1. Personal Data
Personal data (also “Personally identifiable information”) includes individual information by which you as a natural person are or can be identified by, e.g. your name, address, telephone number, email address or date of birth, as well as information which does not reveal your name, but which relates to you or your device and enables you to be treated individually.
Non-personally identifiable data is information that cannot be connected to your real identity, e.g. the number of users visiting our website or other any other kind of aggregated information.
2. Collection of personal data and other information
2.1 When visiting the Attrace website www.attrace.com
The Attrace webservers temporarily log traffic data provided by the device you use to enter the Attrace website (including the host name (IP address) of the requesting computer), date, time and duration of your visit, data specifications of your browser and operating system as well as the name of your access provider, and the website you were referred from to the Attrace website (so called Referrer URL). This information is stored in a log file until it is automatically deleted in accordance with the retention policy.
The collection and processing of this data is carried out for the purposes of facilitating the use of the Attrace website (connection set-up), understanding how visitors use it and to ensure the security and stability of the Attrace systems as well as the technical administration of the network infrastructure.
Attrace does not record your name, address, telephone number or email address, unless voluntarily provided by you, e.g. as part of signing up with the Attrace ecosystem.
2.1.2 Analysis: Google Analytics
Attrace uses Google Analytics which is a web analysing tool for the purposes of the adequate design and continuous optimization of the Attrace website. Google Analytics works with cookies and creates pseudomonysed usage profiles, which enable an analysis of your use of our website. Information stored in such cookies (such as browser type/version, operating system used, referrer URL, Hostname of the accessing computer, time of server request) are usually transmitted to and stored on Google’s servers in the USA.
Due to the activation of the IP anonymization (IP masking), Google will truncate and therefore anonymize the IP address of your device within the European Union or the European Economic Area.
2.2 When you are joining Attrace or have joined already
2.2.1 Registration in the Attrace ecosystem
You need to register in the Attrace ecosystem in order to obtain access to the technologies and services. If you register in the Attrace ecosystem, all data, including personal data, which has been provided by you such as your name, address, telephone number or email address will be recorded. You can see from the online registration form which personal data in detail has been recorded. Attrace does not record any further personal data other than voluntarily provided by you.
We may also collect information on the device you are using to enter the Attrace User Interface pages such as your operating system and browser of your device.
Attrace uses all such data in order to comply with the agreements with Attrace users, or in the pursuit of the legitimate interest of fraud prevention and proper administration.
2.2.2 Google Analytics
Attrace will use Google Analytics which is a web analysing tool of Google Inc. on the Attrace main website and User Interface pages.
2.3 When using Attrace technologies and services via websites and online services of our clients
Tracking allows the ecosystem to understand which website referred a user to another website, so that the second website can acquire website traffic. Attrace measures the success of these referrals and assist the payment of commissions from the website receiving the traffic to the website referring that traffic.
Attrace stores cookies on devices of users who are visiting websites of the Publishers and Advertisers that are working with Attrace, in order to record business transactions (leads and sales such as signing up for a newsletter or placing an order in a web shop). The only purposes of the tracking cookies are to allocate one successful advertisement to a particular business transaction, and to perform corresponding payment services. Personally identifiable information on the user are neither collected nor processed nor used in tracking. Nothing but the information when and on which device a click on an advertisement occurred is stored in tracking cookies. We only store an individual sequence of figures that cannot reveal the name of a particular user and contains information on
- the Advertiser’s Partner Programme;
- the Publisher;
- the specific time of the user’s action (click or view); and
- type of device used by user.
While tracking Attrace may also collect information on the device that is used to perform a business transaction, such as the device’s operating system and browser.
This data is collected by Attrace and shared with Advertisers, Publishers and Consultants that are using the Attrace ecosystem. Most data will be anonymised or indexed where possible.
2.3.2 Third Party Cookies and Publishers
3. Processing and use of personal data
Attrace uses personal data provided by the Attrace users only for administration and providing the Attrace technologies and services, for responding to Attrace user enquiries and, where applicable, executing the agreement between a Attrace user and Attrace. Attrace stores personal and any other kind of data strictly in compliance with applicable data protection and privacy legislations and will prevent unauthorized access to data to the best of the Attrace abilities.
Provided you have given your consent or have not objected – where legal provisions allow so – Attrace may use your personal data for advertising and market research. By registering with the Attrace ecosystem you give your consent that Attrace may contact you via email in order to provide you with information on Attrace offers. Of course, you may withdraw your consent at any time.
We may transmit your data to the Attrace Consultant service providers, both in and out of the EU, but only if Attrace has contractually assigned these to process data on behalf of Attrace and, both Attrace and the Consultant service providers comply with all requirements of commissioned data processing regulations pursuant to the Dutch law on data protection. Data is stored within the European Union and the European Economic Area.
Attrace will not transmit data to other third parties unless you have given your consent thereto or the transmission is made to state institutions on the basis of mandatory national legislation.
4. Data security
Attrace takes all technical and organisational security measures required to protect your personal data from loss, unauthorised disclosure or other forms of misuse. Data is stored in a safe environment that is not open to public access. Your personal data may be encrypted before transmission in certain cases (e.g. processing your login data). This means that – support by your browser provided – communication between your device and our servers will include recognized encryption measures.
The Attrace IT team has been trained in privacy matters and in dealing with data and information, which they gain access to in a responsible manner.
5. Individual Rights, Access, rectification, deletion and blockage
You have the right of access to your personal data at any time and may request rectification or erasure of your data.
In case you registered on the Attrace website, you may use your client account to exercise these rights.
While observing applicable privacy legislation we will erase your data without any action required by you, if retention of your data is no longer necessary for the purpose pursued or retention is no longer allowed for any legal reason. Attrace may restrict processing instead of erasing your data where legally not allowed to erase (e.g. legal obligations to maintain your personal data).
7. Questions / Contact