This policy addresses how Qommodity facilitates the collection and use of marketing and interest-based information to help enable interest-based advertising by our Qommodity Advertising customers.
Data collected for Qommodity’s own direct marketing purposes. For information about Qommodity’s processing activities with regard to your personal information collected on Qommodity websites and applications and used for Qommodity’s own direct marketing purposes, please refer to the full Legal Notice
3. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL INFORMATION
4. WHICH CATEGORIES AND SPECIFIC PIECES OF PERSONAL INFORMATION DO WE PROCESS
Information about you may in some cases directly identify you, while in other cases it may only indirectly identify you. Personal information that is collected offline and that can directly identify you may include, for example:
name and physical address, email addresses, and telephone numbers;
demographic attributes, when tied to other information that identifies you;
transactional data based on your purchases, when tied to other information that identifies you;
company data such as the name, size and location of the company you work for and your role within the company;
data from marketing opt-in lists, consumer surveys, or publicly available information;
For the United States only: derived latitude/longitude from a physical address.
Personal information that is collected online and that may indirectly identify you may include, for example:
unique IDs such as your mobile device identifier, or a cookie ID on your browser
a connected device identifier such as an ID from a smart television or streaming device (used for matching purposes in the US only);
IP addresses and information derived from IP addresses, such as geographic location;
information about your device, such as browser, device type, operating system, the presence or use of “apps”, screen resolution, or the preferred language;
obfuscated personal information such as hashed email addresses (direct identifiers are removed);
demographic information such as gender, age, and income range when not tied to information that directly identifies you;
behavioral data of the internet connected computer or device you use when interacting with websites, applications, or other connected devices, such as advertisements clicked or viewed, websites and content areas, date and time of these activities, or the web search used to locate and navigate to a website.
We may associate personal information about you with interest segments or profiles as part of the provision of Qommodity Advertising services to our customers and partners:
Interest segments are a specific group of consumers that share a common behavior or preference used for direct marketing by our customers. For example: in market for travel specials to Hawaii.
Profiles are a set of attributes about a specific consumer or device, or a set of multiple consumers or devices sharing common attributes used for marketing by our customers. For example: age bracket 25-55; adventurous traveler; surfing enthusiast; in market for travel specials to Hawaii.
5. FOR WHAT COMMERCIAL OR BUSINESS PURPOSE DO WE USE YOUR PERSONAL INFORMATION
We use personal information for the following commercial purposes:
a) to help enable Qommodity Advertising customers and partners to market products and services to you based on your interests;
b) for personal information collected outside the EU/EEA, to analyze, develop, improve, and optimize the use, function and performance of Qommodity products and services;
We use personal information for the following business purposes:
c) to manage the security of our sites, networks and systems;
d) to comply with applicable laws and regulations and to operate our business.
These purposes are described below in further detail.
a) To help enable Qommodity Advertising customers and partners to market products and services to you based on your interests
We process personal information about you for marketing purposes to help enable Qommodity Advertising customers and partners to advertise products and services to you via online and offline marketing activities based on your interests. “Marketing purposes” means the processing of offline and online personal information, as defined in Section 4,: (i) to solicit or induce a purchase, rental, lease, or exchange of products or services directly to consumers or businesses via offline and online advertising campaigns; (ii) to develop market research or market surveys or to provide verification services to marketers; (iii) to create, communicate, deliver, and exchange offerings that have value for customers, clients, partners and society at large; or (iv) to encourage safe practices and trends and the provision of factual information, including, by way of example, providing product or automotive recall notices.
More specifically, Qommodity can process information about you:
i. For online interest-based advertising delivered through Qommodity Advertising partners that display online advertising to you on behalf of Qommodity Advertising customers.
Example: a marketing professional working for a travel company wants to market the company’s travel specials to Hawaii to a specific group of individuals (also known as an audience) that may be interested in those specials. The marketing professional uses Qommodity Advertising services to create an audience interested in travel to Hawaii. If you have visited a travel website previously and have expressed an interest in Hawaiian vacations, you may be placed in the travel company’s audience and subsequently see advertisements for a vacation to Hawaii on other websites (because a cookie has been placed on your browser) or, In the United States, via a connected device (due to an association between your IP address and device identifier).
ii. For offline and online campaign measurement, analytics, and development of insights on behalf of our Qommodity Advertising customers.
Example: a marketing professional working for a travel company wants to better understand if the company’s marketing campaign for travel specials to Hawaii contributed to an increase in their product sales. The marketing professional uses Qommodity Advertising services to see how many display or videos ads were viewed, and whether the ads were clicked on and a purchase was made.
iii. For enabling our Qommodity Advertising customers to personalize their products and services, including site optimization, email personalization and dynamic marketing and advertising optimization.
Example: if you have previously indicated an interest in travel to Hawaii and when you visit a travel company’s website, the travel company can display tailored offers for Hawaiian vacations on their homepage.
iv. For linking Profiles and Interest Segments to enable Qommodity Advertising customers and partners to connect your Interest Segments across the various browsers and/or devices you may use for the purposes described in this section.
Example: you are interested in vacations offered by a travel company and have clicked on their online advertising. You are logged into several devices (your desktop, smartphone, and tablet) using the same login. Qommodity Advertising partners have indicated that you are likely the same user across those same devices. The travel company is able to display vacation offers to you (via a de-identified cookie ID) on these different devices
v. For creating modelled online and offline audiences for Qommodity Advertising customers’ products and services.
Example: a marketing professional working for a travel company wants to find new potential customers who are, like you, likely to be interested in travel to Hawaii. Qommodity Advertising services can help the travel company by looking for key characteristics between Profiles that have expressed an interest in traveling to Hawaii and other Profiles where a similar interest can be inferred based on these characteristics, such as an interest in travel to tropical islands.
vi. For enabling our Qommodity Advertising customers to associate first-party information to certain Qommodity Advertising identifiers in order to deliver marketing and advertising services to you.
Example: A travel company has its own lists of customers who have purchased travel arrangements with them, with names, emails, and addresses. The travel company wants to be able to reach out to these customers with online advertising. The Qommodity Advertising services can help the travel company by converting the company’s own customer lists from identified names, emails and addresses, to de-identified groups of cookie and device ID’s provided by Qommodity Advertising, in a process known in the advertising industry as “onboarding”.
vii. For the United States only: to allow our customers to deliver catalogues to your physical address that may be of interest to you based on your previous purchase behavior.
b) For personal information collected outside the EU/EEA, to analyze, develop, improve, and optimize the use, function and performance of Qommodity products and services
We may process personal information for Qommodity’s own research and development purposes.
For example: to enhance data quality, develop new features and functionality, and for statistical analyses related to the performance and operation of Qommodity Advertising services.
c) to manage the security of our sites, networks and systems
We can collect usage and systems operations data from Qommodity Advertising services for security and operations management to help keep Qommodity, customer, and partner networks and systems, as well as our products and services, secure. We may also collect usage and systems operations data to investigate and prevent cyber-attacks, malicious activity, or potential fraud, including ad fraud and to detect bots.
d) to comply with applicable laws and regulations and to operate our business
In some cases, we may process personal information to comply with applicable laws and regulations. For example, to respond to a request from a regulator or to defend a legal claim. We may also process personal information in the operation of our business. For example, to conduct audits and investigations, for finance and accounting, archiving and insurance purposes.
6. CATEGORIES OF SOURCES OF PERSONAL INFORMATION
Qommodity may process both offline and online information about you, including information from publicly available sources or third party data providers.
Offline information about you is obtained by Qommodity from its offline partners such as brick-and-mortar retail stores, grocery stores and their associated loyalty card programs, payment card brands, catalog orders and consumer survey programs, and third parties who may not have a relationship with you and collect offline information from their offline partners.
Online information about you originates from your activities on sites operated by our online partners, such as advertising agencies and website operators (for example, online retail stores or travel sites). Qommodity also obtains online information from third parties who may not have a relationship with you and who collect online information using cookies or similar technologies, such as pixels tags and device identifiers, as you browse the Internet and interact with websites. For more information on cookies and similar technologies used in connection with Qommodity Advertising services, please refer to Section 12 below.
Our online Qommodity Advertising branded data partners are listed in our catalogue. Please note that some of these partners only provide information about individuals in specific regions.
7. FOR INFORMATION ABOUT YOU COLLECTED IN THE EU/EEA, WHAT IS OUR LEGAL BASIS
Qommodity Advertising only collects limited third party data from users located in the EU/EEA, Switzerland or the UK and only for legal compliance purposes, including for data minimization and to avoid using data from these regions. Specifically, upon initial collection Qommodity Advertising segregates, obfuscates and purges the data from users in these regions so as to prevent using the data for the commercial purposes described below in Section 5 of this Policy. Customers are responsible for their own first-party data collection and processing practices. Please see “First-party information collected about you by Qommodity customers” under Section 2 for more information.
8. FOR WHAT PERIOD DO WE RETAIN INFORMATION ABOUT YOU
Qommodity maintains information about you for the following retention periods:
a) Online information about you is retained for up to 13 months.
Exceptionally and for online information collected outside the EU/EEA, online information may be retained up to 18 months, for example for Qommodity customers’ seasonal or cyclical interest-based advertising campaigns or internal analytics and model development.
b) Online information about you for linkage purposes (cross device/cross-context technology) is retained for up to 12 months.
c) Offline information about you may be retained for as long as relevant for applicable purposes (see Section 5 above).
Personal information necessary to preserve opt-out preferences is retained for 20 years, unless you delete it or otherwise prevent its collection as further described in Section 13 below.
9. WHEN AND HOW CAN WE SHARE YOUR PERSONAL INFORMATION
Sharing within Qommodity
As a global organization, information about you can be shared globally throughout Qommodity’s worldwide organization for a business purpose. See a list of Qommodity entities. Please select a region and country to view the registered address and contact details of the Qommodity entity or entities located in each country. Qommodity employees are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.
Sharing with or selling with third parties
We may share personal information with or sell personal information to the following third parties for a commercial purpose:
Qommodity Advertising customers and partners, including digital marketers, ad agencies, web publishers, connected TV providers, demand side platforms, data management platforms, supply-side platforms and social media networks; and
third-party service providers as necessary to perform Qommodity Advertising services on behalf of Qommodity.
We may share personal information with the following third parties for a business purpose:
relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock, including in connection with any bankruptcy or similar proceedings; and
public and government authorities, including public and government authorities outside your country of residence (to the extent legally required to respond to their mandatory requests in connection with national security and/or law enforcement purposes).
10. HOW IS PERSONAL INFORMATION HANDLED GLOBALLY
Qommodity is a global corporation with operations in over 80 countries and personal information is processed globally as necessary in accordance with this policy. If personal information is transferred to an Qommodity recipient in a country that does not provide an adequate level of protection for personal information, Qommodity will take adequate measures designed to protect the personal information, such as ensuring that such transfers are subject to the terms of the EU Model Clauses or other adequate transfer mechanism as required under relevant data protection laws.
11. HOW IS INFORMATION ABOUT YOU SECURED
Qommodity has implemented appropriate technical, physical and organizational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as all other forms of unlawful processing.
12. WHAT COOKIES, PIXEL TAGS AND OTHER SIMILAR TECHNOLOGIES DO WE USE
Cookies and similar technologies (e.g., pixels tags and device identifiers) are used by Qommodity and our advertising technology partners to recognize you and/or your device(s) on, off and across different services and devices for the purposes specified in Section 5 above.
Pixel Tags (also called web beacons or clear GIFs) are invisible 1 x 1 pixels that are placed on webpages that use this technology for marketing and measurement purposes. When you access these webpages, pixel tags generate a generic notice of the visit. Pixel tags can be used with cookies or alone. When used with cookies, pixel tags can track activity on a site by a particular device and provide relevant online advertising to you. When you turn off cookies or have opted out of cookies, pixel tags simply detect a unique website visit and how you interacted with the advertising but do not track an individual to provide relevant online advertising.
You can opt out of cookies using the opt-out tools in the next section.
13. WHAT ARE YOUR PRIVACY RIGHTS
Pursuant to the E.U. General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other applicable laws and regulations, individuals in certain jurisdictions may have data subject rights enabling them to opt-out of third party sharing or selling, delete or remove, or request to access and receive a copy of their personal information in Qommodity’s possession or for which Qommodity is otherwise responsible.
Opt-out and object to our use of information about you
Qommodity offers multiple ways for you to opt out of third party sharing or selling and object to our use of information about you:
Qommodity Advertising Opt out.
Qommodity will opt you out of Qommodity’s use of information about you for Qommodity Advertising services involving both first-party use of your information as well as any third-party sharing or selling of your information. See Section 2 above for more information on the distinction between first party and third party information.
Mobile Opt Out. While the opt out methods described above often also work for mobile web browsing, mobile ‘app’ environments do not accept cookies. You may want to consider installing the AppChoices App provided by the Digital Advertising Alliance (DAA) to exercise opt-out control for specific companies, including Qommodity, when in a mobile app environment.
Audience Matched Advertising Opt Out. Qommodity Advertising provides “Audience Matched Advertising” where Qommodity Advertising uses hashed emails to create tailored digital advertising to provide Qommodity Advertising online services. The NAI provides an email-based opt out to opt out of this activity.
Do Not Track. Qommodity honours “Do Not Track” browser settings, meaning we will not track your browser for marketing purposes while you have “Do Not Track” turned on in your browser settings.
Please note that if you opt out using any of the first three opt out tools, you may still temporarily see interest-based advertising from Qommodity Advertising customers due to advertising campaigns from those customers already underway. However, you will be opted-out of all future advertising campaigns from customers that use Qommodity Advertising services.
Also note that the first three opt out tools are currently cookie-based and prevent Qommodity from using, sharing or selling your personal information for interest-based advertising on the browser on which they are installed. As a result, these opt out tools will only function if your browser is set to accept third-party cookies and may not function where cookies are sometimes automatically disabled or removed (e.g., certain mobile devices and operating systems). If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt out again. Qommodity does not use persistent, unique identifiers to revive a previously opted-out profile or deleted cookie.
If you want to opt you out of Qommodity’s use of information about you for Qommodity Advertising services, but do not want to receive third-party cookies, you can also change your browser settings on your computer or other device you are using to connect to the internet. Most browsers also provide functionality that lets you opt out of all advertising cookies, including Qommodity cookies.
Delete information about you
You can erase or delete all online information about you by using the contact form.If you would like to submit a request to have offline information about you, if any, erased or deleted, you can use the contact form.
Access information about you
In order to exercise your right to access your online and offline information processed by Qommodity, you can use the contact form and request all information. You will be asked to verify your identity when you submit your request. We cannot provide access to data unless Qommodity can verify the identity of the individual making the request.
Deceased Do Not Contact Registration with the DMA
We recognize that receiving mail for a deceased loved one can be difficult for family members, friends, or caretakers. You can opt-out your loved one using the contact form; however, it is limited to only Qommodity’s use and sharing of your loved one’s personal information.
14. DOES QOMMODITY ADVERTISING COLLECT SENSITIVE PERSONAL INFORMATION
Qommodity does not create any online interest segments that reflect personal information that we consider sensitive. We also have operational procedures in our platform designed to prevent our partners and customers from using personal information provided to them by Qommodity to create interest segments that we consider sensitive. While the types of personal information considered sensitive may vary among consumers and applicable law, we treat the following types of personal information as sensitive:
precise health, biometric, or genetic information, such as a certain sensitive medical condition like cancer or diabetes;
certain aspects linked to personal life, such as religious, political, or sexual orientation;
interest in “adult” activities, such as drug use, an interest in weapon, or pornographic material; and
information considered sensitive based on applicable law.
In addition, Qommodity prohibits all segments in the EU/EEA, Switzerland and the UK that fall into any of the following categories: health/biometric/genetic, sex life or sexual orientation, race or ethnicity, religious /philosophical beliefs, political affiliations and opinions, any information related to children under 16, criminal offenses or convictions, or membership in a union. Similar or additional restrictions may apply in other regions.
We do not allow Qommodity Advertising customers or partners to use data provided to them by Qommodity to make decisions related to an individual’s eligibility for employment, credit, healthcare, or insurance purposes or to make decisions solely by automatic means where the decision has a significant effect on the individual, or in any way that may or does discriminate against any person or promote bigotry, racism or harm. For these purposes Qommodity considers harm to be inclusive of the use of data provided by Qommodity to target vulnerable individuals or groups with fraudulent or deceptive marketing campaigns.
15. DOES QOMMODITY ADVERTISING COLLECT PERSONAL INFORMATION FROM CHILDREN
We do not intentionally collect or share personal information of children under 16 years of age or allow the creation of segments targeting children under 16 years of age. Further, we prohibit our Qommodity Advertising partners from providing Qommodity with personal information from sites directed to children under the age of 16 or from consumers whose age these companies know to be under the age of 16.
16. WHAT ARE YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)
If you are a California resident, you may request that we:
1. disclose to you the following information covering the 12 months preceding your request:
the categories and specific pieces of personal information we collected about you and the categories of personal information we sold (see Section 4);
the categories of sources from which we collected such personal information (see Section 6);
the business or commercial purpose for collecting or selling personal information about you (see Section 5); and
the categories of third parties to whom we sold or otherwise disclosed personal information (see Section 9).
2. delete personal information we collected from you (see Section 13); or
3. opt-out of any future sale of personal information about you (see Section 13).
We will respond to your request consistent with applicable law. If you are an authorized agent making an access or deletion request on behalf of a Californian resident, please reach out to us via the contact form and indicate that you are an authorized agent. We will provide you with instructions on how to submit a request as an authorized agent on behalf of a Californian resident.