Digitize New Media Limited (“Digitize”) provides online media buying services via our performance network to our advertiser and agency clients. In doing so, we utilise a technology to help ensure that our client’s adverts are shown to the most relevant users on the most relevant websites. Generally, an internet user’s ID (which is hashed, or digitally shortened, when we receive it) comes into contact with Digitize’s technology when a user views an ad, which then connects to our technology platform. As a general rule, advertisers pay more for relevant and targeted advertising, which in turn supports online publishers in continuing to provide us with the free online content we all love.

Personally Identifiable Information: We don’t process or use Personally Identifiable Information (“PII”) via our technology. Digitize does not have access, process or use your name, address, phone number, email address, Social/National Insurance Number, credit card information, or anything else that can personally identify you. Our demand-side platforms collect the IP address and some send this data to us. Once we receive this data, we delete it before we save it, in truncated form, into our database. (Usually, our demand-side platforms send us IP addresses in truncated form).

Sensitive Personal Data We don’t process any data relating to or referencing racial or ethnic origin, political opinions/affiliations, health, religious and/or philosophical beliefs, trade union membership, or sexual orientation/identity.

Non-Personally Identifiable Information

We collect Non-Personally Identifiable Information (“Non-PII”) via our technology. This may include but is not limited to:

Date and time
User ID (which is hashed)
IP address (which is truncated)
Geo and country
Operating system
Browser
Language
Domain
Device type

Because IP addresses are stored only in truncated form and User IDs are stored in hashed form, this information is not considered as PII but as Pseudonymous Data.

Cookies and Web Beacons: Our technology uses cookies in conjunction with web beacons in order to help make the online advertisements you see more relevant to you. We also use cookies and web beacons to understand your browsing and buying activities, so that we can measure the success of our own and our clients’ online advertising campaigns.

What are cookies? Cookies are small text files that web servers typically send to a user’s computer when they visit a website. Cookies are stored as text files on a user’s hard drive and can be accessed by web servers when the user returns to a website (or goes to another website). Cookies are often used by companies to collect and send information about a user’s website visit – including the number of visits, average time spent, pages viewed, navigation history through the website, and other statistics. This information helps companies improve a user’s online experience in many ways: for example, by allowing companies to monitor website performance, make the website easier to use, measure the effectiveness of their promotional placements, and tailor their website to better match a user’s interests and preferences. Cookies cannot be used to access any other data on a user’s hard drive or to personally identify them. Users who prefer not to accept cookies can set their Internet browser to notify them when they receive a cookie, or to prevent cookies from being placed on their hard drive.

How is our information secured and protected? All of the user data collected by Digitize is stored only in limited and aggregated form – that is, any information about a specific user cannot be retrieved. Even so, we maintain physical, electronic and administrative safeguards to protect all our data from accidental, unauthorised or unlawful access, use, modification, disclosure, loss, or destruction. The data is kept on a secure server and we restrict access to the data solely to authorised users. Data in the database is protected by hard passwords only known to authorised technical users for operational reasons and is encrypted and compressed using the database vendor’s proprietary compression algorithms. Decompression is available only to logged-in authorised users and applications. All data is stored at our offices. No data is stored by us on servers outside of the European Union. No security measures, however thorough, are perfect and there can be no absolute assurance of security. Therefore, we cannot and do not offer an absolute guarantee or warrant the security of the information we possess.

Processing of Data Where data is processed by us it is done only if prior consent has been received by a publisher of a website or app, or where a client of our advertising buying services provides us with instructions that involve prior consent by a user. On occasion, we may also process data under the lawful grounds of Legitimate Use as permitted under the General Data Protection Regulations (GDPR). An example of such Legitimate Use would be fraud detection. In each instance where it is proposed to process data either on a single-use or continuous use basis, the proposal will be subjected to a ‘balance of use’ test where we will evaluate the privacy interests of the user against the Legitimate Use of the data by Digitize. A written copy of this test will be maintained should the processing go ahead.

Information Sharing: The security of information is extremely important to us. We have implemented judicious security measures to protect the information in our care, both during transmission and once we receive it. This includes but is not limited to the use of firewalls and encryption. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect Non-PII information, we cannot guarantee its absolute security. If you have any questions about our security practices, please email privacy@digitize.ie

As previously outlined, Digitize stores only in limited data form (Pseudonymous, non- PII) on its servers. We may disclose this Pseudonymous Non-PII information to third parties when we reasonably believe that we are obligated to do so by law. That is, when covered by Legitimate Interest as permitted in the General Data Protection Regulations (GDPR) in order to investigate, prevent, or take action regarding suspected or actual prohibited activities. These activities include but are not limited to fraud and situations involving potential threats to the physical safety of any person after we have conducted a balance of rights test under legal guidance.

Children: The services of Digitize are not intended for persons under 13 years of age. Our performance network products and services are not developed for or directed towards children. We do not knowingly solicit or collect any personally identifiable information from children under the age of 13, and we do not knowingly market our products or services to children under the age of 13.