Information regarding GDPR
Adtraction cares about personal integrity and we have therefore taken extensive steps to ensure that all processing of personal data is carried out in accordance with applicable privacy protection legislation such as Regulation (EU) 2016/679 (“GDPR”). Personal data includes, for example, names and IP addresses that can be either directly or indirectly attributed to a natural person. Among other things, we have established a personal data policy and cookie policy where we explain what personal data Adtraction processes and the way in which it is done. Also shown below is information to our advertisers (“Advertiser”) and partners (“Partner”) about what is important to keep in mind when processing personal data within the framework for the use of Adtraction's service.
If you are an Advertiser
Data controller
A natural or legal person who determines the purpose and means for a particular processing of personal data is also the data controller for such data. When you as an Advertiser join the Adtraction platform, this means that you will be responsible for the personal data that you collect and process when a visitor has landed on your website after clicking a tracking link. For example, if the visitor makes a purchase, you will be the data controller for the processing that takes place within the framework of the sale.
The Advertiser and Adtraction enter into a business relationship for “Partner Marketing” which means that the Advertiser and Adtraction will need to exchange personal data with each other. In this case, the Advertiser and Adtraction are independent data controllers. This means that the Advertiser must be able to guarantee to Adtraction that the personal data transferred to Adtraction has been processed in accordance with the legitimate purposes and security requirements that appear in applicable data protection legislation.
What agreements will be entered into
In the normal case, Adtraction and the Advertiser are independent data controllers and will therefore enter into a Data Transfer Agreement. The Data Transfer Agreement complements the Cooperation Agreement that we have entered into or will enter into. This is necessary because the Cooperation Agreement only regulates the terms and conditions of Adtraction’s service and not how personal data is processed.
Establish relevant policies
Adtraction requires all Advertisers who join Adtraction’s platform to process personal data within the framework of the service in accordance with the GDPR and other complementary privacy protection legislation. This means, among other things, that you as an Advertiser must have legal grounds for all personal data processing and that you inform the persons concerned about how you process their data. Adtraction recommends that you clarify how you meet the requirements of the GDPR by establishing a personal data policy and/or cookie policy. We also encourage you to consult legal experts to see what other measures are required in connection with the GDPR.
If you are a Partner
Data controller
A natural or legal person who determines the purpose and means for a particular processing of personal data is also the data controller for such data. When you as a Partner join the Adtraction platform, it means that you will be responsible for the personal data that you collect and process when a person visits your website. For example, if you collect a visitor’s IP address, you will be the data controller for the processing that takes place with the IP address.
Normally, Adtraction and the Partner decide independently the purpose and means for the processing that each party performs on its own. The parties are therefore considered to be independent data controllers.
What agreements will be entered into
In the normal case, Adtraction and the Partner are independent data controllers and will therefore enter into a Data Transfer Agreement. The Data Transfer Agreement complements the Partner Agreement that we have entered into or will enter into. This is necessary because the Partner Agreement only regulates the terms and conditions of Adtraction’s service and not how personal data is processed.
Information for visitors
As a Partner, you must inform your visitors that your website contains tracking links. The information can be provided both directly in connection with the advertisement with the heading “Contains your tracking link” and also in your personal data policy or cookie policy. Example of text:
[Name of your website] participates in various partner programmes via Adtraction AB. The purpose of participation in the partner programmes is to earn commission by linking to Advertisers.
As a Partner, you must also inform your visitors that certain personal data is collected when a person visits your website. Example of text:
Collection of personal data when you visit our website
If you only use our website to obtain information, and do not register or send us any personal data, we only process the personal data that your browser sends us. In such cases, we only collect the data below, which is needed to ensure the security and stability of the website.
-
IP number
-
Date and time of the enquiry
-
Time zone
-
Which web page is loading
-
Access status / HTTP status
-
Quantity of data transferred
-
Website from which visitor loading is carried out
-
Browser
-
Operating system
-
Browser version and language settings
Establish relevant policies
Adtraction requires all Partners who join Adtraction’s platform to process personal data within the framework of the service in accordance with the GDPR and other complementary privacy protection legislation. This means, among other things, that you as a Partner must have legal grounds for all personal data processing and that you inform the persons concerned about how you process their data. Adtraction recommends that you clarify how you meet the requirements of the GDPR by establishing a personal data policy and/or cookie policy. We also encourage you to consult legal experts to see what other measures are required in connection with the GDPR.
