KLEVER PROGRAMMATIC INC. - PRIVACY NOTICE

 

1. INTRODUCTION 

Klever provides trading desk services to support our customers in buying, managing, and optimizing data-driven digital advertising campaigns across multiple platforms, devices and formats. In providing these services we may process your data if you are a user or potential user of our customers’ products, services, websites or media, or if you are or work for one of our customers or other business contacts.

 

This Privacy Notice explains how Klever uses and protects personal data and information. Klever is committed to respecting all applicable privacy laws and ensuring your data is secure. This Notice does not apply to our processing of data of Klever employees or employment candidates, which will be communicated separately.

 

Klever may change this Notice from time to time by updating this page. You should check back to ensure that you are up to date with any changes. 

 

2. WHO WE ARE

The entity that takes decisions regarding why and how your personal information is processed (also referred to as a “Data Controller”) is:

 

Klever Programmatic Inc. (“Klever”) (incorporated in Canada) 

6000 Boulevard Rome, Suite 410 

Brossard, Québec J4Y 0B6

Canada

privacy@beklever.com

 

3. CATEGORIES OF DATA THAT WE PROCESS

 

A. Internet and media users: In providing our advertising-related services we may have access to data generated by publishers or advertisers from viewers of their websites, apps, connected televisions, or other media. We ourselves do not collect this data, but this data may be disclosed to us by customers in connection with their ad campaigns, or by demand-side platforms (DSPs) or ad exchanges through whom we buy online advertising or receive information in relation to pricing and performance of advertising.

 

In general, this information relates to online behavior and does not contain real life names or addresses or any other information that could allow anyone directly to identify or contact a particular person. Information we receive may include the following:

 

  • cookie IDs

  • device IDs 

  • advertising IDs (such as mobile advertising IDs)

  • mobile device usage data (such as apps used)

  • browser and device type, version and settings (“user agent”)

  • IP addresses that reveal approximate location of the device

  • webpage browsing information e.g. urls visited or searched

  • interactions with ads (e.g. views, clicks, purchases)

  • advertising bid requests

  • information about likely interests or intentions which either we infer from the above information or is provided to us by customers and partners.

 

B. Business contacts: If you or your employer is a Klever customer (or potential customer), or one of our suppliers (or potential suppliers), an investor or potential investor, or other business contact, then we will need to collect certain personal contact information in connection with our relationship with you. This information may also come from our third party marketing partners. This may include:

 

  • your name

  • company name

  • position

  • professional qualifications or interests

  • mailing address

  • web address

  • telephone numbers

  • e-mail addresses

  • details of  products and services, and

  • information provided to us in the course of correspondence with you (e.g. by email, phone, or online messaging).

 

4. PURPOSES FOR WHICH WE PROCESS DATA 

We collect and use personal data for the following purposes:

 

A. Internet and media users

  • personalizing, targeting and delivering ads

  • limiting the number of times ads are seen

  • measuring effectiveness and viewability of ads

  • measuring clicks, purchases or other actions

  • keeping records, reporting to customers and billing for ad campaigns

  • making links between devices that might relate to the same users

  • preventing fraud or invalid activities.

 

In the EU/EEA and UK our legal basis for this data use is your consent, which the relevant publisher or brand needs to have obtained from you in accordance with local laws. You can manage your consents as set out in Section 9.

 

B. Business contacts

  • setting up, renewing, updating, and managing your or your organization’s contract or account with us 

  • billing and collections for services we provide

  • making payments for products and services supplied to us

  • evaluating new services and products

  • investor relations

  • recordkeeping, accounting and meeting other legal requirements 

  • managing, improving and expanding our business and resources

  • communicating with you and managing our relationship with you

  • answering inquiries including email, telephone, and chat conversations with sales and customer support staff

  • responding to customer services requests

  • organizing events such as webinars 

  • sending promotional communications and offers

  • sending PR or company information (e.g. if you are a journalist or influencer)

  • asking for feedback on our products and services;

  • understanding visitors’ navigation on our websites to understand trends and user interests and requirements.

 

In the EU/EEA and UK our legal basis for this data use is compliance with our legal obligations, performance of our contracts, or our legitimate interests which are compatible with your interests and rights. 

 

5. RECIPIENTS AND INTERNATIONAL TRANSFERS

Our corporate headquarters is located in Brossard, Québec, Canada. Your personal information may be stored and processed in any country where we have facilities or service providers that we work with, e.g. for audience measurement, secure hosting, data storage, ad exchanges and DSPs.

 

We also provide data to our customers in relation to their campaigns and contracts with us in order to ensure proper billing and improve future campaigns.

 

Where we send data originating from the EU/EEA, the UK, or Switzerland internationally (other than to Canada or other places that are officially regarded as having adequate data protection laws), we put in place safeguards designed to ensure that data is processed in a way equivalent to the rules applicable under the EU and UK General Data Protection Regulations. These may include standard contract clauses for data transfers as approved by the European Commission or other supervisory authorities. A copy of these safeguards may be made available if we receive a valid request.

 

Occasionally we may receive a request from a government, law enforcement agency or regulator requesting data from us, and we would normally comply with such request without having to notify you.

 

6. DATA RETENTION PERIODS

We only retain data for as long as necessary for the purpose for which the data was collected. So we will retain your account data for at least the time that you or your organization has an account or contract with us. If you have subscribed to a newsletter or other communications, we will keep your contact details until you unsubscribe. 

 

We retain device IDs and related data for up to eighteen months for billing and service management purposes. Aggregated and anonymized or statistical data may be retained for a longer period for reporting, testing, tax or legal reasons. 

 

7. SECURITY

Once the retention periods are reached and data is no longer required, such data is anonymized so that it does not relate to any identifiable person and is not used for our services.

 

We implement and require our third party suppliers to implement security measures, including physical, logical, contractual, and organizational safeguards, to prevent unauthorized access to, loss, misuse, or alteration of the information that we process in connection with our services. We consider these measures to be appropriate given the sensitivity of the data, and in line with all applicable laws and good industry standards.

 

8.  COOKIES

A cookie is a small piece of data sent from a website and stored in a user’s web browser or device. Every time the user loads the website, the browser sends cookie information back to the server to notify the website that it recognizes the user. You can find more information about different types of cookies here.

 

We use cookies when you visit our websites, for the purposes of analyzing use of our websites, and improving and optimizing our websites and services. 

 

You can remove cookies from your web browser by following the directions provided in your browser’s “help” or “settings” sections. Some cookies may be essential for using different features of certain websites, so if you clear all cookies then those features may not work as expected, or you may need to accept some cookies on your next visit. For mobile devices please review the privacy controls within your mobile operating system. 

 

9.  YOUR RIGHTS

In relation to online advertising data, there are various methods that enable you to manage consents and data use directly, without contacting publishers or media owners:

 

 

Some of these methods may place a cookie on your device to identify you as not wanting to receive targeted ads so, if you change devices or delete cookies, you may need to repeat this process.

 

In addition, under international data protection laws, including the GDPR in the EU/EEA or the UK, PIPEDA in Canada, and the CCPA in California, you may have various additional rights such as the following: 

 

  • to access your personal data

  • to require us to correct mistakes in your personal data

  • to have personal data concerning you erased (“the right to be forgotten”)

  • to receive personal data which you have provided to us (“portability”)

  • to object to processing of your personal data for direct marketing or for certain other purposes

  • to restrict our processing of your personal data in certain circumstances

 

If our data processing is based on your consent, then you can always withdraw that consent (but any processing that took place before withdrawal will still be legal). 

 

If you wish to exercise any of your legal rights, or have another issue or inquiry, it may be easiest to contact the publisher or media provider to whom you originally gave your consent. In other cases, please contact us using the details in this Notice and we will help as far as possible. If you believe that we have not respected your rights then you also have a right to challenge our compliance before the supervisory authority in your country.


Last updated: 22 February 2021