TRUEWAVE AND GDPR
We are committed to consumer privacy and data protection, and have appointed a Data Privacy Officer to oversee our GDPR compliance program (contact information below).
Additional actions we are taking include:
- Implementing new internal controls to ensure Privacy by Design in our products on an ongoing basis
- Enabling processes to ensure data subjects have access to their itemized rights
- Enhancing our contracts with clients and partners to ensure all parties are able to meet their European compliance obligations
Truewave’s Data Privacy Officer (DPO) is Chandru Mullaparthi: [email protected]
Data Subject Rights (EU only)
This section addresses the Article 12 requirement for Transparent information, communication and modalities for the exercise of the rights of the data subject. An individual consumer who seeks access to personal data concerning them, or who seeks to correct, amend, request processing restrictions, object to processing, or delete personal data or exercise a right of portability should direct his or her query to the respective Truewave clients.
Truewave abides by the Data Subject Rights requests referenced within GDPR Articles 13-22 with respect to:
- Right to be informed (about processing activities and applicable rights)
- Right to access data (or obtain data being processed)
- Right to rectify information (when outdated or incorrect)
- Right to erasure (and to be publicly forgotten)
- Right to object to processing (particularly activities based on consent)
- Right to restrict processing (when processing is deemed to be unlawful)
- Right to data portability (between proprietary systems in a common format)
- Rights related to automated decision making (including decisions based on profiling activities)
Truewave and its subsidiaries and partners have put into place operational processes to comply with all Data Subject Rights requests within 30 days when received, however we may need to verify certain Personal data fields to ensure we act upon the correct data.
Right to be Informed about Processing (Articles 13 and 14):
- We respect and acknowledge that individuals frequently desire to access their personal information. However, we have no direct relationship with the individuals whose personal data we process on behalf of our customers. An individual who seeks access, or who seeks to correct, amend, or delete data should direct his or her query to the respective Advertiser. If Truewave is requested to provide assistance by said Advertiser, we will respond/act within 30 days. You may also Opt Out of our services, in which case, we will no longer process your Personal information.
Right to access data (or obtain data being processed) (Article 15):
- A user should first request this from the Advertiser, as we process data on their behalf (processor rather than controller) and as such we will also need their consent to release. We will then request verification of personal data prior to release of the information. If such information cannot be verified, we reserve the right to withhold fulfilment the request.
Right to rectify information (when outdated or incorrect) (Article 16):
- Once data access is given, as per Article 15, the user has the right to rectify. However, as this data is collected from the device at the time of the ad being served, it is usually factual (at the time). Truewave has a Contractual Obligation to report on advertisements being served, so the users personal data is not relevant to the ad serve action, which we are obligated to report.
Right to erasure (and to be publicly forgotten) (Article 17):
- Once Truewave’s Contractual Obligations are fulfilled, the user data may be overwritten/deleted to fully anonymize the individual upon written request and verification, as per Article 15. However, based on user action, they may appear in our system with a new GUID/Cookie ID. The Opt Out mechanism fulfils the user’s objective without risk of a new GUID or entry into our database.
Right to restrict processing (when processing is deemed to be unlawful) (Article 18):
- Truewave will suppress unique identifiers to halt processing if requested to by the Advertiser and individual following the actions in Article 15 and 17. User can also accomplish by the Opt Out mechanism.
Right to data portability (between proprietary systems in a common format) (Article 20):
- Truewave’s system is unique and proprietary making data portability difficult however if requested to, we will act in accordance of Article 15 provided that as per Article 20, a common format is available.
Right to object to processing (particularly activities based on consent) (Article 21):
- Similar to Article 17, users may object to processing by either requesting from the Advertiser or via our Opt Out mechanism. Truewave will comply with all such requests.
Rights related to automated decision making (including decisions based on profiling activities) (Article 22):
- While Truewave is a member of the advertising community, Truewave systems do not rely on any fully automated decision making, making this Article unlikely to apply to Truewave activities.