EUID Privacy Notice


EUID Overview

What is EUID?

EUID is a tool used in digital advertising to show you advertisements in a way that respects your privacy and does not rely on third party cookies. The UK Trade Desk Ltd (‘The Trade Desk’) is a controller for EUID, together with the advertisers and publishers who use it (we call these organisations ‘EUID participants’). This notice describes how The Trade Desk operates EUID and the rights and choices you have if you provide your email address or phone number. Click here if you want to skip ahead to the privacy notice.

Why do EUID participants use EUID?

EUID participants improve their digital marketing campaigns by offering you a better experience of digital advertising. With your permission, EUID enables participants to gather and combine data across different sites, apps, and other contexts, and to share data with each other in relation to the buying and selling of advertising online. This in turn improves the advertising you see online, because it helps advertisers to show ads that are more relevant to you, can limit the number of times you see the same ad, and Publishers are paid more for the same ad. This helps to fund their online content, and you may be able to access more online content at a lower cost or for free.

How does it work?

If you provide your email address or phone number to an EUID participant, such as a website where you log in, or with an advertiser where you have an account, then they can then send your email address or phone number to The Trade Desk to be turned into an advertising identifier (called an EUID).

Example:

You buy a pair of shoes from ShoesRUs.com, and ShoesRUs want to show you an ad for another pair of shoes it thinks you’ll like.

You later read the news on ilovenews.com. If both ShoesRUs.com and ilovenews.com have your EUID, ShoesRUs can make sure that its shoe ad is shown to you.

An EUID is made by putting your email address or phone number through complex algorithms to turn it into a string of text and numbers so that is no longer recognisable as that email address or phone number. It is not possible for anyone with the EUID to reverse this process to determine your email address or phone number.

Example:

An email address: janesmith@myemail.com turned into an EUID will be : ODJYV34CH3645SKGBNDK.

The Trade Desk uses your email address or phone number only to create the EUID and comply with data protection law. You can opt out from having your email or phone number used as an advertising identifer in EUID as a user at any time.

Click here to read more details about your rights and here for details on how to opt-out.

EUID Privacy Policy

This privacy notice describes how The Trade Desk manages EUID and your rights with respect to EUID. The Trade Desk is a joint controller with each EUID participant, as described more fully below, but this notice does not fully describe how advertisers and publishers may use an EUID after it is created. Their use of EUID is described in their own privacy notices.

The Trade Desk also processes EUIDs as a service for advertisers. This use is separate from The Trade Desk’s creation of EUID in this privacy notice. The Trade Desk Services Privacy Policy has more information about this processing.

This privacy notice applies only if you are based in the European Economic Area (EEA) or United Kingdom (UK), or your data is otherwise protected by EEA or UK laws.

Your Rights

You have the right to access your data, to ask us to provide it to you (or a third party) in machine readable format, and to correct, delete and restrict your data. These rights may be limited, for example if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. You can also object to our processing of your data.

If you want to exercise these rights in relation to EUID, you can contact either the EUID participants, using the details set out in their privacy notices, or you can contact The Trade Desk using the contact details provided in this notice. We may take reasonable steps to confirm your identity

How to withdraw consent or opt-out

If your email address or phone number has been used to create an EUID, you can withdraw consent or opt out and stop processing of the EUID at any time. You can do this via the EUID Transparency and Control Portal available here.

If you follow the steps set out at the Transparency and Control Portal, The Trade Desk will stop creating IDs relating to the email address or phone number you provided. We will also instruct EUID participants, to whom The Trade Desk has issued EUIDs, to stop using the EUID for targeted digital advertising campaigns.

Where an EUID participant has asked us to create an EUID from your email address or phone number, you can also contact that party directly to find out how to opt out with that EUID participant and stop their processing of your email address or phone number. If you want to stop all EUID participants creating and using IDs for your email address or phone number, you should use the Transparency and Control Portal.

If you withdraw consent, this will not affect the lawfulness of any processing based on consent before its withdrawal.

Joint Controllers

The Trade Desk and each EUID participant, to whom you provided your email address or phone number to generate the EUID, are joint controllers for the processing involved in submitting your email address or phone number to The Trade Desk, creating an EUID and returning the EUID to the EUID participant.

Other than as described above, The Trade Desk and EUID participants are separately responsible for complying with the data protection laws in the EU and UK. In particular, the EUID participant that provided your email address or phone number is the primary contact for assisting you in exercising your data subject rights, but you can also contact The Trade Desk as set out below, particularly if you want to opt out of all use of your data for the creation of EUIDs.

The data we collect and the purposes for which The Trade Desk and participants process data

The Trade Desk receives the email address or phone number you provided to an EUID participant, and from this creates an EUID by transforming it into a string of digits and numbers. Information on the form in which email addresses and phone numbers are retained by the Trade Desk is set out under our retention section below. The Trade Desk also holds information about the EUID participants that create each EUID in order to comply with data protection law and manage its relationship with those EUID participants.

EUID participants then use the EUID for targeted advertising purposes, such as to:

Each EUID participant decides separately if it wants to use the EUID for some or all of these purposes. More information on each EUID participant’s specific use of your personal data is set out in their respective privacy notices.

Legal basis for processing

The Trade Desk and EUID participants may only process your email address or phone number when we have a “legal basis” to do this. When we process personal data provided by a website or app publisher (for example, a news outlet that you visit), then the legal basis we rely on to process your personal data will be consent.

When we process personal data provided by an advertiser (a company from whom you have bought goods or services and who is allowed to send direct marketing to you) then the legal basis we rely on to process your personal data may either be consent or that the processing is necessary for the legitimate interests of The Trade Desk and the advertiser. Where we rely on legitimate interests, these interests are to provide you with more relevant advertising. Which legal basis applies is selected by the advertiser as our joint controller.

More information on this legal basis can be found in the advertiser’s privacy policy.

We also retain a hashed copy of each email address or phone number used to create an EUID, in order to assist us in the event that you seek to opt out, or withdraw consent. We may, if we receive a lawful request, disclose personal information in response to lawful requests from public authorities. Our legal basis for this is compliance with law.

Sharing and transfer

We will share your information with third parties only in the ways that are described in this policy.

We may also disclose personal information in response to lawful requests from public authorities, including to meet security or law enforcement requirements.

International transfers

When we transform the email address or phone number into an EUID, we do this in Europe. If an EUID participant from outside the EEA and the UK provides us with an email address or phone number, so that we can create an EUID, then we will share the EUID with that EUID participant; this will include (but is not limited to) partners in the US. The Trade Desk itself will also process the EUID in the US.

Whenever we transfer personal data outside the EEA and the UK, we ensure that there is a valid transfer mechanism, primarily by using data transfer agreements which are valid in the EEA and the UK.

Data retention

We store each EUID for up to 30 days from the date on which the EUID was created. If you withdraw your consent, or object to our processing your data, we keep a record of your objection for 5 years in order to implement your request.

We keep a hashed copy of the email addresses and phone numbers used to create an EUID. This is necessary for us to ensure compliance with your data protection rights.

Contact us

You may contact us regarding privacy matters as follows:

Email:  privacy  ((at))  thetradedesk  ((dot))  com

Global Data Protection Officer (DPO) The Trade Desk, Global Privacy Office 42 N. Chestnut St., Ventura, CA 93001 Email: dpo ((at)) thetradedesk ((dot)) com

If you have a concern regarding our privacy practices, please contact us via the contacts above. If after reasonable efforts, you believe your concern has not been satisfactorily addressed by us:

Changes to this policy

We may revise this policy at any time. However, if we make material changes, we will not apply them retroactively.

At a glance

Read the table for a quick overview.

Who we are:

EEA and UK: The UK Trade Desk Ltd. 10th Floor, 1 Bartholomew Close London EC1A 7BL United Kingdom

Email:  privacy  ((at))  thetradedesk  ((dot))  com

What we do:

Generate and facilitate use of EUIDs for targeted advertising online.

The data collected to produce EUIDs includes:

Your email address or phone number.

This is transformed to create a unique, pseudonymous advertising identifier, called an EUID.

How we collect data:

We collect data from our partners (advertisers, publishers) who submit email address for the purposes of generating a EUID.

The purposes for which the EUID is processed:

We generate EUIDs to allow partners to deliver targeted advertising to you

Sharing and transfer:

We generate and share EUIDs with partners who have supplied email addresses for conversion into an EUID. These partners will use this data for the purposes named above.

We may also disclose personal information in response to lawful requests from public authorities, including to meet security or law enforcement requirements.

International transfers:

We may transfer data from the country of origin to the US or other countries. We do so under a valid legal framework.

Data Retention:

We maintain generally accepted security methods to protect data collected for the generation of EUIDs.

We retain the EUID itself for 30 days each date the EUID is created.

Your rights and choices:

You have rights and choices with respect to the use of your personal data.

We may also disclose personal information in response to lawful requests from public authorities, including to meet security or law enforcement requirements.