13. INFORMATION ON THE PROCESSING OF YOUR DATA IN THE CONTEXT OF THE ACTIVITY AS DSP.

We use certain personal information in the context of the activity that TELECOMING develops as a demand-side platform (Display-side-platform, “DSP”).


A DSP is an advertising technology platform that operates in the programmatic advertising ecosystem, allowing the automated purchase of advertising space in real time, in order to connect with users or audiences interested in certain services or products and optimize the performance of campaigns.


TELECOMING participates in IAB Europe’s Transparency & Consent Framework (IAB TCF V.2.2.) and complies with its Specifications and Policies. TELECOMING’s identification number within the IAB TCF V.2.2. is 336. IAB Europe is the European-level association for the digital advertising and marketing ecosystem, through participation in the IAB TCF V.2.2. TELECOMING reinforces its commitment to transparency in the collection and processing of personal information. Membership can be consulted in the updated public registry TCF Vendor List.


– What personal data do we process? How do we obtain this information?
We obtain your data from publishers, on whose digital properties we display our ads, or from supply-side platforms (“SSPs”), which cooperate with publishers in order to deliver personalized ads.
From TELECOMING, we cooperate with the following SSPs:

You can read more about the privacy practices of SSPs and their use of cookies by clicking on each of the SSPs identified.
We also automatically obtain information regarding the characteristics of the device.
Specifically, the data we use for the development of the activity as DSP are IP address ranges, device characteristics (non-precise location, device type, screen size, device language, operating system/browser…), device identifiers (IDFA) and probabilistic identifiers.
The information collected is processed in aggregate form and associated with an identifier generated and subjected to a pseudonymization process, which prevents the direct identification of the user.
We also process data relating to the privacy preferences selected by the user and communicated to us by other operators participating in the IAB TCF V.2.2.


– For what purposes do we process personal data?
The activity of DSP gives rise to different data processing. In this regard, the specific purposes carried out by TELECOMING are described below (also indicating their identification according to the IAB TCF v2.2):


– Advertising selection (P.2 IAB TCF v2.2).
Select which advertisements to display, control the frequency and sequence the order of the advertisements displayed to facilitate a personalized experience.
Advertising presented to you as part of this activity may be based on limited data, such as the characteristics and context of the website or app you are using, your non-precise location, your device type, or what content you interact with (for example, to limit the number of times you are presented with an ad).


– Advertising Performance Measurement (P.7 IAB TCF v2.2).
Understand the reach and relevance of advertising campaigns, measure ad performance. Information about what advertising is presented to you and how you interact with it can be used to determine whether you have been interested in an ad and whether advertising objectives have been achieved. For example: measuring what percentage of the ad was viewed and for how long, quantifying interactions and knowing what the nature of that interaction was (click, tap, swipe, scroll, etc.), quantifying views, time of viewing, knowing the characteristics of the device on which the ad was served, …), measuring ad attribution, conversions and sales lift.
This activity is very useful to understand the relevance of advertising campaigns.


– Understand audiences through statistics (P.9 IAB TCF v2.2).
Generate global aggregate market research reports based on data sets relating to their interactions and those of other users with advertising content. These reports are used internally to study audiences (e.g., to determine which target audience is most receptive to an advertising campaign).


– Ensure security, prevent and detect fraud and correct errors (SP.1 IAB TCF v2.2).
Monitor and prevent unusual and possibly fraudulent activities, such as detection and general blocking of invalid traffic (e.g. advertising spam or automated browsing).
Identify errors in order to correct any problems related to the advertising displayed and ensure the operability of the platform, verifying that it functions correctly and securely.


– Deliver and display advertising and content (SP.2 IAB TCF v2.2).
Ensure the technical compatibility of advertising and facilitate the transmission of the content or ad to the device. For example, deliver compatible ads (language, operating system, connection type…), respond to a user’s interaction with the ad by sending it to a landing page or record the delivery of an ad. Generally, when you click on a link we use technical information automatically included in the request sent by your device, to correctly display the information you have requested. Technically, this exchange of information is necessary to provide the content that appears on your screen.


– Save and communicate your privacy choices (SP.3 IAB TCF v2.2).
Ensure and be able to demonstrate that users have consented to or have not objected to the processing of their personal data, for the intended purposes and/or processing by other providers registered with IAB TCF V.2.2.


What is the legitimacy of the processing?
All data processing deriving from DSP’s activity is based on the legitimate interest of the data controller.
The relevance of the use of the legitimate interest as a legitimate basis for processing has been assessed by TELECOMING for each of the purposes indicated,
To this end, the corresponding Legitimate Interest Assessments (“LIA” – Legitimate Interest Assessment) have been prepared by weighing the benefits, interests and rights affected through the performance of a triple test (purpose, necessity and suitability test).
Specifically, the legitimate interest on which each of the purposes identified above is based is described below:


– Advertising selection: the division of the audience into subgroups according to their different characteristics, making it possible to select the ads with which to impact the audiences that most interest the advertiser, as well as to control the frequency and sequence the order of the ads through data obtained in real time, improving the performance of advertising campaigns.
Likewise, the possibility of selecting advertising means a better user experience by receiving advertising adapted to the characteristics of their device and operating system, in their language, and about products or services that are actually available to them. In the same sense, it allows to adapt advertising to online content and to control the frequency of ads avoiding repetitive impact (for example, by limiting the number of times an ad is shown), resulting in less intrusive advertising.
Only in those cases where legitimate interest would have been opposed, TELECOMING will be able to base the processing of your data for the purpose of selecting advertising based on your consent, provided that the user has given it.


– Measuring advertising performance: measuring different parameters related to user interaction with the advertising presented is essential in DSP’s activity as it allows for service optimization. Knowing the impact achieved and the reach of the campaigns is essential to improve DSP service delivery, which translates into more appropriate and relevant advertising campaigns, less repetitive and improves the user experience in the online environment.


– Understanding audiences through statistics: aggregate market research reports are essential to optimize the service provided through knowledge of the reach and relevance of campaigns and to formulate marketing strategies that improve the performance of advertising campaigns. In turn, understanding audience behavior leads to more appropriate and relevant advertising campaigns, less repetitive and more useful user experiences.


– Ensuring security, preventing and detecting fraud and correcting errors: ensuring the proper functioning of the service and its secure provision is essential for the ecosystem in which DSP operates. In this regard, Recital 47 of the GDPR establishes fraud prevention as a legitimate interest of the data controller. The data processed are necessary to be able to monitor and prevent unusual and possibly fraudulent activities, also allowing to correct any problems related to the advertising displayed and to ensure the operability of the platform.


– To deliver and display advertising and content: to ensure the technical compatibility of advertising, and to facilitate the transmission of the content or advertisement to your device, which is essential for the provision of the DSP service. It also means a better user experience by receiving advertising tailored to the characteristics of your device, operating system and browser, as well as in the language of the place where they are located, or about products or services to which they will foreseeably have access.


– Storing and communicating your privacy choices: The choices you make regarding the purposes and entities identified in this privacy notice are stored and made available to other participating entities in the form of “digital signals” (such as a string of characters, called a TC String). This is necessary to ensure and check whether you have consented to or objected to the processing for any of the intended purposes, in order to respect your privacy choices. The processing is very relevant for TELECOMING since it ensures that the participants in the IAB TCF v2.2 can retrieve and observe the privacy choices of users and, consequently, develop their activity respecting the preferences of users. Likewise, this purpose, allows to know the user’s choice avoiding that he/she must continuously express his/her privacy preferences when accessing the same website.