Titan OS Privacy Policy
In accordance with data protection legislation and, more specifically, with the European General Data Protection Regulation (GDPR), this Privacy Policy complies with the duty to inform you about the Services provided by TITAN OPERATING SYSTEM, S.L.
1. Data Controller
In accordance with GDPR, TITAN OPERATING SYSTEM, SL. (hereinafter, "Titan" or “Data Controller” or “We”) as data controller of the Personal Data shall process your personal data (hereafter, the “Personal Data”) in a lawful, fair and transparent manner. Titan’s contact details are the following:
Tax Identification Number: B10741833.
Registered Office: Avd. Diagonal 571 2nd floor, 08029 Barcelona, Spain
DPO/Data Protection email address: data@titanos.tv
2. Purposes and lawful bases for processing
Titan shall process your personal data for different purposes. For ease of reference, the purposes for which Titan processes your personal data are detailed below, identifying the applicable lawful basis for each of them.To provide the Titan services:
2.1 Connected TV Devices
Titan offers their operating system services to end-customer Connected TV users (hereafter, “CTV Users” or “you”), collaborating with various brands in the Connected TV sector (hereafter, “CTV Sector”). Some of these brands incorporate Titan’s services since the design and manufacture stage of their devices, and these are referred to as Connected TV Devices (hereafter, “CTV Devices”) throughout this Global Privacy Policy. The provision of Titan’s services consists of allowing the display of content and other functionalities associated with the online advertisement sector in CTV Users’ CTV Devices.
The operating system services provided by Titan through the CTV Devices involve the processing of Personal Data for the following purposes:
Provide services: We use your information to ensure the provision of Titan’s services, for example, offering content through fast channels and processing the terms you search for in order to return the expected result on the CTV Device. The lawful basis for this data processing is the execution of a contractual relationship.
Maintenance and Security: We also use Personal Data to ensure that our services are working properly, such as tracking network outages or troubleshooting problems you report to us. Additionally, we may use Personal Data to ensure security, prevent and detect fraud, and fix errors. The lawful basis for this data processing is Titan’s legitimate interest.
Improve our Services: Titan collects the Personal Data in order to conduct internal research, analysis and development to improve our services, content and new features and services. The lawful basis for this data processing is Titan’s legitimate interest.
Communicate with CTV Users: We may contact CTV Users to resolve issues, if needed and deal with any complaints or questions. The lawful basis for this data processing is the contractual relationship.
Offer non-personalized services: We may offer CTV Users non-personalized services. The lawful basis for this data processing is Titan´s legitimate interest.
Offer personalized services: Titan uses the information collected to customize services. This might mean offering recommendations, personalized content and personalized search results. The lawful basis for the processing is the consent of the user given in the Consent Management Platform.
Manage the CTV Users’ account and identify the devices based on information transmitted automatically. The lawful basis for this data processing is the contractual relationship.
Link different devices to allow you to connect your Smart TV to Apps and social media. The lawful basis for the processing is the consent of the user given in the Consent Management Platform.
2.2 TITAN ADVERTISEMENT SERVICES
In this regard, Titan covers the provision of the services, in particular the delivery of the advertisement to you as a CTV User of Titan or to another device, as well as the management of the relationship between Titan, advertisers and CTV Users, and the usage of any Personal data processed. For the provision of the services, Titan offers the possibility for advertisers engaged in this sector to display advertisements, thus acting as partners of Titan.
Titan is highly committed to protecting your personal data. For this reason, Titan will only use CTV Users’ Personal data for the purposes stated hereunder, ensuring that the management of the Personal data is always in line with the purposes that Titan is registered for under the Global IAB Vendor framework, and consisting of the following:
Store and/or access information on a device. The lawful basis for the processing is the express consent of the user given in the Consent Management Platform (hereafter, “CMP”).
Use limited data to select advertising. The lawful basis for the processing is the express consent of the user given in the CMP.
Create profiles for personalized advertising. The lawful basis for the processing is the express consent of the user given in the CMP.
Use profiles to select personalized advertising. The lawful basis for the processing is the express consent of the user given in the CMP.
Measure advertising performance. The lawful basis for the processing is the express consent of the user given in the CMP.
Understand audiences through statistics. The lawful basis for the processing is the express consent of the user given in the CMP.
Develop and improve services. The lawful basis for the processing is the express consent of the user given in the CMP.
Ensure security, prevent and detect fraud, and fix errors. The lawful basis for the processing is legitimate interest.
Deliver and present advertising and content. The lawful basis for the processing is legitimate interest.
Save and communicate privacy choices. The lawful basis for the processing is legitimate interest.
Match and combine data from other data sources. The lawful basis for the processing is legitimate interest.
Link different devices. The lawful basis for the processing is legitimate interest.
Identify devices based on information transmitted automatically. The lawful basis for the processing is legitimate interest.
Use precise geolocation data. The lawful basis for the processing is legitimate interest.
Actively scan device characteristics for identification. The lawful basis for the processing is legitimate interest.
Other purposes
Regardless of the provision of Titan’s services, Titan may conduct processing activities of CTV Users’ and partners’ data with the following purposes:
Send newsletters and/or other commercial communications regarding Titan Services. The lawful basis for the processing is the legitimate interest of Titan.
Send newsletters and/or other commercial communications regarding Titan partners’ products and/or services. The lawful basis for the processing is the express consent of the user.
Comply with potential legal obligations. The lawful basis for the processing is the compliance of Titan’s with legal obligations.
3. Categories of Personal Data processed
Titan will process CTV User personal data provided by users during the provision of Titan´s services, in particular:
3.1 Connected TV Devices
With regards to Titan’ services on CTV Devices, Titan will process the following personal data:
CTV Users’ account: identification data (name, surname, email address, phone number, username and password).
Hardware and software information: IP address, device ID, device type and apps settings and characteristics, app crashes, browser type, version and language, operating system, time zones, service provider and signal strength of your wireless network.
CTV Users´ usage data: date and time you logged in, features you’ve been using, searches, clicks and content which have been shown.
Geolocation data: live-location, via IP address.
Online identifiers: device ID, online identifiers collected through cookies, pixel or other technologies that may uniquely identify your device or browser (e.g., MAC address, Device id).
Further information regarding the use of cookies may be accessed through this www.titanos.tv/cookie-policy.
3.2 Titan advertisement services
With regards to Titan’s advertising services, Titan will process the following CTV User categories of Personal data:
Audience and advertising data: CTV User preferences, interaction with the services and engagement with content.
Online identifiers: device ID, IFA id, online identifiers collected through cookies, pixel or other technologies that may uniquely identify your device or browser (e.g., MAC address, Device id).
Hardware and software information: IP address, web browser, operating system, device information, time and date of downloads, IP logs of the server, metadata, or similar traffic data.
Geolocation data: live-location, provider and signal strength of your wireless network, via the IP address.
4. Data sources
For the provision of the Services, Titan will process certain CTV User Personal Data that either CTV Users provide to us directly (such as through their CTV device) or supplied by third parties and partners that collaborate with Titan.
4.1 Connected TV Devices
Personal data of CTV Users may be received by Titan from the manufacturer partners. In particular, when the CTV User navigates through their CTV Device, the manufacturer of such CTV Device, a technological partner or a contractor that acts as our partner, providing their services, may share with us with CTV User Personal Data to process for the purposes stated above in this Privacy Policy.
4.2 Titan advertisement services
Personal data of users may be received by Titan from the following third-party partners:
Technical partners. In particular, when the CTV User is navigating through the CTV Device, the manufacturer of such CTV Device, a technological partner or a contractor that acts as our partner.
ACR providers. Providers that collect data related to publicly available content displayed on your CTV Device, such as the identity of your broadcast, cable, or satellite television provider, and the television programs and commercials viewed (including time, date, channel, and whether you view them live or later) and the location of your Smart TV.
Advertising Technical Partners. Partners of the advertising sector which use Persona Data, such as marketing purposes, ad targeting purposes, or analytical purposes, among others. For instance, these may include, among others, partners used to provide services such as server-side ad-insertion, data management platforms, supply side platforms, fast channels when it comes to audience extension activities, etc.
5. Data recipients
Personal data from CTV Users may be shared with technological partners or contractors, acting as our partner for the provision of their services. Titan requires its partners to protect CTV User Personal data.
5.1 Titan advertisement services
Titan may share CTV User Personal Data with the CTV Devices’ manufacturer partners. In particular, when the CTV User is navigating through CTV Device, the manufacturer of such CTV Device, a technological partner or a contractor that acts as our partner may receive CTV User Personal Data to process for the purposes stated above in this Privacy Policy.
5.2 Titan advertisement services
Titan may share CTV User’s Personal Data to the following third-party partners:
Technology Partners: Manufacturers and partners of your CTV Device.
Advertising Technical Partners: Partners of the advertising sector may use CTV User data for their own purposes, such as marketing purposes, targeting purposes, or analytical purposes, among others. For instance, these may include partners that provide ad-supported free channels, to whom Titan might carry out the sale of backfill inventory, as well as retail media companies, sales houses, etc.
Advertisers, media agencies, and related third parties.
Ad Measurement Companies: Companies that select advertisements, and measure and improve advertising effectiveness.
Content Partners: Companies that provide content in audio, visual or other forms, as well as supporting us in the curation of content so as to personalize this to CTV Users potential interests.
Further information regarding these third-party partners may be accessed through the CMP.
Additionally, Titan may disclose and otherwise use CTV User personal and other information where we or they reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or (d) protect against harm to our rights, property or safety, its users or the public, as required or permitted by law.
6. Data processors
Titan may engage third parties to act as service providers to perform certain tasks or services on Titan´s behalf (i.e., data processors) that may imply processing CTV User Personal data in connection with the use of Titan’s services. Such tasks or services may include hosting and cloud services providers, IT support services, CRM, mailing, analytics, Ad-server providers, Server-side Ad-insertion systems, Supply-Side Platforms, etc.
These providers will not process the Personal Data for their own purposes but only to comply with Titan’s instructions and are obliged to handle CTV User personal data in a manner consistent with Titan’s privacy policy.
7. Data retention
Titan will retain CTV Users’ Personal Data only for the time necessary to carry out the purposes they were collected for or for as long as the consents granted are not revoked, whenever the processing activity has been based on CTV User´s consent. Subsequently, if required, Titan will keep the information blocked until the legal liabilities that may have arisen as a result of the processing of CTV users' Personal Data have expired.
Further information regarding the data retention periods may be accessed through the CMP.
8. Security and confidentiality duties
Titan has implemented the necessary technical and organizational measures to guarantee the security of Personal Data and to prevent its alteration, loss, or unauthorized access or processing, taking into account the state of the art, the nature of the data, and the risks to which it is exposed. However, please note that measures on the Internet, due to their nature and global character, are not impregnable.
