A – Sources of personal data

B – Personal data that we collect and process

C – Why do we collect your personal data and what are our lawful bases for it?

D – How long do we keep your personal data?

MiQ analyses web browsing usage in order to provide our clients (advertisers and media agencies) with the ability to improve returns on their digital advertising spend by enabling them to serve ads that are relevant to website visitors.We use cookies and similar applications to develop marketing insights about user preferences, sometime in combination with other data sets, in order to better match ad content with user interests.

A – Sources of personal data

The websites that users visit may allow third parties, such as MiQ, to set cookies or similar applications on user devices or browsers when they visit the websites. We collect and analyse the data obtained via these applications. We may combine this data with aggregate data obtained from social media companies and market research firms, and user-level data from other advertising technology companies that support our services in various ways, such as fraud prevention through the detection of “bots.”

B – Personal data that we collect and process

MiQ collects various categories of personal data at the user level, including the following:

1. IP address, which helps us to understand the broad location of a user
2. Device ID (when users access websites on mobile devices), such as IDFA, AAID, SHA1
3. User ID stored in a cookie placed on a user’s browser

1. Latitude-longitude location data
2. Timestamp on accessing the website and the website URL
3. Enrichment data collected about you from third parties, such as Nielsen & Eyeota.
4. Tweets & Twitter handles, made publicly available via the Twitter platform
5. User interactions with the ad placed, i.e. we will know if a user clicks on it or the user’s browser & operating system type. Sometimes advertisers may provide us with information on what users have previously purchased from them and when, in order to make our predictions more accurate.
6. Cookie technology is placed on devices to assist with the ad delivery process. This includes:

(1)  A user ID cookie to support ad personalisation, which lasts for 90 days

(2)  An opt-out cookie to store your opt-out and consent preferences, which lasts for 90 days

(3)  A session cookie to see if a browser supports cookies, which lasts for 1 browsing session

(4)  A cookie which limits the number of ads which a given user sees, which lasts for 90 days

(5)  A cookie which denotes whether a user ID is synced with other partners in the ad-serving chain

(6)  A cookie which supports billing and reporting.

Although we do not collect information that directly identifies individual users by name or physical address, we collect your IP address and other information about you which may make this information personal data. For example, based on a user’s historic browsing behaviour, we may map an IP address to a city or a geographical region and other information such as weather in that region, in order to predict users’ future buying decisions.

However, we never make decisions or predictions based on the characteristics of one individual. Instead we usually only target population segments or groups of individuals.  These segments involve aggregated user data of no less than 1,500 users, but more typically hundreds of thousands of users who may share common characteristics, such as demographics and specific interests, such as preferences for particular types of cars.

C – Why do we collect your personal data and what are our lawful bases for it?

We collect user-level personal data so that users can see ads displayed on the websites they visit which we think are most relevant to them based on their browsing behaviour and interests. This enhances the user experience while at the same time making our clients’ advertising campaigns more efficient and effective.

We use data analytics to predict user interests based on machine-learning techniques involving the use of algorithms.  Our data scientists regularly review the algorithms that we use in order to ensure they are properly adjusted and error-free. MiQ has approved an “Pixel Implementation” policy which provides, among other things, that we will not target children or vulnerable adults or collect any special categories of personal data about users. MiQ’s “Creative Guidelines” prohibit any discriminatory messages and place restrictions on advertising related to gambling, health & politics.

Consent

MiQ has joined a number of industry schemes including the IAB Transparency & Consent Framework (http://advertisingconsent.eu/) and Your Online Ad Choices (http://www.youronlinechoices.com) that have been developed to ensure that users are in a position to decide whether and how they want their web browser data used for digital advertising purposes. MiQ’s Vendor Identification number within the transparency and consent framework is 101.

As a result, MiQ will not process personal data unless it can be evidenced that their publisher & advertiser partners have first obtained the users’ permission to do so. This is usually done by means of a pop-up window that enables users to manage their preferences in regard to cookie application and related data processing.

When a user visits a website with which MiQ is associated, they will see a message asking them if they agree to allow the website publisher’s and third-party cookies to be set on their device and collect information from it when they first visit it. If the user agrees to the application of cookies, they will then be asked whether they consent to the processing of the information collected for each of the following purposes:

1. a) Ad personalisation

The personal data We collect is used to personalise ads that you see over time on other sites. We will use the personal data We collect to infer your interests and place ads that we believe may of interest to you.

1. b) Ad selection, reporting and delivery

We collect information about what ads were shown, how often and when and where they were shown, whether the user clicked on them and made a purchase. This information is used to measure the effectiveness of the ads presented.

1. c) Content delivery, selection and reporting

We collect and analyse information about the user’s interests and what content was shown, how often, when and where, and whether the user clicked on what was shown. This is done to adjust the content displayed to the user to be most relevant.

1. d) Measurement

We collect information on web visitors’ use of content in combination with previously collected information. We use this data to understand and report on their use of content to our advertising clients or for MiQ’s internal quality assurance purposes.

In the process of using data for the above purposes, MiQ also employs the following technical features: i) matching data to offline sources, ii) linking devices and iii) precise geographic location data.

When a user agrees to the placement of cookies by Us and one or more of the identified processing activities, we will receive a message from the website where the visitor’s selection has been made, notifying Us that We have permission to set a cookie, collect information on the user’s device and use it for the agreed purposes. A user may withdraw consent at any time on the websites visited or by changing their preferences on www.youronlinechoices.eu. They can do this by finding the reference to MiQ and withdrawing their consent.

MiQ’s legitimate interest in preventing fraudulent website traffic

We also process personal data in order to detect the use of internet “bots” or similar functionality intended to distort the popularity of websites and digital ads by simulating human browsing activity. If a user agrees to the placement of a cookie and accepts the processing of their personal data for one or more of the purposes described above, our ability to detect this type of fraudulent behaviour is important to ensure that the data we rely on to cater to user preferences is not distorted by false inputs. We therefore use a third-party vendor to assess whether the IP addresses that we are processing are associated with fraudulent activity.

MiQ’s legitimate interest in analysing social trends

We also process personal data in order to analyse trends in social media activity. This involves analysing common keywords that appear in public posts made available on the Twitter platform and producing aggregated insights from these to inform our advertisers about current social trends. We may use Twitter handles to identify trends relating to companies and popular personalities.

Should a user wish to object to our processing of their personal data for these purposes, they may do so by contacting our DPO as indicated in Section 2 above.

D – How long do we keep your personal data?

MiQ minimises the personal data it collects about users and retains the data for only limited periods.

Raw data that MiQ collects about user online activities is kept for no longer than 180 days from the date collected and is stored in a secure environment. The user-level data is either anonymised or aggregated after 180 days, which means the information is expressed only in a summary form about user behaviour representing large groups of individuals. Anonymous data may be kept at MiQ for 2 years and aggregated information relating to financial performance stored for up to 7 years for accounting and audit purposes. During the initial 180-day period, the information about user online behaviour is used to better target the ad campaigns and adjust the audience to ensure the ad is displayed to user groups that may be most interested in the product or service advertised. The data collected as part of the ad campaign may be used to develop insight reports for MiQ clients concerning advertising trends and campaign results.  These reports are based on data that is provided in an aggregated form and does not allow for the identification of individuals.

A – Sources of personal data

B – Personal data that We collect and process

C – Why do We collect your personal data?

D – How long do we keep your personal data?

A- Sources of personal data

We may obtain your personal data from the following sources:

1. from you directly (for example, through subscribing to any services offered on our website (//localhost/), including but not limited to email mailing lists, interactive services, posting material or requesting services);
2. from your device or browser; and/or
3. if you contact us, we may keep a record of that correspondence.

B- Personal data that We collect and process

1. name;
2. username;
3. email address
4. operating system;
5. browser type;
6. cookie data (for more information please see the Cookie Notice ; and/or
7. IP address.

C – Why do We collect your personal data?

We process your personal data for the following purposes:

1. To allow you to participate in interactive features of Our service when you choose to do so;
2. to ensure that content from Our website is presented in the most effective manner for you and for your device;
3. to allow Us to share information in order to provide any product or service you have requested;
4. for the provision of support services;
5. for the management of Our customer records;
6. for system administration purposes;
7. for monitoring statistical data about Our users’ browsing actions and patterns, the number of visitors to Our website, the pages visited and how long they stayed; and/or
8. to exchange personal data with MiQ group of companies for the purpose of reporting, global management, carrying out monitoring, analysing business, and any other purposes that is incidental to or connected with the foregoing purposes.

It is in Our legitimate interests to promote Our services via Our website and to process your information for the purposes listed above. Please do not submit your information to via Our website, if you would not like Us to process your personal data for the above purpose.

If you would prefer Us not to process your personal data for the purposes above, please contact our DPO using the details set out in section 2 above.

D – How long do we keep your personal data?

We will keep and process your personal data only for as long as is necessary for the purposes for which it was collected in connection with your use of our website, unless there is a legal requirement for us to keep it for longer or the data is necessary for the establishment, exercise or defence of legal claims.

We may collect personal data related to employees, directors, authorised signatories and other representatives of MiQ’s existing and prospective customers or vendors as well as other marketing contacts.

Our existing or prospective customers are typically media agencies or advertisers that engage MiQ to help them improve the performance of their advertising campaigns. Our vendors include service providers that supply us with services that we use to deliver or enhance our ad personalisation and placement services.

A – Sources of personal data

B – Personal data that we collect and process

C – Why do we collect your personal data and what are our lawful bases for it?

D – How long do we keep your personal data?

A – Sources of personal data

We may obtain these types of personal data from the following sources:

1. from the individual directly,
2. from a company that employs the individual if they are an employee of an existing or prospective MiQ customer or vendor,
3. from MiQ’s affiliates (please see  Annex 1 for a list of our affiliates);
4. during networking events that we have either hosted, sponsored or attended; and/or
5. from publicly available sources (for example, your company website or social media sites)

B – Personal data that we collect and process

We may collect the following categories of personal data relating to our existing or prospective customers’ or vendors’ employees, officers, authorised signatories, and other associated individuals:

1. name;
2. business address;
3. business email address;
4. business telephone number; and/or
5. job title.

C – Why do we collect your personal data and what are our lawful bases for it?

The purposes for which we collect and process the above-referenced categories of personal data about our business contacts, and the lawful basis for doing so, are set out in the table below.

If you object to our using your personal data for these purposes, including direct marketing, please contact our DPO as indicated in Section 2 above. Where we use your email to communicate marketing information to you we will seek your prior consent where required to do so by law.

D – How long do we keep the personal data of our business contacts?

We will keep and process your personal data only for as long as is necessary for the purposes for which it was collected. We will keep your personal data for the duration of our business relationship and once it ends, we will delete it securely unless there is a legal requirement for us to keep it for longer or the data is necessary for the establishment, exercise or defence of legal claims.

A – Sources of personal data

B – Personal data that we collect and process

C – Why do we collect your personal data and what are our lawful bases for it?

D – How long do we keep your personal data?

A – Sources of personal data

We may obtain your personal data from you directly via registration and CCTV placed at our offices.

B – Personal data that we collect and process

1. name;
2. business contact details;
3. organisation;
4. image, from CCTV cameras at our premises.

C – Why do we collect your personal data and what are our lawful bases for it?

If you object to us using your personal data for these purposes, please contact our DPO as indicated in Section 2 above.

D – How long do we keep the personal data of visitors to our premises?

We keep our visitors’ personal data for as long as necessary to ensure security of our office visitors and as soon as it is no longer necessary. CCTV footage is stored in back-up for 30 days, unless there is a legal requirement for us to keep it for longer or the data is necessary for the establishment, exercise or defence of legal claims.

We may collect information about consumers that visit and otherwise interact with websites, mobile apps, and other Internet-connected properties that publishers, advertisers, and other third parties (or companies acting on their behalf) use to deliver, measure, or track advertising and obtain other insights.
i. Sources of Personal Data
We may obtain information about you from your interactions with our Systems and from various third parties.

• We obtain information about you and your use of the Systems from MiQ Affiliates.
• We obtain information about you from our clients seeking to place advertisements.
• We obtain information about you from our service and content providers that help us place advertisements or measure effectiveness.
• We obtain information about you from companies that provide or sell information we use to target advertising or measure effectiveness.
• We obtain information about you from parties that place cookies or advertisements on their websites.
• We obtain information about you from other users of the Systems.

MiQ may collect the following types of Personal Data about visitors to Publisher’s sites and digital properties such as:

• Device Identifying Information and Other Identifiers, such as data that identifies you like a user ID, cookie ID, hashed email address, registration ID or segment ID, and data that identifies your device or web browser like user agent, device ID, cross-device ID, hashed TV identification, device type, URL, IP address, location address, browser information or other similar identifiers.
• Commercial information, such as customer ID, products or services purchased, obtained, or considered and associated timestamps, or other purchasing or consuming histories or tendencies.
• Demographic information, such as your age, ethnicity, gender, marital or familial status, or education.
• Household information, such as household income, presence of children in the household, or TV commercial and program viewing history (tied to devices in the house).
• Internet or other electronic network activity information, such as your browsing behavior, search behavior within websites and applications, or information regarding your interactions with an Internet-connected website, application, or advertisement.
• Geolocation information, such as zip code, your precise location based on your device’s global position systems (GPS) signal, truncated latitude and longitude, and approximate location data from your IP address.
• Inferences drawn from any of the information we collect to create a profile about you reflecting your preferences, characteristics, behavior, or attitudes.
• Non-sensitive health information, in the US, based on visits to the websites or mobile applications of select health-related advertisers (retargeting) and standard audiences from 3^rd party data providers. A full list of standard health categories used can be found here. Example retargeting segments would include visitors to websites of MiQ clients promoting over-the-counter drugs, generalist hospitals and health centers, or prescription drugs and medical devices for common conditions such as high cholesterol or type-2 diabetes.
• Political information, in the US, we may use data from 3^rd party data providers that is based on political information or interests such as party membership, political affiliation and voter registration. A list of standard political segments used can be found here. We also may work with some political campaigns to utilize their data (e.g., voting history, registration status, etc.) and create or use custom segments based on that data. For example, a campaign may create a segment of users who voted Independent within a particular city or county and share with us as a custom segment.
• Viewed content information, we collect information about the video content you view on certain smart TVs or connected devices.

iii. Purposes for Collecting Your Information
MiQ does not place ads targeted to the characteristics of any particular individual. Instead, we generally target population segments or groups of individuals. These segments generally involve aggregated groups of users, typically thousands or hundreds of thousands of users who may share common characteristics. MiQ may use your information in the following ways:

• To provide our services to clients or receive products or services from vendors:
  • to deliver or assist our clients and business partners to deliver targeted ads;
  • to enable service and content providers to assist or facilitate our provision of advertising and other services to our clients;
  • to measure and analyze the effectiveness of the ads presented and trends in social media activity;
  • to more effectively match advertisements and website content with users’ interests; and
  • to provide customer service, process transactions, verify customer information, manage customer records, or similar services.
• For internal business purposes:
  • to diagnose, repair and track service and quality issues;
  • to help us maintain the quality of our services;
  • to detect and manage security incidents and protect against malicious activity;
  • for system administration purposes;
  • to research technological developments;
  • to monitor statistical data about users’ browsing actions and patterns;
  • to assist us in improving the operation of our services and to enhance our services; or
  • to respond to your requests and choices (as described in the Choices section below).
• For legal, safety, or security reasons:
  • to comply with applicable laws and regulations or to respond to a subpoena, search warrant, or other lawful request for information received by us, whether or not a response is required by applicable law;
  • to enforce the our contracts or to protect our rights; or
• to protect the safety of members of the public and users of the Systems.
• For any other purpose for which you provide consent.

iv. How Long We Keep Your Information
MiQ minimizes the personal data it collects about users and retains the data for only limited periods.
Raw data that MiQ collects about user online activities is kept for no longer than 180 days from the date collected and is stored in a secure environment. User-level data is irrevocably hashed within 180 days. Minimized data is aggregated and expressed only in a summary form about user behavior representing large groups of individuals. De-identified data may be kept at MiQ for 2 years. During the initial 180-day period, data that is not de-identified is used to better target the ad campaigns and adjust the audience to ensure the ad is displayed to user groups that may be most interested in the product or service advertised.

i. Sources of Personal Data

We may collect information about you in the following ways:

• Information you provide to us directly, such as when you register on our Site; sign up for offers or purchase services or otherwise communicate with us.
• Information collected or inferred from your use of the Site, such as when and how often you visit or otherwise interact with the Site., through the use of Cookies or Web Trackers as described in Section 5 of this policy.

ii. Information We Collect

The types of information that MiQ may collect about visitors to our website (www.wearemiq.com) or other digital properties managed by MiQ include:

• Identifiers, such as name, postal address, telephone number, unique personal identifier, user name, email address, account name, or other similar identifiers.
• Device identifying information, such as IP address, location address, browser information, device type, or cookie IDs.

iii. Purposes for Collecting Your Information

MiQ collects your information and may use for the following purposes:

•

• To provide you with services if you interact with MiQ directly:
  • to provide you with products or services you request;
  • to provide customer support, process transactions, verify your information; or
  • to communicate with you.
• For internal business purposes:
  • to diagnose, repair, and track service and quality issues;
  • to help us maintain the quality of our services;
  • to detect and manage security incidents and protect against malicious activity;
  • to manage customer records;
  • for system administration purposes;
  • to research technological developments;
  • to research for marketing purposes;
  • to monitor statistical data about users’ browsing actions and patterns;
  • to assist us in improving the operation of our services and to enhance our services; or
  • to respond to your requests and choices (as described in the Choices section below).
• For legal, safety, or security reasons:
  • to comply with applicable laws and regulations or to respond to a subpoena, search warrant, or other lawful request for information received by us, whether or not a response is required by applicable law;
  • to enforce our contracts or to protect our rights; or
  • to protect the safety of members of the public and users of the Systems.

For any other purpose for which you provide consent.

iv. How Long We Keep Your Information

We will keep and process your Personal Data only for as long as necessary for the purposes for which it was collected in connection with your use of our Site, unless there is a legal requirement for us to keep it for longer or the data is necessary for the establishment, exercise, or defense of legal claims.

i. Sources of Personal Data
We may collect business contact data related to the account representatives of our customers and vendors in the following ways:

• Information you provide to us directly, such as when you register on our Site; sign up for offers or purchase services; attend networking events that we host, sponsor or attend; or communicate with us.
• Information from your employer, such as when your employer provides us information related to its use of or interaction with our services or products.
• Information from publicly available sources, such as your company website or social media sites.
• Information from MiQ Affiliates (please see Annex 1 for a list of our Affiliates).

ii. Information We Collect
The types of information that MiQ may collect about you include:

• Identifiers, such as name or user name.
• Professional or employment-related information, such as business postal address, business telephone number, business email address, job title, organization, and other information you provide when purchasing our services.
• Payment Information, such as bank information, credit card details or other data necessary for MiQ or its service providers to process payments.

iii. Purposes For Collecting Your Information
MiQ may use your information in the following ways:

• To provide our services to clients or receive products or services from vendors.
• To provide you with services if you interact with MiQ directly, including establishing and managing our relationship.
• For marketing to let clients and potential clients know about our products, services, and events that may be of interest.
• For internal business purposes:
  • to learn about how our products and services are or may be used; or
  • for security, risk, and fraud prevention management and reporting.
• For legal, safety, or security reasons:
  • to comply with applicable laws and regulations or to respond to a subpoena, search warrant, or other lawful request for information received by us, whether or not a response is required by applicable law;
  • to enforce our contracts or to protect our rights; or
  • to protect the safety of members of the public and users of the Systems.
• For any other purpose for which you provide consent.

iv. How Long We Keep Your Information
We will keep and process your Personal Data only for as long as is necessary for the purposes for which it was collected. We will keep your information for the duration of our business relationship and once it ends, we will delete it securely unless there is a legal requirement for us to keep it for longer or the data is necessary for the establishment, exercise, or defense of legal claims.

i. Sources of Personal Data
We may collect information about you directly, such as when you register at a MiQ facility and from CCTV cameras at our offices.

ii. Information We Collect
The types of information that MiQ may collect about you include:

• Identifiers, such as name or other similar identifiers you provide when signing in at a facility.
• Professional or employment-related information, such as business postal address, business telephone number, business email address, job title, or organization.
• Visual information such as images of you collected via CCTV cameras at our premises.

iii. Purposes for Collecting Your Information

• For internal business purposes to maintain records of visitors to our premises.
• For legal, safety, or security reasons:
  • to comply with applicable laws and regulations or to respond to a subpoena, search warrant, or other lawful request for information received by us, whether or not a response is required by applicable law;
  • to enforce our contracts or to protect our rights; or
  • to protect the safety of members of the public and users of the Systems.

iv. How Long We Keep Your Information
We keep your Personal Data for as long as necessary for security purposes. CCTV footage is stored in back-up for 30 days, unless there is a legal requirement for us to keep it longer or the data is necessary for the establishment, exercise, or defense of legal claims.