Neodata Services Privacy and Cookie Policy

Neodata Group and its subsidiaries (hereinafter “Neodata”) pay particular attention to the confidentiality and processing of personal data and they’re committed to comply rigorously with the relevant applicable law.

This privacy policy outlines Neodata’s rules on the protection and processing of personal data collected through its services worldwide that display or link to this notice. Neodata’s services are provided to third parties (hereinafter “Clients”), who might use them to profile their online audience.

This document describes: Neodata’s services (hereinafter “Services”) and the technology we use; the data we process through the Services we deliver; the Cookies we provide, how Clients use them and how Users can deactivate them.

With reference to the processing of personal data deriving from the provisioning of Services, the relationship between Neodata and the Client is determined by the actual roles and competences of each party.
Neodata is merely a provider of technical services and by no means has the power to determine the essential purposes and the modalities of the processing of data, or of data management security. Therefore Neodata and its subsidiaries, when dealing with the data collected through the provision of the Services, always and exclusively acts on the basis of the decisions and the directions provided by the Client – which is the only Data Controller – and operates under the Client’s vigilance.

SERVICES
Neodata Group specialises in the analysis of Big Data for the optimization and targeting of digital editorial and advertising contents. Neodata’s Services allow Clients (i.e. online publishers and advertisers) to analyze and profile the browsing behavior of unique visitors navigating their websites or viewing their online campaigns (hereinafter “Users”), to deliver content recommendations and to manage the delivery of digital advertising campaigns..

TECHNOLOGY
Therefore Clients who use Neodata’s technology collect anonymous, aggregated statistical data on unique visitors and their navigation patterns. Collected data might include, for instance, IP address, ISP, browser and device.
Although the data processing modalities described in this document correspond to the standard practices, the Client might process additional personal data that Neodata is unaware of.
To collect data and deliver its Services, Neodata deploys “cookies”.

WHAT IS A COOKIE?
A “cookie” (hereinafter “Cookie”) is a short text file that stores navigation information. Cookies are installed in the User’s browser; they can be read, modified or deleted via the settings offered in most browsers at any time and they never contain viruses.
In principle, Cookies can be categorized into either “technical” or “profiling” Cookies.

Technical Cookies are used to manage activities which are strictly necessary for the functioning of a website. Technical Cookies can be further subdivided into the following subcategories:
- Navigation Cookies, which store the User’s browsing preferences to consistently provide a targeted browsing experience;
- Analytics Cookies, which collect statistical information about Users’ browsing habits. Such information is collected in anonymous, aggregate form;
- Functional Cookies, also by third parties, which are used to perform specific functions of the website and necessary to provide or improve the service.
These Cookies do not require the prior consent of the User to be installed and used.

All remaining Cookies fall into the profiling Cookies category and they might imply User navigation tracking activities. Profiling cookies require the prior consent of the User.

COOKIES INSTALLED THROUGH SERVICES PROVIDED BY NEODATA
Neodata uses both technical and profiling Cookies. The use of either or both depends upon the Services Neodata provides to the Client.
The following table shows the Cookie types (i.e. “technical” or “profiling”) deployed by Neodata based on the following parameters: company delivering the Service (parent or subsidiary) and Service provided.

Company Service Cookie Type
Neodata Group s.r.l.
ad.agio (delivering targeted advertising and editorial content) Technical Cookies
Profiling Cookies
DMP Profiling Cookies
Audience Analysis Profiling Cookies
Paywall Simulator Profiling Cookies
Neodata Intelligence s.r.l.
ad.agio (delivering targeted advertising and editorial content) Technical Cookies
Profiling Cookies
DMP Profiling Cookies
Audience Analysis Profiling Cookies
Paywall Simulator Profiling Cookies
Newscurve No cookies
Neodata Intelligence, Inc.
ad.agio (delivering targeted advertising and editorial content) Technical Cookies
Profiling Cookies
DMP Profiling Cookies
Audience Analysis Profiling Cookies
Paywall Simulator Profiling Cookies
Newscurve No cookies

Normally, Cookies installed through Neodata’s services refer to the following domains: smart-dmp.com and neodatagroup.com, unless differently set up by the Client and specified in their privacy policy or cookie policy.

The fact that a link to Neodata’s resources appears on the websites or other digital places managed by the Client or any other subject the Client might deliver its services to, or that installed Cookies refer to domains hosted by Neodata, does not imply that Neodata is responsible for the modalities in which data are processed independently by the Client by means of its own tools or tools provided by Neodata.

NEODATA PROFILING COOKIES
Neodata provides Clients with tools that allow for the installation of profiling cookies to collect anonymous data on:
- actions performed by unique visitors on Clients’ websites (e.g. number of pageviews, type of articles visualized, searches etc.);
- socio-demographic information provided by Users, such as age range and gender;
- device used (e.g. mobile vs desktop, operating system, browser etc.);
- information relating to advertising content, such as number of banners viewed by Users
- information relating to email marketing campaigns (e.g. email opening, click, actions performed on landing pages etc)

Neodata’s profiling Cookies are handled in a completely anonymous form; Neodata cannot access Users’ personal data (such as first name, last name, address, date of birth, telephone number etc.), hardware ID numbers (such as MAC address) or sensitive data (health status, political, religious or sexual orientation). Neodata’s tracking tools assign a unique user ID to each visitor, based on which it is possible to recognize the User, track the User’s navigation habits and target. Sometimes Neodata stores IP addresses to extract geographical information, never to identify the User.
Unique user IDs are assigned to the browser; collected data are never used by Neodata, directly or indirectly, to determine the identity of Users.
Collected data are stored and processed automatically through Neodata’s IT system; data are used to provide aggregate statistical analyses to publishers and advertisers, and/or to provide recommendations on editorial content, and/or to optimize advertising delivery based on Users’ preferences, as suggested by their navigation habits.

Data are extracted, processed and stored for the sole purpose of enabling Neodata to provide its Services through its proprietary systems, and exclusively for the duration of such services; data are destroyed as soon as they’re not serving any of these purposes.
Neodata might share collected data in aggregated or non aggregated form with subsidiaries, associates and trusted affiliates upon request of the Data Controller (the Client). The Data Controller is responsible for collecting authorization from the data subject to share his/her personal data.
Neodata reserves the right to disclose collected data when required by Law or required by judicial, prosecuting or investigating authorities.
Neodata has implemented all necessary security measures to grant that data are collected, used and maintained confidentially. We use advanced technologies and security procedures to protect information from unauthorized access, use or sharing. Nevertheless, current technologies do not allow to control every data transmission or storage over the web. For these reasons, Neodata can only ensure the deployment of technologically advanced security tools.

HOW TO DEACTIVATE NEODATA’S COOKIES
Users can prevent anyone, including Neodata, from collecting their navigation data by deactivating Cookies in their browser settings.
Browser settings also allow to eliminate Cookies that have been installed in the past.
Users can find information on how to deactivate Cookies via browser settings at the following addresses:
Google Chrome, Mozilla Firefox, Apple Safari, Microsoft Windows Explorer.

Users should be aware that deactivating Cookies may interfere with the correct visualization of some websites (e.g. access to restricted areas requiring log in credentials).
Alternatively, Users can ask Neodata directly to opt-out from having the Clients track their navigation preferences by means of Cookies, even when the Client does not provide tools to opt-out.
By choosing to Opt-Out, Users will prevent Neodata from placing Cookies in their browsers on behalf of Clients.
Users who have opted out can decide to restore Cookie usage at any time by clicking on the Opt-In button.

Users can opt-out from profiling activities operated by Neodata by following this link:
http://www.neodatagroup.com/data-security/opt-out-opt-in-procedure/

Last updated: May 28, 2015