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    Qt Digital Advertising Privacy Policy

    The Qt Company Oy (“The Qt Company” – “we”, “us”, or “our”), in addition to other products and services, provides digital advertising services to its customers, which facilitate such customer's monetization of their digital properties ("Digital Advertising Services"). 

    In this privacy policy, we use the following terms: 

    • Demand Partners: means advertisers, ad agencies, ad networks, exchanges and demand-side advertising platform
    • Digital Properties: means websites, connected televisions or other over-the-top television devices (essentially streaming devices), or mobile applications which can be monetized through the display of third party advertising content.
    • Personal data: means any data that identifies or is capable of identifying a particular unique user or device.
    • Publisher Customers: means customers of The Qt Company who use our services to monetize their Digital Properties, through the display of third party advertising content.
    • End Users (or "you" "your"): means the individuals that access or otherwise interact with the Digital Properties of The Qt Company's Publisher Customers.  

    1. Scope of this privacy policy 

    This privacy policy applies to The Qt Company's Digital Advertising Services and the collection and processing of End User personal data as part of providing Digital Advertising Services to its Publisher Customers. 

    Information about The QT Company's privacy practices in relation to its website and other services can be found here.  

     

    2. What Personal Data do we process? 

    When you interact with our Publisher Customer's Digital Properties, we may receive Personal Data related to you or your device from our Publisher Customers. The Personal Data we may receive includes: 

    • Identifiers (alphanumeric or numeric strings that are unique to you, your device or your internet connection), including:
      • Cookie IDs
      • IP address
      • Advertising IDs
    • General geo-location data:
      • Geo-location approximated based on your IP address, including country or region, if you have given the Digital Property permission to collect your location information.
    • Internet or other electronic network activity information, including:
      • Network information: Mobile carrier, Network provider or ISP, Network type (e.g., WiFi or cellular)
      • IP address
      • Date and time of connection
      • Information on our Publisher Customers’ Digital Properties: e.g., information about the activities or actions on those Digital Properties, information about ads served, viewed or clicked on.
    • Demographic information and characteristics:
      • High-level demographic groupings, such as age group, or gender.
    • Other device information:
      • Device type (e.g., make and model), Operating system and version (e.g., iOS, Android, Windows), Mobile browser used (e.g., Chrome, Safari, Firefox), Language settings (including country code).

    Our Publisher Customers may also disclose to us certain Personal Data or non-Personal Data they have separately collected about you during your interaction with their apps, sites, services or Digital Property so that we can effectively provide our Digital Advertising Services. This may include information captured via cookies, other technologies, or other aggregated characteristics or other identifiers related to your device to understand your interaction with such site and to serve certain types of advertisements relevant to your interests. 

    These parties serve you cookies in accordance with their own specific privacy/cookie policies and subject to their own applicable legal requirements. We do not use Personal Data they provide to us for any purpose other than as permitted by such third parties or for providing or improving our Digital Advertising Services. 

    Please see the below section 3 for more information about how we use this Personal Data. 

    Please note that, as part of our Digital Advertising Services, we do not collect any Personal Data that could directly identify you. This means we do not know who you are. We do not know your name, your address, your place of work, your date of birth, your email address, or your phone number. We do not collect sensitive information (such as your religious affiliation, political opinions or health details). We do not create audience segments and we are not involved in the targeting of advertisement to children under 13 years old. 

     

    3. What are the purposes and legal basis of processing Personal Data? 

    We use the Personal Data detailed in section 2 for various business and commercial purposes, described below:  

     

    Purpose Details Types of Personal Data processed Lawful basis Source of Personal Data
    To facilitate the sale of advertising inventory on Publisher Customer Digital Properties We receive information about the audience of our Publisher Customers' Digital Properties and we pass this information on to Demand Partners to facilitate their decision making (i.e., whether or not to purchase advertising inventory on the Publisher's Digital Properties).
    • Identifiers
    • General geo-location data
    • Demographic information and characteristics
    • Other device information
    		 Consent Publisher Customers
    User frequency capping We use Personal Data to prevent displaying the same ad to the same End User too many times. Identifiers Consent Publisher Customers
    Inferences We use Personal Data to allow us to deliver aggregated insights, at advertising campaign or market level and report of the performance of campaigns in different locations for advertisers and publishers.
    • Identifiers
    • General geo-location data
    		 Consent
    • Publisher Customers
    • Demand Partners
    Cookie matching We maintain cookie IDs for a period of 14 days so that we can know whether your consent to the use of cookies and similar technologies has already been obtained (to avoid asking your for consent again). Identifiers Consent
    • Publisher Customers
    • Demand Partners
    Providing customer support We may use Personal Data to resolve disputes, feedback, or other issues related to our Digital Advertising Services.
    • Identifiers
    • General geo-location data
    • Demographic information and characteristics
    • Other device information
    		 Legitimate interests – managing our relationship with our customers Publisher Customers
    Debugging, identifying, and repairing errors We may use Personal Data to fix issues that impair the functionality of our Digital Advertising Services.
    • Identifiers
    • General geo-location data
    • Other device information
    		 Legitimate interests – ensuring network and information security on our systems. Publisher Customers
    Protecting the rights and property of The Qt Company and complying with the law We may use Personal Data to protect our rights and property and comply with our legal obligations, including to detect, investigate, and prevent fraud and other illegal activities and to enforce our agreements.
    • Identifiers
    • General geo-location data
    • Demographic information and characteristics
    • Other device information
    		 Legitimate interests – protecting our legal rights and prevention of crime Publisher Customers

     

    4. Who do we share your Personal Data with? 

     

    Purpose Details
    Demand Partners We share Personal Data in the form of a bid request (including identifiers, general geolocation and demographic information) with Demand Partners so that the Demand Partners can determine whether to bid on the advertising inventory available on our Publisher Customers' Digital Properties. The data we share depends on the Demand Partner's specification (such as approximate geo-location).
    A link to our current Demand Partner list is included below.
    Ad Exchanges We connect our Publisher Customers with demand partners through ad exchanges including Google Ad Manager and SmartyAds. These partners facilitate the passing of advertising bid requests from our Publisher Customers to our various demand partners.
    Qt Group companies Employees of various Qt Group subsidiaries provide support in connection with the Qt Digital Advertising Services.
    Third parties such as advisors and law enforcement authorities We may access, preserve, and disclose any Personal Data we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to:
    • comply with law enforcement or national security requests; and
    • legal process, such as a court order or subpoena;
    • protect your, our or others’ rights, property, or safety;
    • enforce our policies or contracts;
    • collect amounts owed to us; or
    • assist with an investigation or prosecution of suspected or actual illegal activity.
    Service Providers We may share Personal Data we collect about you with our third-party service providers.
    The categories of service providers to whom we entrust Personal Data include: IT and related services; fraud detection, information and services; customer service providers; and vendors to support the provision of the Digital Advertising Services.
    Disclosures in the Event of Merger, Sale, or Other Asset Transfers If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your Personal Data may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

     

    You can find the complete list of advertising Demand Partners of The Qt Company here. 

     

    5. How long do we store your Personal Data? 

    The Qt Company will retain Personal Data it collects based on the activity and purpose for collection. 

    Digital Advertising Service:  

    The Qt Company retains Personal Data collected in the context of our Digital Advertising Service as follows:  

    • We retain cookie IDs for a period of 14 days in order to provide cookie matching.
    • We retain bid requests (which includes Identifiers, General geo-location and Demographic Information and bid responses for approximately 10 minutes before they are deleted and refreshed. 

    We do not retain any other Personal Data related to you in connection with the provision of our Digital Advertising Services.  

    Business Administration: The Qt Company may retain the Personal Data it obtains about you as per the instructions of its customers or partners who provide such Personal Data or as required to fulfill our contractual obligations.  

    Legal and regulatory: Sometimes, the Qt Company may need to retain your Personal Data for a longer period in order to comply with its legal obligations or to resolve disputes and enforce agreements. 

    After the applicable retention period, The Qt Company will only retain and may only use your Personal Data in an aggregated or anonymized format.  

     

    6. International transfer of Personal Data

    The Qt Company may share your Personal Data with the third parties described above, including where they are located in countries outside of your country of residence (for example, if you are an EU resident, we may share your Personal Data with third parties cased outside of the EU ) These countries may have data protection laws that are different from the laws of your country of residence and may not provide the same level of protection as your jurisdiction. 

    When The Qt Company transfers your Personal Data outside of the EEA, we ensure it is protected by making sure at least one of the following safeguards is in place: 

    • by transferring your Personal Data to a country that has been deemed to provide an adequate level of protection by the European Commission; or
    • by using specific contracts approved by the European Commission known as Standard Contractual Clauses to protect your Personal Data. 

    If you wish to learn more about the specific circumstances when each of these protection measures are used, you can contact us at QtAds.privacy@qt.io for the details as to how we protect specific transfer of your Personal Data. 

     

    7. Cookies

    Qt does set cookies on your device or browser in connection with the processing activities described in this privacy policy. For example, Qt works with its Ad exchange partners to facilitate the placement of cookies on our Publisher Customers’ Digital Properties in connection with the Digital Advertising Services. Such cookies, however, are only placed with the requisite permissions obtained via the Publisher Customers Digital Properties. Qt may receive information captured by the cookies set (or permitted to be set) by its Publisher Customers on their Digital Properties. Please visit the relevant Digital Properties for information on the cookies in use and how you can consent to them or withdraw your consent for their use. 

     

    8. Your privacy rights

    Depending on your location, you may have certain rights related to the Personal Data we process, as further detailed in this section.  

    Individuals located in the EEA or UK

    You may ask us at any time:

    • to confirm that your Personal Data is being processed and provide you with a copy of your Personal Data;
    • to rectify your Personal Data if it is inaccurate or incomplete;
    • to withdraw your consent to our processing of your Personal Data (where we have relied on your consent as our lawful basis for processing);
    • to erase your Personal Data in certain circumstances, for instance if you have withdrawn your consent to our processing and there is no other lawful ground for our processing;
    • to restrict the processing of your Personal Data, (i) if the Personal Data we are processing is inaccurate, (ii) the processing is unlawful, (iii) you need us to retain the Personal Data in connection with a legal claim, or (iv) you have objected to our processing and a verification of our legitimate interests is pending;
    • to object to our processing of your Personal Data, where we rely on our legitimate interests;
    • to provide you with an electronic file of your Personal Data, or to transfer your Personal Data to a third party, if technically feasible (portability).

    In addition, you have the right to complain to a data protection authority regarding our processing of your Personal Data. You can also make a complaint to us directly at any time, in which case we will work with you to resolve your concerns.  

    Please note that we do not process Personal Data that identifies you directly (i.e., your name or email address). In order for us to determine whether we process your Personal Data, we will need to receive your iOS devices’ Identifier for Advertising (IDFA) or Google Advertising ID (GAID) and we will be able to connect this information with the Personal Data tied to this ID.  

    Your request should be addressed to QtAds.privacy@qt.io. When we receive your request, we will assess your request and may ask you to provide additional information to enable us to identify any Personal Data we hold about you. We aim to respond to requests within one month. If permitted under applicable legislation, we may extend the response period by up to a further two months if such is necessary due to the complexity or number of requests we have received from you. We will notify and explain the reasons for any extension to you. If we deny your request, we will inform you of the reasons for such denial.

     

    9. Additional information for US Residents

    This section provides additional information for “consumers” as defined under relevant state privacy laws, including those in California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, Virginia, and any other U.S. state that has enacted a similar data protection law that is currently in effect (collectively, the “U.S. State Privacy Laws”). Throughout this Section 9, “Personal Information” shall mean “personal data” or “personal information” as defined under the relevant and applicable U.S. State Privacy Laws. 

    Collection, Use and Disclosure of Personal Information 

    You can find a list of the categories of Personal Information that we collect in Section 2 “What Personal Data do we process?” above, and information on the business / commercial purpose for the collection and use of Personal Information in Section 3 “What are the purposes and legal basis of processing Personal Data?” above. 

    For purposes of the CCPA, we may disclose all of the categories of Personal Information that we collect (as described in Section 2 “What Personal Data do we process?” above) to the categories of third parties described in Section 4 "Who do we share your Personal Data with?" above, for purposes that may be considered "selling" or "sharing" under applicable U.S. State Privacy Laws.  The business or commercial purpose of “selling” or “sharing” Personal Information is to provide advertising, marketing, audience measurement and other similar functionality on Digital Properties. We do not knowingly sell or share the Personal Information of individuals under the age of 16. 

    Consumer Rights 

    Depending on your state of residence, U.S. State Privacy Laws grant “consumers” certain privacy rights, subject to certain exceptions and limitations: 

    • The Right to request a description of the categories of Personal Information that we have collected, used, disclosed or "sold" about you: Specifically, you may request that we disclose to you the following information about Personal Information we collect: categories of Personal Information collected, categories of sources of Personal Information collected, the business or commercial purpose for collecting, selling or sharing Personal Information, the categories of third parties with whom we share Personal Information, and the specific pieces of Personal Information we have collected about you over the past twelve (12) months.  
    • The Right to request the deletion of your Personal Information: Upon your request, we will delete the Personal Information we have collected about you.
    • The Right to Correct Personal Information: You can request that we correct inaccuracies in the Personal Information maintained by us is corrected.  
    • The Right to Opt-Out of ‘Selling’, ‘Sharing’: You have the right to opt-out of “selling” or “sharing” of your Personal Information. You can opt out of “selling” or “sharing” of your Personal Information by referring to Section 10 “Opting out of interest-based advertising” below or submitting a request to us at QtAds.privacy@qt.io.  
    • The Right to Non-Discrimination for the exercise of a Consumer’s Privacy Rights: You have the right to not be discriminated against because you exercise your consumer rights under applicable U.S. State Privacy Laws.  
    • The right to submit certain privacy requests through an Authorized Agent, as further described below.
    • California “Shine the Light Law”: Under California Civil Code Section 1798.83, also known as California’s “Shine the Light” law, California residents with whom we have an established business relationship are entitled to request and receive, free of charge, once per calendar year, information about certain personal information we shared, if any, with other businesses for their own direct marketing uses in the previous calendar year. To request a copy, please contact us at QtAds.privacy@qt.io or the postal address noted below. Please be aware that not all personal information sharing is covered by the “Shine the Light” law requirements and only personal information on covered sharing will be included in our response.
    • Appeal Rights: Residents of Colorado, Connecticut, Montana, Oregon, Texas and Virginia have the right to appeal a decision regarding a privacy request. You can exercise this right by responding to the email we send containing our response to your request. In such an appeal, you must: (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under applicable U.S. State Privacy Law. We respond to all appeal requests as soon as we reasonably can, and no later than legally required.

    Please note that we do not process Personal Information that identifies you directly (i.e., your name or email address).  

    Submitting a request: Your request should be addressed to QtAds.privacy@qt.io. When we receive your request, we will assess your request and may ask you to provide additional information to enable us to identify any Personal Information we hold about you. Once you have submitted your request, we will respond within the time frame permitted by applicable U.S. State Privacy Law. If we deny your request, we will inform you of the reasons for such denial. 

    Verification: In order to protect your Personal Information, your ability to exercise some of the rights detailed in this privacy policy may be subject to your ability to verify that you are the person about whom your request pertains. In order for us to determine whether we process your Personal Information, we will need to receive your iOS devices’ Identifier for Advertising (IDFA) or Google Advertising ID (GAID) and we will be able to connect this information with the Personal Information tied to this ID. 

    Authorized Agents: To exercise your rights using an Authorized Agent (as defined under applicable U.S. State Privacy Law), you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf. We reserve the right to deny a request from an Authorized Agent that does not submit proof that they have been authorized by you to act on your behalf.

     

    10. IAB Europe Transparency and Consent Framework

    Qt Digital Ads complies with the policies and technical specifications of, the IAB Europe Transparency and Consent Framework (IAB TCF). Please see the control and opt-out options of this policy for more information about your privacy choices.  

     The Qt Company is committed to data protection, transparency, and ethical data handling practices. By adhering to the guidelines of the IAB Europe Transparency and Consent Framework (TCF), we ensure that our digital advertisements meet the highest standards of data protection and respect for users’ rights, additionally we affirm our dedication to promoting transparency and empowering users to make informed choices about their online advertising experiences.

    Our commitment to the IAB Transparency and Consent Framework includes but is not limited to:

    • Transparency: We openly communicate with users about the purposes of data collection and use, detailed in the Privacy Policy in which this statement is included.  
    • Data Collection Minimization and Purpose Limitation: We only collect necessary data and process it for as long as needed, always respecting purpose specificity. Our data collection is exclusively for measuring the performance of advertisements and content recommendations, and for enhancing user experience. Based on consent, we place a single cookie in the browser, which helps in identifying users, avoiding repetitions, and reinforcing relevance in advertising and content recommendations.
    • Data Accuracy and Accountability: We ensure the accuracy and protection of data, safeguarding against unauthorized access, loss, or misuse.
    • External Data Partners: We encourage our third-party partners to follow the high-level data protection standards we adhere to.
    • Legal Compliance: We fully comply with relevant data protection and advertising laws and regulations.
    • Continuous Training and Awareness: We regularly inform our employees, partners, and stakeholders about the importance of data protection and ethical data handling practices.

    By adopting the TCF framework, our goal is to establish a trustworthy and user-centric advertising environment, always keeping ourselves updated with the developments in data protection and transparency.

     

    11. Opting out of interest-based advertising

    If you want to opt out of receiving interest-based advertising, please review the privacy policies of our Publisher Customers and use the opt-out mechanism provided on their websites, apps or other platforms. 

    Additionally, you can opt out of personalized ads directly from the applications/browser’s consent or privacy settings (if these settings are not available, contact your application/browser publisher for more details) or via the settings on your connected television. If you opt out of interest-based advertising, you will still receive "generic" ads from The Qt Company and our advertising partners.  

    You can also accept or reject some or all cookies (for example, blocking all third-party cookies) directly on your browser by adjusting your browser settings. However, please note that some websites may not be accessible or function properly if you decide to opt-out from all cookies. If you do not know how to do this, the links below set out information about how to change your browser settings for some of the most commonly used web browsers: 

    For mobile devices you can also refer to the following links:

    12. Changes to this privacy policy

    We may amend this Privacy Policy at any time. The amended Privacy Policy will be displayed on our site. Please check our Privacy Policy regularly to ensure you have read the latest version. 

     

    13. Contact

    The Qt Company Oy is a Finnish limited liability company with a Business ID 2637805-2, having its domicile in Espoo, Finland.  

    Postal address:  

    The Qt Company Oy 
    Miestentie 7 
    02150 Espoo 
    Finland