Ve Privacy Guidelines for Clients.

Ve advocates greater transparency in privacy and data protection, resulting in benefits for both businesses and consumers.

Ve is required through a joint agreement with clients to ensure that both parties implement the necessary measures to meet the requirements for the services being delivered.

Below is a table of the services that Ve offers, along with actions and recommendations associated with that service:

Ve Service Type Ve Service Ve’s Privacy Status Ve Privacy Guidelines
Email Remarketing Basket Abandonment, or any emails where cookies and tracking are not involved to prove conversions (fixed fee) including analytical and measuring performance Processor Client must gather first party Consent from the user and ensure transparency by naming Ve in your Cookie Policy as a 1st Party.
Ve will act a Controller for Emails services where Ve uses its third-party cookies to track and charge on a cost per click basis Processor Client must gather first party Consent from the user and ensure transparency by naming Ve in your Cookie Policy as a 1st Party.
Controller Client must gather third party Consent from users on Ve’s behalf. Ve’s third party cookies require the client to name and link to Ve in both Privacy and Cookie Policies, along with a brief statement of the purposes of tracking conversions
Programmatic Advertising Contextual (involves some cookies) Controller / Joint Controller Client must gather third party Consent from users on Ve’s behalf. Ve’s third party cookies require the client to name and link to Ve in both Privacy and Cookie Policies, along with a brief statement of the purposes
Personalised Controller / Joint Controller - Client must gather third party Consent from users on Ve’s behalf. Ve’s third party cookies require the client to name and link to Ve in both Privacy and Cookie Policies along with a brief statement of the purposes
Push Notifications Using Cookies or similar technologies, involving unique identifiers Controller Client must gather third party Consent from users on Ve’s behalf. Ve’s third party cookies require the client to name and link to Ve in both Privacy and Cookie Policies along with a brief statement of the purposes
PUX Uses a first party cookie to make recommendations on your domain only Processor Client must gather first party Consent from the user and ensure transparency by naming Ve in your Cookie Policy as a 1st Party.
Digital Assistant Onsite advertising and messaging using cookies and similar technologies Controller / Joint Controller Client must gather third party Consent from users on Ve’s behalf. Ve’s third party cookies require the client to name and link to Ve in both Privacy and Cookie Policies along with a brief statement of the purposes
Processor Client must gather first party Consent from the user and ensure transparency by naming Ve in your Cookie Policy as a 1st Party.

Requirement for clients to act Transparently with the users who visit their websites
Meeting Transparency obligations requires clients to tell users in an intelligible way, how their data will be processed and who is processing their data, this includes processing by third parties. This is why it is necessary for Ve to be named and linked to in client’s privacy and cookie policies, along with a brief description of purposes.

Suggested wording in clients Privacy and Cookie Policies where Ve is a Controller
Who do we share your personal information with?

We share your personal information with trusted partners (third-party companies) who use cookies and similar technologies to help us deliver targeted marketing campaigns and make the ads you see after browsing our website more relevant and personal to you. Our website integrates these technologies that allow the recognition of your device and the collection of information about your browsing activity, to enable display of advertisements for our products and/or services to you on websites across the internet.

To read more about the technologies used by our partners and their linking capabilities, if applicable, please refer to their privacy policy listed below:

Requirement for clients to collect consent for third party cookies and similar technologies
Ve’s Framework Terms require every client who permits the depositing of our third party cookies and similar technologies on their website, to collect Consent from the user on behalf of Ve. Clients facilitate Ve’s collection of data through their website by allowing the cookies to be deposited. Ve’s processing is regarded as invisible because is not very obvious to the user. The user can only be informed that Ve is processing their data, by ensuring all Consent requirements are met, including Ve being named and linked to, processing purposes named, and an affirmative action by the user. Ve’s third party cookies are not regarded as essential and are not exempt from requiring consent.

In particular, under EU law, for consent to valid the following conditions must be met:

  • Users are informed at the moment they are giving their consent about the use of cookies and non-cookie technologies by Ve for the purpose of serving targeted advertising
  • Your users must take a clear and positive action to consent to non-essential cookies
  • Your websites and apps must tell users clearly what cookies will be set and what they do
  • pre-ticked boxes or any equivalents, such as sliders defaulted to ‘on’, cannot be used for non-essential cookies

Consent records
Consent must be evidenced, and clients must keep sufficient records about when the website user gave consent, how they consent (ticking a box, switching a toggle), what message and information was given before the user accepted, as well as the date and time consent was given. Users must also be able to withdraw that consent.

Ve also retains some records evidencing which client’s website consent was collected on, when it was collected, and by whom (usually via a cookie id) to assist in responding to any data subject access requests.

Further information about GDPR and its application to cookies and similar technologies

This guidance and information provided here does not constitute legal advice. Clients are responsible for seeking professional legal advice where appropriate.

We may update this guidance at any time to reflect changes required by applicable data protection laws.

Ve’s Data Protection Team can be contacted by sending an email to privacy@ve.com

Sub Processors

  • Microsoft Azure - Infrastructure and hosting
  • Google – Infrastructure and hosting
  • Freshworks – CRM ticketing system
  • Ve Group Members – processing of data to enable the business to run efficiently
  • Hubspot – CRM system
  • Juice Tactics – CRM system
  • Plain Concepts – CRM system
  • Converygtics – Analytics
  • Cloud Technology Solutions Ltd - Analaytics

Last updated: 26/07/19