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.
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; and
- to demonstrate that we provide services and products to agreed industry standards.
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
Unruly uses the information it collects to operate and improve the functionality, presentation, distribution and appeal of the Distributed Content we place for our clients on Unruly’s network of Participant Sites. On occasion, this involves sharing raw logs with a client if we ascertain that the information being shared is the same information that such advertising or publisher client was in a position to have collected themselves.
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.
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]
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
Last updated: May 2018