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This privacy policy (version no. 1 dated 15 March 2024) is provided by Aryel S.r.l. and concerns the activities that Aryel and/or the third parties indicated in paragraph 7 below carry out in order to provide digital advertising services.
Dear Visitor (hereinafter, “You” or the “User“),
This page is the property of the company Aryel S.r.l. with registered office in Milan, Via Morimondo, 26 – 20143, VAT number 11294810962 (hereinafter, the “Company“). Our Company carries out the activity of deploy and distribute creative digital advertising via online digital channels, including email, on behalf of advertising agencies and/or clients, and related measurement activities (hereinafter, the “Services“). Therefore, we act as a third party of the publisher’s/advertiser’s website and/or mobile app that you have just come from (hereinafter, the “Website of Origin“). In some cases, we act as an intermediary between the publisher of the aforementioned Website of Origin and third parties (as better described in paragraph 7 below).
Users can contact the Company at any time for any information on this privacy policy, using the following methods:
You can also contact the Data Protection Officer (DPO) of the Company, whose contact details are as follows: email address dpo@aryel.io
We operate in the field of digital advertising, working with third-party publishers, advertising agencies and/or clients, as well as third parties to deliver advertising messages relevant to those browsing the internet and to measure advertising campaigns carried out on behalf of advertising agencies/clients, also using owned and third-party technology.
Since cookies and/or other tracking tools – similar to cookies – are used through our Services for various purposes, in this privacy policy we would like to explain what these tools are and how they are used.
Some tracking tools are used and controlled directly by the Company. Through these tracking tools, the Company collects and processes certain personal data concerning you. In this privacy policy, pursuant to art. 13 of the Regulation EU 2016/679 of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (hereinafter, the “Regulation“) and pursuant to Italian Legislative Decree no. 196/2003 and subsequent amendments and additions (hereinafter, the “Code” and, together with the Regulation, the “Applicable Law“), we will explain how we collect this data, for what purposes and what your rights are.
Other cookies on the Website of Origin, on the other hand, are carried and controlled by third parties. In this privacy policy you will find links to the privacy policies published by these third parties, which we ask you to read carefully (see paragraph 7 below).
Cookies are only one of the tools used by our Services. In fact, it is also possible that other tracking tools (such as pixels, tags, Software Development Kits (SDK), etc.) may be used for the same purposes of profiling (in order to deliver personalized behavioural advertising, etc.) or analysis and measurement (analysis and monitoring of the behaviour of users of the Website of Origin, analysis of the advertising campaigns delivered, etc.) as set out below.
If you are not familiar with cookies and/or other tracking tools, please read this policy carefully so that you can be aware of your choices.
Company by choice, only processes so-called pseudonymous data (i.e. data that will never allow us to identify you), only alphanumeric codes and never directly identifies you. Therefore, this means that we will never know the name, surname or email address of a user that has visited a Website of Origin. The data collected autonomously by the Company, as explained in this policy, may be combined also with other information which the Company may receive from third parties or other partner, with the only intent of deliver advertising campaigns more in line with the preferences of the users. The Company requests to these subjects to maintain reserved all the information shared and the Company will use this information only for the purposes described below. In order to do this, the Company enter into specific contracts with third parties and partners, and it requires these subjects to guarantee that they collected and process the data in compliance with the Applicable Law. We process data in order to:
To provide the Services, the Company uses:
The above-mentioned data may be associated with information relating to the advertising campaign delivered by a publisher and the User’s interaction with the advertising campaign itself (e.g., clicks, time of day, subject that delivered the campaign, type of advertising campaign, etc.), in order to count the delivery of such campaign and to prepare accurate reports.
The legal basis for the processing carried out to provide the Services is the prior consent of the User (art. 6, paragraph 1, letter a) of the Regulation).
As set out in the Applicable Law, your prior consent is required to install tracking tools that does not have a technical purpose. For this reason, when you access the Website of Origin, a special banner is displayed or, in some cases, a so-called Consent Management Platform (hereinafter, “CMP“), which you can use to state your preferences.
You are, of course, free to not give your consent to the installation of profiling tracking tools and to opt-out of using them at any time, without this affecting your ability to visit the Website of Origin and enjoy its content in any way.
As a sign of its commitment, Aryel is a member of the IAB Europe Transparency & Consent Framework (hereinafter, the “IAB Framework“ or the “TCF”) – the European framework for transparency and consent management – and complies with the Specifications and Policies of the IAB Framework. The Vendor ID of Aryel is 1237, in the context of the IAB Framework. You may find further information regarding the IAB Framework on the IAB Europe’s website.
If the User provides his/her consent to the use of cookies and/or other tracking tools via the CMP, the consent expressed will be tracked through technical methods linked to the use of the CMP, allowing for the documentation of the User’s choices to be kept up to date in compliance with Applicable Law. In this latter case, the Company may process data and metadata relating to the granular choices made by the User: the possible expression of consent, the details of the granular purposes for which the User has given consent, as well as the User’s possible choice to continue browsing while maintaining default settings by pressing the relevant button provided by the CMP on the Website of Origin. Such information might also passed on to partners and other technologies quoted in this policy.
The following table aims to show that the subsequent processing of data collected with cookies and/or other tracking tools used by Company on Websites of Origin, carried out by the Company under its legitimate interest, is disclosed to Users and is based under a prior legitimate interests’ assessment, as required under the IAB Framework. In particular, as a controller under the TCF, Company is required to justify the processing of personal data carried out under legitimate interest for “Special Purpose 1 – Ensure security, prevent and detect fraud, and fix errors” and for “Special Purpose 2 – Deliver and present advertising and content”. When assessing Company’s legitimate interest, the interests of Company as well as the interests of its publishers and its advertisers (and their respective intermediaries and agencies) were considered. In particular, the table below summaries Company’s legitimate interest assessment.
| CONTEXT | Context of processing. Users will receive notice of the subsequent processing and of the legal basis under which Company processes the data through the Consent Management Platform (“CMP”), connected to the TCF, used by Company’s publishers and/or advertisers on the Websites. As required under the applicable law and the TCF, a balancing test was carried out by Company in which it was confirmed that, having prior obtaining the consent of the user for the “Purpose 1 – Store and/or access information on a device”, the processing for the two subsequent Special Purposes at stake carries no risk of undue negative impact on the data subjects’ interests or fundamental rights and freedoms. |
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| PURPOSE TEST | Purpose of processing: Special Purpose 1 – Ensure security, prevent and detect fraud, and fix errors. | Purpose of processing: Special Purpose 2 – Deliver and present advertising and content. |
Company will subsequently process the data, collected through cookies and/or other tracking tools, only to:
Both Company and advertisers will benefit from the prevention and detection of frauds (as, by way of example, this processing will avoid advertisers to pay for ads that were not delivered to human nor clicked by human). Both Company and publishers will benefit from the fixing of errors encountered as this will increase the possibility of monetization of the publishers’ Properties without losing any valid traffic. Moreover, also the User will benefit from the processing at stake as Company will be able to ensure data is securely transmitted, as well as it will be able to correct any problems that the User encounters in the delivery of an ad or in his/her interaction with the ad. |
Company will subsequently use certain information (like an IP address), collected through cookies and/or other tracking tools, to ensure the technical compatibility of the advertising, and to facilitate the transmission of the ad to the User’s device. In particular, the said information will be used by Company in order to:
Both Company and the advertisers benefit from the processing activities at stake, as Company shall be able to deliver the ads as requested by the advertisers. At the same time, being able to deliver the ad to the Users will benefit the publishers as their intention is to monetize the advertising spaces available in the Properties. Finally, also the Users will benefit from this processing activity as Company will be able to provide a response to a request deriving from the Users’ devices (such as a click on an ad). |
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| NECESSITY TEST | The intended processing is necessary and proportionate for the purposes and interests explained above considering that Company is not allowed to use the data for any other data processing operation allowed under a different purpose of the TCF (such as improving its system). There are no less intrusive alternatives that use less, or no, personal data as the use of personal data is necessary in order to carry out the purpose specified. | The intended processing is necessary and proportionate for the purposes and interests explained above considering that Company is not allowed to use the data for any other data processing operation allowed under a different purpose of the TCF (such as logging personal data about the user to which an ad was delivered). There are no less intrusive alternatives that use less, or no, personal data as the use of personal data is necessary in order to carry out the purpose specified. |
| BALANCING TEST | Taking into account the nature and purposes of the processing, it is possible to affirm that risks for Users to their rights and freedoms are very low. In particular, among the others, Company evaluates the following aspects:
There are also other mitigating factors:
Even if Users cannot execute the “Right to Object” to these legitimate interests (because of the fact that the “Right to Object” to Special Purposes is not technically supported by the TCF), Users are always free to withdraw their consent to the “Purpose 1”, thus implying for Company the interruption of any collection of data carried out through the use of cookies and/or other tracking tools and any subsequent processing. |
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In conclusion, considering that (a) the TCF specifies two Special Purposes, that Company needs to fulfill in order to i) technically be able to serve ads over the network to an IP address, and ii) ensure security and fix errors; and (b) the only legal basis that is applicable to these Special Purposes under the TCF is the legitimate interest, Company is going to carried out the processing activities (“Special Purpose 1 – Ensure security, prevent and detect fraud, and fix errors” and “Special Purpose 2 – Deliver and present advertising and content” of the TCF) to achieve the above mentioned benefits for ourselves and others (such as Company’s advertisers and publishers), considering that there are no risks nor impacts on Users and Company believes its interests outweigh those interests of the Users.
For any information, to exercise your rights, or to obtain further information or explanations, User can consult the other paragraph of this policy or contact Company by using the modalities explained in this policy.
We use the data collected for:
Other tools (such as cookies, pixels, etc.) are installed on the Website of Origin by third parties other than the publisher of the Website of Origin and the Company.
Below is a list of the third parties currently used to provide the Services, with an indication of the links to the information pages created by their developers (also containing information on how to opt-out of installing them, and on the relevant retention periods):
| Third Party | Link to the privacy policy |
|---|---|
| Amazon | https://www.amazon.co.uk/gp/help/customer/display.html?nodeId=201909010 |
| Xandr | https://www.xandr.com/privacy/platform-privacy-policy/ |
Further partners of the Company
Through the Website of Origin, if you give your consent, additional partners of ours may process personal data in order to provide advertisement and/or make measurements on the advertisement already delivered. Please refer to the related policies: i) for which links are provided next to each vendor within the CMP; ii) for which links are provided within the policy of the Website of Origin; and/or iii) for which links are provided by the publishers that provide the advertising content that the User interacted with before landing on the Website of Origin, within their properties.
There are various options for managing, disabling and deleting cookies and/or to opt-out to the use of similar tracking tools.
As highlighted in the introduction of this privacy policy, the Company may collect and process some of your personal data through cookies and/or other tracking tools that it places directly on the Website of Origin. The Company acts as the “data controller” of these data, in accordance with the provisions of the Applicable Law. We will process the data collected only by electronic means, in a fully automated manner and without human intermediation. Therefore, our employees and partners will never access the content of the personal data obtained through cookies and/or other similar tracking tools, which means that they will never be able to access and/or have PII (Personally Identifiable Information), i.e. information which can identify you directly. Some of our employees and partners, authorised to process personal data pursuant to art. 29 of the Regulation, may carry out maintenance work on the computer systems that host the data, without ever being able to access its actual content. Personal data may be stored on servers managed by third parties (e.g. suppliers of computer systems) or may be managed by parties specializing in online advertising, who act as data processors on the basis of a written appointment by the Company, pursuant to art. 28 of the Regulation.
We inform you that, in compliance with the requirements and guarantees established by the Regulation, your data may be transferred to countries outside the European Economic Area (EEA). Such countries may not offer a level of privacy protection and protection of personal data comparable to the level guaranteed by the Applicable Law; where the Company acts as data controller, it will take the utmost care of the security of the data and will therefore manage such transfers with all the appropriate precautions and safeguards in accordance with the Applicable Law and, in particular, in accordance with articles 45 (Transfer on the basis of an adequacy decision) and 46 (Transfer subject to adequate safeguards) of the Regulation. Specifically:
Please note that some of the third parties indicated in paragraph 7 above – as independent data controllers – may process the personal data collected through the tracking tools installed on the Website of Origin from a location outside the European territory and, therefore, it is recommended that you read their privacy policies carefully for more details.
Moreover, we would like to point out the transfers carried out by Meta (more information here and here), and the transfers made by TikTok (more information here and here) with respect to the subsequent processing carried out by the latter as autonomous controllers after the initial collection as joint data controller with the Company.
Your personal data will not be communicated to third-party data controllers or disseminated.
Your personal data will be kept by the Company for the time considered strictly necessary to carry out the primary purposes described in this privacy policy, or as necessary for the protection in civil law of both your interests and those of the Company and, in any case, for no more than twenty-four (24) months. The User’s personal data collected on the Website of Origin, by means of Aryel’s proprietary tag tracking solution, are processed by the Company for the purpose of correct attribution of the delivery of the advertising only for the time strictly necessary and, in any case, for no longer than 24 hours.
To exercise your rights, or to obtain further information or explanations on this privacy policy, please contact the Company using the following methods:
You can also contact the Data Protection Officer (DPO) of the Company, whose contact details are as follows: email address dpo@aryel.io
Under the Applicable Law, Users have:
The Company is not responsible for the updating of all links that can be viewed in this privacy policy. Therefore, whenever a link is not functional and/or updated, Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to in these links.
