Cookie Policy of theViewer Service
This document informs Users about the technologies that help theViewer Service to achieve the purposes described below. Such technologies allow the Owner to access and store information (for example by using a Cookie) or use resources (for example by running a script) on a User’s device as they interact with theViewer Service.
For simplicity, all such technologies are defined as "Trackers" within this document – unless there is a reason to differentiate.
For example, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, within this document, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker.
Some of the purposes for which Trackers are used may also require the User's consent. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document.
TheViewer Service uses Trackers managed directly by the Owner (so-called “first-party” Trackers) and Trackers that enable services provided by a third-party (so-called “third-party” Trackers). Unless otherwise specified within this document, third-party providers may access the Trackers managed by them.
The validity and expiration periods of Cookies and other similar Trackers may vary depending on the lifetime set by the Owner or the relevant provider. Some of them expire upon termination of the User’s browsing session.
In addition to what’s specified in the descriptions within each of the categories below, Users may find more precise and updated information regarding lifetime specification as well as any other relevant information – such as the presence of other Trackers - in the linked privacy policies of the respective third-party providers or by contacting the Owner.
Activities strictly necessary for the operation of theViewer Service and delivery of the Service
TheViewer Service uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service.
Other activities involving the use of Trackers
Experience enhancement
TheViewer Service uses Trackers to provide a personalized user experience by improving the quality of preference management options, and by enabling interaction with external networks and platforms.
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Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of theViewer Service.
The interaction and information obtained through theViewer Service are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on theViewer Service isn’t being connected back to the User’s profile.
Twitter Tweet button and social widgets (Twitter, Inc.)
The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.
Personal Data processed: Cookies and Usage Data.
Place of processing: US – Privacy Policy.
Measurement
TheViewer Service uses Trackers to measure traffic and analyze User behavior with the goal of improving the Service.
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics
Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on the location theViewer Service is accessed from, (“Google”). Google utilizes the Data collected to track and examine the use of theViewer Service, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Legal basis for Data transfer outside the EU: Privacy Shield.
TestFlight (Apple Inc.)
TestFlight is a beta testing service provided by Apple Inc.
Personal Data processed: Cookies, email address and Usage Data.
Place of processing: US – Privacy Policy.
User ID extension for Google Analytics (Google Inc.)
Google Analytics on theViewer Service makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device.
The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by theViewer Service.
The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well.
Personal Data processed: Cookies.
Place of processing: US – Privacy Policy – Opt Out.
Google Analytics Advertising Reporting Features (Google Inc.)
Google Analytics on theViewer Service has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy – Opt Out.
Google Analytics for Firebase
Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC or by Google Ireland Limited, depending on the location theViewer Service is accessed from.
In order to understand Google's use of Data, consult Google's partner policy.
Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.
TheViewer Service uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.
Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.
Personal Data processed: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)
Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on theViewer Service. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.
Personal Data processed: Cookies and Usage Data.
Place of processing: US – Privacy Policy.
HubSpot Analytics (HubSpot, Inc.)
HubSpot Analytics is an analytics service provided by HubSpot, Inc.
Personal Data processed: Cookies and Usage Data.
Legal basis for processing: Consent.
Place of processing: United States – Privacy Policy – Opt Out .
theViewer Analytics
Personal Data collected
Anonymized User ID
Usage data
Privacy Policy
theViewer Analytics is a heat mapping service provided by theConstruct B.V.. theConstruct B.V. utilizes the Data collected to track and examine the use of theViewer Service, to prepare reports on its activities and share them with content owner.
theConstruct B.V. may use the Data collected to contextualize and personalize the data stored on theViewer Service.
Place of processing: EU – Privacy Policy of theViewer Service
Opt Out: Please clean cache of native theViewer app or web browser for theviewer.co web page, after that no more data will be collected and after that activity you will be again asked to state your consent about sharing analytical data with theViewer Service.
Legal basis for processing: Consent.
Legal basis for Data transfer outside the EU: Privacy Shield.
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Content performance and features testing (A/B testing)
The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of theViewer Service.
Google Optimize
Google Optimize is an A/B testing service provided by Google LLC or by Google Ireland Limited, depending on the location theViewer Service is accessed from, ("Google").
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies and Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Targeting & Advertising
TheViewer Service uses Trackers to deliver personalized marketing content based on User behavior and to operate, serve and track ads.
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Commercial affiliation
This type of service allows theViewer Service to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with theViewer Service.
For details of which data are collected, please refer to the privacy policy of each service.
iDevAffiliate (iDevDirect LLC)
iDevAffiliate is a commercial affiliation service provided by iDevDirect LLC.
Personal Data processed: Cookies and Usage Data.
Place of processing: United States – Privacy Policy.
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Remarketing and behavioral targeting
This type of service allows theViewer Service and its partners to inform, optimize and serve advertising based on past use of theViewer Service by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Remarketing with Google Analytics
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location theViewer Service is accessed from, that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data processed: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of theViewer Service with the Facebook advertising network.
Personal Data processed: Cookies and Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or by Facebook Ireland Ltd, depending on the location theViewer Service is accessed from, that connects the activity of theViewer Service with the Facebook advertising network.
Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.
Personal Data processed: Cookies and email address.
Place of processing: US – Privacy Policy – Opt Out.
Google Ads Remarketing
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location theViewer Service is accessed from, that connects the activity of theViewer Service with the Google Ads advertising network and the DoubleClick Cookie.
Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Cookies and Usage Data.
Legal basis for processing: Consent.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Legal basis for Data transfer outside the EU: Privacy Shield.
Data retention period: Keeping the data, for the time necessary to fulfill the purpose.
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User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to theViewer Service, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving theViewer Service.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on theViewer Service.
Intercom (Intercom Inc.)
Intercom is a User database management service provided by Intercom Inc.
Intercom can also be used as a medium for communications, either through email, or through messages within theViewer Service.
Personal Data processed: Cookies, email address, Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
How to manage preferences and provide or withdraw consent
There are various ways to manage Tracker related preferences and to provide and withdraw consent, where relevant:
Users can manage preferences related to Trackers from directly within their own device settings, for example, by preventing the use or storage of Trackers.
Additionally, whenever the use of Trackers is based on consent, Users can provide or withdraw such consent by setting their preferences within the cookie notice or by updating such preferences accordingly via the relevant consent-preferences widget, if available.
It is also possible, via relevant browser or device features, to delete previously stored Trackers, including those used to remember the User’s initial consent.
Other Trackers in the browser’s local memory may be cleared by deleting the browsing history.
With regard to any third-party Trackers, Users can manage their preferences and withdraw their consent via the related opt-out link (where provided), by using the means indicated in the third party's privacy policy, or by contacting the third party.
Locating Tracker Settings
Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses:
Users may also manage certain categories of Trackers used on mobile apps by opting out through relevant device settings such as the device advertising settings for mobile devices, or tracking settings in general (Users may open the device settings and look for the relevant setting).
How to opt out of interest-based advertising
Notwithstanding the above, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.
The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.
Owner and Data Controller
The processing of personal data as described in this Privacy Policy is done by theConstruct BV. theConstruct BV is a private company with limited liability that falls under Dutch law and has its office at Postbus 10098, 1001 EB Amsterdam, the Netherlands.
If you have any questions about this Privacy Policy or about our processing of your personal data, please contact our data protection officer at dataprotectionoffice@theconstruct.io.
Owner contact email: info@theconstruct.co
Since the use of third-party Trackers through theViewer Service cannot be fully controlled by the Owner, any specific references to third-party Trackers are to be considered indicative. In order to obtain complete information, Users are kindly requested to consult the privacy policies of the respective third-party services listed in this document.
Given the objective complexity surrounding tracking technologies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of such technologies by theViewer Service.