Brazilian Privacy Notice

This section provides you with information specific to Brazil in relation to your privacy. It supplements the General notice so as to reflect the requirements set out in the Brazilian General Data Protection Law (“LGPD”).

This Brazilian privacy notice also enables you to directly exercise the rights granted to you under the LGPD (see section 8 below).

Teads Brasil Solucoes Em Propaganda e Video Ltda is acting as controller in Brazil in respect of the provision of Teads business services to publishers and advertisers, by using the Teads Technology.

For any questions about this privacy policy, our data practices or the way in which you can exercise your rights, you can contact the Data Protection Officer (DPO):

• By email: dpo@teads.com
• By mail:
  Teads Brasil Solucoes Em Propaganda e Video Ltda
  Intention to Data Protection Officer
  Avenida Presidente Juscelino Kubitschek nº 2041,
  Torre D, 14º andar,
  ZIP 04543-011, São Paulo, SP, Brazil

Information we process. To perform our Services, we may collect information from our publisher, advertiser and data partners, as described in detail in the section 4 of our General notice. This data is considered to be personal information when it is associated with an identifier such as your cookie ID, Mobile Advertising ID or IP address.

No sensitive data. Teads does not knowingly collect nor process sensitive data. We do not therefore collect:

• Data revealing racial or ethnic origin,
• Data revealing political opinions,
• Data revealing religious or philosophical beliefs,
• Data revealing trade union, religious, philosophical or political organization membership,
• genetic data,
• biometric data,
• data concerning health,
• data concerning a person’s sex life or
• data concerning a person’s sexual orientation.

Unless otherwise required or permitted by law, before using your personal information for a purpose unrelated to those set out below, we will notify you and explain the purpose and legal basis which allows us to do so. We will only collect, use, and share your personal information where we are satisfied that we have an appropriate legal basis to do this.  The table below explains the purposes for which we process your personal information and the relevant legal basis we rely upon to do so.

Consent. If we ask you to provide consent to us, we will inform you specifically when we seek to obtain this from you as well as informing you of your ability to withdraw that consent (see section 8 “Your Data protection rights”) at any time and any potential consequences that may arise as a result of not providing the personal information that is requested.

Teads accesses your information through our partners, as disclosed in section 4 of the General notice. Therefore, we obtain consent through a partner’s consent management platform (CMP) or any other possible tools where you can choose to accept (opt-in) or refuse (opt-out) of giving consent to the processing of your personal information for the purposes disclosed in the table above. 

The necessary information is also provided to you through this privacy notice, which aims to meet the principle of transparency set out in the LGPD. 

Legitimate interest: Before using your personal data for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you to ensure that your interests and fundamental rights and freedoms do not override those interests. In other words, we have carried out a “balancing test” to determine that we have a legitimate need to process your personal data and that we are not aware of any reasons that, on balance, mean we should not do so. 

In particular for the purpose of selecting basic ads, Teads only processes the IP address and approximate postcode. This processing merely enables Teads to display basic ads that are relevant to the data subject’s location (country, region or city) as well as avoiding excessive ad exposure (frequency capping). The IP address is not combined with any other information when processed on the legitimate interest legal basis. There are no targeted ads or behavioral ads in this case.

Profiling is an automated processing of personal data to evaluate certain things about you.

When we collect information for the purpose of “the delivery of personalized ads”, it may lead to profiling since we use audience segments based on your behavior to personalize the ads.

The advertising you see on publisher websites that use our technology is based on our ad selection algorithms. However, the processing of your information does not involve “automated decision making”.  This means that we do not use automated processing to make decisions which have any legal effect or similarly significant effect on you.

We operate on a global basis. Accordingly, your personal information may be transferred and stored in countries outside of Brazil that are subject to different standards of data protection. We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection under Article 33 of the LGPD or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. To this end:

• We ensure that the recipient benefits from an adequacy decision under the Article 33 of the LGPD.
• Otherwise, we rely on the measures authorized by the National Data Protection Authority (“ANPD”), such as signing the Standard Contractual Clauses or verifying that the recipient has adopted Binding Corporate Rules, which contractually oblige each party to ensure that personal information receives an adequate and consistent level of protection.

In the absence of specific regulation issued by the ANPD, Teads may rely on the European Commission Standard Contractual Clauses or other lawful mechanisms or standard contractual clauses, or otherwise ensure that the transfer only occurs where permitted by applicable law.

You have the right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.

The LGPD provides you with certain rights in relation to your personal information. 

You are not required to pay any charge for exercising your rights. If you make a request, we will respond to you or take the necessary measures within the terms provided for in the LGPD.

If you wish to exercise any of the below-mentioned rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you. You can exercise your rights by contacting us at dpo@teads.com.

Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. 

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way. 

Your rights: 

• Your right to withdraw your consent – You have the right to change your mind and ask Teads to stop processing your personal information where the legal basis for processing is your consent.

You also have the right to request erasure of your personal information processed with basis on your consent, to the extent allowed by the applicable legislation.

If you opt to not give us your consent or if you withdraw a consent previously given, you will have limited access to the services provided by Teads.

Exercise this right

• Your right of confirmation and access – You have the right to obtain confirmation as to whether or not your personal information is being processed by Teads and to ask us for copies of your personal information that we hold, and you have the right to be given specified information about the processing which corresponds to the information contained in this policy.

Exercise this right

• Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete and to update information you think is out-of-date. We may seek to verify the accuracy of the personal information before rectifying it. The consequences of exercising your right to rectification will depend on the objective you wish to achieve by exercising it. To exercise this right, please send us an email at dpo@teads.com.
• Your right to erasure – You have the right to ask us to anonymize, block or erase your personal information that is unnecessary or excessive or that is processed in non-compliance with the provisions of the LGPD. The exercise of your right of erasure will result in the deactivation of our personalized ads.

Exercise this right

However, we are not required to comply with your request to erase personal information if the processing of your personal information is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.

• Your right to object to processing – To the extent that we rely on legal bases other than your consent for processing your personal data, you have the right to object to the processing in case of violation of the applicable law. 

Exercise this right

• Your right to data portability – You have the right to ask that we transfer the information you gave us to another organization, or to you, in certain circumstances, limited to our commercial or industrial secrets.

To exercise this right, please send us an email at dpo@teads.com

• Your right to revision – You have the right to request the revision of decisions taken solely on the basis of automated processing of your personal information which affects your interests, including decisions intended to define personal, professional, consumer or credit profile or aspects of your personality.
• You have the right to lodge a complaint with the ANPD or with the consumer defense bodies  – Please see section 9 below. 

If you have any concerns about our use of your personal information, we encourage you to contact us by sending an email to dpo@teads.com. We’ll do our best to resolve your complaint.

However, if we are unable to resolve a complaint or concern with you, you can also complain to the supervisory authority at https://www.anpd.gov.br.

Minor changes. We may make minor changes from time to time that do not materially affect the way we process your information or the way you can exercise your rights. These minor changes are mainly cosmetic, such as changing the font, correcting typos, etc.

Significant changes. When significant changes are to be made, we will endeavour to notify you 5 days prior to the publication of these changes, by highlighting them on our website. Significant changes are:

•       Changes in laws and regulations,
•       Introduction of new products or services,
•       Changes in the way we process personal information
•       Changes in the way to exercise your rights
•       Changes in our corporate structure

Notwithstanding the changes described above, we’ll review this Brazilian Privacy Notice every 12 months to ensure the accuracy of the information.