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Behavioural Advertising – Terms & Conditions for Our Advertising Partners

This communication forms part of the agreement between Independent News & Media plc. (“INM”, “we”, “us”, “our”) including its subsidiaries and advertising parties (“you” “your”) who place or facilitate the placement of paid-for advertisements on our websites or apps, and is intended to ensure that the privacy rights of users of our websites are adequately protected in line with applicable data protection regulations.

Rationale

When a user visits one of our websites, the user's browser or device may transmit their IP address or other identifier to you through the advertisements we facilitate you to place on our platforms. We understand that in certain circumstances you may proceed to use that data or my place cookies to tailor advertising towards those users, both on our site or around the web.

The Article 29 Working Party guidance on Behavioural Advertising confirms that unique identifiers which enable data subjects to be singled out for the purpose of tracking user behaviour while browsing on different websites is considered to be personal data.

In this scenario, it is important to note that we the publisher do not transfer the IP address or other identifier of the visitor to you the advertisement provider. Nor do we set cookies on your behalf or have any means to access any data you collect through the encrypted advertising units you use.

Our Approach

Notwithstanding, INM takes its responsibility towards the privacy of our users incredibly seriously. Therefore, with effect from May 25th, 2018, we will be notifying users upon first visit to the INM websites and apps of the range of behavioural advertising activities that may be undertaken through those websites and apps. In addition we will actively direct users to industry standard frameworks from where they can manage their online privacy with regards to behavioural advertising on our platforms and across the web.

INM has chosen to support in the IAB Europe GDPR Transparency & Consent Framework as the most feasible cross-platform framework for the online advertising industry. It is our expectation that all of our advertising partners also participate in this framework. Given the range of advertising partners across our sites, it will not be feasible to provide access to individual privacy statements and consent mechanisms for advertising partners outside of the IAB framework.

Responsibilities

Since INM does not determine the means and purposes of personal data processing that you control on data collected through advertisements placed on our websites, it is your responsibility to ensure that data subjects, are fully informed of how their data may be processed.

As a valued advertising partner of INM we require that you do not process personal data collected through our websites without first having the necessary and appropriate consent from end users.

It is also your responsibility to ensure data subjects are notified of changes to how their data is processed and of any data breaches. You must also provide contact information for your data controller who can facilitate queries and subject access requests.

For the avoidance of doubt, you are obligated to ensure that all third parties that you in turn facilitate to collect personal data through your secure technologies on our websites and apps, are likewise fully compliant with local and EU regulations.

You are responsible for and shall indemnify INM against any and all losses and/or claims relating to your failure to lawfully collect, adequately control and protect the personal data you collect through advertisements which we facilitate you to place on our websites and/or apps.

INM’s privacy policies for each of its websites and apps are easily accessible through the navigation for those websites and apps. These policies inform end users of the personal data we are aware of that is collected and processed through our platforms. You are responsible to inform us of any amendments to this policy required in order to provide the adequate notice to our end users of a site you are advertising through. This is particularly relevant having regard to the information contained in the cookie policy also.

These terms and conditions take affect from May 25, 2018. If you are unable to comply with any aspect of the above, you must notify us immediately and cease all collection and processing of personal data through our platforms at that time.