PRIVACY MATTERS

Ozone is a company that helps premium publishers make money from the advertising on their websites and mobile sites, to re-invest in their journalism. We provide a digital marketplace, which enables advertisers to buy advertising space on websites owned or controlled by publishers; and allows them to provide targeted advertising across a number of journalistic websites. We work with publishers such as: News UK & Ireland Limited, Guardian News & Media Limited, Telegraph Media Group Limited, and Reach Plc you can see a full list here {publisher list}. To make it simple we’ll call them “the Publishers” on this page. 

Ozone is a member of IAB UK and complies with the IAB Europe Transparency & Consent Framework Policies. IAB Europe is the European-level association for the digital marketing and advertising ecosystem. Through its membership of national IABs and media, technology and marketing companies, its mission is to lead political representation and promote industry collaboration to deliver frameworks, standards and industry programmes that enable business to thrive in the European and UK market.

Ozone is based at 20 St Thomas Street, London, United Kingdom, SE1 9RS, is a data controller of the personal information about you that we process. This means that we decide how and why we use the personal information we get about you.

Privacy contacts

If you have questions or requests about how we use your personal data (including using any of your rights), or need additional information, you can contact us at [email protected].

When you visit our website

Our website uses simple analytics tools to tell us things like, which pages you visited, how long you stayed on them. We do not collect other information or use your device data to target you with advertising. 

When you contact us as a company or any of our staff

When you contact us to inquire about our company, or any of the services and products we provide, we will collect the details we need to help you. These will include personal data such as your name, company, email, phone number and so on.  We will only use these details in order to assist you in your inquiry. If we want to stay in touch with you we will ask for your permission to do so. 

Website usage data is collected using cookies on our website. All other data we receive directly from you when you contact us about our services. 

We use your personal information for the following reasons:

• To Operate our website. To understand how people use our website and improve it for you and other people visiting it.  
• To Operate our business. To respond to queries about the products and services provided to our publishers, advertisers and advertising agencies. Once we are working with you we keep you details to ensure we can deliver whatever you’ve ordered. We’ll also use them to make sure we’ve been paid! We also have to conduct normal business functions such as auditing, data analysis and research to help us deliver and improve our technologies, processes and services. 

Comply with applicable laws and regulations. Such as an inquiry by the Data Protection Authority.

When you visit our website we have a Consent Management Platform (CMP) that allows you to control which types of cookies we drop on your machine. We will only collect analytics if you have allowed us to, or given us your consent as it’s often called. If you switch off Analytics cookies we will only drop those cookies that we need to run the website. 

If you contact us as a business we will use your details to help us with your inquiry and any work we then do with you. If you do decide to work with us we will use your details as required in the contract. We will sometimes use your details to help us in our business objectives or if there is a law which requires us to do so.

We only keep aggregated data about our website and it’s use. This is constantly updated and we do not have access to the underlying cookie data. 

We’ll keep the data you give us as part of a business relationship as long as that relationship is in existence and for up to 7 years after it ends, in line with relevant UK tax and business laws.

We may need to share your personal details with our professional advisors, like lawyers or auditors, but only when needed. We may also use other organisations to help us with our business. For example, if we are inviting you to an event or to a meeting may need to pass your details to the venue owner or others helping us with the organisation. 

We may need to share certain of your personal information with regulators, governments and law enforcement authorities.

Transfers of your personal information outside of your home country

Our website uses Google Analytics and, if you consent to their use, Google cookies are dropped on your device. Google will then process them on their servers which we have contractually insist are in the UK or EU. 

We also use Google Cloud Platform (GCP) to store and process all of our documents as a business. Therefore your personal details will be stored on Google servers. Again, we have contractually obliged Google to use servers in the UK & EU. If you are contacting us from outside the EU and UK we will need to respond to your communications using your details which will obviously involve send them back outside the UK. 

There may be other unusual occasions when we need to transfer your details to companies outside of your own country. If we do, we need to point out that the receiving country may not be equivalent to, or as protective as, the laws in your home country. We will however, put in place appropriate mechanisms to ensure that the transfer is legal and safe under data protection laws.

ow we protect your personal information; and your rights regarding your personal information

We use a variety of security measures across our website and our services to make sure that we keep your data safe. We have an external specialist company advise and support us on cyber security, and constantly review the measures we have in place.

Your rights

We run a marketing email and you have an absolute right to opt-out from it. Just drop us a line at the email address below and we will remove you from it. 

The are also other rights you have under UK Data Protection legislation. In summary they are: 

• ask for a copy of any personal details (often called personal data) that we hold on you;
• ask for us to delete your personal data;
• ask us to correct any details we’ve got wrong about you. 
• ask us to stop using your data for a time; 
• tell us to stop using your data if we are doing so based on your telling us we could. 
• Ask us to send the data we hold about you to another organisation; and
• complain to your local Data Protection Supervisory Authority if you think we’ve broken a data protection law or not given you your rights correctly. 

If you don’t supply us with your personal data we may not be able to supply you, or your organisation, with the service or product you require. Even if you withdraw your agreement for us to use the data or to delete it we may have legal reasons why we have to keep using it for a while. We’ll explain this at the time.   If you would like to exercise your rights, please let us know by getting in touch at [email protected] (if you would like to exercise any other rights that you may have).

Many organisations use very legal language in their Privacy Notices for those that like, or want such things, here are the main points again in the language of the law. 

All of the following have already been explained in the preceding sections, but there we have tried to use plain and simple language to make our processing as clear as possible, This section uses the technical or legal terms to allow you to see the legal terminology for what we are doing.  

Data Controller: Ozone Ozone Project Ltd is based at 20 St Thomas Street, London, United Kingdom, SE1 9RS

ICO Registration reference: ZA548524

Legal Basis of processing

We use your personal information on the following legal basis:

• Because you have given your consent. At times we may ask for your consent to allow us to use your personal information for one or more purposes. We may request your consent either directly (e.g. when you interact with us via our website), or the organisation. via one or more of our trusted partners. See the Your rights section for information about the rights that you have if we process your information on the basis of your consent.
• Contractual Necessity. We need to use your personal data in order to perform the contract that is in place between us or your organisation, or to take appropriate steps prior entering into such a contract. 
• For legitimate business purposes. Using your personal information is necessary for us to operate and improve our business, as it promotes an understanding of when and how individuals engage with us and/or our trusted partners, and enables the provision of relevant content and advertising for your benefit.
• To comply with legal and regulatory obligations. In some cases, we may have a legal obligation to use or keep your personal information.

What information do we collect about you? 

We collect some personal data directly from you. This includes: 

• Contact details: When you provide us with details necessary for the company to work with, or for, us. 
• Cookies: Analytic cookies when we have your consent.
• Service data: Please see the terms of your agreement with Ozone to understand how any data collected during the provision of our services to you is processed. 

​​In addition to the information you provide us directly, we may receive information about you from others, including:​

• Service providers: We may engage service providers when we need to carry out legally required checks (such as AML).

​​Who do we share your information with?

With third party organisations 

We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including personal information hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.  We may also provide aggregated (anonymised) information to third parties.

When required by law

We may disclose your personal information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

 To enforce legal rights

We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

With your consent or at your request

We may ask for your consent to share your personal information with third parties.
In any such case, we will make it clear why we want to share the information.

Retention

Your personal information will be stored in accordance with applicable laws and kept for as long as needed to carry out the purposes described in this Privacy Notice or as otherwise required by applicable law.

International transfers

• Your personal information will normally be processed in the UK or EU. However, in some unusual circumstances it may be processed by Ozone, its affiliated companies and Ozone’s trusted third party suppliers anywhere in the world, including in countries where data privacy. 
• We will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside of your home country, in accordance with applicable data protection and privacy laws. These measures include data transfer agreements implementing standard data protection clauses. 

Security

We use a variety of security measures and technologies to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection and privacy laws. 

Although we will do our best to protect your personal information once with us, we cannot guarantee the security of any personal information sent to our site while still in transit and so you provide it at your own risk.

Your Rights

• ask about the processing of your personal information, including to be provided with a copy of your personal information;
• request the correction and/or deletion of your personal information;
• request the restriction of the processing of your personal information, or object to that processing;
• withdraw your consent to the processing of your personal information (where your personal information is being processed based on your consent) by emailing [email protected];
• withdraw your consent to the use of cookies by following the instructions in Manage your cookie preferences section of this privacy policy;
• request receipt or transmission to another organisation, in a machine-readable form, of the personal information that you have provided to Ozone; and
• complain to your local supervisory authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your personal information.

Where you are given the option to share your personal information with us, you can always choose not to do so. If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described (see How do we use your personal information?) or that you are unable to make use of the services and products offered by us. After you have chosen to withdraw your consent Ozone may be able to continue to process your personal information to the extent required or otherwise permitted by law.