IgnitionOne is committed to transparency, and we want EU data subjects to have access to personal data that we may have about them and/or the devices that they may use to access the Internet.
Your EU Data Subject Access Rights
If you make a subject access request as set out in this policy, you are entitled to see the personal data that we have about you including any digital identifiers such as cookie IDs and mobile advertising IDs that IgnitionOne may store. We will also do our best to provide you with other information that we may have stored and associated with your personal data and digital identifiers—for example, transaction logs reflecting where one of our customers used or attempted to use our services in a way that impacts a website or application that you accessed.
We will provide you with the ability to see the personal data that we have by providing you with a copy of that data. You have the right to port that data to a different entity than IgnitionOne, although we can’t guarantee that others will be in position to ingest this data. We will also provide you with the ability to correct errors in the data, but reserve the right to simply delete data which you’ve indicated may contain errors or inaccuracies. We will restrict or cease processing of this data upon request and offer you the ability to object to our processing of this if you visit https://www.ignitionone.com/cookie-opt-out/. And we will delete the data upon request so long as we are not prohibited from doing so by applicable law and/or the information is not required for us for billing, fraud prevention or security purposes.
Please note that some of the information we process is owned and/or controlled by our clients as controllers of that data. We provide our customers with tools to help them honor your EU Data Subject Access requests directly. Where we are merely the agents and/or processors of data, we may be prohibited from processing this data except as directed in writing by those clients. If that’s the case, we will submit your request to the applicable client and await their written instructions. Also, if we are unable to locate any of the information you have requested, we will let you know.
Making an EU Data Subject Access Request
Step 1: Locating Your Information
Providing us with your email address and telephone number should be relatively straightforward. Please note that we will send you an email to the address(es) provided in order to help us authenticate your request.
Here’s what you need to do in order to share your digital identifiers.
Please keep in mind that different cookies are placed on each browser that you use to access the Internet. As a result, if you use multiple browsers (for example, Google Chrome and Mozilla Firefox), you will need to locate our cookies for each browser. Your browser’s help section should provide an overview of how to locate your cookies. An internet search of how you may find cookies in your browser may also be helpful. If you need more assistance locating these cookies for your browser, please feel free to email us for assistance at GDPR-request@IgnitionOne.com.
Additionally, certain mobile devices (for example, mobile phones or tablets using the iOS or Android operating systems) generate persistent a “Advertising Identifier” per device, which, among other things, can be used by third parties for purposes of providing you with targeted advertising. On iOS devices, your Advertising Identifier may be referred to as an “IDFA,” “IFA,” or an “ID for Advertising.” On Android devices, your Advertising Identifier may be referred to as an “Advertising ID.” Please follow instructions from your mobile device manufacturer on how to locate your specific Advertising Identifier.
Step 2: Authentication of the Information Provided
In order to make sure that we are only providing personal data to the correct person, we also will need to take reasonable steps to authenticate your request. We request that you provide screen shots of any cookies and mobile Advertising Identifiers for which you are submitting a request. We also reserve the right to send you an email to any addresses you provide in order to authenticate that portion of your request. If we only have your cookie or mobile ID in our database, we also request that you fill out and sign the affidavit we’ve prepared. By filling out and signing the affidavit, you’re promising IgnitionOne that you’re the person listed on the affidavit, and proof to demonstrate that you are indeed connected to the personal data and digital identifiers you located in Step 1. If we have your email address in our database, no affidavit is needed.
Step 3: Contacting IgnitionOne
Once you have located your Digital Identifiers and can provide us with verification of those Digital Identifiers, you should reach out to us. The easiest way to do so would be to email us at GDPR-request@IgnitionOne.com. Please make sure to include the following information in your email:
- Your full name
- The country in which you are located at the time you are making your request
- A signed affidavit (if required), linked in Step 2
- The screenshots providing supporting proof of the Cookie IDs and Mobile Advertising IDs, as described in Step 2
EU data subjects can also make a subject access request by mail, by sending a written request with all of the above-listed information to the following address:
Attn: GDPR Request
470 Park Avenue South, 6th floor
New York, NY 10016