers and enable more relevant advertising.
- IDs are used also to comply with users’ opt-out requests.
- Data is used to prevent denial-of-service attacks and other fraudulent activities, such as the use of bots or malware.
- IDs can be synchronized with other online advertising services for the purposes of serving targeted and tailored ads and to evaluate the performance of advertising campaigns run through the Readpeak platform. This is a core functionality of the digital advertising ecosystem, as it enables linking up data from multiple advertising services providers. No other data is used for this purpose.
- Data is used to enable the buying and selling of online advertising. This includes calculating a price for a bid or bid request and the submitting of bid requests or bids to partners.
In addition, data is used for internal research and service development, for example analyzing the use of Readpeak’s services; developing new services, for improving existing features and functionalities of services; and for developing and training the computer algorithms which form part of our services.
Data Retention
The typical lifetime of the cookies created in context of the services is 90 days, although this duration may be changed to a different and shorter duration within the scope of what is permissible by law at any time and without advance notice to our clients and end users.
The collected data is stored for 13 months.
For more information on cookies and retention times, please see Cookie Policy.
Legal Basis for Processing
Data is collected only when there is a valid legal basis for doing so. We place cookies on the basis of user’s consent. Further processing of data may be based on our legitimate interest. Particularly, we rely on legitimate interest:
- to use limited data to select advertising: advertising presented to you can be based on limited data, such as the website or app you are using, your non-precise location, your device type or which content you are (or have been) interacting with (for example, to limit the number of times an ad is presented to you);
- measure advertising performance: information regarding which advertising is presented to you and how you interact with it can be used to determine how well an advert has worked for you or other users and whether the goals of the advertising were reached. For instance, whether you saw an ad, whether you clicked on it, whether it led you to buy a product or visit a website, etc. This is very helpful to understand the relevance of advertising campaigns;
- develop and improve services: information about your activity on the service, such as your interaction with ads or content, can be very helpful to improve products and services and to build new products and services based on user interactions, the type of audience, etc.
Given the types of data, the nature of processing and the choices available to you, we have assessed that your interests or fundamental rights or freedoms do not override the legitimate interest described above. For more information on our legitimate interest, please visit: Legitimate interest assessment (LIA) – Readpeak. You can, however, object processing based on legitimate interest at any time as described below.
Data Processing Roles
Readpeak’s Services form one part of the so-called online advertising ecosystem. This means that when providing our Services, we work together with partners and clients (“partners”), including partners on whose websites and mobile applications data is collected via the use of cookies and similar technologies.
With some of these partners and with respect to the placement of Readpeak tag or implementation of similar technologies on partner’s site to enable the collection of data for the purposes of targeting advertising, we are joint controllers within the meaning of Article 26 of the GDPR. This means that we and our partners jointly determine the purposes and means of data processing and that we have shared certain responsibilities among each other as follows:
- Readpeak provides a partner with a cookie or similar technology, and the partner integrates this technology on its website. This enables the collection of the data for the purposes described in this Privacy Policy.
- Our partner informs users of the existence of cookies and the data processing they do and ensures that the data collection is based on a valid legal basis such as consent in which case the partner informs us of users’ choices.
- In particular, each party bearing the joint responsibility ensures that there are appropriate data security measures in place. In case of a data breach, the parties work together to ensure swift and effective handling of the breach.
- You can exercise your rights described below as a data subject both towards us and towards our partner.
- We and our partner are liable for any processing that does not comply with the provisions of the GDPR.
After the initial processing, i.e. the placement of Readpeak tag or implementation of similar technologies on partner’s site to enable the collection of data for the purposes of targeting advertising, the partner and Readpeak act as independent controllers.
With respect to client data (such as customer data or online behavioural data provided by advertiser or publisher via our platform), Readpeak acts as a data processor. Such processing is governed by the data processing agreement entered between Readpeak and its client providing the data.
Data Transfers
To the extent that we transfer personal data out European Union or European Economic Area, via certain clients or partners, we rely on appropriate data protection safeguards such as the EU-U.S. Data Privacy Framework, the UK Extension to the DPF, and/or the European Commission’s Standard Contractual Clauses, as applicable.
Compliance with IAB Europe Transparency & Consent Framework
Readpeak is part of the IAB Europe Transparency & Consent Framework. Readpeak complies with the policies and specifications of the Transparency & Consent Framework. Readpeak’s vendor id is 290.
Readpeak is a participant in the IAB UK Gold Standard and holds verification by the Trustworthy Accountability Group (TAG), demonstrating our adherence to recognized industry standards for transparency, accountability, and quality.
Your Rights
As a data subject you have the right:
- to access your data, and to request the rectification in case of error or the deletion of your data;
- to restrict processing of your data;
- to request copy of your data in a portable format and transmit the data to another entity;
- to withdraw your consent via the cookie consent mechanism;
- to object the processing based on legitimate interest via the cookie consent mechanism;
- to complain to a data protection authority about our collection and use of your personal data. There is a data protection authority in each EU and EEA country as well as in the UK. Please contact the authority of your country of residence for more information on how to complain. The contact details for the Finnish Data Protection Ombudsman may be found here: www.tietosuoja.fi.
As we process pseudonymous data, we do not know the real-world identity of the individuals associated with the pseudonymous ID. When a user, for example, withdraws their consent, user request will be honoured without requiring further proof of identity as our and our partner’s primary focus is to respect user choices. However, to exercise certain rights, e.g. a right to request a copy of your personal data, will require that we obtain additional information from you to identify you personally.
Automated Decisions
Our Services may be used to profile you to serve advertising that is likely of interest to you, but we do not make automated decisions that have legal effects or otherwise significantly affect you.
Contact
Should you have any privacy concerns, please contact us at Readpeak or by post: Readpeak, Tammasaarenlaituri 3, 00180 Helsinki, Finland or via email at info@readpeak.com.
Changes
We are continuously developing our business and services, which is why we may occasionally need to make changes also to this Privacy Policy. We will inform you about any changes we make, either personally or through our services. We suggest that you check this page periodically.