The purpose of this privacy policy is to provide You with all the information on the processing of your data carried out by Tangoo S.r.l. in the context of its services

 

UPDATED: February 27, 2024

(previous version updated March 09, 2022)

 

1. INTRODUCTION – WHO ARE WE?

The company Tangoo S.r.l., with registered office in Via Lentasio n.9, 20122 Milan, Italy (hereinafter, “We“/“Us” or “Tangoo“) hereinafter provides the data subjects (hereinafter, “You” or the “User“) with its privacy policy (hereinafter, the “Privacy Policy“) pursuant to Italian Legislative Decree No. 196/2003, as amended by Italian Legislative Decree No. 101/2018 (hereinafter, the “Privacy Code“) and pursuant to Article 13 of EU Regulation 2016/679 of 27 April 2016 (hereinafter, the “Regulation“; the Regulation and the Privacy Code are together referred to as the “Applicable Law“).  

 

Through our services, We collect and process some of your personal data: with this Privacy Policy, We explain how We collect the abovementioned data, for what purposes and what your rights are.  

 

2. HOW TO CONTACT US?

You may contact Tangoo at any time, using the following methods:

 

• by sending a registered letter with return receipt to the registered office of Tangoo (Via Lentasio n.9, 20122 Milan – Italy)
• by sending an email to the address privacy@tangoomedia.com

 

Tangoo has not identified a Data Protection Officer (RPD or DPO), as it is not subject to the obligation of designation provided for by Article 37 of the Regulation.

 

In order to exercise your rights, please find all the information in Article 11 below.

 

3. WHAT DO WE DO? – COMPLIANCE

We are an advertising technology company that provides programmatic advertising services to advertisers (hereinafter, “Media Advertising Activities” and “Advertisers”).

 

If the User comes from a website (hereinafter the “Website“), Tangoo plays a third-party role with regard to the publishers of the Website or App that the User comes from (hereinafter the “Publishers“) and, in the event of the (optional) consent of the User, Tangoo may collect certain personal data via the Website. 

 

Within the context of the Media Advertising Activities, in particular, Tangoo performs the following activities: when You visit an Advertiser’s website or app (for example, an e-shop), We collect information about your activity there, such as which items You viewed, added to your basket, and purchased. These browsing patterns on the Advertiser’s website or app help us understand what kinds of products and services You are currently interested in and therefore display to You only ads compatible with these interests on publishers’ digital properties.

 

We use a programmatic instantaneous auction system known as real-time bidding to display our personalized ads (RTB). The real-time bidding procedure begins when You visit a Publisher’s website or app that sells advertising space. While such a website is loading, the Publisher or a business partner working with the Publisher (e.g., supply-side platform, SSP) sends us a bid request inviting us to purchase a specific ad space. Following the receipt of such a bid request, our technology uses information about your previous browsing activity on advertisers’ websites or apps to determine whether to purchase the auctioned ad space and, if so, which ad to display.

 

In compliance with applicable laws and regulations governing data privacy and advertising practices, our services utilize various sources of ad traffic, predominantly relying on exchanges such as Index Exchange and Google Ad Exchange for supplier-side traffic. As a Google Authorized Buyer, our practices align with the privacy policies outlined by Google, and users are encouraged to refer to the policies detailed at the following link for further information: https://policies.google.com/privacy.

 

To show its commitment to the User, Tangoo is a member of the IAB Europe Transparency & Consent Framework (hereinafter, “IAB Framework“) – the European framework for transparency and consent management – and complies with the Specifications and Policies of the IAB Framework. The Vendor ID of Tangoo within the IAB Framework is 962. Users can find additional information on the IAB Framework on the IAB Europe website (https://iabeurope.eu/transparency-consent-framework/).

4. WHAT DATA DO WE PROCESS?

Tangoo, by choice, only processes “pseudonymised” data (i.e. data that will never allow Us to identify You) or personal data that is then pseudonymised after collection and never geolocates User in real time. We do not receive any additional data from advertisers or partners that, when combined with the data collected by our technology, would allow Us to identify You directly.

 

Please note that Tangoo does not collect any data through the Publishers’ Websites unless You have given your consent.

 

Tangoo uses profiling cookies to collect data that may store: 

a) Information about your browsing activity on advertisers’ websites or apps — this helps Us understand what kinds of products and services You are interested in and, as a result, which ads should be displayed to You to match your current shopping interests.

b) Information that You are currently entering a Publisher’s website or app, where We may display an ad to You — this information is contained within a bid request, which is an offer to purchase advertising space on the Publisher’s website or app in order to display an ad. 

c) Information about the delivery of our advertisements, such as ad impressions and your interactions with an ad. 

 

Cookies are small text files that are sent by Websites visited by the User directly to his/her terminal (usually to the browser), where they are stored and then sent back to the same websites the next time they are visited by the same User. Some of them are used to trace your consumer profile and to display advertisements on the Website that may be of interest to You, as they are consistent with your tastes and consumer habits (so-called “profiling cookies”).

 

Our profiling cookies are installed directly by Tangoo when You visit the Websites. These cookies are permanent and have a maximum duration of 12 months. Below is a list of the profiling cookies We use:

 

Name of the Cookie	Type and Purpose of Cookie	Duration
xxx_productnew	Tracks if the user has shown interest in specific products. Used for Optimize dynamic banners based on interest based	60 days
xxx_viewnew	Banner impression based tracking system. Used to track how many impressions were served and optimize ads based on it	60 days
xxx_conversionnew	Store Click id on clicking on the advertiser’s ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user	60 days
adc_opt_out	To notify our system that user have selected against showing advertisement and prevent ads. This cookie is necessary for GDPR-compliance of the website.	12 months
fingerprint	Unique User identifier. Registers a unique ID that identifies a returning user’s device. The ID is used for targeted ads	12 months
xxx_pagetracks	Collects data on user behavior and interaction in website to optimize the website and make advertisement on the website more relevant	60 days

 

The following data is collected through cookies:

• Cookies – a random identification ID saved on your browser; 
• IP of the Device used while connected to the internet;
• URL of the web page visited;
• A session identification number.

5. LEGAL BASIS

The legal basis for the processing carried out for Media Advertising Activities is the prior consent of the User (art. 6, paragraph 1, letter a) of the Regulation).

 

We will only collect your data via Websites after You have given your consent to the processing of your data via cookies. For this reason – when You visit a Website – the Publisher of the Website asks for your permission to use profiling cookies, also on behalf of third parties, such as Tangoo.

6. PURPOSES OF THE PROCESSING

We process your data:

• for marketing and profiling purposes (i.e. to show You advertisements and commercial offers that match your preferences as closely as possible) and to help advertisers to deliver non-invasive advertising that meets your needs more closely;
• to provide statistical analysis in aggregate form to advertisers and Publishers and/or to provide recommendations on the delivery of advertising campaigns in line with the preferences You have expressed while browsing;
• to analyse, develop, measure (particularly for frequency capping and ad rotation) improve and optimise our services;
• to control and maintain the security of our systems.

 

Under no circumstances do We use the data collected by Us or third parties to determine the personal identity of Users.

 

Creation of a Unique ID

Cookies assign You a unique ID which can be used to track and target your habits, recognising You each time You visit. In some cases We store IP addresses for the sole purpose of extracting statistical information. In some cases We store email addresses, but these are subject to pseudonymisation after collection.

 

7. WITHDRAW YOUR CONSENT – OPT OUT

You have various options:

 

A) Tangoo’s opt-out

To disable Tangoo’s profiling cookies, change the settings on your browser or use this practical interactive link:

OPT-OUT

 

If You use the interactive button to block our profiling cookies You will still receive a technical cookie to store your preference. Please note that, if You delete all the cookies from your browser, this technical cookie may also be removed and, therefore, You may have to express your choice to block these cookies again using the interactive button in this Privacy Policy.

 

B) Browser settings or mobile settings

Follow the instructions provided by the manufacturer of the browser You use to find out how to manage, disable or delete all cookies (technical, analytics and profiling cookies):

• Explorer: http://windows.microsoft.com/it-it/windows-vista/block-or-allow-cookies
• Chrome: https://support.google.com/chrome/answer/95647?hl=it&p=cpn_cookies
• Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
• Safari: https://support.apple.com/it-it/guide/safari/manage-cookies-and-website-data-sfri11471/
• Opera: https://help.opera.com/en/latest/web-preferences/  

Choose carefully. If You indiscriminatingly block the receipt of all cookies, including technical cookies, without making a specific exception for the Website, You may, in fact, be no longer able to browse the Website or to use some or all of its features. In addition, if You delete all the cookies from your browser, technical cookies may also be removed and, therefore, for example, You could remove the preferences You have set when using the Website.

 

For mobile devices, please use device settings.

– For iOS, select “Privacy” → “Tracking” → disable “Allow Apps to Request to Track”

– For Android, select “Users Area” → “Google” → “Ads” → “Opt out of Ads Personalization”

 

C) Use the Internet website www.youronlinechoices.eu/ 

Your Online Choices is an Internet website managed by the non-profit association European Interactive Digital Advertising Alliance (EDAA), the English version of which can be found at the address https://www.youronlinechoices.com/uk/. It provides information on behavioural advertising based on profiling cookies (https://www.youronlinechoices.com/uk/about-behavioural-advertising) and allows Internet users to easily opt-out of the installation of the main profiling cookies installed by advertisers and used on Internet websites (https://www.youronlinechoices.com/uk/your-ad-choices). Before using this tool, We recommend that You carefully read the general terms and conditions of service of the Your Online Choices website (https://www.youronlinechoices.com/uk/terms-conditions), as well as the frequently asked questions (FAQ) (https://www.youronlinechoices.com/uk/faqs) and the user guide (https://www.youronlinechoices.com/uk/opt-out-help ).

Use Your Online Choices sensibly. Although Your Online Choices brings many of the world’s leading advertising companies that use cookies together, some of the third parties that install cookies through the Website may not have signed up with Your Online Choices. Therefore, the use of Your Online Choices does not guarantee that You will receive third-party cookies while browsing the Website. Remember, also, that if You delete all cookies from your browser, even the technical cookies issued by Your Online Choices to remember your preferences may be deleted, rendering third-party cookies active once again.

8. TANGOO’S PARTNERS

Tangoo sends the majority of its cookies on the Websites through ad-exchange networks.

9. DATA RETENTION PERIOD

Your data will be kept by Tangoo for the time considered strictly necessary to carry out the primary purposes described in this Privacy Policy, or as necessary for the protection in civil law of both your interests and those of Tangoo and, in any case, for no more than ninety (90) days. 

 

All the data is collected, extracted, stored and processed exclusively for purposes related to the provision of services through Tangoo’s systems and is subsequently transferred into anonymous form or destroyed when no longer required for the aforesaid purposes.

 

10. PROCESSING METHODS

Tangoo acts as the data controller in accordance with the provisions of Applicable Law, with state-of-the-art security measures, such as the use of sophisticated pseudonymisation techniques. No personal data will ever be visible to Tangoo as “cleartext”.  We will only process your data by electronic means, in a fully automated manner and, for the most part, without human intermediation. Therefore, our employees and partners will never access the contents of your personal data obtained through cookies and/or other tracking technology. Some of our employees and partners, appointed by Us as persons in charge of the processing, may carry out maintenance work on the computer systems that host your data, without ever being able to access its actual content. Personal data may be stored on servers managed by third parties (e.g. suppliers of computer systems) or may be managed by parties specialising in online advertising, who act as data processors on the basis of a written appointment by Tangoo. 

All processing activities are carried out with systems strictly related to the purposes themselves and, in any case, to ensure the security and confidentiality of the data.

11. YOUR RIGHTS

You may exercise the rights guaranteed by the Applicable Law by contacting Tangoo in the following ways:

• by sending a registered letter with return receipt to the registered office of Tangoo (Via Lentasio n.9, 20122 Milan – Italy)
• by sending an email to the address privacy@tangoomedia.com

 

Tangoo has not identified a Data Protection Officer (RPD or DPO), as it is not subject to the obligation of designation provided for by Article 37 of the Regulation.

 

Under Applicable Law, You have the right to be informed about: (i) the origin of personal data; (ii) processing purposes and methods; (iii) logic applied in the event of processing carried out with the aid of electronic tools; (iv)  identification details of the data controller and data processors; (v) of the parties or categories of parties to whom personal data may be disclosed or which may become aware thereof, in their capacity as persons in charge or data processors.

 

In addition, where technically possible depending on the processing carried out and the personal data collected by Tangoo, the User has the right to obtain: a) the access to, updating, rectification or, where applicable, the integration of the data; b) the deletion, transformation into anonymous form or blocking of the data processed in breach of law, including data which does not need to be stored in relation to the purposes for which it has been collected or subsequently processed; and c) proof that the procedures, as well as their content, under sections a) and b) have been brought to the attention of those to whom the data has been communicated or disclosed, except in the case where this obligation is impossible or involves the use of means clearly disproportionate to the right being protected.

 

Furthermore, where technically possible depending on the processing carried out and the personal data collected by Tangoo, the User has:

a) the right to withdraw consent at any time where processing is based on consent;

b) (where applicable) the right to data portability (the right to receive all personal data concerning You in a structured, commonly used and machine-readable format), the right to restrict the processing of personal data and the right to delete it (the “right to be forgotten”);

c) the right to object:

i) in whole or in part, for legitimate reasons to the processing of personal data, even if pertinent to the collection purposes;

ii) in whole or in part, to the processing of personal data for the purpose of sending advertising material or direct sale, or for the purpose of market research or commercial communications;

iii) at any time to the processing of personal data for purposes of direct marketing, including profiling to the extent to which it is connected to such direct marketing.

d) if You consider that the processing of your data is in breach of the Regulation, the right to lodge a complaint with a supervisory authority (in the Member State in which You usually reside, in the Member State in which You work or in the Member State in which the alleged infringement took place). The Italian Supervisory Authority is the Garante per la protezione dei dati personali, with headquarters in Piazza Venezia no. 11, 00186 – Rome (http://www.garanteprivacy.it/).

 

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Tangoo is not responsible for the updating of all links that can be viewed in this Privacy Policy, therefore whenever a link is not functional and/or updated, Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to in these links.