Privacy Policy
Video Research Interactive Inc. (hereinafter referred to as "Video Research Interactive," "we," "our" or "us") respects your privacy and explains in a transparent manner the types and usage of personal information we collect and process regarding you (hereinafter referred to as "Personal Information").
This Privacy Policy applies to measurements that we carry out on the status of browsing and use of websites and applications (hereinafter "Privacy Policy") regarding data subjects outside Japan. It explains how we will process your Personal Information, both as a Controller and a Processor, such as histories of access to and usage of websites and terminal applications collected by using the mechanisms we provide in compliance with the EU's General Data Protection Regulation (GDPR) and the Japanese "Act on the Protection of Personal Information" (Japanese APPI) and other applicable laws and regulations on the protection of personal information and privacy.
"Access Measurement of Websites" and "Access Measurement of Applications"
The Access Measurement of Websites is a measurement of the browsing history of certain websites. When you browse the website of a company (hereinafter referred to as "Clients" together with companies that perform the following Access Measurement of Applications) that has concluded a contract for "Total number measurement service (website version)" with Video Research Interactive and has set the cookie and web beacon (described below) on the website, your information in relation to your access of the website (referred to as "Access Information" described in Section 2 in detail) such as "number of accesses" and “time of accesses” on the website (including the advertising contents on the website) is measured.
Access Measurement of Applications is a measurement of the usage history of certain applications. When you use applications (including advertising contents on applications) of a terminal provided by a company (hereinafter referred to as "Clients" together with companies that perform the above-mentioned Access Measurement of Websites) that has concluded a contract for "Total number measurement service (terminal application version)" with Video Research Interactive and has set the web beacon (described below) in the application of a terminal, your information in relation to your access with the application (referred to as "Access Information" described in Section 2 in detail) such as "number of accesses" and " time of accesses” is measured.
What kind of Personal Information is collected in Access Measurement of Websites and Access Measurement of Applications?
The following information is collected from those who browse the websites of Clients that have concluded a contract for "Total number measurement service (website version)" with Video Research Interactive.
This is a randomly written letter we grant for "Access Measurement of Websites." This uniquely identifies the user terminal that isviewing the website via browser or application. Access Measurement of Websites uses Cookies to store user identifiers.
It is a unique ID that we grant to identify the website.
Percentage of video viewing time (the percentage of the video viewing time of those who accessed the website to the total time of the video), advertising IDs, advertiser IDs, campaign IDs, and material IDs (the IDs for identifying who advertised on the website and what campaign the advertisement is for).
We regard Access Information as information pertaining to a distinct person but does not enable the identification of said person, and should be processed with care.
With respect to the application provided by the Clients that have concluded a contract for "Total number measurement service (terminal application version)" with Video Research Interactive, the following information is collected:
This is a randomly written letter we grant for "Access Measurement of Applications." This uniquely identifies the application. Access Measurement of Applications uses UUID as user identifier.
A unique ID that we grant to identify the application.
This refers to "Advertising ID” (AdID) in the case where the OS of the terminal in which the application is installed is Android, and "Identifier for Advertiser” (IDFA) in the case of iOS.
Percentage of video viewing time (the percentage of the video viewing time of those who accessed the website to the total time of the video), advertising IDs, advertiser IDs, campaign IDs, and material IDs (the IDs for identifying who advertised on the website and what campaign the advertisement is for)
We regard Access Information as information pertaining to a distinct person but does not enable the identification of said individual, and should be processed with care.
How is your Personal Information collected?
We use "cookies" and "web beacon" below to acquire Access Information on the websites.
Combining web beacon and cookies allows us to acquire Access Information on the websites. Those who browse the websites can refuse to receive cookies or display a warning when they receive cookies by setting up the browser. Even in such cases, the web beacon will acquire Access Information on the websites.
In addition, we use the “web beacon” to acquire Access Information on the application.
Details of the cookies and web beacon are as follows.
This is a technology that can store information in the access person's terminal browsers and in the app's WebView in order to acquire information that is transmitted and received between the browsers and servers when using the websites. Access Measurement of Websites retains user identifiers.
This is a technology for using GIF files and scripts, collecting Access Information from browsers or applications and acquiring data related to the Access Information of websites.
What is Video Research Interactive's role under the GDPR?
With respect to Access Measurement of Websites and Access Measurement of Applications, Video Research Interactive processes Personal Information mainly as a Processor under the GDPR of EU. However, Video Research Interactive may also process some Access Information as a Controller. For more details on how Video Research Interactive processes the Access Information as a Processor and a Controller, please refer to section 5 below.
| Category | Main role | |
|---|---|---|
| Clients | Controller (The natural or legal person who determines the purposes and means of the processing of Personal Information) |
The Client as the Controller is directly responsible towards the data subjects and the EU Data Protection Authorities regarding the overall processing of the Personal Information the Controller determined. |
| Video Research Interactive | As a Processor: (The natural or legal person who processes Personal Information on behalf of the Controller (i.e. Clients) and on instructions only from the Controller. As a Controller: (The natural or legal person who determines the purposes and means of the processing of Personal Information) |
Video Research Interactive follows the instructions of the Controller (i.e. Clients) and processes the Personal Information on behalf of the Clients as the Controller. Video Research Interactive processes the Personal Information for its own purposes and as such is responsible towards the data subjects and the data protection authorities. |
For what purposes and on what legal grounds will Video Research Interactive process the Personal Information?
In order for us to process the Personal Information as a processor, we rely on the purposes that were determined by our Clients who are the Controllers. We also rely on the legal basis for the processing that has been assessed by the Clients who are the Controllers. Our Clients rely on consent of the data subjects and/or their legitimate interests to process Personal Information.
Given the fact that the purpose of the processing of the Personal Information is determined by the Controller, our use of the Access Information shall be limited to the purpose of marketing research as agreed with our Clients and shall not be used for any other purpose under the contract between us and the Clients.
With respect to the advertising identifier, the Clients shall clearly indicate the transferee of shared information and shall provide it based on your consent in accordance with the policies of Apple and Google.
We will also collect, use, and store the following Access Information as a Controller:
- IP Address
- Types of browser and OS
- Starting time of access on our website
- User identifier
- URL of the website that you browsed prior to accessing our website
We will process the above Personal Information for market research and statistical purposes. We rely on our legitimate interests as a legal basis for processing the Personal Information as a Controller.
Will Access Information be provided to third parties?
- 6.1 Personal Information processed as a Processor
- 6.2 Personal Information processed as a Controller
We do not share or disclose any Access Information to any third party unless the Clients have first obtained the consent of the data subject of the Personal Information as appropriate. As agreed with our Clients, we may use third party IT service providers with whom we share the Personal Information and who will process it as sub-processors on our behalf. We will impose the same obligations on any such sub-processor as those that are imposed on us in the above paragraphs.
We may provide or share your Access Information with the affiliates of our group or trusted third party companies, such as IT-service providers, whom we have selected to process the data on our behalf.
What is the retention period of the Personal Information?
When we process the Personal Information as a Processor on behalf of our Clients, we will store the Personal Information for a maximum period of two (2) years or as otherwise agreed with our Clients. When we process the Personal Information as a Controller for our own purposes, we will store the Personal Information for a maximum period of two (2) years.
How does Video Research Interactive protect the Personal Information?
Whether we process the Personal Information as a Controller or Processor, we take necessary and appropriate measures to protect the Access Information from unauthorized access, leakage, loss, or damage.Our Information Security Policy stipulates the contents of our security management measures.
When outsourcing operations related to the use and management of the Access Information, we will properly supervise the processing of Access Information by the trustees.
In addition, regarding data subjects in the EU, when we are entrusted by our Clients who are Controllers under the GDPR of the EU to process your Personal Information as a Processor on their behalf, we comply with the following obligations in accordance with Article 28 (3) of the GDPR.
i. We will appropriately process your Personal Information in accordance with only the instructions from the Clients who are the Controllers.
ⅱ. We obligate all officers and employees authorized to process the Personal Information to maintain confidentiality.
ⅲ. We will strictly store and manage your Personal Information, and take appropriate security measures to protect your Personal
Information from leakage, loss, and damage. We endeavor to maintain the accuracy of the Personal Information. The contents of our security management measures shall be stipulated in our Information Security Policy and shall include the following as appropriate.・The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services.
・The ability to restore the availability and access to Personal Information in a timely manner in the event of a physical or technical
incident.・A process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring
the security of the processing.ⅳ. We will support our Clients who are the Controllers to fulfill their obligations as the Controllers.
ⅴ. As requested by our Clients, we will either delete or return your Personal Information after completion of the measurement of status of browsing on the websites using the measuring tag. We do not store any Personal Information after the agreement with our Client has been terminated.
What to do to invalidate information?
If you want to discontinue the association of your user identifier with any other Access Information, please click here and invalidate your user identifier. Any Access Information acquired by us prior to the invalidation will continue to be used by us within the scope of the purposes of use described in Paragraph 5.
In addition, in case the following measures are taken, the setting to invalidate the user identifier will be reset. In such cases, it will be necessary to invalidate the user identifier again.
If you want to discontinue the association of your user identifier with any other Access Information, please follow the procedures provided on the application and invalidate your user identifier. Any Access Information acquired by us prior to the invalidation will continue to be used by us within the scope of the purposes of use described in Paragraph 5.
In addition, in case the following measures are taken, the setting to invalidate the user identifier will be reset. In such cases, it will be necessary to invalidate the user identifier again.
If you want to discontinue acquiring an advertising identifier of the Access Information, you should invalidate the advertising identifier information in accordance with the methods listed on the websites below. Any information acquired by us prior to the invalidation will continue to be used by us within the scope of the purposes of use described in Paragraph 5.
https://support.google.com/ads/answer/2662922?hl=ja
https://support.apple.com/ja-jp/HT202074
Access for inquiries regarding Video Research Interactive "Access Measurement of Websites" and "Access Measurement of Applications"
For inquiries regarding the information herein or the Access Information we acquire, please access us using the e-mail form below.
Your rights
Where the processing is based on your prior consent, you may withdraw your consent to the processing of your Personal Information by us at any time. However, if you do, the withdrawal of your consent shall not affect the lawfulness of the processing based on your consent before its withdrawal. You also have the right to object at any time to our use of your Personal Information for direct marketing purposes. You may also object at any time to our use of your Personal Information to achieve our legitimate interests (including for profiling purposes) on grounds relating to your particular situation. In such case, we will cease to process your Personal Information unless we can demonstrate a compelling legitimate ground for the processing which overrides your rights and freedoms, or for the establishment, exercise or defense of legal claims.
You are also entitled to request disclosures (right to access), corrections (right to rectification), deletions (right to erasure), suspensions of use or provision (right to restriction of processing) of your Personal Information that we have, and the provision (right to data portability) of Personal Information in a computer-readable manner. For details on how to exercise your data protection rights, please refer to the inquiry desk in section 12 "Inquiries" below.
You have the right to challenge the processing of any personal information relating to you to the Personal Information Protection Commission or any other competent supervisory authority.
Inquiries
If you have any questions or queries about our processing of your Personal Information as a Controller, please access us at the following address:
Video Research Interactive Inc.
privacy@videoi.co.jp
In all other situations where we are processing your Personal Information as a Processor on behalf of our Clients, and you wish to exercise any of your data protection rights, please access the relevant Client who is the Controller.
Established October 31, 2019
Video Research Interactive Inc.