1. Who is your Data Protection Officer?
According to the GDPR, it is not obligatory to have a DPO at our company, however, all questions and issues regarding privacy must be addressed to Eskimi advisers “Ivanauskas & partners” and specifically our counsel Tomas Ivanauskas.
2. What personal data are you processing?
Eskimi processes and uses for the provisioning of DSP services so-called indirect data, such as location, device specifications, browsing history, etc. No data allows Eskimi identify the specific person and to know their name, phone number, or any other directly linkable personal data.
3. How do you gather consent (Clear affirmative act, GDPR preamble p.32) of people you process their personal data?
Eskimi processes data that was gathered by our partners by either obtaining the consent from the data subjects or on other legal grounds for data control (such as legitimate interest, service provisioning, data security, etc.). The data has been transferred to Eskimi on a legitimate contractual basis having permission from the data subject. Eskimi requires that partners would ensure that the data initially has been collected on a legitimate basis.
4. How do you ensure it is transparent to natural persons that personal data concerning them are collected, used, consulted, or otherwise processed? (GDPR preamble p. 39).
5. Data subject should have the right of access to personal data which have been collected concerning him or her, and to exercise that right easily and at reasonable intervals, in order to be aware of, and verify, the lawfulness of the processing (GDPR preamble 63). How these rights can be exercised?
Eskimi has a special procedure and a form for data subjects to request information about the scope of a person's data processing including the possibility to require that the processing would be stopped and/or the data would be deleted. We follow all the provisions of GDPR ensuring that the data subject would have full access to information about his/her data processing. Normally we would provide all the information requested under the Data Subject Access Request Form within 30 calendar days.
6. For how long you keep data in your databases?
Data is only kept for a limited period of time that is strictly required to perform the obligations towards the clients under the contracts or observing other legal requirements. The data is periodically reviewed and deleted if it is not required for the purposes of business, according to Data Retention and Erasure Policy.
7. Do you have a data breach policy?
Eskimi has a procedure according to which the data breach incidents are detected, reported, and addressed. Eskimi complies with the GDPR provisions for reporting data breach incidents to relevant data authorities as well as data controllers.
- Eskimi is fully GDPR compliant.
- Eskimi is data processors for the provision of B2B services.
- Eskimi does not process any direct personal data.
- Eskimi obtains data from data controllers and check with them for the legal basis of data use.
- Eskimi ensures that the user access we provide to our clients is based on either consent of the user or has another legal basis for processing.
Eskimi and GDPR
GPDR requires companies to have applicable legal basis for:
1. Any kind of user data used
2. All ways of how is that data used
In online advertising, companies normally use non-personally identifiable data (such as cookies, device IDs) to target users and measure ad performance.
In order to perform these activities, an applicable legal basis is needed. It is Eskimi, as well as most of the market, understanding that 2 legal basis are appropriate here: consent and legitimate interest.
Consent is when user says 'yes' to the kinds of data and to the ways of data. User can agree or deny to companies processing user data.
Legitimate interest is when a company must use user data to survive and it can not hurt the user in any way. User can object to legitimate interest claims.
How to achieve all this for companies?
There can be multiple ways of asking users for consent and/or showing legitimate interest declarations. The most used one, and the one we use in Eskimi, is by using Transparency and Consent Framework (TCF).
What is TCF?
TCF is framework to pass if user consented and/or objected to legitimate interest to online advertising companies. It is not the law - it's how companies like Eskimi understand the law.
TCF consists of:
* CMP (consent management platform): actual popup where user sees and selects: data usage purposes, companies
* Preferences string:
* Vendors: companies using user data
Eskimi DSP (UAB Aktyvus Sektorius - Eskimi vendor name) is part of the IAB approved TCF vendors.
Global TCF vendor list: https://iabeurope.eu/vendor-list/
To sum up, TCF allows:
* Showing purposes - how will companies use data
* Showing types - what data will those companies use
* Allowing user accept/reject usage of this data
* Passing user preferences to the companies
What do clients have to do?
Client page should have a CMP (Consent Manager Platform) integrated on the website and make sure that "UAB Aktyvus Sektorius - Eskimi" is on the vendor list. CMP usually handles a lot of integration automatically and provides customisability in order to correctly generate the consent string.
Then, if user agrees with Eskimi data purposes and what data will be used.
How to check if UAB Aktyvus Sektorius - Eskimi is under the CMP vendor list?
Visit the page you want to check. You should be greeted with a notice. Such as the below one. Click on manage settings: