1. About this privacy Policy

C WIRE AG (“C Wire”, “we”, “us”, or “our”) recognizes the importance of privacy and is committed to providing transparency over the use of the data in online advertising. This privacy policy details C Wire’s data practices on how we collect, use, process and share the data we may collect through our advertising services (collectively, the “Services”) as well as the ways in which individuals may exercise control over the use of information collected by us. This privacy policy also describes C Wire’s data practices relating to information C Wire collects through its website www.cwire.com, and not only pertains to C Wire’s Services. Your use of the Services is also governed by the Terms & Conditions. As used herein, “personal data” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular C Wire customer or consumer or his or her household. Please note that we may update or change this privacy policy. If we make any material changes we will notify you by means of a notice on our website prior to the change becoming effective.

2. User Identification

We do not collect or process information related to (i) name, user address, place of work, date of birth, email address, or phone number, (ii) hardware-based identifiers such as UDID or MAC Address or (iii) sensitive targeting categories as defined by the European Interactive Digital Advertising Alliance (EDAA) in the European Economic Area (EEA) and under other applicable law (e.g. religion, political opinion, health).In order to deliver ads, C Wire uses the following 2 methods to identify users depending on the device they use, whether they access our Services on web or mobile, and operating system:

• Cookieless indentification
  C Wire uses a randomly generated string stored in the LocalStorage of the user's browser. This means that the ID will be different for every domain that the user visits. This method allows C Wire to identify a user in order to limit the number of times the same ad is shown to the same user. Predictive models may be applied to improve cross-domain frequency capping but no data or ID is matched across domains. C Wire might process and transmit identifiers already available within the browser but will not store nor match those identifiers together.
• Mobile Applications identification
  C Wire uses its software development kit (“SDK”) technology to identify your advertising ID for mobile applications. For Google Android operating system, we use the Google Advertising ID and for Apple iOS the IDFA.

We do not collect information about you directly, but we collect data through our web tags on publisher web pages, our prebid adapter, or through our SDK within publisher mobile apps. We also automatically collect the information listed below about your use of our Services. These tools help us collect and measure session information, time spent on certain pages, and page interaction information.

3. Automatically Collected Information

• Identifiers: randomised cw_id or cwid(C Wire ID), advertising ID for Apps.
  
• Internet or other electronic network activity information: Page URL, Browser Information (e.g. Browser name and version), Device Information (e.g. Device type, OS), Network carrier information (e.g. Wifi, 4G or Wired connection), Mobile application information (e.g. Application name or IDFA), User Interactions with C Wire Ad Formats or Ads delivered by our Demand Partners.
  
• Non-Prcise Geolocation Information:
  On web and web mobile, we collect non-precise location information at the country and/or city level that are derived from user IP Address.
• Privacy choices:
  users’ signals or part of it as defined by the Policies or Specifications sent by a CMP, usually on behalf of a Publisher, to C Wire that includes, amongst others, information about the transparency, consent, and/or objection status of a C Wire and/or Purpose, the opt-in status of a Special Feature, and Publisher restrictions.

4. Data use

We use the information we collect for various business and commercial purposes, including those described below:

• User frequency Capping: We use data to prevent displaying the same ad to the same user too many times;
  
• Analyzing traffic and user interactions: We use data for monitoring and reporting the campaign delivery for advertisers and publishers and for internal business analysis;
• Delivering ads: We may transmit identifiers to 3rd party technologies so that they can deliver their advertising campaigns;
  
• Providing, maintaining, and improving our Services: We use data to improve our Services and technology, including training our ad delivery algorithms;
  
• Providing customer service: We may use data to resolve disputes, feedback, or other issues related to our Services;
  
• Debugging, identifying, and repairing errors: We may use data to fix issues that impair the functionality of our Services;
  
• Protecting the rights and property of C Wire and Complying with Law: We may use data to protect our rights and property and comply with our legal obligations, including to detect, investigate, and prevent fraud and other illegal activities and to enforce our agreements; and
  
• Insights: We may use the data to deliver aggregated insights, at advertising campaign or market levels.

DATA DISCLOSURE

Data shared with Third Parties.

In order to provide the Services, we need to share data (including personal information) with third party vendors, service providers, contractors or agents who perform functions on our behalf, including the ones listed below. Our service providers are authorized to use the information we provide only as necessary to provide these services to us.

• Geo-location. We may transmit the IP address of the user to companies such as digiseg which provide non-precise geo-location services. These providers have no technical capability to identify the user online.
• Affiliates. We may disclose the information we collect through the Services to our affiliates or subsidiaries for the purposes described in this privacy policy; however, if we do so, their use and disclosure of your personal information will be subject to this privacy policy.
• Hosting. We utilize third party hosting and data-center providers to store data.

Other Disclosures

We also may disclose information in the following circumstances.

• Business Transfers. If we are or may be acquired by or merged with another company, if any of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
• In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal processes, such as in response to a court order or a subpoena.
• To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which C Wire is involved.

Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.

ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

If you are located in the European Economic Area or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data.

Legal Basis for Processing

When we process your personal data, we will do so, e.g., in the following situations:

Consent:

• We may store and/or access information on a user's device only with the user's consent

Legitimate interest when possible:

• We may present advertisments to users with the use of limited data, such as the website or app you are using, the user’s non-precise location, the user’s device type or which content the user is (or have been) interacting with (for example, to limit the number of times an ad is presented to the user).
• We may collect information regarding which advertising is presented to a user and how he interacts with it in order to determine how well an advert has performed for a user or other users and whether the goals of the advertisment were achieved. For instance, whether the user saw an ad, whether he clicked on it, whether it led him to buy a product or visit a website, etc. This is very helpful to understand the relevance of advertising campaigns.
• We may collection information about the user’s activity, such as his interaction with ads or content, in order to improve products and services and to build new products and services based on user interactions, the type of audience, etc. This does not include the development or improvement of user profiles and identifiers.
• We may collect user’s data in order to monitor and prevent unusual and possibly fraudulent activity (for example, regarding advertising, ad clicks by bots), and ensure systems and processes work properly and securely. It can also be used to correct any problems the user, the publisher or the advertiser may encounter in the delivery of content and ads and in the user’s interaction with them.
• We may collect certain information (like an IP address or device capabilities) in order to ensure the technical compatibility of the content or advertising, and to facilitate the transmission of the content or ad to the user’s device.
• We may use user's data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the products or services you have requested).
  
• We may use user's data to comply with our legal obligations.

Data Subject Requests

You have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us as indicated below.

DATA RETENTION AND SECURITY

We retain the data linked to a user up to 12 months from the date of collection.

We may also store aggregated and non-personal data for a longer period than 12 months for financial and statistical reasons.

C Wire uses generally accepted industry security standards to protect data. Your personal information will be retained in accordance with our data retention policy which is designed to retain data for as long as needed for us to comply with our contractual obligations, employment obligations, and other business purposes, including global legal obligations to retain data.

We may retain some information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze or troubleshoot programs, enforce our Terms and Conditions, or take other actions permitted by law.

We have implemented reasonable security measures to protect the information we collect from unauthorized access, exfiltration, theft, loss, misuse, disclosure, alteration, or destruction. Please be aware that despite our best efforts, no data security measures can guarantee security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES

C Wire is based in Switzerland and we process and store information in Europe or Switzerland. Therefore, we and our service providers do not transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. The data might occasionally be accessed from different locations with the use of VPNs.

PRIVACY POLICIES OF THIRD PARTIES

This privacy policy only addresses the use and disclosure of information and data by C Wire. Publishers, advertisers and other websites that may be accessible through our Services have their own privacy policies and practices that govern the collection, use, and disclosure of your personal information when you interact with their services and use their products. We encourage you to familiarize yourself with the privacy policies provided by all third parties prior to giving them information or taking advantage of an offer or promotion.

CHILDREN’S PRIVACY

Our Services are not directed to children under the age of sixteen (16) in the United States or children under the age of legal majority in jurisdictions outside the United States, nor do we market products or services to such children.

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Contact us

For any questions about this privacy policy or our data practices, you can contact C Wire:
By email: dpo@cwire.com‍

By mail: C Wire AG, Militärstrasse 90, 8004 Zürich, Switzerland