# Compass Privacy Policy

In this Privacy Policy you will find all the information relating to the processing of your personal data by MARFEEL SOLUTIONS, S.L. ("Marfeel", "We", "Our" or "Us") as a Data Processor when you visit a publisher's website which uses our Compass Tool (hereinafter, the "Publisher(s)"). If you are a Compass CLIENT, this Privacy Policy forms part of our General Terms of Service.

This Privacy Policy only applies to users who, when visiting a Publisher’s website that has configured the Compass tool, accept its use ("You" or "Data Subject"), and only regarding the processing carried out through this tool. This Privacy Policy does not cover the general privacy practices of the Publisher or other processing that may take place through their website.

Note to California consumers: Take into account that, if you reside in California, in addition to this policy, Annex 1 will be applicable to you. In this Annex, you will find more information regarding the protection of your personal data in accordance with California regulations.

Note for users in Brazil: Take into account that, if you are located in Brazil, in addition to this policy, Annex 2 will be applicable to you. In this Annex, you will find more information regarding the protection of your personal data in accordance with brazilian data protection law.

# WHO IS THE DATA CONTROLLER FOR THE PROCESSING OF YOUR PERSONAL DATA?

When you visit a Publisher's website which uses our Compass Tool, the Data Controller will be the Publisher which owns the website you are visiting.

We, MARFEEL SOLUTIONS, S.L., act as Data Processors, meaning that We process your personal data on behalf of the Data Controllers (the Editors), following their instructions. Processor acts on behalf of the relevant controller and under its authority.

Our company details: MARFEEL SOLUTIONS, S.L.; Tax Identification Number: B65651259; Address: Josep Tarradellas Avenue, 20-30 Pl 6, 08029 – Barcelona (Spain). Contact Details: dpo@marfeel.com

# Data Protection Officer

We have appointed a Data Protection Officer (DPO) in accordance with the privacy regulations, who is at your disposal for any doubts, queries or issues you may have in relation to this Privacy Policy or the processing of your personal data within the scope of the Compass Tool, and whom you may contact through this email address: dpo@marfeel.com or this Company’s address: Josep Tarradellas Avenue, 20-30 Pl 6, 08029 – Barcelona (Spain).

# WHAT TYPE OF DATA DO WE COLLECT?

Information collected by tracking devices when using the Publisher’s Website. When you access the Publisher’s website, the following information is collected through cookies or other tracking tools. These tools are small files that are downloaded to your device and collect data about your use of the Website. Through these tools, we can collect:

  • Device Information: During your use of the Publisher’s website, we collect information about the mobile device, browser and/or operating system from which you access the Publisher’s website. The information we obtain is the model of the device, the operating system and version, the unique identifier of the device, and where appropriate the mobile network.
  • Location information: We also get the IP address, time zone, and mobile service provider, allowing Us to get your general location.
  • User Navigation Information: We collect information about your use of the Publisher’s website. Specifically, the frequency of use, the sections you visit, use of specific functions, time spent in each section, scrolling done, etc.

Information provided to Us by the Publisher: Publishers may submit to Us some personal information, such as your user ID in the Publisher’s website.

Information deduced or calculated through the Compass Tool: All the information We collect allows us to generate information regarding your interests (e.g. engagement to the media, favorite sections, contents, authors, etc. of the Publisher’s website or other similar parameters.

All previous information regarding Data Subjects will be aggregated or pseudonymized, which means that that each Data Subject will be assigned a randomly-generated identification code in order to detach the data from the individual identifying information (e.g. IP or MAC address) and thus guarantee that data which may reveal the identity of a Data Subject is not disclosed.

# WHAT ARE THE PURPOSES FOR THE PROCESSING OF YOUR PERSONAL DATA?

The specific purposes of the processing will be defined by the Publisher, which is the Data Controller of your Personal Data. However, here we explain the basic functions of the Compass Tool. We strongly recommend you visit the Publisher’s web Privacy Policy in order to know more detailed information about the purposes of the processing of your data.

The basic functions of the Compass Tool are the following:

  1. Elaborate real-time statistical reports and monitoring of your use of the Publisher’s website.
  2. Determine users' engagement to a Publishers’ website.
  3. Elaborate a user profile in order to identify specific groups of users and target each segment with communications, suggestions and other actions that may be more relevant for their particular behavior in the Publisher’s website, taking into account the information collected on his/her browsing.

Generally, this profiling takes into account the recency and frequency of the user’s interactions with the Publisher and the monetary value of those transactions to segment the different groups, although each Publisher may decide their own parameters.

The Publishers are required to provide you with appropriate information on the processing of your personal data.

All personal information collected through the Compass tool is processed by Marfeel as a Data Processor Consequently, the Publisher is the party responsible to establish the legal basis on which the personal data is collected and processed, which will have to be determined in their own Privacy Policies. We strongly recommend you to check the Publisher’s website policy to obtain details about the processing of your personal information.

When consent is the applicable legal basis, Publishers are required to obtain all Users consent to the use of cookies. Marfeel, as Data Processors, shall not be liable for the failure to obtain the user's consent or obtaining defective consent, when applicable, or for any use of Data Subjects’ personal data carried out by the Publisher not in accordance with the present Privacy Policy, our terms and conditions or applicable legislation.

# DO WE DISCLOSE YOUR PERSONAL INFORMATION TO THIRD PARTIES?

In general, we will not transfer your data to third parties outside the Publisher which is the Data Controller, except if required to do so by the Publisher or when required by a public authority, the justice administration, or law enforcement agencies in compliance with legal obligations applicable to Us.

However, we may employ third companies or professionals to perform specific tasks on Our behalf that involves them to have limited access to the personal data. One of these service providers is the data hosting service provider SCALEWAY SAS, a hosting provider located in France which guarantee a high level of security and availability of the information systems.

We sign specific agreements with our service providers that include a duty of confidentiality and are also required to have the same, or higher, level of security to protect the information provided to them.

# International transfers of Data

We may transfer your personal data to our subsidiary Marfeel Colombia S.A.S, located in Colombia, a country outside the EEA (European Economic Area) for support purposes. Although the existence of this international transfer of your personal data could mean a lower degree of protection than that provided for in European regulations, we have signed the corresponding standard contractual clauses approved by the European Commission with our subsidiary, an agreement by which we guarantee that it is applied the European data protection standards. Therefore, this transfer does not result in a lower level of protection of your personal.

The servers that host the database are located within the EU.

# HOW LONG DO WE STORE YOUR PERSONAL DATA?

Your Personal Data will only be kept in a form that permits your identification for no longer than is necessary for the purposes for which it was processed, according to the instructions given to Us by the Publishers.

At the end of the contractual relationship with our publishers or when requested by them, we will make reasonable efforts to return or irretrievably erase all personal data processed on behalf of Our Publishers. However, We may keep the information blocked in order to comply with the legal storage periods or in order to defend any actual or possible legal claims.

We will take reasonable measures to periodically review the data held, and erase or anonymise it for statistical purposes when it is no longer needed.

# WHAT ARE YOUR RIGHTS AS DATA SUBJECT?

As the Publisher is the Data Controller of Your Personal Data, You may exercise Your data protection rights before the Publisher. The Publisher should inform you about the rights you have as a data subject in its privacy policy and how you can exercise them. Nevertheless, you may exercise your rights before Marfeel, in which case, we will inform the Data Controller about said exercise so that it may take the appropriate actions.

In this section we inform you about the data protection rights that you can exercise before the Publisher or before Marfeel in relation to the protection of your personal data.

You may exercise your rights at any time and free of charge by sending an e-mail to the following e-mail address: dpo@marfeel.com or Marfeel’s postal address: Josep Tarradellas Avenue, 20, 08029 – Barcelona (Spain).

Any claim We receive will be resolved as soon as possible and, in any event, within the periods established by law. In some cases, it may be necessary to ask for a copy of your identity document or other identifying document if it is necessary to verify your identity.

As explained before, depending on the request, it may be forwarded to the Publisher which is the Data Controller of Your personal data.

# Right of access

You have the right to know which data are being processed, if any, and, if so, to obtain a copy of them, as well as to obtain information concerning: the origin and recipients of the data; the purposes for which they are processed; whether there is an automated decision-making process, including profiling; the period of data retention; and the rights provided by law.

# Right of rectification

You have the right to obtain the rectification of your personal data or to complete them when they are incomplete.

# Right to erasure

You have the right to request the deletion of your personal data if they are no longer necessary for the purpose for which they were collected or if we are no longer authorised to process them.

# Right to data portability

You have the right to request data portability in the case of the processing of your data based on your consent or the execution of a contract, as well as when the processing is carried out by automated means. If you exercise this right, you will receive your personal data in a structured format, commonly used and readable by any electronic device. However, you can also request, where possible, that your data be transmitted directly to another company.

# Right to the limitation of the treatment of your personal data

You have the right to limit the processing of your data in the following cases:

  1. When you have requested the rectification of your personal data during the period in which we verify their accuracy.
  2. When you consider that it is no longer necessary for us to continue processing your data and you want us to keep them for the purposes of exercising or defending claims.
  3. When you consider that we are not authorized to process your data. In that case, you can ask us to limit their use instead of requesting their deletion.
  4. In cases where there is a processing based on our legitimate interest and you have exercised your right to object, you may ask us to limit the use of your data during verification of the prevalence of such interests over yours.

# Right to object

You have the right to object at any time to the processing of your personal data based on our legitimate interest and, when applicable, profiling.

You can withdraw your consent in connection with all processing based on it. However, we remind you that the withdrawal of consent will not affect the lawfulness of processing based on consent prior to withdrawal.

# Right to file a complaint with the Supervisory Authority

Remember that, at any time, and in case you consider that we have infringed your right to the protection of your data, you will be able to a complaint with the corresponding Authority in Data Protection, in the case of Spain, the Spanish Data Protection Authority (www.agpd.es (opens new window)).

# CHILDREN

Our COMPASS TOOL is not intended to collect personal information from minors. If we become aware that a child under the legal age to grant valid consent,according to applicable national privacy regulations, has provided us with his/her personal information, we will take steps to remove such information.

However, if you become aware that your child has provided us with personal information without your authorization (when he/she does not reach the minimum age to grant a valid consent), please contact us at dpo@marfeel.com or at the contact address of the Publisher whose website your child provided the data.

We will take reasonable steps to remove such data as soon as possible.

# HOW DO WE PROTECT YOUR PERSONAL DATA?

As explained before, all data collected by the Compass Tool will be pseudonymized, so that each Data Subject will be assigned a randomly-generated identification code and/or any other kind of pseudonymization technique in order to erase data that may directly or indirectly identify them particularly (e.g. anonymizing the last octet of the IP address).

The data hosting service provider, SCALEWAY SAS, which manages the datacenter where the services are placed, guarantees a high level of security and availability of its services, complying with international security certifications, such as TIER 3, Healthcare HDS, ISO 27001 or ISO 50001, according to the information provided in its web site on the date of publication of this Privacy Policy.

Therefore, the Personal Data will be securely hosted and made available to the Publishers through controlled and secure access. Strict measures will be taken to ensure the pseudonymity and non-identifiability of the Data Subject.

All persons authorized to access the personal data are required to know and observe the policies, rules, and security procedures that are applicable to the performance of their duties and the processing of personal data. In this context, they have committed themselves to confidentiality by signing the corresponding confidentiality agreements.

Also, we provide our Publishers with the instructions and documentation so that the collection and use of the data by the Compass Tool is done correctly and securely. However, we cannot be held responsible for the practices and procedures performed by them.

Finally, we have conducted a partial privacy impact assessment (PIA) to evaluate the adequacy of the data processing carried out by Marfeel as Data Processor through the tool and manage the risks that may exist in relation to the privacy of users. You can obtain our public privacy impact assessment report upon request at the following electronic address: dpo@marfeel.com.

# UPDATES TO THIS PRIVACY POLICY

This Privacy Policy may be subject to some further updates in the future, either to improve it, or to comply and adjust to new applicable legislation that may affect the processing, collection and management of personal data. We will try to notify you beforehand of any material changes that may apply to you, although this may not always be possible.

By continuing to access or use Our services after those changes become effective, you agree to be bound by the revised Privacy Policy.

This Privacy Policy has been updated and published on 1 February 2021.