This is a privacy notice of Fiducia DLT Limited.
FIDUCIA DLT Limited is dedicated to the highest standards of consumer privacy. We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or in relation to our products and services. We will also tell you about your privacy rights and how the data protection law protects you. By visiting www.fiducia.eco you are accepting and consenting to the practices described in this privacy notice.
This privacy notice is subject to change without notice. We may change it at any time by posting a new version on our website. Each version will be identified by its effective date. This notice was last revised on September 4, 2019.
1. WHO WE ARE AND IMPORTANT INFORMATION
What is the purpose of this privacy notice?
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, or in relation to our products and services, including any data you may provide through this website when you, for example, sign up to our newsletter.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. This website is not intended for children and we do not knowingly collect data relating to children.
What data do we collect and process for our products and services?
Our products and services enable our clients to report on advertising delivery and performance by making use of distributed ledger technology, advertising measurement tags and log files. Our primary focus is on creating cryptographically protected consolidated advertising delivery data feeds based on the data provided by supply chain vendors and measurement tags, providing compliance and discrepancy analysis. Our product and services are not processing IP addresses, cookies or personally identifiable information. Reports are generated based on non-PII data, such as programmatic auction ids, publisher and advertiser ids, bid prices, viewability and brand safety metrics.
Third-party links outside of our control
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Fiducia DLT Limited is the controller and responsible for your personal data (collectively referred to as "FIDUCIA", "we", "us" or "our" in this privacy notice). Our contact details are 590 Green Lanes, London N13 5RY. For all data matters contact our Data Controller at Fiducia DLT Limited using the following email address: email@example.com
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data This is information about you that you give us by filling in forms on www.fiducia.eco or by corresponding with us by email or otherwise. Such information may include information that you provided when contacting Fiducia or subscribing to a Fiducia service such as a newsletter or any general communication. The information you give us may include but is not limited to your name, address, e-mail address, company name, position and phone number.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
Directly - You may give us your name and contact details by filling in forms or by corresponding with us by email, phone, post or otherwise. This includes personal data you provide when you:
Subscribe to our services or publications
Request information about our company, products or services to be sent to you.
Indirectly - When you visit our website, our servers record and collect log data automatically sent by your browser through the use of tags and cookies. We use the log data to monitor, analyse, administer, and improve the FIDUCIA site and our services. We do not associate this data with your name, email, address, phone number or any other personal identifiable information.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by emailing us at firstname.lastname@example.org
Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing and communication activities at any time by contacting us at email@example.com
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity: To subscribe you to our newsletter
Type of data: (a) Identity, (b) Contact
Lawful basis for processing including basis of legitimate interest: Performance of a contract with you
We strive to provide you with choices regarding certain personal data uses, particularly around marketing. You may receive marketing related communications from us if you have requested information from us.
We will get your express opt-in consent before we share your personal data with any company outside the Fiducia group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting email@example.com at any time.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. WHO WE SHARE YOUR PERSONAL DATA WITH
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Internal Third Parties being any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006
External Third Parties Service in connection with the provision of services by Fiducia.
Providers acting as processors who provide IT and Administration services
Professional advisers acting as processors including lawyers, bankers, auditors and insurers who provide consultancy, banking. Legal, insurance and accounting services
HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We share your personal data within the company, which might involve transferring your data outside the European Economic Area (EEA).
Where our external third parties are based outside the European Economic Area (EEA), the processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by implementing safeguards:
Please contact us by email on email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
The right to request a copy of the personal data which we hold about you;
The right to request that we correct any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary to retain such data;
The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable (i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact firstname.lastname@example.org
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer. In this case, we will notify you and keep you updated.
10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
11. QUERIES, REQUESTS OR CONCERNS
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our data protection officer on email@example.com
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.