Privacy Policy

Privacy Policy

Effective Date: 16th May 2025

Last Updated: 16th May 2025

KLIR DIGITAL LTD (“we”, “us”, or “our”) is committed to protecting the privacy and security of our website visitors and users. This Privacy Policy outlines how we collect, use, disclose, and protect your personal data when you visit our website, use our services, or interact with our advertising.

We understand the importance of your privacy and are dedicated to being transparent about how we handle your information, particularly in the context of online advertising and the use of technologies like cookies. We comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003 (PECR) concerning the use of cookies and electronic communications.

1. Who We Are

KLIR DIGITAL LTD is a digital solutions provider based in London, England, specialising in ad operations and ad stack management services.

Our registered address is: Camfrey Court, 2A Priory Road, N8 7RY, London

For any questions regarding this Privacy Policy or our data protection practices, you can contact our Data Protection Officer at:

Email: [email protected]

2. Data We Collect

We may collect and process various types of data from and about you when you interact with our website and services. This includes:

  • Technical Data: Information about your device and how you interact with our website, such as IP address, browser type and version, operating system, referral source, length of visit, page views, and website navigation paths. This data is primarily collected through cookies and similar technologies.
  • Usage Data: Information about how you use our website and services, including the pages you visit, the time and date of your visit, the time spent on each page, and your clicks and interactions.
  • Advertising Data: Information related to the ads displayed on our site and your interaction with them. This may include the type of ad, where it was served, whether you viewed or clicked on it, and information about the website or app where the ad appeared. This data may be used for purposes such as measuring ad effectiveness and delivering relevant advertising.
  • Personalised Advertising Data: If you consent to personalised advertising, we may collect and use information about your interests, demographics, and online behaviour (across our site and potentially other websites and apps) to show you ads that are more likely to be relevant to you. This may involve the use of cookies and other tracking technologies to build a profile of your interests.
  • Communication Data: If you contact us directly, we may collect information you provide in your communication, such as your name, email address, phone number, and the content of your message.
  • Consent Data: Records of the consents you have provided or withdrawn regarding the use of your data, particularly in relation to cookies and personalised advertising, managed through our Consent Management Platform (CMP).

We do not typically collect ‘special categories’ of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. How We Collect Your Data

We collect data through various methods, including:

  • Direct Interactions: You may provide us with data by filling in forms on our website, corresponding with us by post, phone, email, or otherwise.
  • Automated Technologies or Interactions: As you interact with our website, we may automatically collect Technical Data and Usage Data using cookies, server logs, and other similar technologies.
  • Third Parties: We may receive Technical Data and Advertising Data from third parties, such as advertising networks, analytics providers, and search information providers, some of whom may be based outside the UK and EEA. We ensure that any data transfer from these third parties complies with data protection laws.

4. How We Use Your Data

We use your personal data for the following purposes and rely on specific legal bases under UK GDPR:

  • To Provide and Maintain Our Website: To ensure our website functions correctly and is accessible to you (Legal Basis: Legitimate Interests – necessary for running our business).
  • To Improve Our Website and Services: To understand how our website is used and identify areas for improvement (Legal Basis: Legitimate Interests – to develop and grow our business).
  • To Manage Our Relationship With You: To respond to your enquiries and provide customer support (Legal Basis: Performance of a Contract or Legitimate Interests – to respond to queries).
  • For Advertising and Marketing:
    • To display advertising on our website (Legal Basis: Legitimate Interests – necessary for our business to generate revenue from advertising).
    • To deliver personalised advertising to you, where you have provided your explicit consent (Legal Basis: Consent).
    • To measure the effectiveness of the advertising displayed on our site (Legal Basis: Legitimate Interests – to analyse ad performance and improve our advertising services).
  • For Internal Analytics and Reporting: To analyse website traffic, user behaviour, and advertising performance (Legal Basis: Legitimate Interests – to understand our business performance).
  • To Comply with Legal Obligations: To meet our legal and regulatory requirements (Legal Basis: Legal Obligation).
  • For Security and Fraud Prevention: To protect our website and systems from fraud and security threats (Legal Basis: Legitimate Interests – to ensure the security of our systems).

5. Advertising and Personalised Advertising

Our website is supported by advertising. This allows us to provide content to you free of charge. We work with various advertising partners to display ads on our site.

  • Non-Personalised Advertising: This type of advertising is based on the context of the website you are visiting, such as the content of the page. It does not rely on information about your past online activity.
  • Personalised Advertising: This type of advertising is tailored to your interests based on your online behaviour, including your visits to our website and potentially other sites and apps. To deliver personalised ads, our advertising partners may use cookies and other technologies to collect information about your interests and build a profile.

We will only serve you personalised advertising if you have given us your explicit consent to do so via our Consent Management Platform.

6. Cookies and Similar Technologies

Our website uses cookies and similar technologies (such as tracking pixels and local storage) to collect information about your Browse behaviour. Cookies are small text files placed on your device when you visit a website. They are widely used to make websites work more efficiently and to provide information to website owners.

We use different types of cookies for various purposes:

  • Strictly Necessary Cookies: These are essential for the operation of our website and enable core functionalities like page navigation and access to secure areas. The website cannot function properly without these cookies.
  • Analytical/Performance Cookies: These allow us to recognise and count the number of visitors and see how visitors move around our website when they are using it. This helps us to improve the way our website works.
  • Functionality Cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).
  • Targeting/Advertising Cookies: These cookies record your visit to our website, the pages you have visited, and the links you have followed. We will use this information, with your consent, to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

7. Consent Management Platform (CMP)

We use the Cookiebot by Usercentrics Consent Management Platform (CMP) to manage your cookie preferences and obtain your consent for the use of cookies and similar technologies that are not strictly necessary for the functioning of the website, including those used for personalised advertising.

When you first visit our website, you will be presented with a consent banner provided by Cookiebot by Usercentrics. This banner allows you to:

  • Accept all cookies.
  • Reject all non-essential cookies.
  • Customise your preferences and choose which categories of cookies you consent to (e.g., analytics, marketing).

Your choices are recorded and respected by the CMP. You can change your cookie preferences at any time by clicking on the cookie icon or link typically located in the footer of our website. The CMP provides a clear overview of the cookies used on our site and their purposes.

By providing your consent through the CMP, you are giving us permission to place and use the selected categories of cookies and process the data collected by them for the stated purposes. You can withdraw your consent at any time through the CMP.

8. Sharing Your Data

We may share your personal data with the following categories of recipients:

  • Our Advertising Partners: Including ad exchanges, SSPs, DSPs, and ad networks, for the purpose of displaying ads on our website and, where you have consented, for personalised advertising. These partners are contractually obligated to handle your data in accordance with applicable data protection laws and our instructions.
  • Service Providers: Third-party vendors and service providers who perform functions on our behalf, such as website hosting, analytics, and IT support.
  • Legal and Regulatory Authorities: If required by law or in response to a valid legal request, such as a court order or government inquiry.
  • Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred to the acquiring entity.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

9. International Transfers

Some of our advertising partners and service providers may be based outside the UK or the European Economic Area (EEA). When we transfer your personal data outside the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government or the European Commission.
  • Where we use certain service providers, we may use specific contracts approved for use in the UK or EEA which give personal data the same protection it has in the UK/EEA.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield or an equivalent framework that provides similar protection to personal data shared between the UK/EEA and the US.

10. Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, you can ask us to delete your data (see “Your Legal Rights” below).

12. Your Legal Rights

Under UK data protection law, you have several rights regarding your personal data. These include:

  • The right to be informed: To be informed about how your personal data is collected and used. This is what this Privacy Policy provides.
  • The right of access: To request a copy of the personal data we hold about you.
  • The right to rectification: To request that any inaccurate or incomplete personal data we hold about you is corrected.
  • The right to erasure (the right to be forgotten): To request that we delete your personal data in certain circumstances.
  • The right to restrict processing: To request that we restrict the processing of your personal data in certain circumstances.
  • The right to data portability: To request a copy of your personal data in a structured, commonly used, machine-readable format and to transmit that data to another controller.
  • The right to object: To object to the processing of your personal data in certain circumstances, including where we are processing it for direct marketing purposes or based on our legitimate interests.
  • Rights in relation to automated decision-making and profiling: To not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

If you wish to exercise any of these rights, please contact us using the contact details provided in the “Who We Are” section above. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

13. Right to Withdraw Consent

Where we are relying on your consent to process your personal data, you have the right to withdraw that consent at any time. You can typically withdraw your consent for cookies and personalised advertising through our Cookiebot by Usercentrics CMP. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal or regulatory reasons. We will post the updated Privacy Policy on our website and indicate the “Last Updated” date at the top of the policy. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

15. Complaints

If you have any concerns about our use of your personal data, you can make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

This Privacy Policy is intended to provide you with clear and comprehensive information about our data processing practices. If you have any questions or require further clarification, please do not hesitate to contact us.