Who Targets Me Privacy Policy

Introduction

We are committed to protecting and respecting your privacy.

Everyone has rights with regard to the way in which their personal information is handled. During the course of our activities we will collect, store and process personal information about our customers, suppliers and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will allow us to operate successfully.

This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.

For the purpose of UK data protection laws, the data controller is Who Targets Me Ltd. of 149a Kirkwood Road, London, SE15 2BG (collectively referred to as “we”, “us” and “our” in this policy).

Data protection principles

When processing your information, we must comply with the six enforceable principles of good practice. These provide that your personal information must be:

  • processed lawfully, fairly and in a transparent manner,
  • processed for specified, explicit and legitimate purposes,
  • adequate, relevant and limited to what is necessary,
  • accurate and kept up-to-date,
  • kept for no longer than is necessary, and
  • processed in a manner than ensures appropriate security.

Information you give to us

We may collect, use, store and transfer different kinds of personal information about you, including:

  • Identity and Contact Data: such as your name, email address, gender, your age and your location (limited to postcode, zip code or county)
  • Profile Data: such as your Who Targets Me User ID, your stated political affinity and a record of advertisements that you see on Facebook
  • Technical Data: such as IP addresses, browser type and version, time-zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our browser extension or website

‘Special category’ data

Information relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, criminal convictions, sex life or sexual orientation, or certain types of genetic or biometric data is known as ‘special category’ data.

During the course of dealing with you, we would expect to collect and use information relating to your stated political opinions. This is most likely to occur, for example, if you install our browser extension for Chrome or Firefox and create a Who Targets Me user profile. We use this information to perform the service requested, namely to assess the political advertisements you receive via Facebook. Other than political opinions, we do not expect to collect any other form of ‘special category’ data.

How we collect your personal information

We may obtain personal information by directly interacting with you, such as:

  • creating a profile in our browser extension,
  • subscribing to our email newsletter,
  • corresponding with us by phone, email, letters or otherwise.

We may obtain personal information via automated technology when you interact with our website or app by using cookies, server logs and other similar technologies.

How we use your personal information

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  • you have given us consent,
  • we need to perform a contract we are about to enter into, or have entered into, with you,
  • where it is necessary for our or a third party’s legitimate interests, and your interests and rights do not override those interests, or
  • where we need to comply with a legal or regulatory obligation.

We will only use ‘special category’ information:

  • provided we have your explicit consent to use it,
  • where you have previously made that data public knowledge, or
  • if we need to use that data to establish, exercise or defence legal claims.

Purposes for which we will use your personal information

We may use your personal information for a number of different purposes. For each purpose, we are required to confirm the ‘legal basis’ that allows us to use your information, as follows:

Information Purposes for which we will use the information you give to us Legal basis
Voluntary anonymous profile (age, location, gender, self-defined political leaning) and ads in your Facebook newsfeed To register you as a new user of our services and to deliver the services It will be necessary for the performance of the contract between you and us
Voluntary anonymous profile (age, location, gender, self-defined political leaning), ads in your Facebook newsfeed, anonymised data provided by Google Analytics and WordPress To administer our website and app, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to allow you to participate in interactive features of our service, when you choose to do so, and to make suggestions and recommendations to you and other users of our website and app about services that may interest you or them It will be necessary for our legitimate business interests to ensure you receive the best experience possible when accessing and using our website and app.

Where our processing includes special category data, we will only do this if you give us your consent.

Contact information you choose to provide (email, social media accounts, phone number) To provide you with information about new campaigns and other services we provide that are similar to those that you have already received from us Where you have previously received marketing communications from us, then it will be necessary for our legitimate business interests, namely to ensure you continue to receive communications that you have previously agreed to receive

In all other cases, we will only do this if you give us your consent

We will only use your personal information for the purpose(s) for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

What if you cannot or will not provide us with your personal information

It is a requirement for you to provide us with certain information. If you do not provide us with that information, we will be unable to set up your profile and deliver the services in the web browser extension to you.

Cookie policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie and Purpose More information
Google Analytics for website performance analysis purposes. Google Analytics is a simple, easy-to-use tool that helps us measure how users interact with our website content. As a user navigates between web pages, Google Analytics provides us with JavaScript tags (libraries) to record information about the page a user has seen, for example the URL of the page. The Google Analytics JavaScript libraries use HTTP Cookies to “remember” what a user has done on previous pages / interactions with our website. Further information can be found on Google’s website.
WordPress login cookie for site administrators WordPress is a common open-source content management system (CMS) and these cookies are for information and site management purposes only, and contain no personal information.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Except for essential cookies, all cookies will expire after 6 months.

Disclosure of your information

We may share your personal information with the parties set out below:

  • providers of IT and system administration services to our business including Amazon Web Services (AWS, who host our services) and Google (GSuite business tools, for data analysis purposes),
  • our professional advisers (including solicitors, bankers, auditors and insurers),
  • HM Revenue & Customs, the Information Commissioner’s Office, regulators and other authorities who require reporting of processing activities in certain circumstances,
  • analytics and search engine providers that assist us in the improvement and optimisation of our website, and
  • third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this policy.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

Where we store your personal information

All information you provide to us is stored on our secure servers in Germany.

We will take all steps reasonably necessary to ensure that your data is treated securely, including taking the following safeguards:

  • Firewalls and Encryption. We use commercially-available and up-to-date firewall and encryption technology.
  • Equipment. Our internal policies require that individual monitors do not show confidential information to passers-by and that users lock or log-off from their computer when it is unattended.
  • Password Protection. We employ password protection to protect sensitive data.
  • Training. We ensure our employees are trained in the importance of data security.
  • Overseas transfers. Whenever we transfer your personal information outside the United Kingdom, we ensure a similar degree of protection is afforded to it by ensuring that we apply appropriate safeguards (either by transferring data only to recipients in the European Union, to recipients in countries approved by the European Commission, to recipients that are party to the EU-US Privacy Shield, or by using specific contracts approved by the European Commission).

If you are concerned about the levels of data security in any of those countries, please let us know and we will endeavour to advise what steps will be taken to protect your data when stored overseas.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

How long we will store your personal information

The length of time that we will store your data will depend on the ‘legal basis’ for why we are using that data, as follows:

Legal basis Length of time
Where we use/store your data because it is necessary for the performance of the contract between you and us We will use/store your data for as long as it is necessary for the performance of the contract between you and us
Where we use/store your data because it is necessary for us to comply with a legal obligation to which we are subject We will use/store your data for as long as it is necessary for us to comply with our legal obligations
Where we use/store your data because it is necessary for our legitimate business interests We will use/store your data until you ask us to stop. However, if we can demonstrate the reason why we are using/storing your data overrides your interests, rights and freedoms, then we will continue to use and store your data for as long as it is necessary for the performance of the contract between you and us (or, if earlier, we no longer have a legitimate interest in using/storing your data).

We may retain your data indefinitely for research and analysis purposes where we are able to anonymise the data.

Where we use/store your data because you have given us your specific, informed and unambiguous consent We will use/store your data until you ask us to stop

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitive of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your rights

You have various legal rights in relation to the information you give us, or which we collect about you, as follows:

  • You have a right to access the information we hold about you free-of-charge, together with various information about why and how we are using your information, to whom we may have disclosed that information, from where we originally obtained the information and for how long we will use your information.
  • You have the right to ask us to rectify any information we hold about you that is inaccurate or incomplete.
  • You have the right to ask us to erase the information we hold about you (the ‘right to be forgotten’). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we are unable to do so, we will explain why not.
  • You have the right to ask us to stop using your information where: (i) the information we hold about you is inaccurate; (ii) we are unlawfully using your information; (iii) we no longer need to use the information; or (iv) we do not have a legitimate reason to use the information. Please note that we may continue to store your information, or use your information for the purpose of legal proceedings or for protecting the rights of any other person.
  • You have the right to ask us to transmit the information we hold about you to another person or company in a structured, commonly-used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.
  • Where we use/store your information because it is necessary for our legitimate business interests, you have the right to object to us using/storing your information. We will stop using/storing your information unless we can demonstrate why we believe we have a legitimate business interest which overrides your interests, rights and freedoms.
  • Where we use/store your data because you have given us your specific, informed and unambiguous consent, you have the right to withdraw your consent at any time.
  • You have the right to object to us using/storing your information for direct marketing purposes.

If you wish to exercise any of your legal rights, please contact us by writing to the address at the top of this policy, or by emailing us at privacy@whotargets.me.

You also have the right, at any time, to lodge a complaint with the Information Commissioner’s Office if you believe we are not complying with the laws and regulations relating to the use/storage of the information you give us, or that we collect about you.

Opting out of receiving marketing communications

You can ask us to stop sending you marketing communications at any time by contacting us by writing to the address at the top of this policy, or by emailing us at privacy@whotargets.me.

Automated decision-making

We do not use automated decision-making processes.

Third party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Changes to our policy

Any changes we make to our policy in the future will be posted on our website and, where appropriate, notified to you by email or via social media. Please check our website frequently to see any updates or changes to our policy.

Contact

Questions, comments and requests regarding this policy are welcomed and should be addressed to us by writing to the address at the top of this policy, or by emailing us at privacy@whotargets.me.