Privacy Policy for Consumer Complaints Plug-in

1. Scope of this Privacy Policy

This Privacy Policy applies with respect to the protection of your privacy and your data collected and processed (“Data”), during your use of the Consumer Complaints Plug-in (“CC Plug-in”), by the national Self-Regulatory Organisation, which is identified, on the basis of your geographical location, as exclusively competent for handling your complaints (“SRO” or “we” or “us”). In order to determine the local SRO, which is competent for you, you should consult the list of the national Self-Regulatory Organisations available here.
CC Plug-in is a software application provided to you by the European Interactive Digital Advertising Alliance, a non-profit association (AiSBL) with registered office at Rue des Deux Eglises 26, 1000 Brussels, Belgium, company number BE 0846.790.105(“EDAA”), acting as processor for us with respect to collecting and processing Data with the CC Plug-in. The terms of use for CC Plug-in are available here.
Your local SRO is the Data controller. Consequently SRO undertakes to comply with the applicable legislation regarding the protection of privacy concerning the processing of personal data. When required by applicable legislation these processing operations have been declared to the relevant local data protection supervisory authority.

2. Data collected

The Data collected and further processed by us are those that you voluntarily provide to us through the complaint form available through CC Plug-in (the « Complaint Form ») and include at a minimum, your name, you age, your location and a valid e-mail address. Depending on the country where you are located some other information may be mandatory required in order to file a complaint with the competent SRO. CC Plug-in also records your answers to specific questions.

When you use CC Plug-in, some Data are collected automatically notably technical data (such as the IP address and operating system of your computer and your browser details) and information relating to the web pages and the advertisements you are reporting to us (such as the URL and print screen of the website, cookies of ad serving platforms, timestamp of the screen capture).

3. Purpose of the Data processing

The Data, identified as mandatory in the Complaint Form, are required in order for us to handle your complaint.

The non-mandatory Data provided by you or the ones automatically collected by CC Plug-in will enable us, in an dissociated manner, and without using any of your personal data, (i) to personalize and improve your use of CC Plug-in and the services of SRO and (ii) to analyse and create statistics regarding your use of CC Plug-in and the services of SRO.

The Data will also enable SRO to send follow-up information on the complaint to the e-mail address you have provided in the Complaint Form.

The Data are also kept for security reasons, in order to comply with SRO’s legal and regulatory obligations.

4. Data recipients

The SROs and EDAA are the primary recipients of your data and the only ones processing your Data.

Your Data may be shared with the company and/or physical person that is the subject of your complaint as per the rules applicable by the SRO for handling your complaint.

Your Data may also be shared with the European Advertising Standards Alliance (“EASA”), a non-profit association (AiSBL) with registered office at Rue des Deux Eglises 26, 1000 Brussels, Belgium, company number BE 0450.933.006. Under such circumstances EASA is acting as a coordinator between the SROs and, under such coordination role, your Data may be shared with EASA for the purpose of transmitting information to the relevant SROs when the handling of your complaint involves several SROs.

Except for what is aforementioned your Data will not be shared with other third parties without your express and informed consent.
However, you are hereby informed that they may be disclosed pursuant to a law, a regulation, or a decision by a regulatory or competent legal authority.

5. Transfer of Data

As part of the processing of your Data, they may be transferred by SRO to servers located in several countries.

You are hereby informed that your Data may be transferred in a country other than your country of residence and notably outside of the European Union, in which case we ensure that (i) such transfer is based on a legally enforceable mechanism and to a country that ensures an adequate level of protection for your Data as defined in your national data protection requirements and (ii) such transfer is for the same purpose than the one for which your Data were initially collected and processed.

6. Data security

SRO attaches great importance to the security of your Data and takes all appropriate (including but not limited to data transfer in a secure manner using SSL) steps to minimise the risks of loss, deterioration or incorrect use of this data, pursuant to applicable Data Protection Regulations.

7. Data storage

The Data are stored with Microsoft Azure cloud-computing platform and will be stored for the duration of time strictly necessary to fulfil the aforementioned purposes. After this time period, they will be stored in a dissociated manner for statistical purposes only and will not be used in any other way.

8. Your rights

You have the right to object to the processing , access to, rectification or erasure of personal data as well as the right to Data portability by written request to EDAA’s postal address or the following email address: [EMAIL].

You also have the right to lodge a complaint with your local data protection supervisory authority.
For more information and/or for exercising your rights please contact us at the address mentioned in the list of the national Self-Regulatory Organisations available here .

9. Changes

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.