Data and Privacy

We believe data has the potential to transform advertising, to make it more relevant to consumers, more valuable for media companies and more effective for advertisers.

That’s why we’re completely transparent in the data we collect, how we collect it and what we use it for.

For the purposes of this policy:

  • “Personal Data” for non-residents of the European Economic Area means any information that can be used to identify, contact, or precisely locate a person, including name, email, address, and telephone number.  
  • “Personal Data” for residents of the European Economic Area means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, specifically by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. This includes IP address and advertising ID (IDFA/AAID).
  • “Non-Personal Data” means information not included in the definition of Personal Data, such as pages or ads visited, time spent on pages, browser and device type, and referring and exit pages. For non-residents of the European Economic Area, IP address and advertising IDs (IDFA/AAID) are Non-Personal Data.

What type of information don’t we have access to?

We explicitly do not collect names, email addresses or dates of birth.

What type of information do we have access to?

When a user watches a video, we may collect the following data:

  • Date
  • Time
  • Location (country)
  • Viewing device
  • IAB category
  • The user’s unique ID
  • Page URL

Do we install any tracking software on computers?

No, we do not install anything on your computer. The data is collected using cookies which are dropped by your web browser. These cookies can be deleted at any time. For more information on what cookies are and how they work please click here.

What do we use this data for?

This data is made available to trusted advertisers who will use it to inform their advertising decisions. Giving advertisers access to anonymised, authentic, current data allows them to target their audience more effectively. This means more relevant advertising for the viewer and a better user experience.

Cookies & Privacy Policy

A. GENERAL

Coull is committed to respecting your privacy. This policy explains how we collect, store and use certain attributes of your Personal Data and other data when you use the Coull Platform, products and services (Services) and the Coull website (Website) www.coull.com. It also explains how we and our partners use cookies and other technologies as part of the Services and Website.

Please read this policy carefully. By visiting the Website or using and/or interacting with the Services, you are accepting the policies and practices described in this Privacy Policy.

Coull may change this policy from time to time by updating the relevant page on the Website. You should check this page from time to time to ensure that you are happy with any changes. This policy was last updated on 10th May 2018.

Who we are

We are Coull Limited, a company registered in England and Wales (registration number 06679670) and with the registered address of 77 Stokes Croft, Bristol, UK BS1 3RD (Coull, we, us, our). We are registered with the Information Commissioner's Office with number Z1610134.

We respect your right to privacy and will only process Personal Data you provide to us in accordance with the Data Protection Act 1998 and other applicable privacy laws including GDPR.

We regard the fair and lawful treatment of Personal Data and other data as very important to successful business operations, and to the maintenance of confidence between you and us.

Our use of Personal Data and cookies

We collect, store and use the Personal Data and other data that you share with us differently depending on how you interact with us. Different technologies and cookies are also used depending on how you interact with the Website and Services. We have described these below, split into sections depending on who you are.

EEA

We may transfer Personal Data that we collect to third party data processors located in countries that are outside of the European Economic Area (including the US) or to members of our group of companies (including in the US) in connection with the purposes set out in this policy.

Please be aware that countries which are outside the European Economic Area may not offer the same level of data protection as the United Kingdom, although our collection, storage and use of your Personal Data will continue to be governed by this privacy policy. You consent to these transfers.

Some of the entities that we transfer Personal Data to in the US are also registered with The US Department of Commerce EU-U.S Privacy Shield. The EU-U.S Privacy Shield is designed by the US Department of Commerce and European Commission to provide adequate protection for the rights of individuals in connection with the transfer of their Personal Data to those registered entities.
For more information see the EC Data Protection Rules.

Your rights & the EU General Data Protection Regulation (GDPR)

We are committed to GDPR compliance when enforcement begins on May 25, 2018.  As such, you have the following rights with respect to data for which Coull is the Data Processor:

  1. The right to request access to, or ask us to provide you with copies of, Personal Data that we hold about you at any time, which may be subject to a fee specified by law for processing your request (but not for making a request for access). We may redirect your request to Coull’s customer acting as the Data Controller with respect to your data. We may decline a request for access to Personal Data in circumstances prescribed by relevant privacy laws. If we decline a request, we will provide you with a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint;
  2. The right to ask us to delete any Personal Data that we hold about you free of charge unless we are required to maintain a copy of this data pursuant to applicable law;
  3. The right to ask us to update and correct any out-of-date or incorrect or inaccurate Personal Data that we hold about you free of charge. We will take reasonable steps to correct the information so that it is accurate, complete and up to date. If we refuse to correct your Personal Data, we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint;
  4. The right to opt out of any marketing communications that we (or any third-party to whom we have disclosed your Personal Data with your consent) may send you or to withdraw your prior consent or object to any further processing of your Personal Data;
  5. The right to request information about any automated decisions made using your Personal Data that have legal consequences for you or which significantly affect you; and
  6. The right to lodge a complaint with your local Data Protection Authority concerning Coull’s processing of your Personal Data.

If you wish to exercise any of the above rights, please contact us at Coull Limited, 77 Stokes Croft, Bristol, UK, BS1 3RD or via http://coull.com/contact-us. Before we process any request, we may ask you for certain Personal Data to verify your identity and consult with the Data Controller of your data. Where permitted by local law, we may reject requests that are unreasonable or impractical. Please allow us a reasonable time to respond to your inquiries and requests.

If you wish to unsubscribe from any email marketing communications that we send you, you can easily do this by clicking on the unsubscribe link at the bottom of any e-mail newsletter we have sent to you or emailing us at account.support@coull.com.

If you believe we are processing your Personal Data not in accordance with the law, data subjects covered under the GDPR framework have the right to lodge a complaint with a supervisory authority in the Member State of their habitual residence, place of work, or place of the alleged infringement.

Security of your Personal Data

Coull uses reasonable technical and organizational security measures to safeguard Personal Data that is submitted to us voluntarily through our Website or collected through interactions with the Services. However, no security measures are perfect or impenetrable. We cannot control the actions of third-parties with whom you elect to share your Personal Data and we cannot accept liability for improper access to that data. We cannot guarantee that only authorized persons will view your Personal Data. We cannot ensure that information you share on our Website and/or through the Services will not become publicly available.

Children’s Privacy

The Website is not intended for children under 13 years of age. You must be at least 13 years old to use the Website and/or the Services. We do not knowingly collect Personal Data from any child under 13 years of age. If you are under 13 years of age, do not use the Services and do not provide any Personal Data to us. If you are a parent of a child under 13 years of age and become aware that your child has provided Personal Data to us, please contact us via http://coull.com/contact-us and you may request access, correction, deletion, and/or objection rights.

B. WEBSITE VISITORS

Your information and what we do with it

When you access, browse or otherwise deal with us via the Website, we may collect certain information from you, including any Personal Data you knowingly provide to us (for example via forms and email), such as your name, address, email details and telephone number; and your preferences for, and use of, email updates (if you choose to receive these).

We (or third party data processors acting on our behalf) may use your information:

  • to send you email newsletters and other emails relating to Coull offers, discounts, press releases and other products and services from us (if you choose to receive these) for our own administration, marketing, survey, customer service and continuous business development purposes
  • to carry out research and analysis and monitor visitor use of the Website on an anonymous basis to identify general trends and to better understand visitor behaviour; and
  • to investigate, respond to and comply with any legal, regulatory and similar requests in relation to the Website.

We will not sell or share your information with a third party (other than any data processors acting on our behalf) unless you consent to this.

Cookies

Cookies are small text files which are sent to your browser when you visit our Website. When you visit our Website again, the cookie allows our Website to recognise your browser.

Essential cookies

We use a number of cookies which are essential to the operation of this Website and which enable services you have asked for to be provided. For example, these cookies let us provide necessary Website security and help ensure the content of the pages you request load quickly. They are also used for the content management system that serves coull.com (to store user interface preferences). Without these cookies, Website services that you have asked for cannot be provided.

Performance cookies

These cookies collect information about how visitors use our Website, for example, which websites our visitors have come to us from, which of our pages our visitors go to most often, and if visitors get error messages on those pages. These performance cookies do not collect information that identifies you as an individual and all information they collect is aggregated and anonymous.

Session cookies

The coding language our Website is written in also uses session cookies. These are deleted each time you close your browser. These cookies do not store any information about a visitor once the browser is closed.

Google Analytics

We also use Google Analytics on our Website to help us analyse how our Website is used. You can find out more about this popular website analytics tool here:
http://www.google.com/analytics/index.html

Google Analytics uses performance cookies to track visitor interactions. For example, by using cookies, Google can tell us which pages our visitors view, which are most popular, what time of day our Website is visited, whether visitors have been to our Website before, what website referred the visitor to our Website, and other similar information. All of this information is anonymised.

Google Analytics also uses IP addresses to identify the geolocation of users. For example, this information can tell us the city or country the user’s IP Address is located in. This geolocation is not combined with any other Personal Data and the IP address itself is not shared with either Coull or other Google Analytics customers.

Google takes the privacy and security of your Google Analytics data seriously and you can find out more about how it protects your data here:
http://www.google.com/analytics/learn/privacy.html

Disabling cookies

You can disable and/or delete all types of cookies by using your browser settings. Cookies are generally easy to disable and/or delete but how you do so varies from browser to browser. The "help" function within your browser should tell you how to do it. The best way may be to close your browser and then search for "cookie folder" or "cookie manager" or simply "cookie". Please also visit www.allaboutcookies.org for more information about cookies and how to disable them.

C. SERVICES - GENERAL

Publisher/Advertiser information and what we do with it

If you are an organisation who has registered to use our Services, we may directly collect certain information from you, including: any Personal Data you knowingly provide to us (Upon registration, for example), such as names, addresses, bank details, email details and telephone numbers; and information about when and how you use our reports and other tools and interfaces provided by us as part of the Service.

We (or third party data processors acting on our behalf) may use your information:

  • to enable us to generally provide the Services to you (for example to pay you);
  • to send you emails, service messages and otherwise communicate with you regarding the Services and your account;
  • for our own administration, marketing, survey, customer service and continuous business development purposes;
  • to carry out research and analysis and monitor your use of the Services on an anonymous basis to identify general trends and to understand better our clients' behaviour; and
  • to investigate, respond to and comply with any legal, regulatory and similar requests in relation to the Services.

We will not sell or share your information with a third party (other than any data processors acting on our behalf) unless you consent to this.

IP Address Sharing

Coull collects IP addresses, which are shared with 3rd party traffic verification providers for the purposes of removing fraudulent traffic from Coull’s SSP. These IP addresses are shared confidentially only with certain 3rd party verification providers and are not shared for any use other than to identify fraudulent traffic.

D. COULL PLATFORM

The Coull Platform encompasses a variety of Products and Services that you may use including, OverStream, QUASAR and Header Bidding. The following explains the information collected when you agree to use any of these Products or Services.

OverStream Service

What is the OverStream Service?

The OverStream Service helps website publishers earn revenue through video advertising. The OverStream Service delivers adverts within the videos available on those publishers' websites. Each time an advert displays, we are paid for this by advertisers and in turn, pay the publisher.

What do we do on the websites and apps registered with the OverStream Service?

As part of the setup for using the OverStream Service, you (the Publisher) will configure your own services to trigger a request to the OverStream Service whenever a video is played. Therefore, once you start using the Service on one of your websites or apps, when visitors play a video on that website or app, this initial request will be made.

The initial request will trigger one or more JavaScript files to be downloaded to the visitor's device. Depending on the technology that is used in the Publisher video player, there may also be Flash files downloaded to the visitor's device prior to the JavaScript file. These files will be used to collect information about the visitor, the page they are on, the video they are watching and their interaction with that video. They will also trigger a request to one of our advertising partners for an advert to display within the video.

What data do we collect?

We collect information about the pages visited and videos watched by visitors across our Publisher network. This data will be used to optimise the Service we provide, to deliver reporting and analytics to Publishers, and to enable the adverts we deliver to relate to products and merchants that we think those visitors will prefer. This information includes:

  • Website and page URL
  • Video title, content category, player size
  • Visitor browser and device
  • The IP address of the visitor

Do you need to update your website or app privacy policies or make other disclosures if you use the OverStream Service?

It is important that all website(s) and app(s) that you use the Service in respect of (including any not owned or controlled by you) make clear to visitors that they are engaged in behavioural advertising through the OverStream Service. In order to promote transparent use of the OverStream Service, you, therefore, need to update (or ensure that the website or app owner or controller updates) the privacy policy(ies) or other relevant aspect or text of the website(s) or app(s) to include an appropriate disclosure statement about the use of our OverStream Service and ensure this is adequately disclosed and consented to. The standard minimum disclosure that we require is as follows, but in signing up to be a Publisher you have also agreed that this may change and/or there may be other disclosure requirements.

'We use advertising services on this website or app which are provided by our partner, Coull. Coull serves the adverts that you see displayed in the videos on this website or app. As part of these services, this website or app allows cookies and other technologies to be placed on your device by Coull and its partners. To find out more about what cookies and other technologies Coull and its partners use, what information they collect, how they use that information, what they do to protect that information, and your choices regarding the collection and use of that information see 'Visitor' section below.’

Cookies

The visitor’s unique ID is stored as a cookie on the visitor’s browser. This will expire after 90 days, although if the visitor watches another video within that time, the cookie is renewed for another 90 days.

QUASAR, Header Bidding

If you use Coull’s QUASAR or Header Bidding technology the following information will be collected to ensure our service standards.
Website and page URL
Video title, content category, player size
Visitor browser and device
The IP address of the visitor
Pricing information

This information is passed through our Platform and to third-party processors to enable us to deliver a better service. The information is not saved or sold and is not used to personally identify the Visitor.

E. VISITORS

If you are a visitor to a publisher website or app that uses our Services, this section explains how the Services operate and how your information is collected, stored and used by us (and third party data processors acting on our behalf) and our partners.

What information do we collect about visitors and what do we do with it?

When you play a video that is linked to our Services, this triggers a request to us that will, in turn, trigger one or more JavaScript files to be downloaded to the device. Depending on the technology that is used in the video player hosting the video, there may also be Flash files downloaded to your device prior to the JavaScript file.

We do not intentionally capture Personal Data about you such as your name, address or date of birth.
However, we may collect and store your IP address, from which we can work out your approximate location. Your IP address is a string of numbers unique to your device(s) that is recorded by our web server. We need these IP addresses to ensure the adverts we show you are relevant to where you live and for analytical purposes. However, we do not use IP addresses to specifically identify any individuals or identify exactly where you live.

We also collect and store information about:

  • The device(s) you use to access the internet, such as the browser type, browser version, and type of device used. This helps us ensure we can diagnose and fix browser compatibility issues more swiftly, and optimise the Services to suit preferred browsing environments
  • The website or app page(s) you are visiting when you watch the video(s)
  • The date and time you watch a video
  • Information about the video(s)

This helps us to provide, optimise, develop and improve the Services, to use the information for reporting and analytics (including to advertisers and publishers) and to enable the adverts we deliver to relate to products and merchants that we think you will prefer and for analytical and reporting purposes.

We also assign you a visitor ID. This is stored as a cookie on your device(s) browser. This will expire after 90 days, although if you watch another video within that time the cookie is renewed for another 90 days.

You can disable and/or delete all types of cookies by using your browser settings. Cookies are generally easy to disable and/or delete but how you do so varies from browser to browser. The "help" function within your browser should tell you how to do it. The best way may be to close your browser and then search for "cookie folder" or "cookie manager" or simply "cookie". Please also visit www.allaboutcookies.org for more information about cookies and how to disable them.
You can also remove the Javascript files from your device(s), but how you do this will depend on the device(s)

F. CONTACT US

If you have any questions or comments at all about this policy please contact us at Coull Limited, 77 Stokes Croft, Bristol, UK BS1 3RD or via http://coull.com/contact-us.

Thank you