Arty Labs ABN 78 937 244 172 (“Arty Labs”) is firmly committed to protecting user privacy and fostering user confidence in the Internet and digital advertising. We continually evaluate innovative ways to protect user privacy while also seeking to deliver relevant advertising and custom online experiences on behalf of our clients.
What is in this Privacy Notice?
This Privacy Notice describes the information Arty Labs collects from web sites, applications, and other digital properties (we refer to all of these as “Sites”), and on the Arty Labs corporate website, Artylabs.com.au (“Arty Labs Web Site”). We explain how we use this information to provide “Services” to our clients. We also explain how you can manage your privacy choices and exercise your rights in relation to certain data about you that is collected and used by Arty Labs.
Who are we?
Arty Labs is a business which operates primarily in Australia. Except as expressly stated otherwise, the use of information by our non-Arty Labs affiliates, our clients, our service providers, and other third parties is not covered by this Privacy Notice.
If you have any questions, please contact us via firstname.lastname@example.org
SECTION 1: ARTY LABS SERVICES
Arty Labs does not provide its advertising-related services (“Services”) directly to consumers. Instead, our clients are corporate businesses and government departments, including advertisers and agencies. Our clients may include other companies which in turn perform advertising-related services for their own clients.
Our clients use our Services, on their own behalf and/or on behalf of their own clients, to help them understand the advertising they deliver online (e.g. what sites it was delivered on, who saw it and whether or not anyone interacted with it) and to improve the effectiveness of that advertising. We also help them to try to deliver advertising to consumers who are more likely to be interested in their products and services.
When we help clients to select audiences to deliver their advertising to, we may use certain demographic information (such as age, gender, education, income and household status (e.g., number of children)), geography (but not precise location), interests, activities, and similar information (“User Information”). We explain below where this information comes from. We call this type of advertising “Interest-Based Advertising”.
Types of Information We Collect and Use through Provision of Our Services
When you view and interact with Sites and with advertisements where our Services are utilised, we do not collect data that reveals your real-world identity, such as your name, address, phone number or other non-publicly available government-issued identifiers.
Rather, our Services are designed to collect and/or use information about the type of web pages that you visit and about interactions you have with Sites and with our clients’ advertisements. We also collect information that identifies the browsers and devices of users who have viewed our clients’ advertising. This information includes the following categories of data:
These can be used to identify a user’s browser, mobile advertising environment, and/or device (i.e. the device that a user is using to connect to the internet which is usually a mobile handset, tablet or PC but may also be a connected television and/or over-the-top television device (“OTT TV Device”). Technical Identifiers include:
- Mobile advertising IDs (e.g., IDFAs and Google Advertising IDs)
- OTT TV Device Identifiers for Advertising (a unique ID assigned by an OTT TV provider, e.g., Roku ID for Advertising)
Additional Technical Information
- Internet protocol address (“IP address”) and data derived from an IP address, such as non-precise geolocation data that indicates the country, region, city, and/or postal code of a device
- Type of Internet browser, browser language, and operating system
- Connection type (wired or Wi-Fi), network to which the device is connected, and mobile carrier (if available)
- Longitude/latitude of a (mobile) device.
For purposes of this Privacy Notice, “device” includes computers, smartphones, tablet computers, e-readers, and other digital devices capable of maintaining an Internet connection, including OTT TV Devices, and “mobile device” includes smartphones and tablet computers.
Online Activity Information
Arty Labs collects the information explained below about your online browsing activity to determine what types of activities, services and products you and other users may be interested in and how you and other users interact with certain advertisements. This information includes:
- Domain level information and/or content topics about the Sites and pages viewed (i.e., in order to ascertain interests)
- Site/page you came from before, and visited after, viewing an advertisement
- Date and time of online activity
- Frequency of visits to a Site
- Search terms used on a Site
- Interaction with an advertisement (e.g., whether you click on an advertisement)
User Information received from Third Parties
We also receive both online and offline User Information collected by third parties, including demographic and interest information for use in our Services. The third parties include our clients and carefully selected service providers. When we receive offline User Information, this information is provided to us via a service provider in conjunction with a cookie ID, advertising ID, or similar user ID that identifies a user to us, the client or service provider (through a process called “cookie syncing”), but we do not receive users’ names, mailing addresses, phone numbers, email addresses or similar data that would enable identification of a particular individual connected with these IDs.
How We Collect Information through Our Services
- Cookie is a small alphanumeric text file that is stored in a browser by a web site or by a third-party ad server or other third party which allows that web site or third party to recognise that browser and remember User Information and other information.
- Advertising ID is an alphanumeric identifier made available by a platform or operating system (such as Apple iOS or Google Android) that allows application developers and third parties to recognise a particular device in an application environment. It is associated with User Information and other information and, together with this associated information, is used in the performance of our Services, and in particular Interest-Based Advertising activities.
- Pixel is a line of code that is used by a Site or third party to assign online activities to a device or browser, or more specifically to the applicable cookie or advertising ID. The use of a pixel allows us to record, for example, that a device or browser has visited a particular Site or page.
How We Use This Information
Arty Labs processes the information it collects and receives for the purposes of providing the Services to clients as explained above, as well as for administrative, security and compliance purposes. Specifically, we carry out the following activities:
Ad Selection, Delivery, Reporting
We analyse the information collected when client advertising is delivered using our Services and information received from our partners. We organise this information into collections of IDs (which we call segments), based on various components of the User Information we explained above. For example, we may have segments of IDs that visit car Sites. Our clients can then use our Services to use these segments to deliver Interest-Based Advertising on their own behalf or on behalf of their clients, using our partners and service providers. This advertising may be delivered across computers, smartphones, and other devices.
We may also integrate (and use for the same purposes) User Information obtained from other carefully selected companies (including Site owners, data providers and data aggregators).
While Arty Labs does not knowingly create segments that are based upon what we consider to be sensitive information (e.g. we do not create segments based on sensitive health categories or segments of EEA users based on personal data considered to be sensitive in the EEA, such as personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, personal data concerning your health, sex life or sexual orientation, or genetic or biometric data), our clients may use our Services to process some sensitive data, which may come from our clients’ Sites or our partners. We take steps designed to ensure that this is done in compliance with applicable laws and self-regulatory guidelines, including through our contracts and policies with our clients and partners.
In order to provide our client-specific personalisation Services, we:
- collect information on each client’s Sites (this includes websites, apps, and other digital properties) – as described above in “How We Collect Information through Our Services”;
- access or store this information on devices (via cookie IDs and advertising IDs, as applicable); and
- analyse the information collected, sometimes with other information received from the client and organise it into segments of IDs, based on the various User Information.
Our clients can then use these segments to deliver, on their own behalf or on behalf of their clients, Interest-Based Advertising to users on their computers, phones, and other mobile devices (this is through a variety of means).
Where we are providing this client-specific personalisation, the segments that we build for one client are logically segregated from the segments and data of other clients. Data collected in this way, and the segments produced, can only be used on behalf of that specific client.
We process User Information to deliver advertisements and measure the delivery of these advertisements, to learn about what factors make advertising successful or unsuccessful for advertisers and to generate reports to understand and improve Service usage and advertising effectiveness.
Storage and Access of Information
In order to provide our Services, we store cookies on the browser(s) of individuals to whom we have delivered advertising and then recognise the cookies when that browser(s) is used to access websites of our clients and publishers we work with. Sites on which we are dropping and/or reading, or seek to drop and/or read, cookies should tell you about the use of third-party cookies where required by law, on those Sites. In the data feeds we receive from our partners in connection with the delivery of digital advertising in mobile application environments we also receive advertising IDs associated with users’ mobile device platforms/operating systems and recognise these advertising IDs.
We use the information collected and received for Interest-Based Advertising, such as:
- Matching Data to Offline Sources – as indicated above under “User Information received from third parties”:
- We receive offline User Information, including demographic and interest information, from other companies, including our clients, partners and service providers, that is collected outside the Services and is provided to us for use in our Services. It is the responsibility of those companies collecting that data to do so in an appropriate and legal way, and to permit sharing that information with us for our purposes.
- When we receive offline User Information, this information is provided to us via a service provider in conjunction with a cookie ID, advertising ID, or similar user ID that identifies a customer or consumer to the client or service provider.
- We do not receive any names, mailing addresses, phone numbers, email addresses or similar data that would enable identification of a particular individual connected with the IDs we receive.
- Linking Devices – we make use of a number of 3rd party platforms to associate information relating to browsers, environments, and/or devices that we reasonably believe belong to the same user, in order to help provide more useful and relevant advertising regardless of browser, environment, or device.
- Precise Geographic Location Data – when we have the necessary rights to do so, we may receive and/or use a user’s precise geographic location data for the purpose of delivering “moment in time” advertising. Arty Labs does not store or otherwise save the precise geographic location data after serving or delivering an advertisement in real-time.
Disclosure of Information to Third Parties
If we reasonably believe we are obliged by law or legal process to disclose information to a third party (including law enforcement), then we will do so. In addition, we may disclose information to a third party (including an auditor or other service provider).
Opt-Out/Right to Withdraw Consent
You may opt out of Arty Labs Interest-Based Advertising through several mechanisms.
In browser environments, you may refuse or remove cookies from both Arty Labs and other service providers via the following methods:
- Adjusting your browser settings to refuse or remove cookies, which would result in the elimination of Interest-Based Advertising via cookies from Arty Labs and from other providers. However, by doing so, you may not be able to use certain features on certain web sites you visit or take full advantage of all web site offerings and Interest-Based Advertising. You may refuse or remove cookies by following the directions provided in your browser settings. Further information about cookies is available ataboutcookies.org, www.youronlinechoices.com and http://www.aboutads.info/consumers#cookies.
- Adjusting the cookie settings at the level of the web site owner where you granted us your consent to our cookie usage; cookie settings options may vary by web site owner. Opting out of Interest-Based Advertising as well as the targeting cookies of other service providers, at the following Sites:
- http://youronlinechoices.com (by clicking the “Your ad choices” link after selecting the appropriate country)
You may also limit ad tracking in mobile and OTT TV Device app environments. For the most effective and up-to-date methods for doing so, you should consult instructions provided by those device manufacturers. The following information is solely for informational purposes, and we cannot guarantee that the methods below are the most current:
- Going to the privacy setting on your mobile device as well as on your OTT TV Device and selecting “Limit Ad Tracking” via your device settings, which will result in the elimination of Interest-Based Advertising via the applicable advertising ID from Arty Labs and from other providers in addition to Arty Labs:
- Apple instructions for how to Limit Ad Tracking on devices such as iPhones, iPads and Apple TV: https://support.apple.com/en-us/HT202074
- Google instructions for how to express choice on Android devices https://support.google.com/ads/answer/2662922?hl=en
- Opting out of Interest-Based Advertising via the applicable advertising ID from Arty Labs and/or other providers via the AppChoices app. Please note that, in order for the AppChoices app to function properly, your “Limit Ad Tracking” device setting must not be selected. Interest-Based Advertising data previously collected or received in association with the replaced advertising ID will not be used via Arty Labs for Interest-Based Advertising on any other device or browser that we have reasonably linked to the mobile app environment where the information was collected. In addition, if we have actual knowledge that another device or browser is linked to the opted-out mobile app environment, that other device or browser will also be opted out from receiving Interest-Based Advertising via Arty Labs. Additional information regarding the AppChoices app is available at http://youradchoices.com/appchoices.
Additional information regarding user choice in application environments is available at https://www.networkadvertising.org/mobile-choices.
Arty Labs supports deployment of the Advertising Option icons (AdChoices and, where available, AppChoices). Advertisements that are provided by organisations that participate in these frameworks will display the AdChoices icon when technologically feasible. Clicking on the icon provides you with information about Interest-Based Advertising.
You can view the DAA site http://optout.aboutads.info/?c=2&lang=EN which has additional information about Interest-Based Advertising and the DAA’s self-regulatory framework, as well as a mechanism to opt out of receiving third-party Interest-Based Advertising via cookies from us and other DAA member companies.
Neither the Services nor the Arty Labs Web Site is developed for, or directed at, children (as defined by applicable law) or at Sites primarily directed to children. We do not knowingly collect information from children (determined in accordance with the age requirements for the applicable country). If you believe a child has provided us with personal data and you would like to have the information removed, please contact us via email@example.com
Transfer of Data in the Event of Acquisition
In the event that another company acquires all or substantially all of the assets of our business through a consolidation, merger, asset purchase, corporate reorganisation, or other transaction, we reserve the right to transfer all information (including any information a user may have provided through our “Contact”/“Contact Us” page on the Arty Labs Web Site) that is in our possession or under our control to the acquiring party.
Information Security and Global Data Transfers
We follow generally accepted online advertising industry standards to protect against unauthorised access to, unlawful processing of, unauthorised retention of, and unauthorised disclosure of data. These standards include undertaking necessary physical, electronic, and management activities required to protect data integrity, access, and use. Please keep in mind, however, that despite these efforts to protect data on our servers, no method of transmission over the Internet is guaranteed to be secure.
Arty Labs Services may be used globally, and therefore we may transfer data to countries around the world, including countries outside of your country. We will, where necessary, put in place appropriate safeguards to ensure this data is protected. When we transfer personal data from the EEA or Switzerland to an affiliate outside the EEA or Switzerland, we enter into standard (“model”) contractual clauses, with the recipient in order to ensure an appropriate level of data protection. When we transfer personal data from the EEA or Switzerland to an unaffiliated entity (such as a service provider performing services on our behalf) outside the EEA or Switzerland, we either enter into standard (“model”) contractual clauses, or ensure that the transfer is pursuant to another valid mechanism, such as the service provider being certified under the EU-U.S. Privacy Shield Framework.
We maintain the information we collect through our Services in aggregated and non-aggregated form for a period of not more than 25 months, and we retain much of this data for shorter periods of time. This data includes domain level information, content topics, ad interactions, IP addresses, browser type and language settings. We maintain this information for the 25-month period to enable our clients to perform year-over-year analyses. For example, a retailer may wish to compare the effectiveness of its online advertising activities at Christmas for the current year vs. the effectiveness in the prior two years. A 25-month retention period enables that client to perform such comparison.
SECTION 2: ARTY LABS WEBSITE
We respect your privacy
Arty Labs ABN 78 937 244 172 (“Arty Labs”) respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors. We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth). This policy sets out how we collect and treat your personal information.
“Personal information” is information we hold which is identifiable as being about you.
Collection of personal information
Arty Labs will, from time to time, receive and store personal information you enter onto our website, provided to us directly or given to us in other forms. You may provide basic information such as your name, phone number, address and email address to enable us to send information, provide updates and process your product or service order. We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.
Additionally, we may also collect any other information you provide while interacting with us.
How we collect your personal information
Use of your personal information
Arty Labs may use personal information collected from you to provide you with information, updates and our services. We may also make you aware of new and additional products, services and opportunities available to you. We may use your personal information to improve our products and services and better understand your needs.
Arty Labs Australia may contact you by a variety of measures including, but not limited to telephone, email, SMS or mail.
Disclosure of your personal information
We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Policy. Personal information is only supplied to a third party when it is required for the delivery of our services.
We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.
We may also use your personal information to protect the copyright, trademarks, legal rights, property or safety of Arty Labs, www.Artylabs.com.au, its customers or third parties.
We may transfer your information (including your personal data) to countries around the world, including countries outside of Australia. We will, where necessary, put in place appropriate safeguards to ensure your information is protected. When we transfer personal data from the EEA or Switzerland to an affiliate outside the EEA or Switzerland, we enter into standard (“model”) contractual clauses with the recipient in order to ensure an appropriate level of data protection. When we transfer personal data from the EEA or Switzerland to an unaffiliated entity (such as a service provider performing services on our behalf) outside the EEA or Switzerland, we either enter into standard (“model”) contractual clauses, or ensure that the transfer is pursuant to another valid mechanism, such as the service provider being certified under the EU-U.S. Privacy Shield Framework.
If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.
Security of your personal information
Arty Labs Australia is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
Access to your personal information
You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth). A small administrative fee may be payable for the provision of information. If you would like a copy of the information, which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at firstname.lastname@example.org
We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act.
Complaints about privacy
If you have any complaints about our privacy practices, please feel free to send in details of your complaints to 135 Main ROad Hepburn Victoria 3461Australia. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.
When you visit our website
When you come to our website (artylabs.com.au) we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
Third party sites
Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Arty Labs is not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.
The Arty Labs Web Site is not intended or designed to attract children (as defined by applicable law). We do not knowingly collect personal data from children (determined in accordance with the age requirement for the applicable country). If you are a child and wish to ask a question or use this site in any way which requires you to submit your personal data, please get your parent or guardian to do so on your behalf.
SECTION 3: STATE AND COUNTRY-SPECIFIC INFORMATION; CONTACTING US
EEA and Switzerland
Legal Bases for Processing Information
We collect, use, share, and/or transfer personal data of individuals in the EEA and Switzerland only when we have a lawful basis for doing so, which typically entails user consent or our legitimate interests.
Where required by applicable law we only deliver Interest-Based Advertising to individuals who have provided consent for that activity.
To the extent we rely on your consent, which may be provided either directly to us or via a third party, to use your information in certain ways, we will process your personal data within the scope of that consent.
In our capacity as a data controller we intend to rely on consent as a lawful basis for all “Purposes” under the IAB Europe’s Transparency & Consent Framework other than “Measurement” (which Purpose includes measurement, analysis, and reporting with respect to the applicable personal data). In connection with such Purpose, when we process data for measuring the delivery of advertising or analysing its effectiveness, we have a legitimate interest in understanding that our suppliers have delivered the advertising that they have contracted to deliver. In addition, we believe that advertising clients have a legitimate interest in understanding whether or not their advertising is delivered and whether it is effective. We believe these activities are fundamental to online advertising but do not result in any decisions which affect individuals.
If you are in the European Union, you have the right to object to any of this processing. If you want to object, please contact us via email@example.com
Rights of Individuals in the EEA and Switzerland
Individuals in the EEA and Switzerland have a number of rights with regard to their personal data, including the right to access their information. For these users, in many cases where we process your personal data, you may also have a right to restrict or limit the ways in which we use that personal data.
In certain circumstances – for example, where we process your personal data for directing marketing purposes or pursuant to our legitimate interests – you also have the right to object to the processing of your personal data by us, and you can also request that we delete your personal data. You also have a right to obtain a copy of your personal data in an easily accessible format, and in certain circumstances, you may also request to transfer personal data about you to third parties. We don’t retain and store your actual browsing activity history in association with a cookie ID or a mobile advertising ID. As a consequence, we are unable technically to offer the ability for you to change individual elements of data that lead to the segment allocation simply because we do not retain them. If you believe that we hold or have used inaccurate personal data elements about you, please note that you have the right to withdraw your consent to our processing of your personal data at any time.
If you have questions about any of these rights, please contact us. You should also contact us if your personal data or preferences change, if you don’t want us to send you the information you previously requested, or if you have any queries about how we use your personal data.
Without limiting any other rights you may have, you also have the right to lodge a complaint against us with a supervisory authority in the EU Member State where you are based or in which we are based. Visit http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080 to find your local supervisory authority.
Information Received from Market Research Companies in the Netherlands
If you have provided consent to market research companies in the Netherlands to disclose your panel data to Arty Labs, then, based on the scope of such consent: we may receive User Information and other information, including panel IDs, from such companies; and we may use this information only for purposes of research and analysis, campaign optimisation, advertising customisation, and reporting on the effectiveness of online advertising campaigns.
Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of “personal information” that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. To request a list of companies, if any, to which Arty Labs has provided personal information for its own marketing purposes, please contact us through email at email@Arty Labs.com or by mail at Arty Labs, Level 2, 165 Fitzroy Street, St. Kilda, Victoria 3182 Australia Attn: Legal Department. Please allow 30 days for a response.
California law requires us to disclose how we respond to browser “Do Not Track” signals or other choice mechanisms relating to Interest-Based Advertising. We have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
We are committed to honouring your privacy choices. For more information on opting-out of Interest-Based Advertising, please see the “Opt-Out/Right to Withdraw Consent” subsection of Section 1 above.
Changes to this Privacy Notice
Please note that because of the changing nature of privacy laws and regulations, digital technologies, and our business, we may modify this Privacy Notice from time to time. Please review this Privacy Notice periodically to become aware of any changes that may have occurred (we will update the effective date at the top of the page to help you know when changes have been made).
Other than when acting at the direction of a client or other third party, Arty Labs is a data controller responsible for your personal data (as this term or similar term is defined by applicable law) when you interact with our Services.