Last updated: July 12, 2024
EWP PTE. LTD., along with its subsidiaries and affiliates (“we,” “our,” or “us”), is an independent marketing technology company. We provide intelligent, data-driven advertising and marketing services and solutions designed to help businesses of all sizes accelerate their growth (“Services”).
This Privacy Policy describes how EWP collects your information through our website at www.ewp.sg (“Site” or “Website”). By using our Site, you acknowledge that you have read and understood this Privacy Policy. Please review this Privacy Policy carefully before using our Services or this Site.
What Information We Collect
As you navigate through this Site, some of your personal information may be actively collected (for example, names, birth dates, personal ID card numbers, addresses, telephone numbers, E-mail addresses, occupations, education, work experience and related information) or passively collected (which you did not actively provide) such as your browser type, domain name, IP address, pages visited, and the length of your user session using various technologies and means, such as Internet Protocol Address, cookies, Internet Tags and navigational data collection. In order to improve our service quality, it may be necessary to ask for personal information to fulfill your requests and provide a better service. EWP is entitled to take measures to validate the authenticity of personal information you provide. If you give us personal information of somebody else, we will assume that you have their permission to do so. Transmissions to and from this Site may not be confidential and consequently, may be read or intercepted by others.
How We Use Your Information
Specifically, we use this information for:
- Segmenting Audiences: We use data from our Digital Properties you visit in addition to data from Audience Partners to segment you into groups (like high or low intent visitors) for reporting, analytics and determining what ads and email content would best peak your interest.
- Mapping Data to our Cross-Device Asset: EWP cross-device asset is used to connect multiple devices to one person, household, and/or online identifiers such as an email address (hashed for security) that you may have submitted to EWP. Our cross-device asset allows us to better understand your online activity and helps us improve our ability to target and measure ad campaigns (including limiting the number of times you or your household sees an ad for EWP Services).
- Providing our Services and Customer Support: For example, to monitor usage of features, manage campaigns and log data for audit purposes. We may contact you when you ask us for support or when it appears to us that you might need support. We maintain records of our communications with you for future reference.
- Troubleshoot Problems: To monitor and fix our website performance, for example, if the site is slow, not loading properly, or to investigate aberrations in performance of our Services.
- Prevent Potential Fraud and Enforce our Terms of Service: To prevent fraud on our sites or through the use of our Services, to enforce our Terms of Service or other policies or investigate any potential violation of those Terms and policies, any potential violation of the law, or to protect ourselves, our Customers or any third party from any potential harm (whether tangible or intangible).
- Customize, Measure and Improve our Websites and Services: To provide customized content and to measure which content is most helpful (or unhelpful) to our Customers, which helps improve our website and our services.
- Contact You About Your Account or our Services, Including to Market our Services to You or Provide Updates: We may use your contact information to contact you about your account, for example, in relation to the performance of your campaigns, to follow up on billing issues or to tell you about new Services we are offering.
- Conducting Our Corporate Operations. Data collected in our corporate capacity, such as our own B2B lists of Customers and prospective customers, is used to conduct our business operations and send communications.
- Complying with Legal Process: To satisfy in good faith any applicable law, legal process or proper governmental request, such as to respond to a subpoena (whether civil or criminal) or similar process.
- Investigating Wrongdoing and Protecting Ourselves or Third Parties: To enforce or investigate any potential violation of our Terms of Service and policies, any potential violation of the law and to protect ourselves, our Customers, or any third party from any potential harm (whether tangible or intangible).
The Legal Basis for Our Processing of Your Personal Information
We may process your personal information based on your consent. You can withdraw your consent at any time.
If you are located in the EEA, we may use your personal information based on the “legitimate interests” set forth in the GDPR, in necessary cases. Our legitimate interests include: remove technical obstacles to system operation and ensuring systems and processes work properly and securely.
Disclosure of Your Personal Information
We may disclose information about you:
- With our Audience Partners: We share hashed email addresses or other pseudonymous online identifiers with our Audience Partners in connection with audience creation and modeling and creating segments.
- With our Service Providers: We contract with companies who help with parts of our business operations (e.g., website and data hosting, fraud prevention, view ability reporting, data hygiene, marketing and email delivery), as well as billing, collections, tech, customer and operational support.
- With our Subsidiaries and Affiliates: These entities will only process your data for the purposes already explained in this Website Privacy Policy.
- In connection with legal proceedings: When we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of EWP, our Customers or any other third party.
- In connection with a sale of our business: If a third party acquires some or all of our business or assets, we may disclose your information in connection with the sale (including during due diligence in preparation for the sale).
Information Retention
We retain data for as long as necessary to perform our Services and for the purposes described in this Website Privacy Policy. For example, we may retain information as long as necessary to meet legal requirements, resolve disputes or enforce agreements.
We retain cookie data such as device and browser information, ad data and data collected on our Digital Properties as follows:
- Mobile Identifiers and Cookie Identifiers: Cookie identifiers we collect expire (and are then deleted) 13 months from the last time your device accessed a Digital Property using our technology. If you visit another Digital Property that uses EWP Technology inside that 13-month expiry period, then the expiry period will be reset and measured from that date instead. The expiration period for mobile identifiers is controlled by you on your device.
- Personal Data Associated with Mobile and Cookie Identifiers Related to Browsing History: We delete personal data associated with mobile and cookie identifiers after 12 months (for example, data such as a EWP Digital Property you visited or EWP ads that you may have clicked).
International Transfers
We may transfer the information we collect about you to countries other than the country where we originally collected it for the purposes of performing our Services. In general, these countries will be the countries in which we or our service providers operate.
Those countries may not have the same data protection laws as your country. However, when we transfer your information to other countries, we will protect that information as described in this Website Privacy Notice and take steps, where necessary, to ensure that international transfers comply with applicable laws.
For example, when we transfer your information from a European Territory to our parent company in Singapore, we do so under the European Commission’s Standard Contractual Clauses. When we transfer your data outside of a European Territory to Advertising Partners (or vice versa), we do so under lawful data export mechanisms which may include Standard Contractual Clauses and Binding Corporate Rules.
Additional Information for California Residents
If you are a California Resident, please email us at: support@ewp.sg for instructions for how you can exercise your California access, deletion and Opt-Out rights.
Personal Data
In the course of providing the Services, EWP processes Personal Information as a “business” under the California Consumer Privacy Act (“CCPA”). As a business, we do not sell Personal Information that we process when providing the Services. We disclose the following categories of Personal Information to business partners for the purpose of providing our Services:
Categories we collect: Session and persistent cookies, IP addresses, apps used or downloaded, web sites visited, browser and operating system type, type of device used, information actively provided by users responding to a form in an ad, randomly assigned identifiers, precise and general location information and system information that our SDK may collect about your device or network provider. This information is retained for a period of 14-30 days.
Sources: All the information above is collected from your device when you are using an app to visit a website and is provided to us from the business partner you interact with by using their app. We also acquire this information from advertising or data exchanges.
Each Category is collected for the following business purposes: securing, protecting, auditing, bug and fraud detection, debugging and repair of errors and the detection, protection and prosecution of security incidents or illegal activity; enforcing our terms and policies; complying with law.
Each Category is also collected for uses that advance our commercial interests including creating profiles to target ads on behalf of advertisers, using data collected from publishers and from other third parties.
Sale/Sharing Information
EWP may disclose the categories of information described above to business partners, such as analytics companies and may share the information with other partners, and third parties.
Opt-Out signals
If a EWP publisher or advertiser partner has transmitted to EWP a “Do Not Sell or Share My Personal Information” signal, an “Opt-Out of the Use of My Personal Information for Interest-Based Advertising” signal, or a “Limit Use of My Sensitive Personal Information” signal, we will limit our use of Personal Information from that partner and we will act only as a service provider as defined in the CCPA. You may also exercise your opt-out rights as described below.
Access, Deletion and Opt-Out Rights
Subject to certain exceptions and restrictions, the CCPA provides you as a California Resident the right to submit requests to EWP: (i) to provide you with access to the specific pieces and categories of Personal Information collected by EWP about you, the categories of sources for such Personal Information, the business or commercial purposes for collecting such Personal Information, and the categories of third parties with which such information was shared; and (ii) to delete such Personal Information.
Please email us at support@ewp.sg for instructions for how you can exercise your California access, deletion and Opt-Out rights. We will need to verify your identity and that the information you requested relates to you before completing your rights request. We generally do not associate Personal Information (such as device history) with identified individuals as we generally do not have information such as names or email addresses connected to device information. Therefore we will need your Advertiser Identifier to process your request. If you do not provide us with the required information, we will be unable to process your request.
You may designate an authorized agent to make California Requests on your behalf.
We do not discriminate against you.
You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. EWP does not discriminate against California Residents for exercising their rights.
We do not sell the personal information of minors under 16 years of age without affirmative authorization.
Additional Information for European Residents
If you are situated in the European Union, the European Economic Area (“EEA”) or the United Kingdom, the following provisions will apply in addition to the Advertising and Data Services Privacy Policy to any Personal Information.
Data Controller
For Purposes of the European Union’s General Data Protection Regulation (“GDPR”), EWP is the data controller of the Personal Information.
Legal Basis for Processing
We will process your Personal Information (a) for the purpose of legitimate interests pursued by us in accordance with Art 6 para. 1 lit. (f) GDPR; or (b) because you have consented to the processing in accordance with Art. 6 para. 1 lit (a) GDPR.
We will only process Personal Information based on our legitimate interests for storing and accessing Personal Information necessary to provide the Services; selecting, delivering and reporting on the effectiveness of advertisements; measuring the performance of advertisements and campaigns and investigating and preventing fraud.
Transferring your Information outside Europe
We transfer Personal Information from the European Union, the EEA and the United Kingdom, to other countries, some of which have not yet been determined by the European Commission to have an adequate level of data protection. For example, their laws may not guarantee you the same rights, or there may not be a privacy supervisory authority there that is capable of addressing your complaints. When we engage in such transfers, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protection of the Personal Information.
If we transfer your personal information to a third party service provider outside the European Union, the EEA or the United Kingdom we are responsible for such transfer and we will impose obligations on the recipients of that Personal Information to protect your data to the standard required in the GDPR.
Rights under the GDPR
You have the following rights: (a) you have the right to obtain information about the data processed about you (Art. 15 GDPR); (b) if inaccurate personal data is processed, you have a right to rectification (Art. 16 GDPR); (c) if the legal requirements are met, you may request the erasure or restriction of processing as well as object to processing (Art. 17, 18, 21 GDPR); (d) if you have consented to the data processing or a contract for data processing exists and the data processing is carried out with the help of automated procedures, you may have a right to data portability (Art. 20 GDPR).
We generally do not associate Personal Information (such as device history) with identified individuals as we generally do not have information such as names or email addresses connected to device information. Therefore, we will need your Advertiser Identifier to fulfill your rights. If you do not provide us with the required information, we will be unable to ensure your rights. To exercise your rights, for questions or further information please contact us at support@ewp.sg.
Your Data Rights
Subject to local law, you may have certain rights over your Personal Information. These rights may include, depending on the circumstances, the rights to access your personal Information, delete personal Information collected from you, receive additional information regarding the information of yours we hold, stop certain disclosure of your Personal Information, withdraw consent for processing you may have given to us. If you would like to exercise your right under local law or if you have any questions or concerns about our privacy practices, you may contact us at: support@ewp.sg.
Security
We apply technical, administrative and organizational security measures to protect the data we collect against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against other unlawful forms of processing.
We have implemented physical, technical and administrative security measures for the Advertising Services that comply with applicable laws and industry standards. For example, we use firewalls, encryption technology and other automated software designed to protect against fraud and identity theft; our data is only stored in centers that provide high-level security for your information. Physical access is strictly controlled both at the perimeter and at building ingress points by our staff utilizing video surveillance and other electronic means. We will not collect your sensitive personal information without your consent. (For purposes of GDPR, CCPA, CDPA, CPA, UCPA and VCDPA, we do not process your sensitive personal information.)
Children
We ensure that we comply with the Children’s Online Privacy Protection Act (COPPA), and does not knowingly collect personal information about users of websites or apps directed to children under the age of thirteen (13). If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should promptly contact us and we take reasonable steps to ensure that such information is deleted from our files.
Use of Cookies and Other Tracking Technologies
EWP may use cookies, or other technology (collectively “Cookies”) to collect certain information about you when you are visiting the Site. Cookies is a small text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Generally, the purpose of Cookies is to provide convenience. You may reject our Cookies or delete them manually. Please however note, that, if you delete or reject Cookies, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly. Please see our Cookies Policy for more details.
Changes to this Service Privacy Policy
This Privacy Policy may be updated from time to time in order to reflect changes in our practices. We will notify you of any material changes by posting the new Privacy Policy on the Site with an updated effective date, and will obtain the necessary consents as may be required under applicable law if we seek to collect, use or disclose personal data for purposes other than those for which consent has been obtained. We encourage you to visit this page periodically to learn of any updates.
Contact Us
If you have any questions about this Website Privacy Policy or our privacy practices, or want to appeal EWP’s decision as a Controller with regard to a consumer request, you can contact support@ewp.sg.
If you are located in a European Territory then, where we process your data as a data controller, EWP is the data controller of your information. To contact EWP please email support@ewp.sg.