- As a publisher, do not consider GDPR pertinent to your commercial activities and do not consider compliance is required
As Improve Digital will be GDPR compliant, and if as a publisher there is no user consent obtained for data processing, we are obliged to consider the publisher to be using ‘legitimate consent’.
- As a publisher we are still deciding how we will work with GDPR
Publishers can decide to either stop processing user data by hardcoding the user opt-out value in their Improve Digital inventory (tags, Header, etc.) and accept the revenue impact, or use ‘legitimate interest’ in order to continue sending user data to Improve.
- As a publisher I cannot/will not sign the updated contract agreements.
Publishers should decide on 'consent' or 'legitimate interest' as the legal basis for data processing and inform Improve Digital prior to 25th May, and inform of the chosen CMP implementation and framework. The process of updating contracts can happen in parallel to the technical implementation with no dependency.
- Can I decide later for either legitimate interest or user consent?
Yes, and in the interim period we will consider publishers to have legitimate interest until you inform Improve that you will obtain consent. You can change your decision at any time.
- As a publisher based in a country not covered by GDPR, do I have to do anything?
The grounds for data processing is based on the location of the user themselves, not the publisher's business location. If a publisher's users are accessing content from countries covered by GDPR, they should either obtain their ‘consent’ for data processing, or claim legitimate interest to continue processing. This will also ensure they are maximising the revenue opportunity from these users. If a publisher choose not to decide on or implement a solution, Improve will continue to process the user's data during a grace period; after this time we will assume no user consent is given and the user data will no longer be processed.
Frameworks and implementation
- As a publisher, we have implemented IAB framework – what do we do to pass you the consent indicator and consent string?
Great news; we support the IAB Framework, implement as shown in the GDPR Implementation Guide.
- How are Improve going to handle cases of missing consent (neither positive/negative consent)?
For the time being we will continue to process this traffic under a publisher 'legitimate interest' in a grace period to allow publishers to complete their GDPR consent manager implementations, or finalise their legal position on 'legitimate consent'.
- Is Improve listed as an approved vendor on the IAB Transparency and Consent Framework global vendor list?
Yes, Improve is a registered vendor and has ID 253. Publishers can implement the IAB framework to pass consent values to Improve Digital.
- What is your IAB vendor ID?
See previous question.
- As a publisher we are unsure whether to use the Improve Digital or IAB frameworks
The IAB solution is fast becoming the industry standard on supply and demand sides. We support this and publishers can implement the solutions as detailed in the GDPR Implementation Guide.
- If Improve receives an opt-out from a user, what happens?
Opt-out values are logged for the specific user id within Improve Digital databases, and opt-tut indicators signify a withdrawal of consent, and are will be flagged in the Improve platform. This includes, but is not limited to: user matching cookie IDs; ‘search’ parameter key name and values; and geo location. The impact of this will largely be determined by the targeting settings of our demand partner's buyers.
- If Improve doesn’t receive any consent indicator from a user, what happens?
Unless the publisher is marked as processing impressions based on ‘legitimate interest’, either via one of the consent frameworks or through notifying their Account team, we will process the data under assumed ‘legitimate interest’ for a short grace period after 25th May. Following this period, if the user is in a GDPR applicable region, Improve will assume no consent is given and will no longer process the user data. For impact of this, see the previous question.
- As a publisher, how do I push the consent string from my consent manager into the Improve Digital ad call?
As long as the setup for your Improve Digital products is setup as detailed in GDPR Implemenation Guide, the consent management platform documentation or support team should provide should be able to provide assistance on how to add the values to the ad calls.
- Which consent manager should I use?
The IAB has a list registered consent management provider vendors here: http://advertisingconsent.eu/iab-europe-transparency-consent-framework-list-of-registered-cmps
- Where can I find more information about the IAB Transparency and Consent Framework?
This information is available here: http://advertisingconsent.eu
Inventory types and Header Bidding
- A publisher is using the Improve Digital InApp SDK – what do they need to do?
Improve is updating the InApp SDK to allow GDPR compliancy; when this is finalised publishers will be contact notified to start the implementation.
- When will the GDPR compatible Improve Prebid adapter be available?
The Improve Prebid adapter supporting GDPR is publicly available. Please see the GDPR Implemenation Guide for more information.
- As a publisher I have classic campaigns with third party tags - how does GDPR apply?
Information coming shortly. Likely these tags need to be updated in order to grab the user consent information and send to the third party, who in turn should process accordingly.
- As a publisher I have viewability vendors running on my inventory - how does GDPR apply?
Under the IAB framework, the five purposes for which consent is to be gathered cover viewability and metrics. That means consent will have to be acquired for these in order to keep utilising these. The vendors will be able to provide more information on how to work with their platform to ensure compliance.