Privacy Policy

What data do we collect

• data regarding the device and operating system of the User;
• IP address;
• the web pages visited within our Customers' websites;
• the link that brought the User to a Customer's website;
• the accessing dates and times on a Customer's website;
• event information (e.g., system crashes);
• the geographic location of the User's internet service provider (i.e., country, city);
• other diagnostic data.

How we collect your data

If you are a User, we may collect your personal data from the following sources:

• Automatically, when Users come into contact with the Services featured on the websites of our Customers and other digital properties. This User Information is collected through the use of cookies and other technologies employed by most web-based services.
• User data may also be obtained from our data partners (accredited or authorized institutions are able to request such documents).

Our collected User Information may be used for the purposes featured down below:

• Service Provision. For the purpose of providing our services to our Users and Customers. Our Customers are asked to acquire consent on our behalf to allow us to collect this User Information (whenever it's required by applicable data protection laws).
• Content Customization. For the purpose of customizing and personalizing the content and information that we may deliver or feature to Users; retargeting content to Users via our Services; personalizing our Services' user experience. The lawful basis we rely on to use your personal data is your consent, in accordance with Article 6 (1) (a) of the GDPR. For additional information regarding the personalization of our content, please access the Interest-Based Advertising section of this Privacy Policy.
• Content Personalization for Multiple Devices. For the purpose of offering an improved user experience for an all-encompassing variety of browsers and devices (e.g., smartphones, tablets, PCs) with better-targeted ad campaigns. We aim to provide the same quality, user experience, and personalized content, whether you are using a web browser or a mobile app. To achieve this, we may sync cookies and identifiers with our service providers or Customers that already have this implementation so that our Users can benefit from improved data and data segments and gain insight into other customers from the market. The lawful basis we rely on to use your personal data is your consent, in accordance with Article 6 (1) (a) of the GDPR.
• Providing Data Segments for Targeting Content and Advertisements for Services of Possible Interest. We may provide our Customers with several data segments (groups of Users with common attributes) either from us or from our data partners (accredited or authorized institutions are able to request such documents) to help them gain exposure to Users that have a higher chance of showing interest in their content and ads. When forming segments, we do not base our creation process on sensitive information (e.g., race, ethnicity, religious affiliations, health status, genetic or biometric data, sex life, or sexual preferences). Our Customers may use, via our Services, several standard health-related segments which focus on non-sensitive issues that mostly concern general health and well-being or over-the-counter treatments. We may also provide standard finance-related segments that are about Users who have an interest in financial services. The lawful basis we rely on to use your personal data is your consent, in accordance with Article 6 (1) (a) of the GDPR.

• Sevio’s Affiliates. Any of the existing or future Affiliates, parent companies, or subsidiaries of Sevio may receive User Information for data processing according to this Privacy Policy's designated purposes.
• Sevio’s Service Providers. Our vendors, service providers, agents, contractors, or other parties that provide our platform with services (e.g., maintenance, data analysis, surveys, payment and credit card processing, data hosting, etc.) may receive User Information on our part.
• Third Parties with No Affiliation. User Information may be disclosed to other third-parties that hold no affiliation with Sevio, such as (i) our data partners (accredited or authorized institutions are able to request such documents) so that we can enable our advertisers to offer targeted content to specific audience segments, and (ii) our programmatic demand and supply partners (accredited or authorized institutions are able to request such documents) so that we can offer personalized advertisements.
• Customers. User Information may be disclosed to the Customers that have a Service we think might benefit from such information. For instance, publishers may receive from us data regarding the viewing and click-through patterns of their content, and advertisers may receive conversion rates data that they can use for analytics.

You are able to submit a request to access the personal information Sevio may hold about you, as well as to correct, delete, erase your personal data, and restrict how this Information is processed. To make your request, please contact us at [email protected].

Sevio’s Users are provided with options that allow them to control how their Information is used by certain Services. Customers are able to control the interest-based content and ads they receive through several options:

• The display of interest-based ads from Sevio can be disabled by clicking on the opt-out button below. It should be noted that you will still be able to see Sevio’s content recommendations even if the opt-out function is enabled. Opting out prevents Sevio from using your Information to generate recommendations based on your particular interests. The recommendations you will receive from now on will be based on the specific website you are visiting (i.e., contextually based ads).

You can opt out using our form at the Sevio opt-out page.

• Not Opted-Out: You will receive personalized recommendations from Sevio based on your browsing history.
• Opted-Out: Your activity will no longer be tracked by Sevio, and therefore, you will not be receiving personalized content recommendations derived from your past online activities.
  • As we individually track device or browser operations, you will need to opt out on each device and browser individually in order to opt out completely across multiple devices.
  • Your opt-out may not come into effect if your browser is set to reject cookies, as we have already recognized your opt-out configuration based on an opt-out cookie that we've sent to you. For the opt-out to be effective in this scenario, you will be required to confirm that your browser has the proper configuration. Users that have a Safari browser on iOS11 or macOS High Sierra first have to change their Privacy and Security Settings in order to disable "Prevent Cross-Site Tracking" and "Block All Cookies" and then access, once again, this privacy policy or their opt-out platform of choice to reset the opt-out settings.
  • Technologies that do not use cookies may be used by Sevio in very few specific situations. These technologies work in a similar manner to cookies, as they help us create tailored ad recommendations based on your interests and verify if the opt-out function was enabled. Please keep in mind that you may not be able to restrict the use of non-cookie technologies with certain web browsers, but you can go to the "User Choices" section on this page and click on the Opt-Out feature to have this function enabled.
• Users can also disable getting targeted ads from Sevio and other advertising companies.
  • The NAI opt out tool stops Sevio and other NAI-approved member companies from sending you targeted ads. The NAI offers a guideline on how to opt out from mobile devices that run on Android, iOS, and Windows Phone operating systems.
  • The Digital Advertising Alliance affiliate websites also feature more information regarding User Choices and how to disable targeted advertising for each of the member companies.
  • The DAA consumer choice page is available to United States-based Users at www.aboutads.info/choices.
  • The DAAC consumer choice page is available to Canadian Users at www.youradchoices.ca/choices.
  • The EDAA consumer choice page is available to European Users at www.youronlinechoices.eu.
  • You will still be able to see the advertisements from the companies featured in the DAA, DAAC, or EDAA consumer choice pages, even if you have activated the opt-out function. Opting out prevents these companies from using your Information to create ad recommendations based on your particular interests. The recommendations you will receive from now on will be based on the specific website you are visiting (i.e., contextually based ads).
  • Your opt-out may not be effective if your browser has been set to reject opt-out cookies when visiting DAA, DAAC, or EDAA consumer choice pages (these cookies notice companies if your opt-out preference is enabled).

For ad-related purposes, User Information may be held for twelve (12) months since the User last interacted with our Services, after which we will de-identify the information by removing unique identifiers or aggregating the data.

The resulting de-identified or aggregated data may also be held by us to be used for reporting and analysis during the entire period it is of commercial necessity. This type of data cannot be used for the identification of an individual or device. Opt-out data may be retained for longer than twelve (12) months in order to track and keep active the opt-outs that have been requested, but no longer than necessary.

Our data collecting and advertising is not knowingly targeted toward websites that have, as their audience, children under the age of eighteen (18).

What data do we collect

If you are a Site Visitor, we may collect your personal data from the following sources:

• Directly from You. Site Visitor Information may be collected by Sevio directly from you when you send us an e-mail with an inquiry or a form on our Sites that confirms you want to receive marketing materials or e-mail newsletters. The data inputted into these fields before submitting the forms may be recorded by third-party analytics.
• From Third Parties. Site Visitor Information may also be collected by Sevio through third-parties that automatically do so on our behalf when you access our Site.

To find out additional information regarding the use of cookies and other technologies, please read our Cookie Policy.

Your Site Visitor Information may be used by us for the following purposes:

• Service Provision. For the purpose of providing the Services of our Sites, as well as for management motives. The lawful basis we rely on to use your personal data is the performance of a contract and our legitimate interest to ensure the quality of our services, know our Visitors, and ensure adequate performance of the contract, as well as documentation of such performance.
• Content Personalization. For the purpose of offering personalized content and data to you when you visit our Sites and to give you a tailored browsing experience. The lawful basis we rely on to use your personal data is your consent.
• Communication Purposes. In order to communicate with you and to respond to your questions or complaints regarding our Services through e-mail or to offer you news, pieces of advice, or other updates we deem are of interest to you. The lawful basis we rely on to use your personal data is your consent and our legitimate interest to manage our relationship with visitors.
• Marketing and Advertising. To send and contact you about services and materials that we believe might be of interest to you, such as newsletters, exclusive offers, and promotional services, as well as for other purposes that involve marketing and advertising. All of the information we will send will be compliant with the communications preferences set by you. The lawful bases we rely on to use your personal data are: our legitimate interest to promote our activity to you via post/live calls; our legitimate interest to develop and improve our services and to better know our Visitors; your consent for the marketing communications sent to you via e-mail, SMS, social media, MMS, and other similar communication channels.
• Analytical Purposes. To have an ampler insight on how our Sites are accessed and used at an aggregated and individualized level; to offer our response to any demands and preferences; and to analyze and research how our site is used. The lawful basis we rely on to use your personal data is your consent.

Site Visitor Information may be disclosed by Sevio to the following parties:

• Sevio’s Affiliates. Any of the existing or future Affiliates, parent companies, or sub-branches of Sevio may receive Site Visitor Information for the processing purposes detailed in this Privacy Policy.
• Sevio's Service Providers. Third-party service providers, such as vendors, agents, contractors, or other entities that perform services for our platform (e.g., maintenance, data analysis, surveys, payment and credit card processing, data hosting, etc.) may receive Site Visitor Information from us.

We may collaborate with third-parties that employ their proprietary cookies, web beacons, and other technologies which record Site Visitors' online activities, either on our Sites and/or other sites, so that we can provide personalized advertisements that are suited to your interests.

Advertisers and ad networks are some of the included third-parties that may gather data upon your view or interaction with their advertisements and may also collect Information on your web browsing activities either on our Sites or other different sites.

The ad placement of Sevio is based on the principle that they should be featured in places that are of interest and have the most relevance to visitors. By enabling ad networks to place their own cookies when our Sites receive a visitor, we are able to place our ads organically.

Ad networks are able to identify past visitors of Sevio’s Sites through the use of these cookies. The ad network will be able to deliver a Sevio advertisement on any of its new ad spaces on a third-party website to the same individual that visited the Sevio Sites, as its cookies recorded his activity and noted his interest in Sevio.

To find out more details regarding the collection of Site Visitor Information through third parties, please read our Cookie Policy.

Site Visitors may opt out of third-party ad networks and advertisers that collect Information on the Sites that serve ads about Sevio. By visiting one of the Digital Advertising Alliance affiliate websites, you can learn more about User choices and opting out of interest-based advertising displayed by the many member companies.

• The DAA consumer choice page is available to United States-based Users at www.aboutads.info/choices.
• The DAAC consumer choice page is available to Canadian Users at www.youradchoices.ca/choices.
• The EDAA consumer choice page is available to European Users at www.youronlinechoices.eu.

You will still be able to see the advertisements from the companies displayed in the DAA, DAAC, or EDAA consumer choice pages, even if the opt-out function is enabled. Opting out averts these companies from using your Information to generate ad recommendations based on your particular interests. The advertisements you will receive from now on will be based on the specific website you are visiting (i.e., contextually based ads).

Your opt-out may not be effective if your browser has been configured to reject opt-out cookies when visiting sites from the DAA, DAAC, or EDAA consumer choice pages (these cookies notice if the opt-out preference is set in your browser).

Site Visitors that receive our e-mail subscriptions can manage their subscriptions: For Publishers Newsletter.

We will not keep your Personal Data for any longer than necessary, after which we will de-identify the information by removing unique identifiers or aggregating the data.

The resulting de-identified or aggregated data may also be held by us to be used for reporting and analysis during the entire period it is of commercial necessity. This type of data cannot be used for the identification of an individual or device. When deciding how long to keep your Personal Data, we consider factors including:

• our contractual obligations and rights in relation to the Personal Data involved (including the Terms of Service);
• legal obligation(s) under applicable law to retain data for a certain period of time;
• whether we relied on your consent to use the Personal Data, but you have since withdrawn your consent;
• statute of limitations under applicable law(s);
• our legitimate interests where we have carried out balancing tests;
• fraud and risk management;
• (potential) disputes; and
• guidelines issued by relevant data protection authorities.

4.1. How Your Information Is Used

In addition to the purposes aforementioned in Sections 1-3, we may use data collected from Customers, Users, and Site Visitors for several other purposes:

• Service Analysis. To improve our comprehension of how our Sites and Services are accessed and used at an aggregated and individualized level; to offer our response to Customers', Users', and Site Visitors' demands and preferences; and to perform other analysis and research involving our Sites usage. The lawful bases we rely on to use your personal data are your consent and our legitimate interest to improve our Services.
• Legal Compliance. To achieve full compliance with the laws set forth by legal authorities or other governmental regulatory bodies. The lawful bases we rely on to use your personal data are our legal obligations and our legitimate interests to ensure compliance with legal requirements applicable to us.
• Protection of Rights and Interests. With the purpose of protecting our rights and interests, and, by extension, the rights and interests of our Customers, Users, Site Visitors, and the general public, in addition to the enforcement of our Privacy Policy and our Terms of Service. The lawful bases we rely on to use your personal data are: our legitimate interest to exercise and defend our rights in the context of particular disputes/complaints; our Users’/Visitors’/Customers’ legitimate interest to exercise/defend their rights.

Third parties that receive Information collected from us, as mentioned above, are required to agree and comply with this Privacy Policy and our contractual specifications in order to use the Information provided by us and are not allowed to use said information in other contexts or for other purposes than those underlined in this Privacy Policy.

Additional Information disclosures may be made for the following purposes:

• Business Acquisitions or Transfers. In case of our company’s acquisition or merger by/with another company, or if our business unit or assets are sold or transferred to another company, in the context of bankruptcy events or other business transmissions, we reserve the right to disclose and/or transfer Information to the company in question.
• Compliance with Legal Matters. Information may be disclosed if it is required by law via legal procedures, such as subpoenas, court orders, or other laws, regulations, or judicial proceedings.
• Protection of Rights and Interests. If we believe that an investigation, prevention, or action against illegal activities is required, we may disclose Information in order to combat cases such as suspected fraud attempts, potential threats to personal safety, breaches of our Terms of Service or this Privacy Policy, or to provide them as evidence in court cases in which we are involved.
• De-identified and Aggregated Data. Our Customers and other third-parties may receive aggregated or de-identified user Information to be processed for purposes such as marketing, advertising, or research.

We use cookies and similar technologies on our websites and applications for analysis purposes and to personalize the audience. Certain cookies or similar technologies are necessary for the proper functioning of our sites (so-called "necessary cookies") or to ensure their performance (so-called "performance cookies").

We also use cookies for online advertising tailored to your interests (so-called "interest-based advertising") to provide you with relevant advertising. This can be done on Sevio sites, as well as through other online media channels, such as social networking sites.

We may also combine and correlate the data collected through cookies or other similar technologies with other data collected by us.

If you do not want such processing through cookies and similar technologies, see the Cookie Use Policy available. That policy explains how to control cookies and how you can object to the collection and processing of data through these technologies.

Depending on the categories of cookies, we rely on (i) Sevio’s legitimate interest in ensuring that our services function properly (for "necessary cookies") or (ii) Users' permission (for "performance cookies” and “interest-based advertising”).

Furthermore, links to third-party websites may be embedded in our Sites and Services. The use and access of these websites are not in compliance with this Privacy Policy but with the privacy policies set forth by the third-party websites. We absolve ourselves from any responsibility regarding the information security and privacy practices employed by these third-party websites.

Our Sites, for instance, incorporate features from third-party social networking platforms, such as the "Like" button from Facebook. When using such features, they may collect certain Information, including, but not limited to, the IP address or the pages visited within our Sites, and may also deploy a cookie to enable the feature to have proper functionality. Features and widgets from social media networks either have third-party hosting or direct hosting on our Sites.

The interaction with these features falls under the privacy policy of the providing company of said features. Links to Customers' websites are not governed by this Privacy Policy but by the Customers' privacy policy.

Sevio has implemented policies and rules regarding the retention of personal data in compliance with the principles set out in the legislation on the protection of personal data. Retention periods are reviewed periodically to ensure that we do not store or otherwise process your data unless necessary.

In general, we will retain your personal data (1) for the duration of your account, plus a certain period which may vary from case to case according to our retention policy) or (2) for the duration provided by law or established by a public authority, in accordance with the law, or (3) in case of disputes/complaints/investigations, until their termination, plus a reasonable period (depending on the circumstances) After the expiry of this period, personal data will be destroyed, deleted, or irreversibly anonymized (as appropriate).

The Information collected through our Sites or Services is secured through the application of proper technical and organizational procedures in order to prevent the data from being lost, altered, misused, accessed, or disclosed by unauthorized entities, destroyed, removed, or any other type of unofficial activities.

Please keep in mind that no security implementations can provide complete security.

4.6.1. Data Controller

The personal Information of EEA residents which has been provided, collected by or for, or processed by Sevio in relation to our Services, will be controlled by Sevio.

4.6.2. Legal Basis for Data Collection and Processing

The legal basis for collecting and using the personal Information of European Economic Area Customers, Site Visitors, or Users (denoted in this Section 4.6 as "EEA Data") will vary according to the type of personal Information collected and the specific circumstance in which the collection took place.

We will only collect Information from you for the following purposes: (i) when we have your consent; (ii) to establish a contractual agreement with you; (iii) when processing is in our legitimate interest, and this does not come into conflict with your data rights, interests, and liberties. We may be legally required to collect personal Information from you in certain cases or may need the personal data to ensure the protection of your own or another individual's personal interests.

In case of a legal requirement or establishing a contract with you, we will clearly state, at the right time, when and if it is compulsory for you to provide us with your personal Information (you will also be informed of the possible consequences of refusing to supply the required personal Information). The same applies should we require to collect and use your personal Information for our own legitimate interests (or any of our third parties), as we will explain to you, in due time, what these specific interests are.

Should you have additional questions or require further information regarding the legal basis on which your Personal Information is processed and used, and to have a better understanding of how our legitimate data processing interest affects your data protection rights and freedoms, please reach out to us by filling out our contact form.

4.6.3. Personal Rights on Information

In accordance with applicable data protection laws, regulations, guidelines, and policies, you may exercise the following rights in connection with your personal data. Sevio makes every effort to keep your personal data safe.

Your Rights

Right of access: You can obtain confirmation from us that we process your personal data, as well as information on the specifics of the processing such as: purpose, categories of personal data processed, recipients of the data, the period for which the data is kept, the existence of the right of rectification, deletion, or restriction of the processing.

You have the right to request a copy of the personal data that Sevio holds about you.

To make this request as an authorized individual or third-party, please send it by e-mail to the address mentioned below. Alternatively, you can contact our Customer Service team. In order to exercise this right, please note that we may ask you for additional information in order to identify you so as not to mislead essential information by mistake to third parties.

The right to rectify personal data: You have the right to rectify the data held about you if they are incorrect. If the data we hold about you needs to be updated or if you think it may be incorrect, you can contact our Customer Service.

The right to data portability: You have the right, where we process your data via automated means, based on your consent or for contract performance, to ask us to provide you with your own data that you have provided to us in a commonly used electronic format. For example, Sevio ensures that you can access your own data via your Account.

The right to revoke your permissions for marketing messages (commercial communications): If you no longer wish to receive marketing messages (commercial communications) from Sevio, you may opt-out of all marketing communications or only the selected methods (e.g., e-mail notifications).

There are various ways to opt out of receiving marketing messages (to oppose the processing of personal data for marketing purposes, including profiling):

• Log in to the My Account section to manage your permissions;
• Contact our Customer Care team;
• Click the link at the end of an e-mail or marketing text to unsubscribe.

If you opt out of marketing messages, this does not mean that you will no longer receive functional messages. These messages do not fall into the category of commercial communications, and as such, you will continue to receive them.

Do you want to disable a cookie or understand more about it? Consult the Cookie Policy on our website for complete details in this regard.

For any other processing carried out under your agreement, you may withdraw your permission at any time by contacting us at any of our contact details listed in Section 5.

The right to object to the use of personal data: In certain circumstances, you have the right to object to Sevio’s processing of your personal data. Depending on the specific situation, if we have legitimate interests in processing that prevail over your interests, rights, and freedoms, or if we need data for the establishment, exercise, or defense in formal proceedings, we may further process your data for correlative purposes.

In the case of the processing of your data for marketing purposes/correlative purposes based on legitimate interest, you can object at any time. In these cases, we will immediately stop processing your data.

The right to make a complaint to a supervisory authority: You have the right to file a complaint to a data protection authority regarding our collection, use, and processing of your personal data. If you are interested in finding out more, please communicate with your local data protection authority by contacting them through the methods described here.

Should you have queries regarding our collection and use of your personal Information, please contact us first at [email protected].

Users that want to find out more about the personal Information and behavioral Information Sevio may hold about them, and the enforcement of their personal Information rights can request such Information by sending us an e-mail at [email protected] so that we may provide them with the answers they are seeking or direct this request to/cooperate with their employer, if needed.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is manifestly unfounded or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

The statutory period under GDPR for us to reply to a legitimate request is one month. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.

As mentioned above, in order to provide our services, we may disclose your personal data to our contractors (Sevio’s Affiliates, parent companies, and/or subsidiaries), who may be located both in the EU and outside of the European Economic Area ("EEA"). Therefore, in order to prevent such discrepancies from affecting your Personal Information, we seek to comply with the guarantees listed below:

the country to which we transfer your personal data has been deemed to provide an adequate level of protection for personal data by the European Commission;

a specific contract approved by the European Commission which gives safeguards to the processing of personal data, the so-called Standard Contractual Clauses.

Customer, User, and Visitor Information is currently stored in Sevio’s data centers located in the United States, Germany, France, India, Singapore, and Japan.

Under the General Data Protection Regulation, all the member states of the European Union have uniform protection of personal data and personal privacy. This also applies in the EEA countries. Personal data can thus be transmitted freely within this area without any restrictions (e.g., Germany, France).

Your data is transferred to USA, India, and Singapore based on standard contractual clauses. Copies of the implemented standard contractual clauses can be provided upon request.

Japan is recognized as providing an adequate level of protection.

Should you have inquiries regarding the privacy aspects of our Sites or Services, please feel free to reach us at the following addresses:

Sevio Digital Limited

Headquarters Address
20 HARCOURT STREET, DUBLIN, DUBLIN 2, D02 H364, IRELAND

E-mail: [email protected]

European Economic Area residents are able to take their inquiry or complaint to a higher level if they are not satisfied with the support team by contacting our Data Protection Officer at [email protected].

This Privacy Policy is updated starting with the Effective Date stipulated above.

This Privacy Policy may be subjected to occasional updates or changes, so please read this policy periodically to keep abreast with the new modifications. Any changes related to this Privacy Policy on our Sites will be immediately published by us.

If any revisions to our Privacy Policy have a significant impact on our practices concerning the personal data we may have about you, we will try our best to alert you of such updates in advance by emphasizing the changes on our Sites.

By continuing to use the Sites and our Services, you express your agreement regarding this Privacy Policy and any updates.