Dynatón is a global digital advertising marketplace. Our technology (the Dynatón Platform) helps deliver advertising between Buyers and Sellers. The Dynatón Platform hosts digital auctions that help our clients buy and sell online ads. These ads can be found on websites, mobile applications (apps), or video services, such as streaming apps and CTVs.
As with any exchange platform, we act as a hub between buyers and sellers. Throughout this Policy, we refer to clients that buy ad space (e.g., advertisers or advertising agencies) as Buyers. Buyers may include Demand-Side Platforms (DSP) and Data Management Platforms (DMPs). We refer to our clients that sell ad space as Publishers. Publishers own or operate the Digital Properties you may use or visit.
This Policy describes Dynatón’s practices. It does not apply to information or Data collected by third parties, including those of Publishers or Buyers.
Please note, the first sections of this Policy provide information about the Data we access in the provision of our Services Platform to our clients.
We recommend that you read this Policy in full; however, the links on the right are intended to help you navigate to sections that are relevant to the information in which you may be interested.
How we access Data
- Services Platform: Dynatón accesses your Data when you visit a Publisher’s Digital Properties. Dynatón accesses your Data only to provide our Services Platform, and if we have permission from Publishers to do so. The Data we access is limited to digital identifiers that indirectly identify you (e.g., cookies, device information). We do not access information such as your name, email address or similar information.
- Corporate: If you interact with us in a business capacity, we access your Data as part of our business relationship with you, either pursuant to a written agreement, or because of our legitimate interest.
Types of Data We access
Below is a list of Data we may access solely for the provision of our Services Platform to our clients. We may not receive all of the information listed below every time we provide the Services Platform; the information we receive is primarily determined by each Publisher or Buyer with which you interact. We access the Data listed below when we are permitted by client or by law to do so.
Browser and Device Information
- Online identifiers (IDs) – these are digital identifiers that may indirectly identify you and include:
- Information about your browser including: the type of browser you use, browser language, browser settings, and cookie information. This may include data about you related to brequests and an ad impressions, which is collected when we decide to show you an ad on a Digital Property and when we deliver an ad.
- Pixels – HTML code snippets loaded when you visit a website that allows us to collect Data.
- Third-party online identifiers – IDs that belong to third parties. Third-party IDs may be associated to broad aggregate audience segments and shared with Buyers to serve more relevant ads to you based on your interests (e.g., ads related to sports or fashion).
- Browser information – information such as the type and version of your browser, browser settings (such as language and local time), user agent, and your IP address.
- Device Information – as applicable, general information such as device type (e.g., laptop, mobile, TV), model, manufacturer, operating system, time zone, telephone carrier information, network information (e.g., WIFI), and mobile application information. Mobile device information includes standard mobile advertising identifiers located on every mobile device. These are IDFA or AAID, and the IP address from which the device accesses a client’s Digital Property.
- Location information – geolocation information such as city, country, zip code/postal code, and/or longitude/latitude. Such location information may be referred to as precise geolocation data.
- Other Information – We collect other information, including without limitation personal information, from our affiliates and other companies as further described below (Our affiliates, and Other companies).
- Our affiliates. We collect information from affiliates, such as information generated or derived by your use of affiliate companies’ services – such as technical and usage information.
- Other companies. We collect information from other companies such as analytics providers, advertising and marketing firms, third-party data providers, and other promotional and strategic partners.
How we use your data
We access your Data to provide our Services. Please find described below the business purpose(s) for which we process Data, and our legal basis for doing so:
For Our Business Purpose:
We access your Data (per Section 3 above) for the following business purpose(s):
- Ad delivery – to deliver ads to you on Publishers’ Digital Properties.
- Ad reporting – to verify an ad was delivered to you with accuracy.
- Troubleshooting, optimizing, and product improvement – to improve our Services Platform and ensure ads are delivered correctly to you.
- Ad vetting – to prevent fraud, malware, and other unacceptable behavior.
- Privacy Rights – to view and enforce your opt-out choices, “do not sell” signals, and honor your privacy choices/rights.
Legal Bases For accessing Data:
International law, such as European data protection law, requires us to have a legal reason for accessing your Data. Dynatón accesses your Data under one or more of the following legal bases:
- Consent – Dynatón may access your Data if you provide Publishers with the consent for us to do so. This means, for example, if you visit a website that has a cookie banner and click “Accept All”, Dynatón will receive a technical signal confirming you provide us with the consent to access your Data.
- Legitimate Interest – we may also access your Data if we have a legitimate reason to do so. For example, we access your Data to provide our Services Platform. Such Services Platform allow you to view the free online content in which you may be interested (e.g., a news website or blog). Dynatón will not override your privacy and/or fundamental rights and freedoms to exercise our legitimate interests.
How Your Data Is Shared With Our Partners
We may share your Data with the following partners for the purpose of delivering ads to you:
- Buyers – As noted above, we connect Publishers with Buyers of ad space and Buyers include Demand-Side Partners (other intermediaries) and Ad Partners (advertisers and ad agencies). We share your data with Buyers to source ads that may be relevant to your interest(s). Buyers may share your information with their clients and partners for the provision of their services. Each Buyer processes Data in accordance with their own privacy policies. We encourage you to review their policies for more guidance on how your Data is accessed by Buyers.
- Identity Partners –Your Data may be accessed by our identity partners. These partners show you more relevant ads based on your interests in broad, aggregate audience segments. Identity partners collect Data to deliver these services.
- Quality Vendors – We may send your Data to third-party vendors that help maintain the integrity of our Services Platform, for example, by preventing malicious software (e.g., viruses, trojans) or traffic from non-humans (i.e., robots) from loading on the websites you browse.
- Legal Reasons – We may be required to disclose your Data to comply with our legal obligations, or in cases where we believe in good faith that disclosure is required by law.
How we protect your Data: If we share your Data with another company, the information received by that company is controlled by the recipient. It becomes subject to their privacy practices. To protect your Data when it is transmitted to third parties, Dynatón contractually requires Buyers to protect your data: (i) in accordance with applicable data protection laws; and (ii) by implementing user-centric privacy practices to ensure your Data continues to be protected if it is shared. These companies have their own policies that govern how they access your Data. These practices may differ from the information found in this Policy. We encourage you to review the privacy policies of the websites you visit and apps you use to become familiar with their privacy practices.
The security, integrity, and confidentiality of your Data are extremely important to us. We implement technical, administrative, and physical security measures to protect your information from unauthorized access, disclosure, use, and modification. Such measures include, but are not limited to: (a) encryption, (b) controls that limit the access of your data both technically and at our physical data center locations, and (c) internal information security practices. We regularly review our security procedures to ensure the protection of your information. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. If you have reason to believe your interaction with us is no longer secure, please immediately notify us in accordance with the Contact Us section below.
Your Privacy Rights:
Please find details on how you can exercise your privacy rights below.
- Access and Deletion Data – You can access or delete the Data we may have about you by using our User Rights Request Form.
- Data Portability – When you submit a request to access your information, Dynatón will provide your Data to you in a pdf document.
- Correct Your Data – You have the right to correct your Data. However, please note that any such correction is subject to our practical limitations. The Data we access is in the form of technical identifiers and changing it can be impossible/impractical. If you feel the Data we have about you is incorrect and would like us to rectify, please contact us for assistance.
- Object to accessing – The ads you see on Publisher’s Digital Locations may be tailored to your interests. Dynatón offers options to opt-out of (“stop” or “object to”) ‘interest-based’, or ‘personalized’ advertising. This ensures you will not receive advertising based on your personal interests. Kindly note, opting-out of personalized advertising does not mean you will no longer see online ads, it simply means you will not see ads tailored to your personal interest.
- WebBrowser Option to Opt–Out
- To opt-out of the accessing of your Data for personalized advertising, please visit the Network Advertising Initiative’s opt-out page.
- Please note that when you opt-out, a cookie will be stored in your web browser signaling your opt-out preference to Dynatón. If your browser is configured to block third-party cookies, then the opt-out cookie may not work. If you delete your browser cookies, you will need to opt-out again. The opt-out will only apply to the specific browser in which you set it, and the opt-out access must be repeated for each different browser.
- Mobile Opt-Out
- Mobile device system software such as Apple iOS or Google Play Services provide mechanisms that allow users to opt out of the use of information about their usage of mobile apps to deliver targeted ads to their mobile device. For more information, or to opt out using these mechanisms, consult your device settings (“Opt out of Personalized Ads” on Android devices and “Limit Ad Tracking” on iOS devices). When Dynatón’s technology encounters “Limit Ad Tracking” signals they are respected. Devices vary in where they include the setting to adjust, you can use the Network Advertising Initiative’s mobile optout guide here.
- Television & Digital Video Programming Opt-Out:
- Digital video programming devices (such Smart TVs and apps on Smart TVs) may give you the ability to opt out of the use of your Data for advertising purposes. To determine if your device has these options, please visit your device’s setting menu(s). You may wish to consult the following guidance for consumer choice mechanisms on various connected devices.
- California: Do Not Sell my Personal Information – To submit a request to opt-out the sale of your information, please visit this link.
- Right to Lodge a Complaint – Europe: Dynatón complies with our obligations under European privacy laws and makes every effort to ensure your rights are protected and respected. If you have any questions or complaints regarding our Data processing, please Contact Us directly, or through our Data Protection Officer (DPO). You have a right to lodge a complaint with your local Data Protection Supervisory Authority if you wish to dispute the way we access your Data. Please see the contact details of supervisory authorities below:
The information in the section above describes how Dynatón accesses information in connection with our corporate relationships (i.e., if you are a client or business and you are engaging in a business relationship with Dynatón). For clarity, this Section applies to your interactions with us in a business capacity only.
Such business-related activities include when you: (a) register to become a member on the Dynatón client user interface; (b) use the Dynatón client user interface; (c) attend an Dynatón sponsored event; and/or; (d) participate in a business relationship with Dynatón that requires the submission of your information to Dynatón (i.e., negotiating your business relationship with us, or providing responses to our company surveys). Collectively, these are our Commercial Purposes for collecting your information. Dynatón may also collect your professional and academic background when you send us your CV/resume to work with us (Employment Purposes).
- Type of Information We Collect – Dynatón may collect your full name, mailing and/or billing address, email address, company name, job title, department or job role, and similar contact data (your Identifiable Data) in the course of our business relationship with you.
- Purpose and Legal Bases for Using Identifiable Data – Listed below are the purposes and legal bases for which Dynatón may access your Identifiable Data in the course of our business relationship with you.
- Management of the contractual or pre-contractual relationship: Dynatón uses your Identifiable Data to service accounts and respond to inbound inquiries related to sales or technical support requests and for billing purposes. This may include sharing inviting you to provide feedback to us using a third-party service provider. We may internally use Identifiable Data for analytical purposes, for example, to improve our UI or the services we provide to you. We may also use your Identifiable Data in the assessments of your CVs/resume and to manage our recruitment processes.
- Legitimate interest: As applicable, we may use Identifiable Data to send you marketing and promotional communications (for clarity, this is not for Employment Purposes), to evaluate and improve our internal services, and to build our relationship with you.
- Consent: Kindly note, you provide us with consent to use your Identifiable Data for the above Purposes and Employment Purposes when you participate in a business relationship with Dynatón.
- Transfer of Identifiable Data
- Dynatón does not sell, supply, distribute or otherwise make your Identifiable Data available to any third party under any circumstances. We may be required to disclose your Identifiable Data to comply with our legal requirements, or in cases where we believe in good faith that disclosure is required by law.
- We may transfer your Identifiable Data internationally to any of our data center locations globally, ensuring that any international transfer of your Data is compliant with the laws of that region. When we transfer Identifiable Data outside of the EEA, we ensure that appropriate legal protections are in place under European data protection legislation. These protections may include technical measures, such as encryption, or a legal mechanism such as the Standard Contractual Clauses approved by the European Commission.
- Your Privacy Rights
- You retain your rights to access, correction, erasure, limitation, and objection of the processing of your Identifiable Data. You have the right to revoke consent granted to Dynatón at any time and to file claims with appropriate Data Protection Authority.
- For more information and/or to exercise your rights, please contact us.
- Data Retention – Dynatón will only retain information for as long as it is necessary to carry out our intended Purposes as described herein. Any of the Identifiable Data you provide us through the channels will be deleted once it is no longer necessary to manage our business relationship with you. Any Identifiable Data retained is in compliance with our legal obligations and will only be shared if there is a legal obligation for us to do so, based on a request from the appropriate authorities.
- Data Security – We implement technical, administrative, and physical security measures to protect your information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to ensure the protection of your information. Please be aware, despite our best efforts, no security measures are perfect or impenetrable. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately in accordance with the Contact Us section below.
- Other – Please note that all other sections of this Policy may also be applicable to the processing of your Data (for example, the Cookie and Website Notice below will also apply if you visit one of our websites).
If you have any questions for us, please contact us by e-mail.