Unruly serves and distributes video and non-video content online; our clients are mostly advertisers that ask us to display their video content through advertising units on websites that participate in our network of publisher sites (the “Services“).
By using any Unruly Site, you acknowledge the transfer of your personal data to countries outside the EEA. This is explained in more detail below.
By using any Unruly Site, you are consenting to the placing of cookies and other technologies on your devices which allow Unruly to collect certain information. We provide more detail on this below.
If you have any queries about how we collect or use your personal data, please contact us at [email protected]
Technologies used by Unruly to collect information
Unruly reserves the right to use one or more varieties of technologies to collect information at Participant Sites and Unruly Sites. These are listed and described below.
Pixels. A tracking “pixel” is a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a web page and allows for the collection of information regarding the use of the web page that contains the tracking pixel. Unruly collects technical and usage information (see below) through the use of tracking pixels.
Clients. Some advertisers or other clients (and their third-party service or technology providers) may use pixels, cookies, flash cookies, web beacons and/or similar technologies which are activated when their Distributed Content is viewed by users across our network of Participant Sites or at Unruly Sites. We may request and receive aggregate, non-personal information from our clients from time to time but we do not actively seek from our clients (or their service providers) any information about any individual users.
Opt-Out. Unruly is a member of the Digital Advertising Alliance (DAA), a cooperative of companies committed to building responsible advertising policies across the Internet, and adheres to the DAA’s Self-Regulatory Principles for Online Behavioral Advertising. Our opt-out tool can be found here. To learn more about interest based or online behavioral advertising, and other advertising companies’ privacy practices and opt-out from each or any of them (including Unruly), you may also go directly to the DAA website at http://optout.aboutads.info/.
Information collection on Participant Sites
When you visit a participant site in our advertising network and view distributed content placed by us, we collect information about your activities as follows:
Technical Information. When we serve distributed content, we log and analyze technical information that is openly available to our servers such as information about the kind of browser being used (e.g., Safari, Internet Explorer), the type of operating system it’s running on (e.g., Windows, Mac OS, mobile OSes), the speed and type of Internet connection (e.g., narrowband, broadband, mobile), and other technical information. This information is anonymous and generally non-personally identifiable but does include “internet protocol addresses” or “IP addresses” which can be used to identify a user and may be considered to be “personally identifiable information” (see below). Unruly archives all technical information (including any such IP addresses) in raw log format.
IP Addresses: Unruly analyzes “internet protocol addresses” or “IP addresses” in order to determine an approximate geographic location so that we can serve a client’s Distributed Content that is more relevant to that location and/or perform other analyses based on information that may be collected about the history of interactions with our video player (see below) or clients’ Distributed Content that are common to any single or range of IP addresses. We may also collect or use IP address information for fraud detection or prevention. We archive IP address data as part of the raw log files of technical information maintained by our systems (see above). Unless you use a static IP address, an IP address typically relates to multiple businesses, households or larger communities. For example, if you use an Internet Service Provider (ISP) to access the Internet, your IP address may be assigned from a range of IP addresses. Unruly has no influence or control over how any IP address is assigned. An assigned IP address may also change from time to time within that range of IP addresses. While not impossible, especially if a user has been assigned an IP address permanently or for a period of time, it is difficult to identify an individual user based on an IP address and we do not actively associate IP addresses with any other information in order to identify any individual user on a personally identifiable basis.
Interaction with Video Player and Other Usage Information. Unruly uses a proprietary video player to serve our clients’ Distributed Content. This video player can be hosted on a web page, be featured as part of an application or widget, or be embedded within an advertising unit. Unruly collects data about a user’s interactions with the player, such as what Distributed Content has been featured, played or clicked, whether playback is paused or stopped, and information collected in relation to the serving and display of Distributed Content. Additionally, we may also collect information about the pages you visited at a Participant Site if our video player or Distributed Content are present on the pages, including what site or page you came from, how long you spent on the page, your click activity on the page. The usage and interaction data helps us understand and report to our clients about whether and how often an item of Distributed Content is watched, whether partially or fully, and in what context, by users across our network of Participant Sites. It may also be used to target or re-target relevant advertising or other content to you through involvement of contracted third parties and/or on other sites you visit. Unruly may also use this information to determine what Distributed Content to show in the video player by matching usage with historical data that Unruly may have collected and stored using cookie or other technology. (See above section entitled “Third party suppliers or services”).
Our legal bases for using personal information
All organisations need a legal reason to use your personal information. There are a number of legal grounds that enable data processing. Below are the most relevant grounds you should be aware of.
With your consent
There are some activities where we process personal information with your consent. For example, where we want to send you marketing messages by email, we would ask your permission first and you could opt out at any time.
For a legitimate interest
We may use your information where there is a legitimate interest to do so. For example, we may use your information where it would help achieve our business objectives or to facilitate a benefit to you or someone else.
We only rely on legitimate interests if the reason for using your information is fair and lawful. Where we want to rely on legitimate interests as a legal basis, we will carry out a balancing test between our legitimate interests and your privacy rights.
Our legitimate interests in processing personal data include:
- to develop, deliver and maintain relevant and engaging products, services and advertising;
- understanding when audiences engage with our clients’ ads;
- to build a clearer understanding of who our clients’ audiences are in order to better serve more relevant advertising to those audiences, for the benefit of both individuals and our clients;
- to maximise advertising revenues for publishers and therefore help to maintain a diverse ecosystem of online independent publishers of content for users to enjoy and educate themselves;
- to support individual and societal rights to receive information;
- to improve user website experience by delivering brand safe, high quality advertising to all of the publishers of online content with which we work;
- to carry on the business of a commercial organisation;
- to demonstrate that we provide services and products to agreed industry standards;
- sharing information with Tremor International group companies for analysis, audience insights, business efficiencies, content personalisation and to deliver relevant advertising.
To comply with legal obligations
There may be situations where we need to use your information to comply with legal and regulatory obligations or defend claims.
How Unruly uses your information
The information may also be used to improve the relevance of the Distributed Content served to you and other users visiting a Participant Site. We also use and share aggregated technical and usage data with our publishers and advertisers in order to provide measurement and analytics on the effectiveness of their ad campaigns and content distribution programs, and to conduct research and analysis, including to test different ways, to improve the experience of users who encounter our clients’ Distributed Content on our network of Participant Sites. We may use the information collected from a particular browser or device, or transfer such information to a third party, for the purposes of cross-device mapping or matching. Cross-device mapping or matching means the practice of linking two or more devices or browsers used or likely used (based on analysis) by the same user for online behavioural advertising purposes.
Unruly is part of the Tremor International (“Tremor”) group of companies, and as such, we may rely on our legitimate interests as an organisation that facilitates more relevant advertising for the benefit of our advertiser clients and publisher partners, to share your information with Tremor and its affiliates to:
- perform analytics and analysis of how you interact with the Tremor group’s products and services, to facilitate business efficiencies and develop products and services that would be relevant to you; and
- deliver more relevant advertising from across our Tremor network.
If you would like to opt out of this sharing or exercise your data protection rights, you can email [email protected] but please bear in mind that opting out will relate to any future sharing and not to information already shared. For more information about how to exercise your rights, please see the section on Access and control of your personal information. Opting out may also mean you do not receive the best experience across Tremor products, services and websites.
Where your information is used for advertising purposes, you will be provided with information about how it is used and be able to control what information is used and how, as well as with which affiliates it is shared.
These affiliates may be located inside or outside of the EEA, including the United States of America. We have appropriate agreements in place to ensure they protect your information in accordance with our legal obligations.
Unruly may disclose one or more clients’ and/or individual users’ information if required to do so by law (or in a good faith belief that such action is necessary or advisable in order to comply with any laws of any country or region which may assert jurisdiction) or in order to respond to a judicial or other governmental action, order, subpoena, request, demand or warrant. We may make such disclosures without providing notice to you.
Unruly also reserves the right to disclose one or more clients’ and/or individual users’ information if it is appropriate or necessary in Unruly’s discretion in order to: take precautions against liability; protect against fraudulent, abusive, or unlawful uses; investigate or defend against any third-party actions or allegations (including assisting a client or third party to do so); assist government enforcement agencies; or protect the security, integrity, rights, property, or personal safety of Unruly, its systems and services, as well as its employees, clients or others.
Unruly may in the future, and shall have the right to implement technology to, collect or share any information, including any client’s or individual user’s information, that we determine to be necessary or advisable in order to comply with a judicial order or to cooperate with government and law enforcement officials.
Personal data collection on Unruly Sites
Personal data is collected on the Unruly Sites in various instances including, without limitation:
Registration and Use of Unruly’s Services. If you register to participate in the Unruly network as a publisher or an advertiser, we will require you to provide, and we will store, information that identifies you personally such as your name, contact information, and payment method. We use this information for business purposes such as account maintenance, billing, and to operate and provide the Unruly services.
Requested information. If you submit an inquiry to or respond to a request by Unruly through any “Contact Us form” or similar function on an Unruly Site, any information you provide, including any contact name, address, email address, telephone number, financial information, etc., will be used by Unruly in order to respond to such inquiry or request.
Subscriptions. You may provide an email address or other contact information or otherwise interact with our Unruly Sites in order to commence receiving a subscription-based function or service, such as a newsletter or mailing.
Access to web-based client interface or console. A current client in good standing may be required to provide his or her username and password, which may include or feature personally-identifiable information, in order to access the UnrulyX console, account areas and/or other areas that are accessible only by clients. We use user IDs and passwords, in part, to protect your privacy and security. You are responsible for maintaining the secrecy of your unique password and account information at all times.
You may, of course, decline to share any or certain items of personally-identifiable information with Unruly, in which case we may be unable to provide you with the services or pay you any monies that might otherwise be payable to you. Unruly archives any and all information, including personally identifiable information, that may be input in any registration process even if the user refuses or is declined or fails to use or abandons the services provided by Unruly.
Note about Children’s Privacy: Unruly is very sensitive to the issue of children’s privacy. Our websites, products, and services are neither developed for, nor directed at, children, and we do not knowingly collect personal information about children under 13. If you believe your child has provided Unruly with personally identifiable data by registering or using any offerings at any of our Unruly Sites (i.e., sites owned and operated by Unruly, as opposed to a Participant Site over which we have no control), and you would like to have us look into removing the data from our servers, please contact us at [email protected].com
Where Unruly stores Personal Data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfillment of your order or the provision of support services. However, we only transfer your information where there are appropriate measures and controls in place and all information you provide to us is stored on secure servers.
Use of information that clients provide
Unruly uses the personal data you provide to respond to your enquiries and requests, and to keep accurate records concerning the services you are requesting through any Unruly Site. We generally use non-personally identifiable information in aggregated form to help measure the performance and effectiveness of our Unruly Sites, and to improve their usefulness. Additionally, you should be aware of the following:
- Unruly does not share personally identifiable information of any clients with other organizations for their marketing or promotional uses without your express consent.
- To provide web site hosting, maintenance and security, fulfill orders, offer certain functionality, improve our site, and create new site features, we may disclose one or more clients’ information to affiliated companies or other businesses or persons, such as, for example, credit card service providers or cloud or data storage providers.
- Any personally identifiable information a client provides may be associated with technical and usage information that may be collected at Unruly Sites in same manner as we may collect such information at Participant Sites (see above).
- We may also combine it with information collected from other sources, particularly in cases where we and our third party partners or contractors may be vetting or investigating a new, existing or prospective client for potential of fraud or other undesirable activities.
Access and control of your information
Where we rely on your consent to process personal information, you have the right to withdraw that consent at any time. Please contact us at [email protected] with details of your request. In some instances we may still have an alternative legal basis to continue to process that personal information and we will inform you of that. If you do withdraw consent we may not be able to provide the product or service you have requested.
If you have a comment, concern or suggestion, please contact us at [email protected] If you have a complaint and we cannot resolve the matter, you have the right to comply to the Information Commissioner’s Office or the data protection regulator responsible for your country or region.
Retention of personal data
Changes to this Policy
In addition to any general data protection enquiries you may have, you can use the below details to contact our Group Data Protection Officer:
By email: [email protected]
By mail: Unruly Group Limited, The White Chapel Building, 15 Whitechapel High Street, London, E1 8QS
California Privacy Rights
Categories of Personal Information Collected
- Identifiers (such as your contact information (name, email address)) or unique personal identifiers (device ID, cookies, IP address) (“Identifiers”);
- Internet or other network or device activity (such as browsing history, browser type and language, operating system or app usage) (“Internet Data”);
- Geo-location information (such as IP address) (“Geo-location Data”);
- Profile data about you and any inferences drawn from the profile data (such as characteristics, behaviours, attitudes) (“Profile data”);
- Information that identifies or can be reasonably associated with you (“Associated Data”).
Business or Commercial Purposes for which We Collected or Disclosed Personal Information
- performing the Services, including operating and improving the functionality, presentation, distribution and appeal of the Distributed Content we place for our clients on Unruly’s network of Participant Sites, improving the relevance of the Distributed Content served to you and other users visiting a Participant Site, measurement and analytics on the effectiveness of ad campaigns, cross-device mapping or matching, or providing similar services (“Performing Services”);
- auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance (“Auditing”);
- short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction (“Short-term Use”);
- detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity (“Data Security & Fraud Prevention”);
- debugging to identify and repair errors that impair existing intended functionality (“Repairs”);
- undertaking internal research for technological development and demonstration (“Research and Development”);
- undertaking activities to verify or maintain the quality of the Services controlled by us, and to improve, upgrade, or enhance the Services controlled by us (“Quality and Safety”); and
- to advance the commercial or economic interests of Unruly (“Commercial Interests”).
Categories of Sources from which We Collected Personal Information
- Directly from you (“You”);
- From other sources (such as Company affiliates and/or business partners who provide us with hosting, serving, general campaign or site analytics, ad serving data, or demographic and other audience data about the use and viewership of our clients’ Distributed Content, the Participant Sites we work with or our Unruly Sites) (“Affiliates and Partners”);
- Through your use of the Services (“Services Use”).
How we share and disclose your information
We will share the personal information collected from and about you over the past twelve (12) months as discussed above for various business purposes. The chart below explains the categories of information that we may share with third parties and the categories of those parties.
|Third Parties with which we share information and why||Categories of information shared|
|Third Parties for Legal Requirements and Proceedings. We may disclose information to law enforcement authorities or other government officials if we are required to do so to comply with subpoenas, court orders, legal process or other law enforcement or government measures, and to comply with other legal obligations. We may disclose information if we believe disclosure is necessary or appropriate in connection with an investigation of suspected or actual fraudulent or illegal activity.||· Any or all categories of information may be shared with third parties for legal requirements and proceedings, depending on the specific legal requirements|
|Third Parties for the Protection of our Services and Users. We may disclose information to protect and defend the rights, interests, and safety of the Services, our subsidiaries and affiliates, and their employees, contractors and agents; to protect the security and safety of our users of the Services, including when we believe disclosure is necessary to prevent physical harm or financial loss.||· All categories of information we collect may be shared for the protection of our Services and users|
|Third Parties in Business Transfers. We may disclose information in connection with a proposed or completed corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets.||· Any or all categories of information may be shared with third parties in a business transaction, depending on the specific transaction|
· Geolocation Data
|Data Analytics Providers. We may share information with companies that provide data analytics services in order to operate, evaluate and improve our business.||· All categories of information we collect may be shared with data analytics providers|
California Consumer Privacy Rights and Choices
California Consumers may have certain rights in connection with the personal information we collect about you, many of which are subject to exceptions under applicable law.
The right to access and disclosure. You may have the right to request, twice during a twelve-month period, the following information about the personal information we have collected about you during the past 12 months:
- the categories and specific pieces of personal information we have collected about you;
- the categories of sources from which we collected the personal information;
- the business or commercial purpose for which we collected or sold the personal information;
- the categories of third parties with whom we shared the personal information; and
- the categories of personal information that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.
The right to deletion. You may have the right to request that we delete the personal information we have collected from you.
Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.
How to exercise your access and deletion rights
For security purposes, we will verify your identity – in part by requesting certain information from you — when you request to exercise your California privacy rights. For instance, you may need to provide your name and email address. To request that we provide you with the specific pieces of personal information we have from you or to delete personal information we have collected from you, we may also need to ask you for additional information to verify your identity.
Once we have verified your identity (and your agent, as applicable), we will respond to your request as appropriate:
- Where you have requested the categories of personal information that we have collected about you, we will provide the information you have requested, except where not permitted under applicable law or otherwise exempted by the CCPA.
- Where you have requested specific pieces of personal information, we will provide the information you have requested, except where not permitted under applicable law or otherwise exempted by the CCPA.
- Where you have requested that we delete personal information that we have collected from you, we will delete any information about you that is not necessary for the purposes indicated above. Certain information may be exempt from such requests under applicable law.
If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request.
The right to nondiscrimination. We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.
The right to opt-out of the sale of your personal information. You have the right to opt out of the sale of your personal information. California law broadly defines sale such that it may include, for example, allowing third parties to receive certain information, such as cookies IP address and/or browsing behaviour, to deliver targeted advertising.
If you would like to opt out, you may do so as outlined on the following page: https://optout.privacyrights.info/?c=1
You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.
How to contact us
If you are a California Consumer, to submit a request, please contact us by submitting your request to https://unruly.co/legal/do-not-sell-my-info/ or, by sending an email to [email protected]. To protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.
Last updated: February 2020