2. About ID Ward
3. What personal data we collect
4. How we use your personal data
5. How we protect your personal data
6. How long we keep your personal data
7. Your data rights
9. Contact us for information about your rights
ID Ward’s main mission is to protect your privacy, so it is really important that you understand what data we collects, how we collect it, why we collects, how we protects it and how you can manage it. ID Ward (also referred to as “we” or “us” in this document) is a company incorporated in England and Wales and with registered address at The Ingenuity Centre, Triumph Road, Nottingham, NG7 2TU, United Kingdom.
2. About ID Ward
ID Ward is a data privacy software, created and managed by ID Ward Ltd, that collects your personal data, stores it and makes it anonymous on your own device. ID Ward is deployed across a wide range of websites and applications.
2.1 The ID Ward Network
The ID Ward software is installed on all ID Ward Ltd ‘Owned and Operated’ sites and ‘Data Privacy Network Sites’. Owned and Operated sites are the domains managed directly by ID Ward Ltd, and include www.id-ward.com and www.thecookielessfuture.com. These sites collect data on behalf of ID Ward Ltd, but do not share such data with any third party.
2.2 The ID Ward software
The ID Ward software includes the Consent Manager (that records your consent to be tracked), the Zero Party Pixel and the Data Account (that stores the tracked data on your own device and makes it anonymous). When you sign into a website or app that has the ID Ward Consent Manager, you create an ID Ward’s Data Account which collects and stores the data you generate on these sites.
ID Ward’s Consent Manager
Consent Manager collects your consent for your data to be tracked by a website’s “vendors”, or the companies that track user data. For each vendor, ID Ward shows what type of data they are collecting and what for what purpose. It lets you decide your privacy settings: which types of information can be collected, the means through which it is collected, how it can be used (i.e. what purposes are allowed) and what individual vendors are allowed to operate.
This level of information is required by the General Data Protection Regulation, the California Consumer Protection Act and other privacy regulations around the globe. You can change your privacy settings at any time for all the websites you visited that have the ID Ward Consent Manager.
ID Ward’s Zero Party Pixel
Zero Party Pixel is a script running on publishers’ sites which is responsible for: (1) collecting data about user interaction with a site’s content and storing it locally, (2) processing the data to understand the user interests, (3) helping the user change privacy settings and manage their personal data by providing a link to the Data Account, and (4) anonymising data by using machine learning on the device.
ID Ward’s Data Account
Your ID Ward Data Account shows you what data ID Ward has inferred from your online activities and gives you control over the way the data is used. From your Data Account you can change your Privacy settings on all the sites that are part of ID Ward’s Privacy Network. You can also view, edit and delete your inferred data. When you click on Delete my data, we will delete all of your data within 48 hours and no backup copy will be maintained on our servers. You will not be able to recover the deleted information if you change your mind. Your data account will always be available at this link.
3. What personal data we collect
3.1 Data collected on ID Ward Owned and Operated sites
This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, in the event of the activation of IP anonymisation on this website, your IP address will be shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area.
The IP address submitted by your browser through Google Analytics will not be merged with other data provided by Google.
You can prevent the storage of cookies by a corresponding setting of your browser software; however, please note that if you do this, you may not be able to use all the features of this website to the fullest extent possible. You may also prevent the collection by Google of the data generated by the cookie and related to your use of the website (including your IP address) as well as the processing of this data by Google by using the browser plug-in available for download and installation at this link.
We use Google Analytics to analyse and regularly improve the use of our website. With the statistics obtained we can improve our offer and make it more interesting for you as a user. We also use Google Analytics for cross-device analysis of visitor traffic conducted through a user ID. You can disable the cross-device analysis of your usage under “My Data”, “Personal Information” in your customer account.
3.2 Data collected on ID Ward Data Privacy Network
ID Ward is one of the ‘vendors’ that collect personal information across the sites that are part of the Data Privacy Network. At each stage, the type of information collected, the means through which it is collected and the purpose of the collection are different.
|What we collect||How we collect it||Why we collect it|
|Data collected when you reject cookies (this data is stored on ID Ward servers)|
|Privacy choices||User input||We record your privacy settings for each website or app you visit, so that you don’t have to set it up every time you visit the site/app. This means that we maintain a list of all the sites you visited that are part of ID Ward and record your preferences for each site|
|Data collected when you accept cookies (this data is stored on your local device)|
|IP address||Cookies||We collect the Internet Protocol (IP) address of the device that is being used to view the page in order to know your generic location.|
|Location||Cookies||The IP address tells us what city and what country you are connecting from (but not the exact address!). This can be used, for instance, to recommend stories that are relevant to the location you are in.|
|Page URL||Cookies||We collect the web address (URL) of the web/app page you are viewing in order to understand what stories you are interested in.|
|Date and time of a page visit||Cookies||We collect the date you visited a page in order to recommend the right content on the right day of the week at the right time of the day. We also do this to monitor usage at different times, estimate peak demand and maintain good service performance.|
|Time spent on a page||Cookies||We collect the time spent on a page to understand whether you read/watched its content and, by extension, whether you found the content interesting.|
|Scrolling||Cookies||We collect data on what proportion of a page you viewed (scroll position) to understand whether you read/watched its content and, by extension, whether you found the content interesting.|
|Device data||Cookies||We collect the following information about your device: device type and model, screen resolution, operating system, type and version of the internet browser. This helps understand whether you prefer reading/watching different content on different devices and tailor recommendations accordingly.|
3.3 Data inferred by ID Ward
ID Ward analyses the data you generate to infer the language you speak and the country and city you live in. ID Ward also analyses the content of the pages you visited to infer your interests and your buying intentions. These inferences are called ‘insights’ and they are personal data, of which ID Ward is the controller. You can see, download and delete the insights inferred by ID Ward in your Data Account available on this page. ID Ward does not share the ‘insights’ gleaned about you (a.k.a. your ID Ward ‘profile’) with any third party.
4. How we use your personal data
When you Accept cookies, you give the publisher the (see Does ID Ward share my personal data?) the right to process your personal information. This is right is reversible (you can always change your Privacy settings from the Consent Manager or from the Data Safe) and limited to the provision of the following services:
- Building a profile: the information displayed in Data Account reflects the interests ID Ward has inferred from your browsing history across the ID Ward Network of sites. It is, in effect, a ‘profile’ used to suggest personalised content and ads. Your profile does not include clickstream data (that is, the raw data about your browsing history) and is not linked to any permanent identifier. This means that, if you delete your profile, no one will be able to re-identify you at a later stage.
- Personalised advertising: if you consent to it, your profile is used to personalise ads and other online experiences. However, this is done in an anonymous way as third parties (the ‘advertisers’) only have access to aggregated, anonymous information. No personal data is shared with any third party, other than for the reason required by law.
- Automated decision-making: content and advertising suggestions are the result of automated decision-making. Your profile is created using machine learning algorithms and automated decision-making. Because we do not collect information about sensitive data such as ethnicity, political opinion, religion and so forth, these algorithms have an extremely low chance of performing any form of discrimination. However, our data and algorithms are open and will be periodically audited to ensure that they do not promote any form of discrimination unbeknownst to us.
- Data sharing: We do not sell, trade, or otherwise transfer to outside parties your personal data. Moreover, because we do not collect your clickstream data, we cannot identify you as an individual. For this reason, we do not foresee cases when we will be forced to release information related to you in order to comply with the law, enforce our site policies, or protect ours or others’ rights, property or safety.
5. How long we keep you personal data
6. How do we keep your personal information safe
Your data is encrypted and protected within our servers. We currently store the data on Google Cloud Platform and we use cutting-edge technology to protect your personal information. Should a data breach occur, we will notify you via email within 5 working days from becoming aware of the breach and we will take immediate action to recover and protect your personal information.
7. Your data rights
7.1 Your rights under the General Data protection Regulation (GDPR)
If you are a resident of the United Kingdom or the European Union, the GDPR gives you the following rights in relation to your personal data:
Right of Access (Article 15): you have the right to obtain confirmation as to whether or not your personal data are being processed, and, where that is the case, access to the personal data and additional information.
Right to Rectification (Article 16): you have the right to obtain the rectification of inaccurate personal data
Right to Erasure (Article 17): you have the right to obtain the erasure of your personal data
Right to Data portability (Article 21): you have the right to receive your personal data in a structured, commonly used and machine-readable format and to transmit it to another controller
Right to object (Article 22): you have the right to object to processing of your personal data, including profiling. In practice, this is unnecessary because ID Ward only processes your data if you’ve consented to it and does not claim a legitimate interest to process your data. If you object to processing of your personal data you can withdraw consent from your Privacy Dashboard or delete your ID Ward account.
7.2 Your rights under the California Consumer Privacy Act (CCPA)
If you are a resident of California you may contact us with regard to the following rights in relation to your personal data:
Right of Access: You have a right to request access to the personal data we may hold on you for the past twelve (12) months. You may submit up to two (2) requests per year of access to your personal data.
Right to Opt-In/Opt-Out of Sale of Personal Data: For individuals sixteen (16) years or older, you have the right to opt-out of sale of personal data we may hold on you. You can exercise this right at any time by pressing the “California resident – Do not sell” link in the footer of every page. For individuals between thirteen (13) to sixteen (16) years old, you have the right to opt-in to the sale of personal data we may hold on you.
Right to Deletion: You also have the right to ask us to delete personal data we may hold on you or restrict how it is used. There may be exceptions to the right to deletion for specific legal reasons which, if applicable, we will set out for you in response to your request.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your California Consumer Privacy Act rights.
If you want to exercise your rights, you can do so from your Data Account page and/or the publisher’s Consent Manager, which are easily accessible from the Privacy Dashboard interface on all sites that use ID Ward. If you feel that you cannot exercise your rights as well or as fully as you would like to, or if you have any further questions, please contact us using the details provided below.
8. Changes to this Policy
If you have questions about this policy or simply want to know more about how we protect your data, email us at: firstname.lastname@example.org.