End User Privacy Policy

Last modified: 8.07.2019

This document provides information about our web platform – Indicado. Indicado (owned and developed by Indicado LLC with a registered office at 228 East 45th Street Suite 9E, New York 10017, the United States of America ) serves for automatic consolidation of marketing and sales efforts data for reporting, attribution, analysis, optimisation and activation purposes. Indicado LLC processes data transferred to Indicado web platform by the client and does it solely as a processor in the meaning of the GDPR provisions. It means that a controller of your personal data (i.e. the entity that determine the purposes and means of the processing) is exclusively the client of Indicado LLC.  Despite this, we want to be fully transparent in processing of your personal data and due to that we provide you with the policy regarding your personal data as the end user. Then the intention of this document is to provide you transparent information on how the Indicado web platform runs and how the data is processed, collected, and stored in the platform. We realize that some technical terms might sound complicated to you, so this document presents those terms in simple words as well as explains what the goal of the data processing is.

Indicado LLC is firmly committed to protecting the privacy of Internet’s users. Accordingly, we are committed to observing applicable industry guidelines including those established in connection with General Data Protection Regulation by the European supervisory authorities. We continue to evaluate enhanced ways to protect Internet users’ privacy while seeking to deliver relevant mechanism for our clients that want to manage collected data effectively. 

This document outlines Indicado LLC’s End User Privacy Policy and provides you clear notice about the user’s information we may process online on behalf of our clients and in connection with our services.

This policy DOES NOT apply to the data collected by Indicado LLC through its websites on its behalf and for its own purposes. The scope of such processing as well the purposes of it are described in the following documents: The Privacy Policy and The Cookies Policy.

  1. Glossary
    • Applicable laws: All the laws and regulations relevant to the processing of data, including its collection and storage, especially all the data protection laws and the General Data Protection Regulation (EU) 2016/679 (GDPR).
    • Cookie: They are small text files stored locally by a website or ad server. By storing certain information in a cookie, those web browsers or ad servers are able to remember your preferences and recognize websites visited and / or web browser used from one visit to another. To learn more about cookies and how to disable them, visit http://www.allaboutcookies.org.
    • Client: The party who submits an application on the registration page and uses the Indicado web platform.

 

    • Controller: an entity that determines the purposes and means of the Processing of Personal Data.  
    • Data Source: integrated digital sources of third-parties from which the Client’s data is imported to be used within Indicado LLC’s services.

 

    • Data Subject: means the individual to whom Personal Data relates, including End Users.

 

    • End User –  a user of an Internet connected device, such as a visitor to a website, a user of a mobile app, or a user of an IoT device, or a visitor on an advertisement, landing page, or campaign.

 

    • GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
    • IP address: An Internet Protocol (IP) address is a set of numbers that each device has assigned to connect with other device over the Internet network. The IP address allows addressing and delivering the information to the right receiver. Every time a piece of information is sent, a device needs to communicate with other devices in a computer network to be able to deliver the message. Sending information in that context means every kind of activity such as surfing, exchanging emails, or downloading an application. The IP address is used to identify the device to which the message is supposed to be sent and find the best way to deliver it.
    • Personal Data: Any information relating to an identified or identifiable person as defined in article 4.1 of the GDPR.

 

    • Pixel: This is an invisible, very small (1 x 1) pixel tag that Clients can put on their sites. When you as a visitor open a website where the tracking pixel is placed, the information is sent to Indicado web platform. Pixel tags are used in combination with cookies to track user’s activities while surfing through websites by a particular browser on a particular device.

 

    • Processing: Any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction (the Process, Processes and Processed shall have the same meaning).

 

    • Processor: an entity which Processes Personal Data on behalf of the Controller.

 

    • User Agent: Information on a device, an operating system, a web browser is being used to access a website.

 

    • You:  a person whose data is processed by Indicado LLC on behalf of the Client.

 

  1. What is Indicado?

Indicado is a SaaS analytical and management tool for online advertisers/brand that recommends the most effective media channels, audiences, creatives and the optimal budget, as well as maximizes customers’ satisfaction. In other words, the Indicado web platform enables its Clients to gather and analyze data that they are entitled to process on the basis of applicable law, from different Data Sources (including media channels i.e. social, search, retargeting, email, as well as product/web analytics and transactional sources i.e. CRM, databases).

Therefore, in Indicado web platform, there is processed data about different activities of online visitors to allow the Clients of Indicado LLC to plan their business activities in a more effective way. Those visitors are Internet users who surf through the websites, send emails, communicate on social media and make transactions when purchasing goods or services from online shops or businesses.  

In the next sections, you can find out what information is stored in Indicado web platform and how it relates to your activities as the End User.

III. Indicado LLC’s Role in the Processing of the Personal Information

While our Clients use Indicado web platform, we act as the Client’ data Processor meaning that we process your Personal Data on behalf of our Client’s instructions under the Data Processing Agreement.

We can make available an Indicado’s Pixel to our Client, which shall help them to integrate your data with Indicado web platform. However, to collect the data with the use of such Pixel, the Client is obliged to have a relevant legal basis in the meaning of Article 6 of the GDPR.

  1. What Kind of Data Do We Collect and For What Purposes?

On behalf of our Clients, we may process personally identifiable information – PII. The equivalent of PII in European data privacy law – the GDPR is Personal Data. The PII/ Personal Data can be divided into two categories: linked information and linkable information.

Linked information is any piece of personal information that can be used to identify an individual and includes, but is not limited to, the following: full name, home address, email address, telephone number.

Linkable information on the other hand, is information that on its own may not be able to identify a person, but when combined with another piece of information could identify, trace, or locate a person. The examples of linkable information are as follows: a first or last name, country, state, city, postcode, non-specific age, job position and workplace.

In order to perform our services, we are also instructed on processing certain information about you and your device. Some of this information (including, for example, your IP addresses and certain unique device identifiers such as the User Agent, otherwise jointly called non-personally identifiable information – non PII) may identify a particular computer or device and be considered as the Personal Data in some jurisdictions, including the European Union. 

The Indicado LLC does not collect any data on its own behalf. Our Clients are also obliged to not entrust us with Personal Data of children and any special categories of data (sensitive information) and we do not process such data. 

We process your data only to perform our services on behalf of the Client according to the provisions of service agreement concluded with the Client. These services regards providing the Client with web platform to analyse and manage the data. We do not determine the purposes of processing of your data. To know more about the processing of your data you should read the relevant privacy policy of the Client who is a Controller of your data.

If you are an employee of the Client and you use the account assigned to the master account of the Client, we shall Process your Personal Data (e.g. email address) on behalf of the Client as the Processor. The Client is the Controller of your Personal Data and it is obliged to notify you about this processing as well as to fulfill your rights as the Data Subject.

  1. How the data are integrated with the Indicado web platform?

The Client may entrust your data to Indicado LLC in two different ways.

First one is to integrate Indicado web platform with Data Sources by using API (Application Programming Interface), which allows communication between the two aforementioned. Therefore the Client can integrate Indicado with the chosen Data Source. 

Another way is providing our Clients with tracking Pixel, that is intended to be installed by Clients on their sites. Your interaction with the Client’s site, on which such pixel was installed, results in your data being collected by our Client and stored on Indicado LLC’s servers according to our Client’s instructions. 

  1. Legal Basis for Processing User Information

If you are the European Union End User or the GDPR applies to you under the Applicable Laws, our Clients are obliged to Process your Personal Data according to relevant provisions. You should also be informed about this Processing and your rights as the Data Subject by the Client. Therefore we encourage you to check each time privacy policies of the sites you interact with or in any case that you make your data available to other entities. These privacy policies should state which Personal Data and on what basis is Processed. 

In case of any request regarding your Data Subject’s rights, sent by you to Indicado LLC, we inform the Client about such request if you provide us with its data and will help that Client to fulfill your rights according to the terms of our Data Processing Agreement.

VII. How Long Do We Store Data?

The data entrusted by the Client is stored using generally accepted security standards for the time of performing services for that Client and after their termination according to the provisions of Data Processing Agreement . The data retention of your data is determined individually by each Client as a Controller of your Personal Data. 

VIII. Your Choices and the Opt-Out Option

The opt-out option from the tracking Pixel is applicable for End Users who interact with the Client or its sites. 

If you wish to opt out of being tracked with the tracking Pixel implemented in desktop website environments integrated with the Indicado web platform, you should use the opt-out option. The Indicado web platform only processes data collected by its Clients meaning that the Indicado LLC’s Clients are obliged to deliver the opt-out option and make it accessible to you as a visitor to their sites. Indicado LLC makes every effort to support its Clients to provide such a solution for you, thus you can find below procedures how to make a request to opt out of being tracked.

The generic solution of the opt out option offered by the Indicado LLC is available under the following link:

http://Indicado _client_domain_name.com/opt-out
where:
Indicado_client_domain_name is the name of the domain assigned to the Client of Indicado LLC.

Because the domain name is set by each Client individually, you need to get in touch with the relevant Client to find out the correct domain name under which your Personal Data is collected. Once the Indicado LLC’s Client replies with the domain name, you can provide the link in the address bar in your web browser to be able to opt out.

Opting out of being tracked with the tracking Pixel implemented in desktop website environments integrated with the Indicado web platform is valid for at least 2 years for a web browser where the opt-out option has been set. The option can be enabled only for a particular web browser meaning that if you switch to other web browsers, clear cookies, or use a browser’s incognito mode, you need to go through the opt-out procedure once more. When the opt-out option expires, you need to repeat the same procedure to turn it on again.

  1. Transfer of Your Data to Third Parties  

We also inform you that according to the Client’s instructions we may disclose your information to our sub-processors i.e. the entities that we cooperate with in order to provide services of Indicado web platform. The complete list of sub-processor is indicated here.

We can also disclose Personal Data to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary: 

(i) under applicable law, and

(ii) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities.

In order to ensure that your Personal Data is adequately protected when transferred outside of the EEA, Indicado LLC has entered into inter-company EU “model clause” agreements.

You may also learn more about EU Commission Decision on standard contractual clauses for the transfer of personal data to processors established in third countries here https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087 and here https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

  1. Security

Indicado LLC uses various security technologies and procedures that help protect your Personal Data from unauthorized access, use, disclosure, alteration, or destruction.

For example:

    • Personnel: Only qualified and authorized employees are permitted to access personal information, and they may do so only for permitted business functions.
    • Security Measures: We use encryption in the transmission of your Personal Data between the Client’s system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Data.
    • Additional Safeguards: We maintain physical, electronic, and procedural safeguards in connection with storage of your Personal Data. 

 

    • Trusted Vendors: We rely only on vendors who ensure an appropriate level of security of your data. In this context, we use only secure cloud servers, including AWS cloud – a secure, private cloud platform. AWS participates in the EU-US Privacy Shield framework. Amazon Web Services is our processor. AWS Amazon cloud platform uses various security technologies and procedures to protect personal data and is compliant with third-party assurance frameworks such as ISO 27017 for cloud security, ISO 27018 for cloud privacy, PCI DSS Level 1, and SOC 1, SOC 2, and SOC 3. For more details please see AWS Amazon security and privacy policy at www.aws.amazon.com.
  1. Children

 

Protecting children’s privacy is very important to Indicado LLC. Indicado web platform is not intended for processing children’s data in any way. We do not allow our Client’s to send to us Personal Data of children as defined under the GDPR.

 

XII. Contact Us

If there are any questions regarding this End User Privacy Policy, you may contact us using the information below:

Indicado LLC

with a registered office at 228 East 45th Street Suite 9E, New York 10017, United States of America

Indicado LLC’s privacy contact: privacy@indicado.com