Effective date: February, 14 2022
2. User Identification
We do not collect or process information related to (i) name, user address, place of work, date of birth, email address, or phone number, (ii) hardware-based identifiers such as UDID or MAC Address or (iii) sensitive targeting categories as defined by the European Interactive Digital Advertising Alliance (EDAA) in the European Economic Area (EEA) and under other applicable law (e.g. religion, political opinion, health).
In order to deliver ads, C Wire uses the following 2 methods to identify users depending on the device they use, whether they access our Services on web or mobile, and operating system:
- Cookie-less identification
C Wire uses a randomly generated string stored in the LocalStorage of the user's browser. This means that the ID will be different for every domain that the user visits. This method allows C Wire to identify a user in order to cap the number of times the same ad is shown to the same user. Predictive models may be applied to improve cross-domain frequency capping but no data or ID is matched across domains.
- Mobile Applications identification
C Wire uses its software development kit (“SDK”) technology to identify your advertising ID for mobile applications. For Google Android operating system, we use the Google Advertising ID and for Apple iOS the IDFA.
We do not collect information about you directly, but we collect data through our web tags on publisher web pages, our prebid adapter, or through our SDK within publisher mobile apps. We also automatically collect the information listed below about your use of our Services. These tools help us collect and measure session information, time spent on certain pages, and page interaction information.
3. Automatically Collected Information
- Identifiers: randomised cw_id or cwid(C Wire ID), advertising ID for Apps.
- Internet or other electronic network activity information: Page URL, Browser Information (e.g. Browser name and version), Device Information (e.g. Device type, OS), Network carrier information (e.g. Wifi, 4G or Wired connection), Mobile application information (e.g. Application name or IDFA), User Interactions with C Wire Ad Formats
- Geolocation Information:
Non-Precise Geolocation data: On web and web mobile, we collect non-precise location information at the country and/or city level that are derived from user IP Address.
4. Data use
We use the information we collect for various business and commercial purposes, including those described below:
- User frequency Capping: We use data to prevent displaying the same ad to the same user too many times;
- Analyzing traffic and user interactions: We use data for monitoring and reporting the campaign delivery for advertisers and publishers and for internal business analysis;
- Delivering ads: We may transmit part of the user profile to buyers so that they can deliver their advertising campaigns;
- Providing, maintaining, and improving our Services: We use data to improve our Services and technology, including training our ad delivery algorithms;
- Providing customer service: We may use data to resolve disputes, feedback, or other issues related to our Services;
- Debugging, identifying, and repairing errors: We may use data to fix issues that impair the functionality of our Services;
- Protecting the rights and property of C Wire and Complying with Law: We may use data to protect our rights and property and comply with our legal obligations, including to detect, investigate, and prevent fraud and other illegal activities and to enforce our agreements; and
- Insights: We may use the data to deliver aggregated insights, at advertising campaign or market levels.
Data shared with Third Parties.
In order to provide the Services, we need to share data (including personal information) with third party vendors, service providers, contractors or agents who perform functions on our behalf, including the ones listed below. Our service providers are authorized to use the information we provide only as necessary to provide these services to us.
- Geo-location. We transmit the IP address of the user to companies such as digital elements which provide non-precise geo-location services. These providers have no technical capability to identify the user online.
- Hosting. We utilize third party hosting and data-center providers to store data.
We also may disclose information in the following circumstances.
- Business Transfers. If we are or may be acquired by or merged with another company, if any of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
- In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal processes, such as in response to a court order or a subpoena.
- To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which C Wire is involved.
Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE
If you are located in the European Economic Area or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data.
Legal Basis for Processing
When we process your personal data, we will do so, e.g., in the following situations:
- We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the products or services you have requested).
- We find such processing is necessary to comply with our legal obligations.
Data Subject Requests
You have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us as indicated below.
DATA RETENTION AND SECURITY
TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES
C Wire is based in Switzerland and we process and store information in Europe or Switzerland. Therefore, we and our service providers do not transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. The data might occasionally be accessed from different locations with the use of VPNs.
PRIVACY POLICIES OF THIRD PARTIES
Our Services are not directed to children under the age of sixteen (16) in the United States or children under the age of legal majority in jurisdictions outside the United States, nor do we market products or services to such children.
By email: firstname.lastname@example.org
By mail: C Wire AG, Militärstrasse 90, 8004 Zürich, Switzerland