Wunderkind respects your privacy rights, including the right to opt-out of the sale of information that is afforded to data subjects located in California. We enable Users to opt-out from our Data Onboarding Platform and our Interest Based Ads Platform as described below.
Web based Opt-Out Choice Mechanisms. You can opt-out of our Data Onboarding Platform, and our Interest Based Ads Platform on your browser as follows:
- You can visit Wunderkind’s opt-out page at https://www.wunderkind.co/privacy/opt-out-of-data-processing/. Opting out via this method will also enable Wunderkind to place an HTML5 cookie which may be more persistent than HTTP cookies.
- You can visit the Network Advertising Alliance self-regulatory opt-out page at https://optout.networkadvertising.org/?c=1#!/to opt-out and to see whether Wunderkind is using a statistical identifier on the browser you are currently using. You should select the “opt out” button there for Wunderkind.
- You can visit the Digital Advertising Alliance self-regulatory program opt-out page at https://optout.aboutads.info/?c=2&lang=EN. You should select the “opt out” button there for Wunderkind.
- EU data subjects may visit the eDAA and IAB Europe OBA Framework’s opt-out page at https://youronlinechoices.com/and select Wunderkind. When our systems detect that you’ve opted out via this method, we will treat your opt-out request as a request for Wunderkind to stop collecting or processing data associated with this browser in accordance with EU data protection law.
- Many of the advertisements we deliver via the Services will contain the advertising option Icon, a symbol that we license from the Digital Advertising Alliance. If you click onto the advertising option icon, you will see more information about behavioral advertising, including a mechanism that enables you to opt-out from DAA participating companies.
- Each of the above opt-out mechanisms will also opt you out from Wunderkind’s sale of data under the California Consumer Privacy Act (“CCPA”).
When you opt out via the web based choice mechanisms described above, we will attempt to place an HTTP cookie that instructs us not to use information about your browser for IBA on our Data Onboarding Platform and our Interest Based Ads Platform.
If your browsers are configured to reject cookies when you visit our opt-out page, we cannot set our no-track cookie. Also, this choice mechanism is only applicable to the browser you are using, so if you subsequently erase your cookies, use a different computer or change web browsers, you will need to opt-out again.
Statistical device ID reset. Wunderkind also creates a non-cookie based statistical device-level pseudonymous identifier which is used in cookie-challenged environments. Information collected as outlined in “The Types of Information that We Collect” may be associated to this identifier over time. If you would like to reset the value of this identifier, you may do so here. This will effectively remove any associations between the identifier and any data that Wunderkind has collected. Note that any new data collected after resetting your identifier may resemble data previously collected if you engage in similar activities on websites.
Mobile App Opt-out Choice Mechanism. We honor the mobile device settings for Android and Apple iOS devices. To exercise this opt-out, please visit the privacy settings of your Android or iOS device and select “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android). For devices where we are able to see that such a selection has been made, we will not use information collected about your mobile app usage on our Data Onboarding Platform and our Interest Based Ads Platform. This choice mechanism is only applicable to the apps you are using on your current mobile device.
Precise Location Choices. If you’d like to adjust your choices regarding the use of precise location data by third parties such as Wunderkind, you may do so via your device settings. For your convenience, we provide links to instructions for both Apple iOS and Android devices. Also, most mobile applications that collect precise location information offer mechanisms to control the collection and use of precise location information. Please note that these choice mechanisms won’t impact previously collected precise location information.
Some of our Clients may utilize third-party advertisers on their websites. These third-party advertisers generally collect pseudonymous information across multiple non-affiliated websites and mobile apps to create interest segments for ad targeting and content customization purposes. This practice is sometimes referred to as interest based advertising (“IBA”) or online behavioral advertising (“OBA”) and is distinct from the Behavioral Automation Platform and Data Onboarding Platform offered by Wunderkind. To learn more about third-party advertising companies and your choices regarding how that information is used, please visit https://thenai.org/opt-out/, https://optout.aboutads.info/?c=2&lang=EN or https://youronlinechoices.com/.
Data Subject Access Request Instructions
Wunderkind is committed to transparency, and we want EU and California data subjects to have access to personal data that we may have about them and/or the devices that they may use to access the Internet. Given that these rights are similar in the EU and California, we refer to them as EU and California data subject rights.
Our privacy policy describes the types of personal data that we process. We only ask for the information we need to help us process a request and will only keep information pertaining to your request for up to one year. If you are a client of Wunderkind with a login and password to the Wunderkind platform, we ask that you first direct your request to the person or persons at your organization that administers the relationship with Wunderkind.
Your EU and California Data Subject Rights
If you make an EU and California data subject rights request as set out in this policy, you are entitled to see the personal data that we have about you including any digital identifiers such as cookie IDs and mobile advertising IDs that Wunderkind may store. We will also do our best to provide you with other information that we may have stored and associated with your personal data and digital identifiers—for example, transaction logs reflecting where one of our customers used or attempted to use our services in a way that impacts a website or application that you accessed.
Please note that some of the information we process is owned and/or controlled by our clients as controllers of that data. We provide our customers with tools to help them honor your EU Data Subject Access requests directly. Where we are merely the agents, service providers and/or processors of data, we may be prohibited from processing this data except as directed in writing by those clients. If that’s the case, we will submit your request to the applicable client and await their written instructions. Also, if we are unable to locate any of the information you have requested, we will let you know.
EU Data Subject Rights
We will provide you with the ability to see the personal data that we have by providing you with a copy of that data. You have the right to port that data to a different entity than Wunderkind, although we can’t guarantee that others will be in position to ingest this data. We will also provide you with the ability to correct errors in the data, but reserve the right to simply delete data which you’ve indicated may contain errors or inaccuracies. We will restrict or cease processing of this data upon request and offer you the ability to object to our processing of this data. And we will delete the data upon request so long as we are not prohibited from doing so by applicable law and/or the information is not required for us for billing, fraud prevention or security purposes.
California Data Subject Rights
As a California data subject, if you make a subject access request as set out in this policy, you are entitled to see and delete the personal information that we have about you. We will generally attempt to confirm your request within 10 days and make a good faith attempt to fulfill your request within 45 days.
The CCPA defines personal information broadly and as such, it includes pseudonymous identifiers such as cookie IDs and mobile advertising IDs. Under the CCPA, your request to see the personal information that we have about you may include: (1) specific pieces of personal information that we may have about you; (2) categories of personal information we have collected about you; (3) categories of sources from which the personal information is collected; (4) categories of personal information that we sold or disclosed for a business purpose about you; (5) categories of third parties to whom the personal information was sold or disclosed for a business purpose under the CCPA; and (6) the business or commercial purpose for collecting or selling personal information.
You may make an access or deletion request via an authorized agent by having such agent follow the process below. Please note that we will request any authorized agent demonstrate that they have been authorized by you to make a request on your behalf. And we will attempt to verify your request made in this way. Moreover, we require any authorized agents to provide us with contact details such as an email address and phone number so that we may ensure a timely response.
Making an EU and California Data Subject Request
Step 1: Locating Your Information
Providing us with your email address should be relatively straightforward. Please note that we will send you an email to the address(es) provided in order to help us authenticate your request.
Here’s what you need to do in order to share your digital identifiers.
As described in our privacy policy, our systems may drop text files called “cookies” that are placed on your computer or device. For more general information about cookies, please visit http://www.allaboutcookies.org/. Some of the cookies we place may provide a unique ID which helps our systems recognize your browser or device over time. In order to find these cookies, please follow the instructions in Appendix A of this document.
Please keep in mind that different cookies are placed on each browser that you use to access the Internet. As a result, if you use multiple browsers (for example, Google Chrome and Mozilla Firefox), you will need to locate our cookies for each browser. Your browser’s help section should provide an overview of how to locate your cookies. An internet search of how you may find cookies in your browser may also be helpful. If you need more assistance locating these cookies for your browser, please feel free to email us for assistance at privacy@wunderkind.co.
Additionally, certain mobile devices (for example, mobile phones or tablets using the iOS or Android operating systems) generate persistent a “Advertising Identifier” per device, which, among other things, can be used by third parties for purposes of providing you with targeted advertising. On iOS devices, your Advertising Identifier may be referred to as an “IDFA,” “IFA,” or an “ID for Advertising.” On Android devices, your Advertising Identifier may be referred to as an “Advertising ID.” Please follow instructions from your mobile device manufacturer on how to locate your specific Advertising Identifier.
Step 2: Authentication of the Information Provided
In order to make sure that we are only providing personal data to the correct person, we also will need to take reasonable steps to authenticate your request. We request that you provide screen shots of any cookies and mobile Advertising Identifiers for which you are submitting a request. We also reserve the right to send you an email to any addresses you provide in order to authenticate that portion of your request. We also request that you fill out and sign the affidavit we’ve prepared. By filling out and signing the affidavit, you’re promising Wunderkind that you’re the person listed on the affidavit, and proof to demonstrate that you are indeed connected to the personal data and digital identifiers you located in Step 1.
Step 3: Contacting Wunderkind
Once you have located your Digital Identifiers and can provide us with verification of those Digital Identifiers (via the affidavit available above), you should reach out to us. The easiest way to do so would be to send an email with the information above to privacyrequests@wunderkind.co.
EU and California data subjects can also make a subject access request by mail, by sending a written request with all of the above-listed information to the following address:
Wunderkind, Inc.
Attn: Privacy Officer
1 World Trade Center, FL 74
New York, NY 10007
Wunderkind, Inc.
Attn: Privacy Officer
15 Alfred Place
London,
WC1E 7EB, UK
Appendix A – Obtaining Browser Storage Values
To exercise your data rights around the identifiers we set on your browser, please follow the instructions below:
Option 1: Localstorage value
- View your browser’s localstorage cache; under the domain assets.wunderkind.co, you may see values with names similar to bounceClientVisit1234. Each of these corresponds to a session on a website on which Wunderkind software is installed.
- For each session you would like to obtain information from, click on the bounceClientVisitXXXX entry. Copy & paste the value for the “did” field into a new text file. Also copy & paste the XXXX value from the bounceClientVisitXXXX value you have selected.
- You should end up with information that looks like the below:
1016: 6878487254792785497
1084: 4678928170010495402
Each line should correspond to a bounceClientVisit, with the XXXX value first and the did value second.
Option 2: Cross-website cookie value
- Visit wunderkind.co, and view your browser’s cookie cache.
- Find a cookie named “__idcontext”. Copy and paste the value of that cookie.
- You should end up with information that looks like the following:
{“cookieID”:”0xwnYosK6uz9xlxg9dn7U8qd1oQ”,”deviceID”:”0xwnYn5VUvYM4oFgue2exqhXXPT”}
What to do with the information you have collected
Please combine the information you have collected as follows:
1016: 6878487254792785497,
1084: 4678928170010495402,
{“cookieID”:”0xwnYosK6uz9xlxg9dn7U8qd1oQ”,”deviceID”:”0xwnYn5VUvYM4oFgue2exqhXXPT”}
Note: please know that these methods will not cover the same sets of data. For example, Wunderkind may have collected data associated to an email address that we have not associated to a device-level identifiers (options 1 and 2). As such, you may want to explore both options above when exercising your data rights.
