What is the GDPR and How it Affects Affise Customers
On May 25, 2018, The European Union enforces a new data privacy law, the General Data Protection Regulation (GDPR). A primary aim of the GDPR is to harmonize data privacy laws across Europe, to protect and empower all EU citizens data privacy and to reshape the way organizations across the region approach it.
Any company that collects or processes personal data of persons in the EU falls under the scope of the GDPR, even if the company has no physical presence in the European Union. This means that most businesses with a global or online presence, including Affise customers are affected.
GDPR Compliance as Shared Responsibility Between Data Controllers and Data Processors
Data Controller ‘Controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data
Affise clients are data controllers.
Data Processor ‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Affise is a data processor.
Our Commitment to You on Behalf of Your Data Processor.
How does Affise Prepare for the GDPR?
Collection of Personal Data
We enable our users at the account level to opt in for real-time IP obfuscation and unique Device ID blanking for all EU countries.
- IP obfuscation (replacing the last octet of the IP with a 0) currently exists within the platform for German IPs, and will be expanded to include all EU countries.
- Device ID blanking will replace any incoming values from these macros with an empty string.
- device_id, android_id, ref_android_id, ref_device_id
- user_id, unid
Data Collection and Retention Policies:
With data minimization principles in mind, we’ve made the following changes:
- IP addresses and the above listed Device IDs will have a 120-day rolling retention.
- All log-level reporting will have a 12-month rolling retention period.
- Note: these retention window changes will only impact the Conversion Report and Click Logs. All Stats Report queries will still be available beyond these retention windows, though Affiliate Sub 1-8 or Source stats queries are available for 18 months.
Data Deletion Process:
The measures that are required by articles 17, 30 and art. 32 para. 4 GDPR. include:
Physical Access Control
Our physical data centers are secure. Security measures include having security officers onsite, monitoring and alarm systems, video/CCTV monitors and much more. No person, not even a member of Affise, has self-determined access to the servers.
Data Access, Usage and Transmission Controls
Tools in place to protect unauthorized access, usage or transmission of data. The data cannot be changed or deleted by unauthorized persons during transmission.
To keep data private and secure we ensure that any information collected for different purposes is separate during processing. This extends to test systems and production systems as well.
Any data is hashed as early as possible. The processing of personal data happens in a way that the data can no longer be assigned to a specific data subject without additional information being provided.
Availability Control and Rapid Recoverability
Frequent backups protect all stored data against loss. Affise creates continuous backups, which are also transferred to a remote site. With this, we can restore data if lost.
Incident Response Management
If data is lost we inform those affected immediately.
* Deleting Affiliate, Advertiser, and Account Employee Personal Data
- You will have an option to permanently delete any personal data you store regarding your affiliates, advertisers, or employees.
- Note: When deleting end user, affiliate, advertiser, or employee data, we will not delete the entire user record, just the column containing the PII, to ensure the accuracy of your aggregates.
Privacy by Design
Affise has implemented appropriate technical and organizational measures into our software development life cycle for ensuring that personal data is processed strictly in accordance with our customers’ instructions and configurations.
- Personal Data is collected only when assurance of user consent is obtained
- No selling or re-brokering of personal data
- Opt-out/opt-in options
- Honoring do-not-track privacy choices
While the content on this page is to help you understand the GDPR when working with third parties, the information contained should not be construed as legal advice. You should consult with your own legal counsel with respect to interpreting your unique obligations under the GDPR and the use of a company’s products and services to process personal data.
For more on our GDPR compliance, get in contact with our privacy team — firstname.lastname@example.org.