Part 1 – General privacy principles
Personal data and controller of personal dataPersonal data comprises all information that directly or indirectly can be referred to a natural person who is alive, e.g. name, postal address, e-mail address and phone number. A controller of personal data is the natural or legal person who processes personal data and who decides why and how such data shall be processed.
RaGaPa AB is the controller of personal data provided by you through the website ‘www.RaGaPa.com’. Depending on the issue in question, RaGaPa AB or any of its subsidiaries is the Controller of personal data provided to us by you through sub-sites of www.RaGaPa.com, published and maintained by RaGaPa AB or its subsidiaries (all RaGaPa websites hereafter referred do as the “Site”), or personal data that you are asked to provide us with in other situations if not otherwise is indicated.
Collection of personal dataPersonal data for which RaGaPa is controller may be provided by you to us e.g. in the following situations:
If you are a Client you may be required to provide us with personal and corporate information, such as name, address, email address and other account information, in order to be able to access and use our services;
As part of our sales efforts, we may collect and store data through online forms for contact purposes;
If you are a prospect Client, you may provide us with personal data through this Site when applying to join our network;
Use of personal data
Disclosure and transfer of personal data
Personal data may be transferred to other companies within the RaGaPa group of companies. RaGaPa may as a consequence of service agreements with third parties, also transfer personal data to such third parties who process personal data on behalf of RaGaPa. Such service agreement shall contain obligations for third parties to process data only in accordance with RaGaPa’s instructions and to take appropriate measures to secure that the processing of the personal data is secure.
Withdrawal of consentYou are at all times entitled to withdraw your consent to process personal data that you have provided to RaGaPa. In such case RaGaPa will not process your personal data based on consent any more.
You are entitled to request that RaGaPa shall not process your personal data for direct marketing purposes (such as direct marketing by e-mail, letter or telephone). Contact details for withdrawal of consent and/or for request that RaGaPa shall not process your personal data for direct marketing purposes are set out in Part 3 below.
Right to information and rectification of personal data
Destruction of personal data
Any personal data that we hold on you is only stored as long as it is required for us to keep them in order to fulfill the purposes for which they were collected. Data may however be necessary to store for a longer period due to legal requirements, e.g. for accountancy purposes.
RaGaPa is dedicated to maintain the security of personal data and preventing unauthorized access through the implementation of appropriate technical and organizational measures, as far as is reasonably possible. Such security measures also include that personal data may be accessed only by a limited number of persons within RaGaPa.
The Site contains cookies. According to applicable law, everyone who visits a website containing cookies shall receive information about how the cookies are used and how they can be avoided.
This Site sends your browser a cookie – a small piece of data stored on your computer’s hard drive. The purpose of the cookie is to improve your reading of and your search possibilities on our Site. If you are a registered Client (e.g. a publisher), the cookie will also manage and control your login and session on those part of our Site that are only available to registered Clients. If you do not want to accept that your computer receives and stores cookies, you can alter your security settings on your web browser (Internet Explorer, Netscape etc.). However, note that certain parts of our Site may only be used fully if your browser allows cookies. Thus, your reading experience of our Site may be affected negatively by removing and not allowing cookies. In addition, RaGaPa may serve ads on this and other websites using our own ad-serving technology. In doing so, one of our ad servers will place or read a unique ad-serving cookie on your computer and will use non-personal information about your browser and your activity at this site to serve ads on this and other sites. The ad-serving cookie is a persistent cookie.
Part 2 – Interest Based Advertising privacy principles
What is Interest Based Advertising and what services are provided by RaGaPa?
There exists a range of different kinds of online Interest Based Advertising services; from fairly simple forms to the far-reaching monitoring of web surfer activities carried out by search-engine owners or services carried out in partnerships between technology companies and Internet Service Providers. As a common denomination, you could say that Interest Based Advertising is intended to make online display advertising more relevant to web surfers’ likely interests. RaGaPa’s Interest Based Advertising services are cookie based. “Cookies” are small simple text files (not programs or spyware) stored on the hard drive of a web surfer’s computer. Based on the anonymous information stored in User’s cookie, RaGaPa is able to create an interest profile of that User in order to provide more relevant advertising to the User on behalf of our Clients. For example, a User that visits sports sites often will be categorized in the “sports fan” segment, and will primarily be served advertisements that are relevant to the interests of a sports fan. The fundamental integrity principle underlying all RaGaPa’s processing of digital data relating to Users, is that such data shall be anonymous. Therefore, we do not store IP addresses on the cookie of a User, only a unique randomly generated ID that does not allow RaGaPa to trace the User; we do not have, and will not initiate, any co-operation with Internet Service Providers in order to trace the identities of Users. The data stored on the cookie is limited to information collected at the User’s visits to websites belonging to RaGaPa’s Advertising Network. With the exception of a marginal proportion of cookies saved for statistic purposes solely, a User’s cookie can only be viewed by RaGaPa when the User visits a website that belongs to our Advertising Network.
Information stored on cookies
The cookie information stored on the User’s hard drive for Interest Based Advertising purposes is: (i) User segment hits (for example a User that visits a sport site of one of RaGaPa’s Clients, will record a hit in the ‘sports’ segment) and (ii) time and date stamp of the latest update of the User profile. The User segments used by RaGaPa for cookie hits are: (1) Animals; (2) Humanities; (3) Automotive (4) Business; (5) Computers & electronics; (6) Entertainment; (7) Finance; (8) Food & drink; (9) Gaming; (10) Health & beauty; (11) Home & garden; (12) Insurance; (13) Lifestyle & society; (14) News & current events; (15) Reference; (16) Shopping & retail; (17) Social; (18) Sports & recreation; and (19) Telecom & utilities. If the cookie is deleted by the User, the profile stored cannot be tied back to the User or the unique randomly generated ID.
For the sake of clarity, no segments relating to information which RaGaPa considers sensitive have been or will be created, such as segments relating to political opinions, religious beliefs, physical or mental health conditions or sexual life. Further, RaGaPa is very sensitive to the issue of children’s privacy and marketing directed to children. No segments are intended to be established for the profiling of children.
Use of collected digital data
RaGaPa will use the User data in order to better target advertisements on behalf of our Clients, to provide aggregated non-personal reporting to our Clients, and to improve our advertising systems and products. The data may be combined with other anonymous information collected from other sources so that we may better serve Users with offers that may be of interest to them. We may also share anonymous data between companies within the RaGaPa group of companies.
RaGaPa is dedicated to maintain the security of all its data and to prevent unauthorized access through the implementation of appropriate technical and organizational measures, as far as is reasonably possible. Such security measures also include access restrictions, i.e. that data may be accessed only by a limited number of persons within RaGaPa.
Display and delete your profile
You may at any time easily view and/or delete the profile that has been stored on your cookie. To do so, please follow the instructions on the following URL: http://www.captivexs.com/delete-cookie.html
You may at any time easily block further cookie-based Interest Based Advertising activities from RaGaPa by opting-out from our program. To do so please follow the instructions on the following URL: http://www.captivexs.com/uk-en/legal/targeting.html
In addition, note that you are always able to prevent cookies from any website from being installed on your computer by readjusting your browser settings. For more information about cookies and how to disable them, you should consult the help section of your browser.
For avoidance of doubt, please note that the foregoing requirement of notification does not limit any of your obligations according to applicable law. You are yourself as a publisher responsible for providing relevant and accurate information required by law, including applicable privacy laws.