Scrutineer Privacy Policy

Privacy Notice

How and why we collect data and covering your choices.

(last update, 24 May 2018)

WHO ARE WE?

Scrutineer ("Scrutineer") is a service offered to companies who place online advertising to help them determine how effective their ads are. Scrutineer is a product of 2Sixty Technologies Limited, part of Essence Global Limited ("Essence"). In the European Economic Area (EEA) and Switzerland the Essence legal entity responsible for the data that Scrutineer collects is 2Sixty Technologies Limited. Outside of the EEA and Switzerland the responsible legal entity is 2Sixty Technologies LLC. This notice outlines how and why Scrutineer collects and uses personal data specifically from visits to the Scrutineer website ("Website") or Scrutineer services, including Scrutineer surveys ("Services").

This notice also explains your rights as someone who may provide personal data to Scrutineer through the Website and how to exercise these rights. If you are an individual residing in the EEA or Switzerland you should be aware that our DPO can be contacted at DPO@GroupM.com. We respect the privacy of users of our website and recognise that when you choose to provide us with information about yourself, you trust us to act in a responsible manner with that information. This privacy policy contains important information about how we use your personal information.

WHAT INFORMATION IS COLLECTED AND USED BY SCRUTINEER?

Survey Information

We collect information that you provide to us by responding to our online and mobile surveys ("Survey Information"). Survey Information may include answers to questions about ads and demographic information, such as age and gender. The decision to provide this information is optional; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Website or Services.

We automatically collect information regarding the actions you take on the Website and when you access or use the Services ("Usage Data"). For example, each time you use the Website or answer a question from one of our surveys we automatically collect the type of web browser you use, your operating system, your Internet Service Provider, the pages you view, and the time and duration of your visits to the Website. We use this information to help us understand how people use the Website and Services, and to enhance the services we offer.

We do this by using the following:
Cookie a small alphanumeric text file that we automatically assign to visitors to our website. It is stored in your browser and allows us to identify your interaction with us. Sometimes a cookie resides on your device for just the single time you’re visiting our Website; this is called a session cookie. Sometimes a cookie remains on your device until you delete it or it expires automatically; this is called a persistent cookie. Both types of cookies are used on our Websites.
Apple IDFAs The Apple iOS device Advertising Identifier
Android Ad IDs The Android device advertising identifier
IP address Internet protocol address
Pixel a line of code that sits within our webpages and which we use to record that you have visited a particular page within our Websites.

We use cookies and other tracking technologies to provide and improve the experience of the Website and Services, to track the ads you have viewed across different websites, and to present you with relevant surveys. We do not use cookies or tracking technologies to collect personal data, like your name or e-mail address. Scrutineer does share the survey results with its clients so that they can determine and improve the effectiveness of their ads. Scrutineer may also use aggregated data (i.e., the data of a number of users combined together so that no one user can be identified) in reports it publishes about online and mobile advertising.

Most web browsers and mobile devices are initially set up to accept cookies and other tracking technologies. You can reset your web browser or mobile device to refuse all cookies and tracking technologies or to indicate when a cookie is being sent, however, certain features of the Site or Services may not work if you delete or disable cookies and other tracking technologies. Some of our Service Providers (defined below) may use their own cookies, web beacons, or other tracking technologies in connection with the services they perform on our behalf.

We delivered this advert to you through the Doubleclick platform. If you choose to opt out of the original ad, please see the Google Doubleclick opt out details here. If you have any questions regarding your response to a Scrutineer survey, please contact privacy@essenceglobal.com.

HOW DO WE USE SERVICE PROVIDERS?

From time to time, we may establish a business relationship with other businesses whom we believe to be trustworthy and who have confirmed that their privacy practices are consistent with ours ("Service Providers"). For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, data storage and management, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your information from unauthorized access, use, or disclosure. Service Providers are prohibited from using information provided by or at the direction of Scrutineer other than as specified by Scrutineer.

Specific cookie types used

For more information about the specific cookie types used, you may reference the Essence cookie policy at https://www.essenceglobal.com/cookies/.

Collection and use of contact information

By entering your response to a survey as noted above you are consenting to Scrutineer using that information to contact you regarding your request. This consent is our legal basis for using the information in this way.

Scrutineer may pass your contact information to our subsidiaries and affiliated companies so that they may contact you in connection with the objective of your inquiry for the purposes set out in this policy. Where we pass your contact information to our subsidiary or affiliated companies in another country, we will make sure that they apply the same level of protection to your information as we do.

If at any time you decide to withdraw your consent and you would like us to remove you from our database, you can contact us using the details provided at the bottom of this Privacy Notice. You must include your name, e-mail address, and clear instructions regarding changes you are requesting. You may also unsubscribe from e-mail newsletters by clicking on the “unsubscribe” link found at the bottom of the e-mail.

Scrutineer is a data controller responsible for your personal data (as this term or similar term is defined by applicable law) when you visit our Website or provide us with contact information.

California

Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of personal information that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. To request a list of companies, if any, to which Scrutineer has provided personal information for its own marketing purposes, please email us at DPO@groupm.com. Please allow 30 days for a response.

Frequently Asked Questions

Does Scrutineer share any information with other vendors or partners?:

We may provide access to information we collect to our vendors and contractors (also known as third parties) who are performing services on our behalf to enable the uses of your information that we have described above. These vendors are not permitted to use this information for any other purpose. As noted above the Website uses social media widgets including but not limited to, Facebook, Instagram, Twitter and LinkedIn so users can easily share information about their visits with “likes” or “shares.” Always review the privacy policy of social media sites as their data collection practices are separate from Scrutineer practices.  Additionally, we must disclose information when we believe we’re legally obliged to, or in order to investigate, prevent, or take action regarding prohibited activities, such as incidents of hacking, misuse, suspected fraud, or other prohibited activities.

Does Scrutineer transfer your personal data outside the European Union?:

If you provide us with personal data, we may transfer that personal data to our affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world to enable us to use that personal data as described above. Our standard practice is to use European Union model clauses for the transfer of data from the EEA & Switzerland to other non-EEA countries.

Use of this site by Children and Children’s data:

Our Website is not developed for or directed at children under age 13. We specifically request that children not provide information about themselves through our Website. If you believe your child has provided this kind of information and would like it deleted from our database, you can contact us at DPO@groupm.com. If we become aware that we have collected information about a child under the age of 13, we will delete it.

Data retention and storage:

We will keep your information that we collect on the Website for a reasonable period for the purposes set out above. We follow generally accepted online advertising industry standards to ensure that your personal data disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used.These standards include undertaking necessary physical, electronic, and management activities required to protect data integrity, access, and use.

Information Security:

Maintaining the privacy of our users’ information is very important to us which means we take care and pay special attention to our security measures to protect this information from data breaches. We follow industry standards to protect against the unauthorized access to, retention of, and disclosure of information. This includes physical, electronic, and management activities to protect information integrity, access, and use.

Linking to other websites/Third party sites:

A link from our Website to another website does not imply our endorsement of affiliates or websites, and we do not control third party websites to which we link, nor assume responsibility for their content or privacy policies. Once you follow a link to another website, the Scrutineer Privacy Notice no longer applies. It’s important to always read the privacy policy of any website you are visiting.

Transfer of data upon change of control:

 

In the event that another company acquires us, or all or substantially all of the assets of our business, through a consolidation, merger, asset purchase, or other transaction, we reserve the right to transfer all information (including any information you may have provided through the “contact us” page) that is in our possession or under our control to the acquiring party, and that information may be used by the acquiring party in its business.

Data Subject Rights of individuals in the EEA and Switzerland:

You have the right to access, update, change, delete, restrict the use of, or obtain a copy of your personal data in an easily readable format. In certain circumstances, you may also request that Scrutineer transfer your Personal Data to a third party, and the right to object to its use for marketing purposes. If you wish to exercise any of these rights please contact our DPO at DPO@GroupM.com. Where our processing of your personal data is based on your consent, you also have the right to withdraw this consent at any time by contacting our DPO at DPO@GroupM.com. Please note that your withdrawal of consent will not affect the lawfulness of our processing of your personal data prior to withdrawal of consent.

Changes to this Privacy Notice:

Please note that because of the changing nature of privacy laws and regulations, digital technologies, and our business, we may modify this Privacy Notice from time to time. Please review this Privacy Notice periodically to become aware of any changes that may have occurred (we will update the effective date at the top of the page to help you know when changes have been made).

If you have any Complaints or wish to contact us:

Please use the details set out below depending on where you are located and we will do our best to address any complaints or worries you may have about how we collect and handle your personal data.

If for whatever reason you don’t feel like we have adequately addressed your concerns you can contact the Data Protection Authority in your jurisdiction and make a formal complaint.

Europe:

DPO@GroupM.com

Essence Global Limited, UK House 180 Oxford Street London W1D 1NN United Kingdom – Attn: Chief Financial Officer

Outside Europe:

Essence Global LLC - 130 Sutter St 7th Floor San Francisco, CA 94104 USA - Attn: Chief Financial Officer