Welcome to Threeps
We want to make advertising easier for everyone. And that includes people being advertised to. Like you.
Advertising is an important part of the internet. It’s one of the ways you find out about things you might be interested in: a new model of car or a book, a TV show or movie. It’s also how a lot of websites and apps you use make money to pay their staff, without asking it from you directly.
Without advertising your favourite websites might no longer be free. They might not exist at all.
When they’re good, ads can be very clever. They can be funny and memorable, and even useful – like when you had no idea what to do for Mother’s Day, and saw an ad for a hot air balloon ride.
But we all know advertising can be really annoying. It can also be creepy or inappropriate, or be downright disgusting.
Advertising online is also tricky, because it involves a lot of data. And recently there’s been news about how data can go really wrong.
So we’re going to tell you everything: about the data we collect, what we do with it, and what you can do about it.
This Policy explains how Threeps processes data in our Platform and Website for our users. It also explains what we do with the data, how we secure it, and explains the rights that users have as regards how we collect and process their data.
Threeps is committed to respecting and protecting the privacy of consumers when we process their information. We adhere to applicable industry guideline and strive to best practices. We will continue to review and update our Policy and procedures to ensure the safety and protection of personal information.
What We Collect
Information We Collect in Our Platform
Threeps is committed to respecting your privacy when it comes the provision of our Platform.
The Threeps Platform uses technologies such as cookies to collect information about your browser type, operating system, pages that you may visit on a third party websites, certain actions that you take on those websites (such as signing up or making a purchase), the date and time of your visits to third party websites, whether you respond to an online ad and, where applicable for mobile users, device types, device make and model.
The Threeps Platform does not collect Personal Information such as your name, address, phone number, email address, National Insurance / Social Security Number, credit card, financial or health related information. Customers of Threeps may supply us personal information such as their email address and name, so they may log in and operate the Platform.
We appreciate that, in certain jurisdictions, a Cookie ID and an IP address are considered Personal Information. Cookies and IP addresses are essential to the basic operation of the internet – without them there would be no web. We only store and retain this information where necessary to the service, and where we have a legal basis to do so. When we store this information we also pseudonymise or anonymise this information wherever possible, such that it does not personally identify you.
How We Use the Information We Collect
We use the information collected via the platform in three ways.
- Deliver Interest-Based Advertising to websites & mobile apps on behalf of advertisers
- Help our customers better cater to your needs by sharing adverts for the types of products / services in which you might be interested. (This does not personally identify you)
- Create statistical aggregates (which do not identify you) about the success of an advertising campaign
Who We Share Behavioural Information Collected via the Platform With
We may share and disclose Information in the following circumstances:
- Customers and customers’ partners – we may share Information with our customers and customers’ partners for lawful advertising purposes;
- Vendors and service providers – we may share Information with third party vendors and other service providers who are working on our or our customers’ behalf and require access to such information to undertake that work e.g. to provide data storage and processing services;
- Compliance with laws – we may disclose Information to a third party where we are legally required to do so in order to comply with any applicable law, regulation, legal process or government request, including to meet national security or law enforcement requirements;
- Vital interests and legal rights – we may disclose Information where we believe it necessary in order to protect the vital interests of any person, or to exercise, establish or defend our legal rights; and
- Business transfers – we may share or transfer Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Information We Collect On Our Website Or From Other Sources
When you contact us with questions regarding our service or to request a demo of our
platform we collect personal data such as name, email address and phone number. You also provide personal when you request marketing collateral from our website or third party websites that host our content such as eBooks, one pagers and case studies and when you provide our employees with your business card.
How We Use Information We Collect On Our Website or Other Sources
Personal data on our Website is only collected on the “Contact Us”, “Request a Demo”, “Knowledge Base” or “Newsletter Signup” forms. Information you provide to Threeps will be used for the purpose disclosed at the time of collection, and only if you have opted in and given your explicit consent will the information be used for marketing purposes relating to our Platform and service. Information collected for billing and related purposes shall be used for the purposes disclosed at the time of collection, as well as credit checks, invoicing, collection, troubleshooting, account maintenance, and other related business purposes.
We only use selected third party service providers to store data collected through our Website or related means, including CRM (Customer Relationship Management) and email marketing platforms. These help us manage our communications with our clients and prospective clients.. We have a contract / data processing agreement in place that requires these providers to comply with all relevant data protection legislation, keep your information secure and not to use it for their own direct marketing purposes.
Communications From The Site
If you wish to subscribe to our newsletter, we will use your email address to send the newsletter to you and other relevant marketing communications that may include company news, updates, related product or service information. If at any time you would like to unsubscribe from receiving these emails, you can follow the unsubscribe instructions at the bottom of each email you receive from us or you may contact us at [email protected]
Platform and Service Related Announcements
Only when it is necessary to do so, we will send our customers strictly platform or service related announcements for the benefit of their campaign.
Customers are not able to opt-out of these communications because they are not promotional in nature.
The lawful basis by which we are permitted to use this Information
Under data protection law the uses of information described above are all “legitimate interests” of ours or of others, which we have carefully considered and determined are not overridden by the interests, rights or freedoms of affected individuals (such as you). We need to carry out processing of your information in these ways for the purposes of meeting those interests. In determining this and assessing your rights, we consider a number of factors, such as what you were told at the time you provided your data, what your expectations are about the processing of the data, the nature of the data, and the impact of the processing on you.
In addition, we are permitted by law to use your information where you have given us explicit consent to the processing of your data for one or more specific purposes, namely for marketing purposes.
Cookies and Technology We Use
We use a variety of technologies on our Website and our Platform including cookies, pixel tags and scripts to collect and use Behavioural Information.
Threeps cookies may be served from either of the following domains:
Pixels are tiny images on a webpage or other document that allow the operator of the webpage or other document, or a third party who serves the pixel tag, to set, read and modify a cookie.
Our pixel tags allow Threeps cookies to be set, read and modified when you visit the websites of our partners. Our pixels also allow our partners to better understand how you interact with their websites by observing which pages on their websites are visited.
Other Important Details
We use technical and organisational measures to protect personal data from unauthorised access. These may include encryption and other information security technologies, applied to our networks and systems. However, no mechanism for either storing data, or transmitting data over the Internet, is completely secure. While we strive to protect your information, we cannot guarantee the safety or security of any information you transmit to us.
Threeps processes information in a way that is aligned with the purposes for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current, and reliable for its intended use.
Moving Data Around
The information that we collect from you and about you may be transferred to and stored in a country other than your country of residence, such as another European country or the USA, which may not offer the same level of protection of personal information as your country of residence.
Where your personal data is being transferred outside the EU, we will either undertake an assessment of the level of protection in light of the circumstances surrounding the transfer or:
- Only transfer it to a non-EEA country with privacy laws that give the same protection as the EEA; or
- Ensure we have an agreement in place with the recipient under which they are under a duty to protect your data to the same standards as those in place in the EEA; or
- Transfer it to US organisations that are signed up to the EU-US Privacy Shield scheme; or
- We will make sure that any transfers are not repetitive and only limited to the minimum amount of information possible. In certain circumstances we may need to seek your consent unless there is an overriding legal need to transfer the information]; and
- In all cases where your information is transferred outside the EEA, you have a right to contact us for a copy of the measures we have put in place, by email to [email protected]
How Long We Keep Data
We retain the cookie ID for as long as this is necessary for our legitimate business purposes.
Cookies set via the Platform expire within 13 months of setting. Browsing activity associated with an Threeps cookie expires within the lesser of: 60 days of last known activity and 13 months of setting.
Our log level data is cleansed of any personal data, such as IP address within three days of being produced as a result of interaction with a third party web page we are partnered with, or after being served with an advert via the Threeps platform.
Our Platform and services are designed and directed to individuals of 16 years of age or older. We do not knowingly collect personal information from anyone under the age of 16. If we are made aware that we have received personal information from someone under 16, we will use reasonable efforts to remove that information from our records.
We do not market by email or other electronic means to children under the age of 16 anywhere.
We do not create segments for OBA purposes that are specifically designed to target children (age 12 and under). While this does not mean that ad delivery will not occur, it means that we will not specifically target ads to children ages 12 and under.
Personalised ads, sometimes referred to as targeted or interest-based ads, are based on information about you, such as the products you view online, visits to websites where we provide ads or content.
At any time you can set your preference for ads personalised by Threeps here.
Please note that even if you choose above not to see personalised ads, you may still see ads provided by Threeps on websites; they will just not be personalised.
Choosing not to see personalised ads, changing your recommendations and opting out of your browsing history will not affect other services that use the same technology, such as cookies, and information may still be collected for other purposes. You can manage cookies in the privacy settings on the web browser you are using.
Please also note that these cookies are set on a per browser basis. If you use multiple browsers or devices, you will need to repeat this task on each device and browser.
You can also obtain information on interest-based advertising like Threeps, who follow the IAB Europe’s Framework for Online Behavioural Advertising by visiting the YourOnlineChoices site at www.youronlinechoices.com/uk/
Access to Your Data
Where we hold Personal Information for our own account management, billing or marketing purposes, then we provide individuals with the opportunity to access, review, modify, and delete any such personal information that has previously been provided. You can send an email to: [email protected]
If you are from the European Union or Switzerland, you have the right to access the personal information we hold on you. An EU or Swiss individual who would like to access, correct, change or delete inaccurate data about themselves, can send a request to [email protected], and we will respond to your request within 30 days.
Moving your information to another organisation
In the event that we process your data by automated means where you have either provided us with consent for us to use your information or where we used the information to perform a contract with you, you have the right to request that we send to you or to another organisation, a copy of the personal data we hold about you, for example when you are dealing with a different service provider. If you would like us to move, copy, or transfer your information please let us know by email to [email protected] We will respond to you within one month after assessing whether or not this is possible, taking into account the technical compatibility with the other organisation in question.
How you can request erasure of your data
You can ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where you have withdrawn consent for us to process it (as explained below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
How you can withdraw your consent
You have the right at any time to withdraw any explicit consent you have given us to process your personal data. Please note if you withdraw your consent it will not affect the lawfulness of any processing of your personal data we have carried out before you withdrew your consent. Should you wish to do so you can change your consent preferences at any time by contacting us at [email protected]
How you can restrict or object to us using your data
You can ask us to suspend the way in which we are using your information in certain scenarios, or object to our processing your data where we are relying on a legitimate interest ground (or those of a third party) and you feel it impacts on your fundamental rights and freedoms, or where we are processing your personal data for direct marketing purposes. In some cases where you object, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Please note that if you want us to restrict or stop processing your data this may impact on our ability to provide our services. Depending on the extent of your request we may be unable to continue providing you with our service.
Any queries or concerns about the way in which your data is being used can be sent to [email protected]
Changes to the Policy
From time to time we may revise this Policy. The date of the last update can be found at the top of this Policy. If we make revisions that materially change or affect whether or how we collect or use personal information, we will notify you and we’ll indicate when such changes will become effective. Such a notification might be a message on our website or an email sent to you (if you have provided us your email address as a user of our service or Platform) in advance of the changes taking effect.
We encourage you to review this page periodically so that you are up-to-date on our policies and practices.
Getting in Touch
Or by post at:
Threeps Ltd Attn: Privacy Group High Holborn House 1st Floor, 52-54 High Holborn United Kingdom
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the UK data protection regulator, the Information Commissioner’s Office. Further details can be found at www.ico.org.uk or 0303 123 1113.