Privacy Policy

Introduction

Ve Global UK Limited (“Ve” or “we”) is a technology company headquartered in the UK that provides advertising and marketing solutions (“Services”) to a variety of clients who have online operations (“Clients”).

We contract directly with most of our Clients to provide our Services. We also make available our Services to certain affiliate partner networks who are able to on-provide our Services to their respective clients. In this privacy policy (“Privacy Policy”), the term “Clients” also includes these clients of our affiliate partners.

We take privacy seriously and are committed to ensuring a safe online experience. This Privacy Policy is designed to help you to make informed choices when using Client Sites and/or Our Site.

This Privacy Policy applies only to the use of your personal information when obtained by Ve. It doesn’t apply to personal information collected during your communications with Clients and/or third parties, unless that personal information is shared with Ve in any of the circumstances described in this Privacy Policy.

When we receive or export data from or to organisations outside the UK or the EU, we rely on Standard Contractual Clauses, or other permitted measures to allow the data to flow freely in accordance with the GDPR. Where VE GlobalUK transfers data to recipients inside the EEA, no further measure is necessary currently, although we will keep this under review.

We collect personal information about:

• End users who visit Client websites: when you visit or interact with our Clients’ websites, mobile applications and services (including those of our affiliate networks) (“Client Sites”), we collect and process personal information about you. We use this information to understand more about you and to advertise or promote our Clients’ products and services to you.
• Clients and other visitors to our own website: we collect and process personal information about Client personnel who use our Services and others who visit Ve’s website (“Our Site”).

Below you will find our policies for each of the cases above, as well as further information about our use and storage of personal information and your rights to opt-out, access it and request that we delete, update and/or transfer it.

Part I - Information for end users who visit Client Sites

1. What personal information do we collect and how do we collect it?

We collect the following categories of personal information from you:

• email addresses and/or telephone numbers, if voluntarily entered into a Client Site by you (e.g. to buy a product or service, become a registered user, or sign up for marketing communications) (“Contact Details”);
• data relating to your browsing activity through the use of cookies, web beacons and pixel tags and similar technologies deployed on Client Sites or via emails sent by Ve on behalf of Clients (“Behavioural Data”), including:

• email; name; and phone  number; and gender, in each case if input into a Client Site by you (“Profile Data”).

For more information about the technology that we use to collect Behavioural Data, please see our Cookie Policy.

We also receive Behavioural Data and Profile Data from, and may share it with, third party partners (through “cookie synching” or similar matching technologies).

To serve you our personalised advertisements on Clients websites and provide you with a seamless online experience, we may link your identifiers on the different browsers and environments you are using (“ID Syncing”). Thanks to its ID-syncing technology, Ve is able to serve you the most relevant ads on whichever device or browser you are currently using. For this purpose, Ve uses exact linking methods by leveraging the technical data collected through out technology such as our advertising partners’ identifiers or email hash that they may pass to us. We may also receive ID-syncing information from trusted partners using diverse linking methods for the same purpose and with the same level of guarantees in terms of Privacy and Data Protection.

We do not collect sensitive information from you (such as data relating to health or religious beliefs). Although it may be possible for us to infer certain information, such as your religious beliefs, from certain Behavioural Data that we may collect, we do not create or use segments that rely on the use of sensitive personal information for the purposes of online behavioural advertising.

2. How do we use the information we collect?

We collect personal information from you to a) help our Clients to market, and facilitate the sale of, their products and services more effectively and/or efficiently and b) provide a more personalised online experience for you. We achieve this by using information that we have collected (including Behavioural Data) to create inferences about your personal preferences, interests and behaviour.

Ve combines information that it collects from you across all Client Sites and uses that personal information for the benefit of each of its Clients. By way of example:

• if Ve collects personal information when you visit Client Site A, that personal information may be used to display an ad to you, on a third party website, for products available on Client Site B.
• if Ve collects personal information when you visit Client Site A, and you subsequently visit Client Site B and provide Client B with permission to send you marketing, Ve may use the information collected on Client Site A to personalise the content of Client B’s marketing communications that are then sent to you.

We share personal information about you (including Behavioural Data and Profile Data) within the Ve group of companies to enable us to provide and improve our Services. We may share personal information with third parties for specific purposes, as further explained on the next topic.

If we wish to use your personal information for any new purpose that is not listed below, we will, prior to using such personal information, evaluate whether it is in our legitimate interest to use it for that purpose. If we determine that it is in Ve’s legitimate interest to do so, we will update this Privacy Policy to explain the new purpose. Please check back frequently to see any updates or changes to this Privacy Policy.

3. To what specific purposes we use your personal information?

a) Deliver relevant and interest-based advertising

We use inferences about your personal preferences, interests and behaviour to serve relevant and personalised advertisements for our Clients’ products and services to you when you visit third party websites and platforms. This means that you receive advertisements for products and services that are more likely to be of interest.

For example, Clients may, using our Services, wish to display personalised offers, messages, content and/or product recommendations on Client Sites, based on the personal information collected about you on that website.

• Who do we share personal information with for this purpose?

We do not disclose Profile Data to our advertisers or advertising networks outside of the Ve group.

As for Behavioural Data, we share them beyond Ve’s group of companies via our group owned DSP (demand side platforms), which is platform Volvelle (Optomaton). Behavioural data is shared with platforms called supply side platforms (also known as SSPs), real time bidding platforms (also known as RTBs), and Adservers, as well as with advertisers and third party partners in advertising networks who use the data to select and serve relevant adverts to you.

You can check our group member (DSP) Optomaton’s Privacy Policy to see the data sharing platform partners (www.optomaton.com/privacy.html).

Advertisers whom supply our services, and with whom we may share your data with, fall into the following categories:

• Financial services; banking/credit cards/insurance/lending;
• Estate agents;
• Charities;
• Utilities: gas/electricity/water;
• Telecommunications’ broadband, fixedline, mobile;
• Retailers who supply consumer goods and services, such as;

• What is our legal basis?

Ve Global relies Consent as the lawful basis of processing. Your Consent will be requested for any new cookies that may be deposited on your browser on subsequent visits to the websites of advertising clients with whom we are a Joint Controller.

b) Help our Clients analyse the effectiveness of their ad campaigns and to improve the Services we provide to Clients

We use the information we collect to operate, manage, maintain and improve our Services and to help our Clients analyse the effectiveness of their ad campaigns.
Clients are able to access reports through Ve’s reporting platform that help them to analyse the effectiveness of their ad campaigns.

• Who do we share your personal information with for this purpose?

Ve provides Clients with personal information and analysis of that personal information where the activity is attributed to advertisements served by Ve, or emails viewed and clicked on, as well as details of resulting conversions or browsing activity on that website. This may include the sharing of personal data of the user’s activity on that specific client’s site.

We also provide Clients with aggregated information about you and others across different websites (for example, we may inform Clients that 500 men aged under 30 have purchased a particular brand in the last 6 months).

• What is our legal basis?

Ve Global relies on Consent as the lawful basis of processing. Your Consent will be requested for any new cookies that may be deposited on your browser on subsequent visits to the websites of advertising clients with whom we are a Joint Controller.

c) Email and SMS marketing and other communications sent by Clients using Ve Services

Where you provide your Contact Details on Client Sites and, in doing so, provide Clients with permission to send marketing communications to you, Ve may use the personal information about you that it has collected (from any Client Site) to create personalised marketing communications which are then sent by Ve on behalf of Clients who hold a valid permission to market to you. These marketing communications may be sent by email, text message and in-app push notifications, or similar methods, and will always be sent from Ve on behalf of Clients.

• Who do we share your personal information with for this purpose?

We do not share your personal information with third parties outside of the Ve group for this purpose.

• What is our legal basis?

Marketing communications will be sent by Ve on behalf of Clients to you by email or text message where you have consented to receive such communications from the relevant Client or where our Client has a lawful right to send the communication.

d) Supporting our clients’ websites effectiveness

When clients use our Digital Assistant product we use cookies, and track your usage of our clients’ websites, in order to: understand your needs and preferences on the site; automate answers to common questions; and inspire your purchase decisions with recommendations.

• Who do we share your personal information with for this purpose?

We do not share your personal information with third parties outside of the Ve Group for this purpose. We share your data with the client whose site you are visiting.

• What is our legal basis?

On-website suggestions and responses are sent to you by Ve on behalf of the Clients whose website you are visiting when they use our Digital Assistant product. We only do this when you have consented to the use of cookies on the client website for this purpose.

e) Business administration and legal compliance

We use your personal information for the following business administration and legal compliance purposes:
- to comply with our legal obligations;
- to enforce our legal rights;
- to protect rights of third parties; and
- in connection with a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets.

• Who do we share your personal information with for these purposes?

We may share your personal information with any of our group members, as well as professional advisers, such as lawyers and accountants, and/or governmental or regulatory authorities.

• What is our legal basis?

Where we use your personal information in connection with a business transaction, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so and we will use either legitimate interest, or legal obligation depending on the exact circumstances.

Part II – Information for Clients and other visitors to our own Site

1. What personal information do we collect from Clients (and other people who visit Our Site) and how do we collect it?

We may collect the following categories of personal information from you:

• name, address, e-mail address, telephone numbers, payment and credit card information, passwords, and any other personal information voluntarily submitted by you when you subscribe, register, complete forms or purchase products on Our Site, or correspond with us (via Our Site or otherwise) (“Voluntary Data”); and
• data relating to your browsing activity through the use of cookies, web beacons and pixel tags and similar technologies (“Tags”) deployed on Our Site or emails sent by us to you, (“Behavioural Data”), including:

For more information about the technology that we use to collect Behavioral Data, please see our Cookie Policy.

2. How do we use the information we collect from Clients (and other people who visit Our Site)?

The primary purpose for which we collect the personal information from you is to: (i) verify your identity; (ii) help us improve our Services and develop and market new products and services; (iii) carry out requests made by you on Our Sites; (iv) investigate or deal with enquiries or disputes; (v) comply with applicable laws or the requirements of a court or regulator; (vi) enforce our agreements with Clients and vendors; (vii) protect the rights, property or safety of us or third parties, including our Clients and those who visit Our Site; (viii) provide support for the provision of our Services; and (ix) use as otherwise permitted by law.

To serve you our personalised advertisements on Clients websites and provide you with a seamless online experience, we may link your identifiers on the different browsers and environments you are using (“ID Syncing”). Thanks to its ID-syncing technology, Ve is able to serve you the most relevant ads on whichever device or browser you are currently using. For this purpose, Ve uses exact linking methods by leveraging the technical data collected through out technology such as our advertising partners’ identifiers or email hash that they may pass to us. We may also receive ID-syncing information from trusted partners using diverse linking methods for the same purpose and with the same level of guarantees in terms of Privacy and Data Protection.

3. To what specific purposes we use your information?

a) If you are a Client: fulfilment of Services to you

We collect and maintain Voluntary Data submitted to us on behalf of Clients during your use of Our Site and/or during the provision of our Services. The purposes for which we use Voluntary Data submitted to us on behalf of Clients are as follows:

- Purchases of Services: We use Voluntary Data (and in particular payment and credit card details) so that we can supply Services that Clients have ordered via Our Site and to process any refunds. Any contractual terms relevant to the supply of the particular Services will also apply.
- Account registration and log in: If you register for a VePlatform account, we may use Voluntary Data to process your registration. Once you are registered, we will process your email address and password to identify you when you log into the VePlatform via Our Site. We will use Voluntary Data so that we can administer your VePlatform account.

• Who do we share your information with for this purpose?

We will share your personal information with the following categories of third parties:

- Credit card companies and other payment providers who assist us with the verification of card payments and the processing of refunds; and
- Web hosting, optimisation and management companies who assist us with the hosting, operation, optimisation and maintenance of Our Site, the administration of Ve Platform accounts and the provision of access to secure areas and functionality on Our Site.

• What is our legal basis?

It is in our legitimate interest to use this information to enhance the quality of the Services that we provide to Clients and, to the extent that our clients are businesses and not natural persons, no personal information is involved.

b) Insight and analysis

We analyse Voluntary Data and Behavioral Data in order to better understand our Clients and other users of Our Site.

Where you have given consent (where lawfully required), we use Tags to collect Behavioral Data.

The Tags that we use allow us to track receipt of an email to you, count users who have visited a web page or opened an email and collect other types of aggregated information. Once users click on an email that contains a Tag, some Voluntary Data may subsequently be cross-referenced to the source email and/or the relevant Tag.

In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

Please see our Cookie Policy for further information.

This information is used to create insights about your browsing habits on Our Site. By using this information, we are able to measure the effectiveness of our content and how Clients and other people use Our Site and/or our Services.

This allows us to learn what pages of Our Site are most attractive to those who visit Our Site, which parts of Our Site are the most interesting and what kind of features and functionalities visitors to Our Site like to see.

We also use this information to help us with the selection of future product and service lines and website design and to remember your preferences.

We may also use this information for marketing purposes (Email marketing).

• Who do we share your personal information with for these purposes?

We share your personal information with third party service providers to assist us with insight analytics. These providers are described in our Cookie Policy.

• What is our legal basis?

Where your personal information is anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to enhance the quality of the Services that we provide to Clients.

c) Postal marketing

We use information that we observe about you from your interactions with our Sites, our email communications to you and/or with our products and services (see the Insight and Analysis section above for more details of the information collected and how it is collected) and/or your address details, to send you marketing communications by post.

• Who do we share your personal information with for these purposes?

We share your personal information with a variety of third party postal providers who assist us in delivering our postal marketing campaigns to you, including the post office.

• What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, such as your postal address, it is in our legitimate interest to use your personal information for postal marketing.

d) Email marketing to current or prospective Clients

We use Voluntary Data (including names and email addresses) to send marketing communications by email, where you have consented to receive such marketing communications or where we have another lawful basis to do so.

Our email marketing may include personalised and non-personalised email marketing. Personalised marketing is marketing that has been specifically tailored to you. For example, our personalised email marketing may feature Services that we think are most likely to appeal to you and/or a Client. Non-personalised marketing is marketing about our Services generally and is not tailored to you or a Client.

Where we are sending you personalised email marketing, we will also use information that we observe about you from your interactions with Our Site, with our email communications to you and/or with our Services in order to decide what sort of personalised marketing communications to send to you. Please see the “Insight and Analysis” section above for more details about the personal information collected and how it is used.

• Who do we share your personal information with for these purposes?

We share your personal information with third party email marketing providers who assist us in delivering our email marketing campaigns to you.

• What is our legal basis?

Where your personal information is anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only send you marketing communications by email where you have consented to receive such communications, or where we have another lawful right to do so.

e) Business administration and legal compliance

We use your personal information for the following business administration and legal compliance purposes:
- to comply with our legal obligations;
- to enforce our legal rights;
- to protect rights of third parties; and
- in connection with a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets.

• Who do we share your personal information with for these purposes?

We may share your personal information with any of our group members, as well as professional advisers, such as lawyers and accountants, and/or governmental or regulatory authorities.

• What is our legal basis?

Where we use your personal information in connection with a business transaction, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so and we will use either legitimate interest, or legal obligation depending on the exact circumstances.

Part III – Miscellaneous

1. Our use of cookies and similar technologies

Ve makes use of certain cookies, pixels, beacons, log files and other technologies on Client Sites and Our Site.

Please see our Cookie Policy to find out more about the cookies we use on Client Sites and Our Site.

Our Cookie Policy explains how you can manage and delete cookies which relate to Our Site.

2. How to opt-out of our use of your personal information

This section explains how you can opt-out of our use of your personal information collected in relation to your interactions with Client Sites, including how you can opt-out of us displaying personalised ads to you when you visit third party websites and platforms.

We explain below various mechanisms which you can use to opt-out of our use of your personal information in respect of Services that we provide in relation to Client Sites.

Note that some of these mechanisms are subject to various limitations and conditions. In particular some of the mechanisms require that we place a cookie on your browser in order to identify you as a person who has opted-out of our use of your personal information. If you clear cookies or reset your device settings, we will not be able to identify you as a person who has opted-out of our use of your personal information.

Where you exercise your right to opt-out of receiving adverts or any personalised form of marketing, we will need to retain enough information (such as a cookie id, advertising id, or email address) in a suppression list to ensure that you do not received further marketing from us or sent by us on behalf of our Clients. This retention period will not expire, unless you contact us to advise that you would like us to, once again, send you marketing communications.

Where you opt-out using the below mechanisms, we will restrict our use of your personal information according to the opt-out that you have chosen, but we may retain your personal data as described in this Privacy Policy (for further information please see “How long do we keep your personal information for”):

a) Contact Us

Contact us at privacy@ve.com to inform us that you would like to opt-out of our use of your personal information for the purposes described in Part I of this Privacy Policy.

Note that if you choose to opt-out of our use of your personal information for the purposes of email and SMS marketing and other communications sent by Clients using Ve Services, you may still receive marketing communications from our Clients (subject to the choices that you make with each of those Clients), but these communications will not then be personalised or sent by Ve. You may also need to contact Clients if you wish to opt-out of other communications made by them or on their behalf.

Where possible, we will try automatically to link identifiers used in relation to other devices and browsers that you use. However, this may not be possible and you may need manually to opt-out of our use of your personal information on a ‘device-by-device’ basis.

b) Deleting cookies on your device or browser

We rely on cookies and other online identifiers to collect and use your personal information. You can delete cookies from your devices and browsers to prevent us from collecting data about you and identifying you.

If you opt-out of our use of your personal information using this method, we would still use personal data that we hold and collect about you from other devices and/or browsers, unless you also delete the cookies from all of the other devices and/or browsers that you use. Accordingly, you may wish to opt-out of the relevant use by using the other toggle buttons above.

c) Using Safari’s ‘Limit Ad Tracking’ function

If you are using Safari browser version 11.2 or above, you can prevent us from using your personal data for the purposes of displaying relevant and interest-based advertising to you by toggling the “Limit Ad Tracking” setting on your device or computer.

On an iPhone, this is typically located under Settings>Privacy>Advertising.

On a computer, this is typically under Safari>Preferences>Privacy.

d) Using the IAB Europe’s opt-out

You can opt out of our use of your personal information for the purposes of displaying relevant and interest-based advertising to you by visiting www.youronlinechoices.com/uk/your-ad-choices. Find VE in the list of online behavioral advertising companies and select ‘off’.

e) Native apps – Apple/iOS and Android

If you have an Apple device, you can opt out of targeted advertising services by updating to iOS 6.0 or higher and setting Limit Ad Tracking to ‘ON’. You can do this by clicking on Settings -> Privacy -> Advertising -> Toggle Limit Ad Tracking to ‘ON’. Our systems are designed to respect your choice and not use information to provide targeted advertising when this setting is ON. Again, you should consult Apple’s support web pages and instructions for the most current applicable settings.

If you have an Android device, you can opt out of targeted advertising services by clicking on Settings -> Google -> Ads -> Toggle Opt Out of Ads Personalization to ‘ON’.

3. Storage and sharing of personal information and transfers overseas

a) Within the Ve Group

We may share your personal information with any member of our group, which means Ve Global UK Limited’s subsidiaries, and its ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

The use of your personal information is governed by an intra-group agreement which, in relation to transfers of personal information from the EEA to a non-EEA jurisdiction, incorporates EU approved model clauses.

b) With Microsoft Azure

VE stores data in Microsoft Azure data centres in Europe, the US, Singapore and Russia. The transfer of personal data to Microsoft Azure data centres that are located outside the EEA is governed by a contract incorporating EU Model Clauses.

c) With other third-party suppliers and partners

We may share your personal information with our third-party suppliers (such as SAP, Bidswitch, Rubicon, Zapier and Tradedesk as well as other DSPs and SSPs), through our own DSP (Volvelle/Optomaton).

We may process personal details (usually contact information) regarding any suppliers and customers that we work with, to allow our business to function, including carrying out audits, dealing with enquiries or complaints and carrying out management functions.

Where we have explained that personal information is shared with a third-party supplier, some of those third party suppliers may be located outside of the jurisdiction where the personal information was collected, or they may transfer personal information to jurisdictions which are outside of the jurisdiction where the personal information was collected.

In some cases, the data protection laws of these other jurisdictions may not be as comprehensive as those of the jurisdiction in which the personal information was collected.

Where this is the case, Ve will take appropriate steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy and all applicable laws. This may include ensuring that there is a lawful basis for transferring personal information outside the EEA.

4. How to access your information and your other rights

In addition to your right to opt-out of our use of your personal information in respect of Services which we provide in relation to Client Sites, you have the following rights in relation to the personal information we hold about you:

a) Your right of access

If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

b) Your right to rectification

If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

c) Your right to erasure

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

d) Your right to restrict processing

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

e) Your right to data portability

With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

f) Your right to object

You can ask us to stop processing your personal information, and we will do so, if we are:

• relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
• processing your personal information for direct marketing.

g) Your rights in relation to automated decision-making and profiling

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

h) Your right to withdraw consent

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

i) Your right to lodge a complaint with the supervisory authority.

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

5. How do we obtain your consent?

Where our use of your personal information requires your consent, you can provide such consent:

• at the time we collect your personal information following the instructions provided most commonly via a cookie style banner on a website, when using cookies or similar technologies; or
• by informing us by e-mail, post or phone using the contact details set out in this Privacy Policy.

6. Third Party Links and Services

Our Site contains links to third party websites and services. When you use a link to go from Our Site to another website or you request a service from a third party, this Privacy Policy no longer applies (except where the third-party website is a Client Site, in which case Part I of this Privacy Policy applies).

Your browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies.

We do not monitor, control, or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website you visit or third-party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

7. How long do we keep your personal information for?

In relation to personal information obtained and used as described in Part I of this Privacy Policy:

We retain your Contact Details, Behavioral Data relating to you and Profile Data (for further information see Part I, item 1 of this Privacy) for a period of thirteen months from the date we collect your data via our cookies.

Please see our Cookie Policy, which explains when cookies that we use on Client Sites are set to expire.

In relation to personal information obtained and used as described in Part II of this Privacy Policy:
Generally, we do not keep your personal information for longer than is necessary for the purposes for which it was collected.

Unless we have a legal obligation to retain your personal information for a longer period:

• we retain personal information collected in respect of visits to Our Site (for further information see Part II, item 1 of this Privacy Policy) for a period of thirteen months from the date we collect your data via our cookies. Please see our Cookie Policy, which explains when cookies which we use on Client Sites are set to expire.
• we retain personal information relevant to our contractual relationship with a Client for the provision of our Services for six years from the date of supply of our Services and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.

Where you have given your consent to our cookies, we will retain this record of your consent for three years from the date that you gave consent. Where you have opted out of receiving marketing/advertising, we will retain your email address and/or cookie ID in a suppression list to prevent further emails and adverts being sent to you, until you advise us to delete this data.

If any personal information is only useful for a short period (e.g. for a specific marketing campaign), we may delete it at the end of that period.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal information indefinitely so we do not send you marketing communications again.

8. Confidentiality and security of your personal information

We are committed to keeping secure the personal information that you provide to us and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

• unauthorised access;
• improper use or disclosure;
• unauthorised modification; and
• unlawful destruction or accidental loss.

All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all persons who use our Services.

9. Industry memberships and affiliations

Ve is a member of the European Digital Advertising Alliance (“EDAA”) and is in compliance the EDAA’s Self- Regulatory Principles. We also use the Interactive Advertising Bureau Europe’s Transparency & Consent Framework (TCF 2).

10. Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time.

To ensure that you are always aware of how we use your personal information, we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.

11. How to contact us

Ve Global UK Limited is a company registered in England and Wales under company number 10706696 and has its registered office at 7 Bell Yard, London, WC2A 2JR.

If you have any questions or wish to exercise your rights set out in this Privacy Policy, please contact our Data Protection Officer at the address above or through the email privacy@ve.com.

July 2021