1.  General notice

This policy applies to the following websites that are operated or controlled by IAB Europe:

• www.iabeurope.eu
• www.advertisingconsent.eu
• www.interactcongress.eu
• www.datadrivenadvertising.eu

IAB Europe respects the privacy of the visitors on its websites (“Websites”) (“Users”) and of its registered members (“Members”) to which it provides services as further specified in the General Terms of Use (“Services”). In this Privacy Policy references to Members mean both individual Members and individuals who are employed by corporate Members. This Privacy Policy is also addressed to individuals outside IAB Europe with whom IAB Europe interacts and whose personal data it processes and for these purposes they will be included within the term “Users”.

IAB Europe processes personal data in accordance with applicable data protection legislation, in particular the General Data Protection Regulation (EU) 2016/679 (the “GDPR”).

This privacy policy (“Privacy Policy”), together with the General Terms of Use and the Cookie Policy exclusively govern the relationship between the User, the Member and IAB Europe, in connection with the Services and your use of the Websites.

IAB Europe reserves the right to modify the Privacy Policy at all times by posting an updated version on the Websites. You should check back to review it regularly. However, if we make any material changes we will notify you by means of a notice on this Websites or if you are a Member, by email (sent to the e-mail address specified in your Member’s account) prior to the change becoming effective.

The Privacy Policy applies to www.iabeurope.eu owned and operated by IAB Europe. This Privacy Policy describes how IAB Europe processes relevant personal data and, in particular, how we collect and use the personal data you provide via our Websites and by other means. It also describes the choices available to you regarding our use of your personal data, including how you can access and update this information.

2. Data controller

IAB Europe A.I.S.B.L. (BE 0812.047.277), having its registered offices at 1040 Brussels (Belgium), Rond-Point Schuman, 11 is the entity that acts as the only data controller for the purposes of this Privacy Policy ( “IAB Europe”). All questions or requests regarding the processing of these data may be addressed to: communication@iabeurope.eu

3. Data collected

3.1  Collection of personal data

IAB Europe collects or obtains personal data from its Members and Users from the following sources:

• IAB Europe obtains personal data when those data are provided by Users or Members (e.g., where a User or Member contacts IAB Europe via email or telephone, or by any other means);
• IAB Europe collects or obtains personal data in the ordinary course of its relationship with its Members and Users (e.g., when IAB Europe provides a service to Members or Users);
• IAB Europe collects or obtains personal data that its Members and Users manifestly choose to make public, including via social media (e.g., IAB Europe may collect information from its Members’ and Users’ social media profile(s), if they make a public post about IAB Europe);
• IAB Europe collects or obtains personal data when its Members and Users visit the Websites or use any features or resources available on or through the Websites;
• IAB Europe collects or obtains personal data when its Members and Users use, or register to use, the Websites or any Services;
• If IAB Europe’s Members and Users interact with any third party content or advertising on the Websites (including third party plugins and cookies) IAB Europe receives personal data from the relevant third party provider of that content or advertising;
• IAB Europe also creates personal data about its Members and Users in certain circumstances, such as records of IAB Europe’s Members’ and Users’ interactions with it.

3.2  Personal data processed by IAB Europe

IAB Europe processes, for the purposes listed in Section 4, the following types of personal data:

• Identification data, e.g. user name, password, real name and first name, email address and professional contact details;
• Consent records, e.g. records of any consents a User or Member has given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent);
• Employer details, e.g. where a User or Member interacts with IAB Europe in their capacity as an employee of a third party, the name, address, telephone number and email address of the employer, to the extent relevant;
• Content and advertising data, e.g. records of a User’s or Member’s interactions with online advertising and content, records of advertising and content displayed on pages displayed to that User or Member, and any interaction a User or Member may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions;
• Views and opinions, e.g. any views and opinions that a User or Member chooses to send to IAB Europe, or publicly post about IAB Europe on social media platforms;
• Communications transmitted through the Websites, communications addressed to IAB Europe;
• Supplementary information that IAB Europe may ask the User or the Member to communicate in order to identify him, or where IAB Europe suspects the User or the Member may be in breach of any of their obligations to IAB Europe
• Any other information voluntarily transmitted to IAB Europe by the Member for a specific purpose.

3.2.1. « Cookies »

When you visit the Websites we will usually place Cookies on your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We process personal data through Cookies and similar technologies, in accordance with our Cookie Policy.

3.2.2. Data recorded on our servers

When the User or the Member accesses the Websites, the relevant servers automatically record the following data which are not made visible on the Websites: the type of domain from which the User or the Member connects them self to the Internet, the IP address allocated to the them (at the moment of the connection), the date and time of access to the Site, the pages viewed and the activities undertaken, the type of browser used, the platform and/or the operating system used, the search engine and the keywords used to find the Websites.

4. Purposes of the data processing and legal bases for the processing

4.1 General purposes

The purposes for which IAB Europe may process the personal data of its Users and Members, subject to applicable law, include:

• Provision of the Websites and Services: providing the Websites to Users and Members; providing Users and Members with promotional items at their request; and communicating with Users and Members in relation to those services;
• Improving the Websites and services: identifying issues with the Websites or services; planning improvements to the Websites or services; and creating new websites, or services;
• Marketing communications: communicating with Users and Members via any means (including via email, telephone, text message, social media, post or in person) news items and other information in which they may be interested, subject to ensuring that such communications are provided to Users and Members in compliance with applicable law;
• Communications and IT operations: management of IAB Europe’s communications systems; operation of IT security; and IT security audits;

• Health and safety: health and safety assessments and record keeping; and compliance with related legal obligations;
• Financial management: sales; finance; corporate audit; and vendor management;
• Surveys: engaging with Users and Members for the purposes of obtaining their views on the Websites, and our services;
• Legal compliance: compliance with IAB Europe’s legal and regulatory obligations under applicable law;
• Recruitment and job applications: recruitment activities; advertising of positions; interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; and acceptance details.

4.2  Sensitive personal data

IAB Europe does not seek to collect or otherwise process Sensitive Personal Data in the ordinary course of its business Where it becomes necessary to process the Sensitive Personal Data of our Users or Members for any reason, IAB Europe relies on one of the following legal bases:

• Compliance with applicable law: IAB Europe may process Sensitive Personal Data where the processing is required or permitted by applicable law (e.g., to comply with IAB Europe’s diversity reporting obligations);
• Detection and prevention of crime: IAB Europe may process Sensitive Personal Data where the processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);
• Establishment, exercise or defence of legal rights: IAB Europe may process Sensitive Personal Data where the processing is necessary for the establishment, exercise or defence of legal rights; or
• Consent: IAB Europe may process Sensitive Personal Data where it has, in accordance with applicable law, obtained the prior, explicit consent of a User or Member prior to processing their Sensitive Personal Data (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).

“Sensitive Personal Data” means personal data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offenses or penalties, national identification number, or any other information that are deemed to be sensitive under applicable law.

4.3 Legal bases for processing

In processing your personal data in connection with the purposes set out in this Privacy Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

• The processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us;
• We have a legitimate interest in carrying out the processing for the purpose of: (i) providing or improving our Services; (ii) fulfilling our regulatory and compliance obligations; (iii) contacting you, subject always to compliance with applicable law; (iv) detecting, and protecting against, breaches of our policies and applicable laws; or (v) establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms);
• We have obtained your prior consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory); or

The processing is necessary for compliance with a legal obligation.

5. Transfer to third parties

We will share your personal data with third parties only in the ways that are described in this Privacy Policy. We do not sell your personal data to third parties.

We may provide your personal data to companies that provide services to help us with our business activities for marketing purposes. These companies are authorized to use your personal data only as necessary to provide these services to us.

IAB Europe transmits the personal data of its Users or Members to third-party services to the extent to which these data are required for the performance of the relevant Services. Any such partner will not communicate these personal data to third parties, except in the following situations: (i) if and to the extent that this communication is necessary for the contract’s performance, and (ii) if the partner is obliged to communicate certain information or documents to a public authority, as required by law, such as to comply with a subpoena, or similar legal process and (iii) if IAB Europe is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/ or prominent notice on our Websites of any change in ownership or uses of your personal data, as well as choices you may have regarding your personal data. The communication of information to the persons set out in point (ii) shall, in any case, be limited to that which is strictly necessary or required by applicable law.

If IAB Europe engages a third-party processor to process personal data of its Users or Members, the processor will be subject to binding contractual obligations to: (i) only process the personal data in accordance with IAB Europe’s prior written instructions; and (ii) use measures to protect the confidentiality and security of the personal data; together with any additional requirements under applicable law.

6. International transfer of personal data

IAB Europe does not transfer any data outside the European Union though some of the services that IAB Europe uses would. “Adequate Jurisdiction” means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for personal data.

6.1 IAB Europe uses Google Analytics

The websites uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the websites analyse how users use the site. The information generated by the cookie about your use of the websites (including your IP address) will be transmitted to and stored by Google on servers in the United States.  Google will use this information for the purpose of evaluating your use of the websites, compiling reports on websites activity for websites operators and providing other services relating to websites activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of these websites. By using these websites, you consent to the processing of data about you by Google in the manner and for the purposes set out above. For more information please visit http://www.google.com/analytics/

6.2 IAB Europe uses YouTube

These websites use YouTube, a video hosting platform provided by Google, Inc. (“Google”). YouTube uses DoubleClick cookies, which have the purpose of collecting information to personalize advertising. For more information about cookies used by Google, please visit: https://policies.google.com/technologies/types

6.3 IAB Europe uses social media API connectors

These websites use Social media API connectors to facilitate the sharing of our content on the following social media channels: Facebook, LinkedIn and Twitter.

6.4 IAB Europe uses Mailchimp

IAB Europe uses Mailchimp, a marketing automation platform provided by Rocket Science Group, LLC to manage our mailing lists. Personal data such as first Name, last Name, email address and company name of our mailing lists subscribers are stored in the IAB Europe Mailchimp account for communications purposes (e.g. IAB Europe news and related activities)  

6.5 IAB Europe uses Google Suite

IAB Europe Google Suite, a service provided by Google, Inc. (“Google”)  to keep lists of members in some of our committees.

6.6 IAB Europe uses Office 365

IAB Europe uses Office 365, a service provided by Microsoft Corp. to receive/send and archive emails.

6.7 IAB Europe uses Trippus

IAB Europe uses Trippus, a service provided by Trippus Norge to process registrations for our annual conference INTERACT and to process payments for the Global Vendor List and for the CMP list in the Transparency and Consent Framework. http://register.consensu.org/

7. Direct marketing

Personal data provided by Users or Members will not be used for direct marketing purposes, except if the User or the Member has expressly given their prior consent by ticking the appropriate boxes (“opt-in” boxes).

If a User or the Member has given their consent for the use of this information for direct marketing purposes, they retain the right to object at any time, free of charge, to such a use. In order to exercise their right to receive no further marketing communications, the User or the Member should send an email to the following address: communication@iabeurope.eu

If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us at communication@iabeurope.eu.

We may offer you the opportunity to participate in surveys on our Websites. If you participate, we will request certain personal data from you. Participation in these surveys is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and address), and demographic information (such as zip code).

9. Accuracy

IAB Europe takes every reasonable step to ensure that:

• Its Users’ and Members’ personal data that it processes are accurate and, where necessary, kept up to date; and
• Any of its Users’ and Members’ personal data that it processes that are inaccurate (having regard to the purposes for which they are processed) are erased or rectified without delay.

From time to time IAB Europe may ask you for a confirmation of the accuracy of your personal data.

10. Minimisation

IAB Europe takes every reasonable step to ensure that personal data that it processes are limited to the personal data reasonably necessary in connection with the purposes set out in this Privacy Policy.

11. Storage periods

The criteria for determining the duration for which IAB Europe will keep personal data are as follows:

• We will retain Personal Data in a form that permits identification only for as long as we maintain an ongoing relationship with you, or
• Where your personal data is necessary in connection with the lawful purposes set out in this Privacy Policy, for which we have a valid legal basis,
• As regards personal data of its Members, IAB Europe will normally store the data during the full period of your membership. IAB Europe may retain personal data of a Member who is deregistered, or a User, including all correspondence or request for assistance addressed to IAB Europe for two years, in order to be able to respond to any questions or complaints which may be addressed to it after deregistration, in order to comply with all applicable laws, and for the duration of any period necessary to establish, exercise or defend any legal rights.

Once these periods have concluded, IAB Europe will either:

• permanently delete or destroy the relevant personal data; o
• anonymize the relevant personal data.

12. Data subjects’ rights

Any Member may, at any time, have access to their personal data and correct them through the thumbnail “Edit Profile”, within the “Members – Account” menu on the Websites (or at the following address: https://www.iabeurope.eu/profile/edit by using their username and password).

The User or the Member may also request access, ask for rectification and for deletion of their personal data, except those which IAB Europe are legally obliged to retain, from IAB Europe’s database by addressing a written request, accompanied with, to the data controller at the following address: IAB Europe, rue Bara, 175, B-1070 Brussels.

Any User or Member may request to have their personal data transferred to another controller, in a structured, commonly used and machine-readable format.

Any User or Member may request restriction of processing of their personal data.

Where IAB Europe processes a User or Member’s personal data on the basis of consent, the User or Member has the right to withdraw that consent (although this withdrawal does not affect the lawfulness of any processing performed prior to the date on which IAB Europe receives notice of such withdrawal, and does not prevent any processing of personal data on any other available legal bases).

IAB Europe will then take all necessary steps to satisfy such request with expediency.

Any User or Member has the right to lodge complaints regarding the processing of their personal data with a data protection authority (which can be any of the data protection authority of the EU Member State in which they live, or in which they work, or in which the alleged infringement occurred).

Subject to applicable law, each User or Member may also have the following additional rights regarding the processing of their personal data:

• the right to object, on grounds relating to their particular situation, to the processing of their personal data by IAB Europe or on its behalf; and
• the right to object to the processing of their personal data by IAB Europe or on its behalf for direct marketing purposes.

13. Persons under the age of 18

Persons under 18 years old and persons who do not have full legal capacity are not allowed to use the Websites, and must not provide their personal data to us.

14. Additional Information

14.1 Testimonials

We display personal testimonials of satisfied members on our Websites in addition to other endorsements. With your consent we may post your testimonial along with your name, but we will always check that you are happy for us to do so first.  If you wish to update or delete your testimonial, you can contact us at communication@iabeurope.eu.

14.2 Links to 3rd Party Sites

Our Websites includes links to other websites whose privacy practices may differ from those of IAB Europe. If you submit personal data to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

14.3 Social Media Widgets

Our Websites includes Social Media Features, such as the Twitter button and Widgets, such as the “Share this” button or interactive mini-programs that run on our Websites. These features may collect your IP address, which page you are visiting on our Websites, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Websites. Your interactions with these Features are governed by the privacy policy of the company providing it.

15. Contact Us

You may contact us for any reason in connection with this Privacy Policy at:

IAB Europe

Rond-Point Robert Schuman 11

1040 Brussels

Belgium

+32 2 256 75 10

communication@iabeurope.eu

Last Updated: 20 June 2018