Doceree UK Ltd respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

This privacy policy aims to give you information on how Doceree collects and processes your personal data and how we obtain it. We generally do not collect information about individuals through our website , but we do collect other online and offline information about individuals’ interests and habits through web tracking technologies, and from our other business partners like data providers, ad exchanges, and mobile app attribution companies (our “Ad Partners”). We use that information to create audience segments that we make available to our Clients to enable them to deliver targeted, interest-based advertising and to conduct analytics and research. The Doceree Service delivers the targeted advertising messages to individuals on computers, mobile phones and similar devices and enables us to report back to our Clients about the effectiveness of their advertising campaigns.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

1. Controller

Doceree is made up of different legal entities, details of which can be found here: [LINK]. This privacy policy is issued on behalf of the Doceree Group so when we mention "Doceree", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Doceree Group responsible for processing your data. Doceree UK Ltd is the controller and responsible for this website.

We have appointed a [data protection officer (DPO) OR data privacy manager] who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise [your legal rights], please contact the [DPO OR data privacy manager] using the details set out below.

2. Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our [DPO OR data privacy manager] in the following ways:

Full name of legal entity: Doceree UK Limited

Email address: privacy@doceree.com

Postal address: Henry Wood House, 2 Riding House Street, London, W1W 7F

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

3. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. [This version was last updated on October 28th 2021. [Historic versions can be obtained by contacting us].] It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

4. Third-party links

This 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 policy of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].

Contact Data includes [billing address, delivery address, email address and telephone numbers].

Financial Data includes [bank account and payment card details].

Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us].

Technical Data includes [internet protocol (IP) address, your login data, 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 this website].

Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].

Usage Data includes [information about how you use our website, products and services].

Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

5. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

6. How is your personal data collected?

We use different methods to collect data from and about you including through:

7. Cookies and Other Web Technologies

In operating the Doceree Service and Site, we use a technology called “cookies,” which are small text files that our Site places on a device through the browser when our Site is accessed or that some of our Clients and Ad Partners place on a device when it engages with them. Our cookies collect and store audience segments, help provide additional functionality to the Doceree Service and Site and help us analyze usage more accurately.

Although most web browsers automatically accept cookies, many browsers’ settings can be set to decline cookies or alert a user when a website is attempting to place a cookie on their computer. However, some of our services may not function properly if cookies are disabled.

We also use an advertising identifier created by mobile operating systems to store information on our servers and later retrieve it to provide the Doceree Service. The Android Advertising ID and Apple iOS’ IDFA are examples of advertising identifiers. For more information about advertising identifiers, please check the settings of the mobile device.

New technologies that perform similar functions to cookies or user tracking may be developed. We will update this Policy to let you know of any changes to the technologies used by the Doceree Service and Site.

8. Log Data

We receive information when an individual views content on or otherwise interacts with our Services, which we refer to as “Log Data.” For example, when an individual visits our website or the websites of our Clients, signs into our services, or interacts with our email notices, we may receive information about that individual. Log Data includes information such as IP address, browser type, operating system, the referring web page, pages visited, location, mobile carrier, device information (including device and application IDs), search terms, and cookie information. We only use the available Log Data to operate our Services and optimize the performance of our Services.

9. Information from Third Parties

Our Clients, Ad Partners, Data Partners, Affiliates, and other products integrated with the Doceree service (“Third Parties”) share information with us such as browser cookie IDs, mobile device IDs, IP address, device type, operating system, hashed email address, or hashed mobile ID (e.g., Apple IDFA or Android advertising ID), as well as location-based data such as Wi-Fi, cell tower, GPS or diagnostic location information, contextual information, and demographic information including age, gender and pin code. Information we obtain from these Third Parties about an individual may be appended to information that we otherwise have for the purposes of targeting advertisements. For example, we match hashed versions of mobile IDs to data that we have de-identified (made pseudonymous) about an individual that resides in our platform in order to target advertising to such individual based on their device activity, inferred interests and location information.

In the process of serving an advertisement to a device, we, or our partners, may decide to serve an ad based on one or more audience segments associated with that device, and the audience segment we believe may be associated with that device. Where Doceree is able to use this and other information to infer that one browser or device likely belongs to the same User or household, the Doceree Service may consider those browsers and devices “linked” for purposes of ad serving and interest-based advertising. This linking process is sometimes referred to as creating a device graph.

Third Parties may collect information about an individual’s activities, subject to their own terms and privacy policies. Those companies’ use of cookies and other data collection technologies are subject to their own privacy policies, and the terms of this Policy do not apply, therefore we are not liable/responsible for their policies or activities. Like many companies, we may allow cookie matching with select Third Parties, but those parties are not authorized to access Doceree cookies under any circumstance whatsoever. We only share pseudonymous information with such Third Parties that does not include an individual’s name, email address, or contact information and we strictly require them to follow privacy and data security principles and practices that are substantially similar to ours.

10. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: We use the information to create audience segments that we make available to our Clients to enable them to deliver targeted, interest-based advertising and to conduct analytics and research. The Doceree Service delivers the targeted advertising messages to individuals on computers, mobile phones and similar devices and enables us to report back to our Clients about the effectiveness of their advertising campaigns. The legal basis for processing such data in jurisdictions to which the GDPR applies is, in cases where you have given your consent, that consent, and otherwise Article 6 1. (f) of the GDPR (“legitimate interest”).

Legitimate Interest means the interest of our business in conducting and managing our business and to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

11. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

12. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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

13. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to request correction of your personal data; request erasure of your personal data; object to processing of your personal data; request restriction of processing your personal data; request transfer of your personal data; or withdraw consent to the processing of your personal data where you have previously given consent; please contact us {{here – link or email address}}

14. No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

15. What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

16. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.