Business Partner Privacy Policy

Teads is committed to protecting your personal data. This Business Partner Privacy Policy (“Business Partner Privacy Policy“) details Teads’ use of personal data collected and processed when you (“Business Partner“) register with or email Teads on behalf of the company you work for, to use the Teads Technology, or where we otherwise process your personal data in the context of providing or receiving services from/to you. We may change this Business Partner Privacy Policy from time to time.
For more information on how Teads uses your personal data when you visit www.teads.com (or any derivation/any of our other sites) (our “Sites“), please see Teads Site Visitors Privacy Policy.
For more information on how Teads uses your personal data when you visit a publisher or advertiser’s website where the Teads technology is present, please see Teads User Privacy Policy.

a) Who we are:

This Business Partner Privacy Policy applies to Teads Inc. a company incorporated in the United States of America and its affiliated subsidiaries (collectively, “Teads“, “we“, “us“, “our“). We operate in various offices around the world and we partner with publishers and marketers across the globe.

b) What we do:

Teads operates a two-sided marketplace, forming an end-to-end advertising platform with direct media owner and advertiser relationships. Teads is an intermediary in the online advertising industry, connecting publishers and advertisers all over Europe, the United States, Latin America, the Middle East, North-Africa and Asia. Teads’ mission is to serve interesting recommendations to you based on what we believe are your interests.
At a high level, we provide the following services to our clients:

1. Publisher partners use Teads’ technology to monetize their ad spaces. Advertisers or their intermediaries (e.g., media agencies) display their advertising campaigns via Teads technology on the websites, mobile apps or Connected TV apps of our publisher partners.
2. Teads also provides Omnichannel graph services to its clients which allows for campaign reach measurement and planning, performance, cross-device remarketing and retargeting.

(collectively, the “Services“)

c) How to contact us:

We regularly review our compliance with this Business Partner Privacy Policy. Questions, comments and requests regarding this Business Partner Privacy Policy are welcomed and should be addressed in the first instance to privacy@teads.com.
If Teads does not satisfactorily answer your questions or concerns, you may also contact our Data Protection Officer at privacy@teads.com or your supervisory authority for advice, support or complaints, including the Information Commissioner’s Office if you are in the UK.

a) We may process your personal information for the following purposes:

• in order to perform our obligations under our agreement as a Business Partner (or prospective Business Partner);
• to monitor your use of our website and/or dashboard to improve the user experience and to ensure that content is presented in the most effective manner for you and for your device;
• to respond to your questions and requests;
• to provide you with access to certain functions and features of the Services to verify your identity;
• to communicate with you about your account, our products, and available promotions relevant to your use of the our services;
• for system administration purposes and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to notify you of any changes to the Services; and
• to comply with applicable laws and regulations.

b) In order to do this, we collect and process your personal data when you:

• visit our Sites (including when you sign up for the Services/for an account or sign up to receive information from us);
• interact with the Teads’ customer dashboard;
• contact our customer service centers; or
• request information from us / communicate with us in any other way.

c) We collect and process the following personal data:

• contact details (such as your name and email address);
• information from you for the purposes of executing a contract; and
• information about your username’s actions in the Teads dashboard (for example, as advertising Business Partner if you change information regarding your campaigns within the dashboard, Teads’ will have a record of all those actions).

d) Legal basis for processing

We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and used your personal information. In almost every case the legal basis will be one of the following:

• Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you.
• Our legitimate business interests: Where it is necessary for us to understand our customers, promote our services and operate effectively, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights.
• Performance of a contract with you (or in order to take steps prior to entering into a contract with you): For example, to perform our obligations under our agreement as a Business Partner (or prospective Business Partner).
• Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.

For Business Partners in the European Territories/UK, Teads has implemented a consent management platform (powered by OneTrust) on teads.com that provides you with the opportunity to consent, or not consent, to cookies and similar tracking technologies. You will see a banner in the centre of the page with information about the cookies we use. You may click the banner to reject any cookies (for example, performance cookies or targeting cookies) that are not strictly necessary cookies (as defined in the Cookie Table). By pressing “I Accept” on the banner you are indicating your acceptance to cookies and similar tracking technologies that require consent. Where you have provided your consent for the use of cookies, you may withdraw your consent at any time by clicking this button: Cookies Settings. You will see a detailed list of cookies that we may drop when you interact with our sites in the OneTrust consent management platform. In respect of all other Business Partners not located in any European Territories/UK, we rely on our legitimate interest for processing any personal data however, this does not preclude non-European Territory individuals from withdrawing consent at any time via our consent management platform.

If as a Business Partner you wish to verify, correct, update or request the deactivation or deletion of your information, please reach out to privacy@teads.com. If you are receiving Teads emails, you may “unsubscribe” using a link in the email. Note that unsubscribing shall not opt you out of notifications critical the Services(e.g., email invoices).

If you are located in the European Territories/the UK, please see Section 8 below which outlines other rights that you may exercise.

a) Security

Teads has a dedicated security team. We maintain tight controls over the personal data we collect, retaining it in firewalled and secured databases with strictly limited and controlled access rights, to ensure it is secure. Please see our security standards for more information.
Business Partners have access to certain password-protected features of our services. Business Partners are responsible for keeping this password confidential and for ensuring the same for their employees and/or their agents.
Please remember that, unfortunately, the transmission of information via the internet is never completely secure. A common Internet scam is known as “spoofing” or “phishing.” This occurs when you receive an email from what appears to be a legitimate source requesting personal data from you. Please be aware that we will not send you any emails requesting you to verify credit card, bank information, or any other personal data. If you ever receive an email that appears to be from us requesting such information from you, do not respond to it, and do not click on any links appearing in the email. Instead, please forward the email to us at legal@teads.com, as we will investigate instances of possible Internet fraud.
Our Sites contain links to other websites that we do not own or operate. We do not control, recommend or endorse the content, products, services, privacy policies or practices of these third party websites. For example, on our Sites you will notice clickable icons which take you to the Teads Facebook page or the Teads LinkedIn page. If you choose to click on these links, you should know that these sites are not owned or operated by Teads and therefore these third party websites may send their own cookies to your device and they may independently collect personal data. It is therefore important that you get familiar with the privacy policies of these third party websites.

b) Sharing

We may disclose certain Business Partner information to vendors, contractors, or others who assist Teads in delivering the services (e.g., credit card processing).
In addition, we may also disclose personal data as follows:

• within the family of companies controlled by Teads for internal reasons, primarily for business and operational purposes;
• If we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, your personal data will likely be among the assets transferred. We reserve the right to transfer personal data as part of the transaction;
• when legally required to do so (e.g., to cooperate with law enforcement investigations or other legal proceedings); and/or
• to respond to a genuine emergency.

We may also combine your personal data with that of other users in order to share trend information and aggregate user statistics with third parties, always in aggregated and anonymized form.

c) Data Retention

Teads shall retain your data for the duration of our contractual relationship and/or any longer period required in accordance with applicable legal requirements.

a) Your rights

In compliance with certain privacy laws, in particular the European General Data Protection Regulation (GDPR) and the UK GDPR, you have certain rights in relation to your personal information. More specifically and under certain circumstances:

• the right to request information about whether and which personal data is processed by us, and the right to request that such personal data is rectified or amended;
• the right to request that your personal data be deleted;
• the right to request that the processing of your personal data be restricted or object to the processing of your information on grounds relating to his or her particular situation, or at any time for direct marketing purposes.;
• withdraw your consent to the processing and use of your data completely or partially at any time with future application;
• have the right to obtain your personal data in a common, structured and mechanically readable format, and to transmit those data to another controller;
• contact our data protection officer if there are any questions, comments, complaints or requests in connection with our statement on data protection and the processing of your personal data; and
• the right to complain to the responsible supervisory authority if believed that the processing of your personal data is in violation of the legislation.

We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of these rights or have any questions, please email privacy@teads.com

b) Data transfers outside the European Territories/UK to non-US territories

We may transfer Personal Data from the European Economic Area (EEA) and/or UK to our data centres. When we transfer Personal Data, we will ensure such transfers are in compliance with relevant data protection laws, including, if applicable, EU/UK Standard Contractual Clauses, or a European Commission/UK Government positive adequacy decision.

In other words, your rights and protections remain with your data and we use approved contractual clauses and other measures designed to ensure that the recipients of your Personal Data protect it. Teads has in place the Standard Contractual Clauses between its entities to govern the transfer of data outside of the EEA/UK. To obtain more information as to the safeguards that we implement in this respect or to obtain a copy of them, please email privacy@teads.com.

For more detail on transfers to the United States, please see Section 8 below.

c) EU-US Data Protection Framework (DPF) Participation and the UK Extension to the EU-U.S. DPF:

i. EU-US Data Protection Framework (DPF) Participation

Teads Inc. complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. Teads Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of Personal Data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

ii. Complaint and Dispute Resolution Procedure under the DPF

Our internal complaints mechanism

In compliance with the EU-U.S. DPF, and the UK Extension to the EU-U.S. DPF, we commit to resolve EU-U.S. DPF Principles and UK Extension to the EU-U.S. DPF Principles-related complaints about our collection and use of your Personal Data. EU and UK individuals with inquiries or complaints regarding our handling of Personal Data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF should first contact us at: dpo@teads.com

You may have the right to lodge a complaint with the data protection authority of your country of residence. If you live in the UK, you can make a complaint with the Information Commissioner’s Office (ICO) at this address. If you live in the EU, you can find the relevant data protection authority here. Teads Inc. is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). To submit a complaint to the FTC, click here.

Independent Recourse Mechanism

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Teads, Inc commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Arbitration

You may also be able to invoke binding arbitration for unresolved complaints but prior to initiating such arbitration, a resident of a European country participating in the DPF must first:

1. contact us and afford us the opportunity to resolve the issue;
2. seek assistance from JAMS (an independent resource mechanism); and
3. contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department of Commerce time to attempt to resolve the issue.

If such a resident invokes binding arbitration, each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the DPF, the arbitrator(s) may only impose individual- specific, non-monetary, equitable relief necessary to remedy any violation of the DPF Principles with respect to the resident. The arbitration option may not be invoked if the individual’s same claimed violation of the Principles has previously been subject to binding arbitration; was the subject of a final judgement entered in a court action to which the individual was a party; or was previously settled by the parties. For more details, please click here.

iii. Choice and means for Limiting Use and Disclosure of Personal Data

Teads Inc. does not disclose personal data to non-agent third parties or use personal data for purposes materially different from that which the data was originally collected or subsequently authorized by individuals. Should this change in the future, we will offer individuals opt-out choice or opt-in (for sensitive data) prior to any such disclosures.

iv. Tead’s liability in case of onward transfers to third parties

In the context of an onward transfer, Teads has responsibility for the processing of Personal Data it receives under the DPF Principles and subsequently transfers to a third party acting as an agent on its behalf. Teads remains liable under the DPF Principles if its agent processes such Personal Data in a manner inconsistent with the DPF Principles, unless Teads proves that it is not responsible for the event giving rise to the damage.

This United States Consumer Privacy Notice (“State Notice“) supplements the Business Partner Privacy Policy and provides additional information for residents of certain states with comprehensive privacy laws, such as California and other similar state laws. Under these applicable U.S. state laws, processing Personal Data across various websites, apps, and devices to deliver targeted advertising may be classified as ‘selling’ or ‘sharing’ your information. Accordingly, this State Notice provides required disclosures regarding how we collect, use and disclose that Personal Data.

a) Your U.S. State privacy rights

As a resident of certain U.S. states, (for example, California, Virginia, Colorado, Utah, Connecticut) you may have the right to submit certain requests relating to your Personal Data, as listed below, depending on your state of residency. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

Right to Know: You may have the right to Request information regarding the categories of Personal Data we collect, the sources of that data, our business purposes for processing it, and the categories of third parties with whom we share or sell that information.

• Right to access, confirm and data portability: You may have the right to confirm whether we are processing your Personal Data, to access your Personal Data, and to obtain a copy of Personal Data you provided to us in a portable format.
• Right to delete: You may have the right to delete the Personal Data that we have collected from you, subject to certain exceptions.
• Right to correct: You may have the right to request that we correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and our purposes for processing it.
• Right to opt out of sales and sharing of personal data for targeted advertising: You may have the right to opt out of the sale of your Personal Data, and to request that we do not share your Personal Data for targeted or cross-context behavioral advertising. See section (c) below for further information.
• Right to withdraw consent or limit use and disclosure of sensitive personal data: If we process Sensitive Personal Data from you, you may have the right to withdraw a previously provided consent for processing your Sensitive Personal Data for a specific purpose. We do not use or disclose Sensitive Personal Data for purposes to which the right to limit use and disclosure applies.
• Right to know third party disclosures: You may have the right to request a list of third parties to which we have disclosed Personal Data.
• Rights related to automated decision-making or profiling: We do not use your information for profiling in furtherance of decisions that produce legal or similarly significant effects or for the purposes of automated decision-making as defined under currently applicable law.
• Right to appeal: Sometimes we are unable to process requests relating to your Personal Data, in which case, your request will be denied. If you have previously submitted a privacy rights request to us that has been denied and you believe that we denied it in error, you may have the right to appeal for reconsideration of your request by emailing us at privacy@teads.com or by calling us toll free on 1-866-I-OPT-OUT and entering service code 777# to leave us a message.
• Non-discrimination. You are entitled to exercise the rights described above free from discrimination.

b) How to exercise your rights

You may exercise your privacy rights described above as follows:

• By calling us toll free on 1-866-I-OPT-OUT and entering service code 253# to leave us a message.
• By emailing privacy@teads.com

c) Right to opt-out of the “sale” or “sharing” for targeted advertising of your Personal Data

We do not sell your Personal Data in the conventional sense (i.e., for money). However, like many companies, we use services that help deliver personalized ads to you. Under certain United States state privacy laws, some of the ways in which we share Personal Data for targeted or cross-context behavioural advertising or analytics may be considered “sales” or “sharing”. To opt-out from this “sale” or “share” for targeted advertising, please refer to Section 5. If you choose to use the Global Privacy Control (GPC) browser signal, you will only be opted out of online sales or sharing of Personal Data, and will need to turn it on for each device/browser combination that you use.

We will need to confirm your identity and state of residency to process your requests. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. Depending on your state of residency, you may be able to designate an authorized agent to make a request on your behalf; however, you may still need to verify your identity with us before your request can be processed. An authorized agent may submit a request on your behalf using the methods listed above.

Some browsers transmit Do Not Track (DNT) signals to websites. Because there is no common understanding of how to interpret the DNT signal, Teads does not currently alter, change, or respond to DNT requests or signals from these browsers. We will continue to monitor industry activity in this area and reassess our DNT practices as necessary. In the meantime, you can use the range of other tools we provide to control data collection and use, including the ability to opt out of receiving personalized recommendations in the Users section. We also honour the GPC browser signal, as described in Section 8 above. Please note that since GPC is a browser-level setting, your preference is tied to that specific browser. If you use multiple devices or clear your cookies, you may need to ensure GPC is enabled across all environments.

If you have any questions or concerns about your privacy you may contact us at:
Teads Inc.
111 West 19th Street 3rd Floor
New York, NY 10011, USA
Attn: Privacy questions

Email: privacy@teads.com or dpo@teads.com