Privacy Policy

1. About this privacy policy

Effective date: February 1, 2020

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’ 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’ data practices relating to information C WIRE collects through its website www.cwire.ch, and not only pertains to C WIRE’ Services. Your use of the Services is also governed by the Terms of Use.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 3 methods to identify users depending on the device they use, whether they access our Services on web or mobile, and operating system:

  • Cookie-based identification

C WIRE drops a cookie on the user browser. Cookies are alphanumeric identifiers that are created on your device through your web browser for record-keeping purposes. Cookies are used to identify a user and store a randomly generated identifier to identify his or her browser across visits.

  • Cookie-less identification

For browsers setup to not allow cookies to be dropped, C WIRE uses an identification methodology based on IP address non-reversible encryption, browser, and device characteristics. This method allows C WIRE to identify a user in order to provide the same level of services, such as reporting and targeting information to users, segmenting users, and capping the number of times the same ad is shown to the same user.

  • 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, or through our SDK within publisher mobile apps. We also automatically collect the information listed below about your use of our Services through tracking technologies such as cookies, pixel tags, beacons, and embedded scripts. These tools help us collect and measure session information, time spent on certain pages, and page interaction information.

3. Automatically Collected Information

  • Identifiers: IP address, 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
  • Geolocation Information:
  • Non-Precise Geolocation data: 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.
  • Precise Geolocation data: On mobile apps, when a user opts-in for Geo Location on the publisher’s app, precise user geolocation (latitude / longitude) might be transferred to C WIRE’ SDK by the mobile app, but this data is not stored by C WIRE.

3. 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 part of the user profile to buyers 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.

  • Viewability measurement. We transmit data to companies specialized in campaign measurement such as MOAT or IAS in order to verify that our ads are viewable.
  • Fraud detection. We transmit data to companies such as DoubleVerify in order to prevent delivering our ads on fraudulent traffic, such as non-human traffic.
  • Geo-location. We transmit the IP address of the user to companies such as digital elements which provide non-precise geo-location services.
  • Analytics and Audience measurement. We transmit data to companies such as Nielsen or ComScore in order to validate the accuracy of our targeting or measure the demographic reach of our network.
  • 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:

  • We need to use your personal 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 have a legitimate interest in processing your personal data.  For example, we may process your personal data to send you marketing communications, to communicate with you about changes to our products and Services, and to provide, secure, and improve our products and Services.
  • We find such processing is necessary 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 cookie is kept up to 365 days after the last user interaction with our services.
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 of Use, 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 throughout the United States, Europe, Latin America, and Asia. Therefore, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.

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.

CONTACT US

For any questions about this privacy policy or our data practices, you can contact C WIRE:

  • By email: info@cwire.ch
  • By mail: C WIRE AG, Militärstrasse 90, 8004 Zürich, Switzerland