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SBDS Group

2nd Floor

One Alfred Place

London

WC1E 7EB

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LEGAL

© 2019 by SBDS Group

Welcome to the privacy notice of Silverbullet Services Group Limited. At Silverbullet, privacy is a top priority and we provide the below Privacy Policies to outline our practices and procedures to enable you to make informed decisions about sharing information with us.

 

INTRODUCTION:

 

Silverbullet is committed to protecting the personal data of individuals whose personal data we process. Please take the time to read this privacy notice, since it contains important information about how we collect, use, disclose and otherwise process personal data concerning the following types of data subjects: individuals who use this website; visitors to other publishers’ websites who’s browsing activities we analyse as part of digital advertising campaigns; business and marketing contacts; and visitors to our physical premises. 

 

Disclosure: Our website is not intended for children and we do not knowingly collect data relating to children.

 

In this privacy policy we aim to provide you with a clear and transparent understanding of the answers to questions including:

 

  • What personal data do we collect from and about you and how do we collect it?

  • How, why and on what legal basis do we process your data?

  • How and with whom do we share your data?

  • How you can contact us with your data protection or privacy concerns and your rights under applicable data protection laws?

In this policy we use the following terms:

“SB Group Limited”, “Silverbullet”, “we”, “our”, “us” all refer to the legal entity Silverbullet Group Ltd and our affiliates.
“you”, “users”, “your” are terms which refer to end consumers whose personal information we may handle and take steps to protect.

 

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GENERAL DATA OVERVIEW

1. Who is responsible for processing your data?

For the purpose of the General Data Protection Regulation and any implementing legislation (the “GDPR”), Silverbullet is the data controller responsible for any personal data we process, 1 Alfred Place, London WC1E 7EB, registration number (06216702).  Silverbullet is part of a global portfolio of companies with offices in Germany, Italy and Australia.

2. Data Protection Officer

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

 

Contact details​: Full name of legal entity: Silver Bullet Data Services Limited

​Email address: data.protection.officer@wearesilverbullet.com

 

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. ​

3. General data collection and usage

Specific aspects of data collection and processing for the custom algorithm’s platform and SBDS Group website are described in greater detail below. Some general principles of collection and processing described here are applicable to both.

 

In the course of delivering our internet services we may interact with your internet connected devices using common internet protocols and techniques. Our partners and clients may implement our pixel code and content into their web or mobile app properties, at which point your device will transfer standard information to our systems which includes; browser information; operating system type; browser language; IP address; referrer address; and cookie information we may have previously assigned to your device.

 

In doing so, our systems receive and log information which we deem to be personal data and as such we take care to handle in compliance to applicable data protection regulations.

We deem all such information to be pseudonymous, by which we affirm that the data we collect from you is not sufficient to identify you personally without reference to additional information which we do not have reasonable access to.

 

We do not intentionally collect any data that is not personally identifiable information. Our partners and clients may have the capability to share with us information which is not personally identifiable in its nature. Doing so is in contravention to data processing agreements we have in place with our clients and partners.

 

All the above data may be recorded and processed on our platform for the purposes of performance, relevant advertising, monitoring our technology, compliance with any legal requirements, debugging and protection against fraud or cyber-attack. We undertake this processing as a data controller on the basis of your consent for us to provide you with internet facing services and the standard management this entails.

 

We never intentionally collect or process personal data which is categorised as sensitive (relating for example to health, religion, race, political orientation, sexual orientation, genetic information etc). We do not intentionally collect or process any personal data which relates to children. We do not process any data in relation to criminal convictions or offences.

 

4. Cookies and Mobile Advertising Identifiers

In line with common industry practices, Silverbullet utilise cookies and mobile advertising identifiers to identify your internet connected device.

Note: A cookie is a small text file that is stored by your browser when interacting with our services. We assign your browser a pseudonymous identifier using a cookie which helps us to monitor the performance of our services and to ensure the most relevant adverts are delivered to you. It enables us for example, to prevent repeated delivery of the same advert to you beyond the intended number of impressions.

 

You have a number of controls available to you surrounding our use of cookies by using your browser settings. Please be aware that some settings may degrade your experience accessing online services and websites. We recommend you review and consider your options by visiting http://www.allaboutcookies.org/.

 

Mobile advertising identifiers fulfil a similar role in the context of mobile apps. On Android this identifier is known as an AAID and on iOS it is known as an IDFA. Your mobile advertiser identifier is generated by your mobile device and made available to the apps you have installed. Where available, this identifier is shared with us by our partners as a pseudonymous unique identifier for your device.

 

You have control over the use of your mobile advertiser identifier using your device settings and you should refer to your device specific controls to make changes.

 

5. Consent

SBDS Group has joined a number of industry schemes including the IAB Transparency & Consent Framework (http://advertisingconsent.eu/) 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. IAB Gold Standard and JicWebs Certification.  Silverbullet’s Vendor Identification number within the transparency and consent framework is ID 113.

 

As a result, Silverbullet 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.

 

6. International Data Transfers

We will ensure through contractual measures and our technical and organisational practices that your data is protected to the standard expected within your legal jurisdiction. In particular when transferring data to the USA we will ensure that the parties we share data with are participants in the EU-US Privacy Shield programme.

7. Security, Integrity and Retention

We take security very seriously at Silverbullet and have implemented industry standard security measures such as firewalls and encryption. However, no form of transmission of information over the internet or storage of information is 100% secure, and therefore we cannot guarantee absolute security.

 

Our policy is to retain personal information for only as long as is required to undertake the processing described in this privacy policy. This is 90 days after the advertiser relationship has ended.

 

8. Your Rights

You have the right to request from us, as the controller, access to and rectification or erasure of your personal data or to restrict processing concerning your data, to object to processing as well as the right to data portability. Please raise such requests to us by contacting us via our contact form. Users would have to share ADID/Cookie ID which is the only time the data becomes PII.

 

If you are not satisfied with our response, you furthermore have the right to raise a complaint to the UK data protection supervisory authority https://ico.org.uk/.

 

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SPECIFIC DATA COLLECTION + USAGE

Silverbullet Business Pillars

Silverbullet is split into three core pillars: Empower, Build and Activate. Within the “activation” arm of the businesses, data is collected, processed and shared. Please see our specific policies regarding the activities within this business pillar.

 

A) Data collection and processing

We collect personal data from you directly in two cases.

 

Firstly, when we service an advert to you, we collect personal data from you and are data controller for that data. In such cases, we collect a tracking identifier from your device which enables us to report our service performance to our customer. This processing is undertaken based on your consent for Silverbullet to provide reasonable metrics on service delivery for our customers. Our assessment is that this does not constitute a privacy risk to you.

 

Secondly, we may collect data from you when you visit our customer’s website and the customer chooses to share your data with us. Under this circumstance, we are acting solely on behalf of our customer and our customer remains the data controller.

 

Beyond the personal data we collect directly from you as described above, our partners and customers share your personal data with us, which we process as a data controller. Where such data is shared with us, we undertake to assure through contractual means that the data has been collected from you legally and transparently, and that our processing of personal data is compatible with the original purposes for which the data was collected. In doing so, we may rely upon appropriate measures such as pseudonymisation to process the data you have consented to for use of improved advertising performance for our customers, and improved relevance of adverts for you. We consider that tailoring digital adverts toward your preferences represents a minor privacy impact on you where the product or service advertised is not sensitive in nature. Considering this, we undertake that we will not consider your personal data when delivering digital advertising for sensitive products or services. You may nonetheless still receive such adverts from our platform based on alternative, non-personal criteria.

 

Considering the personal information described above, and other non-personal sources of data, the SBDS Group platforms are designed to make automated decisions about the relevance of digital advertising to you based on inferences we make about your interests. Given our policy relating to sensitive products or services, we do not believe that the result of this automated decision making produces any legal impact upon you.

 

We may receive and process your location data from our customers and partners. When such data is received in the context of an advertising opportunity, we may make a location-based decision on the most relevant advert, for example to promote a local restaurant or retail outlet. We do not use this data to profile you or your interests.

 

As a safeguard against processing data you are unhappy with, we are an approved member of the European Interactive Digital Advertising Alliance (EDAA). You are able to opt-out of all behavioural advertising on Beeswax, our advertising buying platform, using http://optout.aboutads.info/. Furthermore, you have the right to object as described in “Your Rights” above

 

B) Data Sharing

As part of our service, we provide statistical information to our customers to demonstrate the performance and behaviours of our digital advertising services. Some of this data may be derived from your personal data but is aggregated and fully anonymised prior to sharing.

As part of our service, we frequently share a pseudonymised personal identifier for you with our customer so that they may independently verify the performance of our digital advertising services. In such cases, our customer is the data controller for your personal data.

 

We share your personal data with our contracted partners and processors and ensure by contractual means that your personal data receives the required protection. Such partners include but are not limited to:

 

  • Providers of infrastructure and computing services.

  • Silverbullet website and business systems

 

Beyond the general data collection described above, Silverbullet only collects personally identifiable information with your consent, such as your name, address and contact details, if you have supplied this information to us directly via our website, email or other business system.  We may process this information for a variety of reasons, including for marketing, to send you updates on our services and to keep you informed of developments at Silverbullet. 

 

The data we collect from you using these systems may be shared with contracted data processors.

C) Content Capabilities

We have a native advertising platform that specialise in online advertising targeted at consumers who are interested in the products being advertised. We deliver native adverts to help you discover things that interest you—new websites, new products, new bargains. We use technology to choose the best ads to show, based on everything we know about the context: the ad itself, the page that needs an ad, the time of day and other external factors, and information from your device that we use to predict what advertising would be most relevant and interesting to you.

We adhere to applicable industry guideline and strive to best practices. We will continue to review and update our policy and procedures to ensure the safety and protection of personal information.

 

We use cookie based identifiers to obtain information about you from third parties, but only where we have checked that these third parties either have your consent or are otherwise legally permitted to disclose your personal data to us. We use this information to help us choose the most relevant adverts to show you. The categories of data we may link to the cookie identifier are:

 

  • Preference

  • Behavioral

  • Demographic

  • Computer Device

  • Location

  • Family

  • Public Life

  • Professional

  • Transactional

 

Third party data is provided by the following partners

  • A.C Nielsen

  • IPONWEB T/A BidSwitch

D) Opting-in and opting-out of marketing communications

By filling out any of our contact us forms you are consenting for us to store and use your personal data for the sole purpose of responding to your enquiry. You have the right to request this data is deleted at any point. When downloading resources from our website your personal data is collected and stored for the sole purpose of emailing you the resource you have requested. Your personal data will only be used for marketing purposes if you have selected the opt-in box on the download form. If you do not opted-in we will not use your data to contact you for marketing purposes.

​E) How long do we keep your personal data for?

Silverbullet minimises the personal data it collects about users and retains the data for only limited periods. Raw data that we collect about user online activities is kept for no longer than 90 after client/advertiser relationship ends.

 

F) Sharing information with third parties

We will not share your personal data except to the following categories of third parties:

  • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;

  • to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Privacy Notice;

  • to any other person with your consent to the disclosure.

 

 

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CONTACT + AMENDMENTS

 

Contact

For any queries or comments on this privacy policy, please contact us at data.protection.officer@wearesilverbullet.com or by mail at: 1 Alfred Place, London, W1CE 7EB

 

Changes to Our Privacy Policy

We may update or make changes to this privacy policy. If any changes are made we will post notice of these changes on our website. If there are any changes to the way we collect and use data, or any other significant changes to our policy governing the use of data, we will inform you prior to the changes.

Effective: September 2019.

PRIVACY POLICY