Privacy Policy

funnKEY is a global provider of digital advertising media. funnKEY’s proprietary Fnnky Platform (the "Platform") is an online advertising technology that helps advertisers to deliver more relevant online display (banner) advertisements using anonymous, non-personally identifiable information.

Privacy Practices for funnKEY’s Websites

Thinkandaction S.L. and its subsidiaries (“funnKEY”, “we” and “us”) firmly believe in the importance of online privacy. We do not collect any information that enables us to determine your actual identity (“personal information”) before, during or after your visit to this website (fnnky.com), other than personal information you voluntarily supply to us (e.g. by submitting information through the “Contact Us” form). When you provide personal information directly to us, this information is used by funnKEY solely for the purposes identified at the point you provide it.

Privacy Practices for Advertising and Content Served by The Platform

We respect your right to privacy throughout all of the services we provide. In particular funnKEY adheres to the NAI Code of Conduct as well as the principles of the Digital Advertising Alliance (DAA) and the European Interactive Digital Advertising Alliance’s (“EDAA”) regarding our use of data for interest-based advertising purposes. For more information about these organizations, their policies and interest-based advertising, please visit their websites by clicking on the following links: https://www.networkadvertising.org/, http://www.aboutads.info/, or http://youronlinechoices.eu/.

Data Collection through funnKEY Services

Through our services, our customers – advertisers, advertising agencies, publishers, and other users of funnKEY services – may collect and use information about you to provide you a more tailored online advertising experience. funnKEY’s Platform is used to create/deliver/present advertisements on behalf of advertisers, and to monitor and manage advertising campaigns performance. Delivering relevant ads that are tailored to users’ interests is known as “interest based advertising”.

We use the information we collect for online ad tailoring purposes or to deliver an advertisement to you from a company whose website or mobile application you have visited or whose advertisement you have viewed in the past. Platform’s technology employs cookies and similar technologies (like pixels and statistical device identifiers) to collect information about you in the course of providing our customers with ad-serving and campaign management services. This information, which does not enable funnKEY to determine your actual identity, may be shared with our customers and our customers’ partners for their lawful advertising purposes. In some areas of the world, certain behavioral information, such as IP addresses, may be considered to be personal information. Where this is the case, we comply with applicable laws regarding our use and processing of personal information.

funnKEY, our customers, and our respective partners may collect behavioral information to create interest segments. Unless you opt-out of these activities, funnKEY, our customers and our respective partners may use interest segments to deliver ads to your devices that are related to your interests.

We may also receive interest segments and other pseudonymous information from third parties, when they choose to provide it to us. This information may include identifiers (like cookies) and interest-based advertising data tied to those identifiers, including segments provided by third-party data providers for our clients to use in delivering tailored ads through funnKEY’s services. funnKEY does not use this data to personally identify you, neither does knowingly create or use interest segments based on sensitive categories.

Information Relating to Children

Our products and services are designed and intended for those 18 years of age and older. We do not knowingly collect personal information from persons under the age of 18 on the websites we operate or through our services. Please advise us if you are aware of our having received personal information from someone under the age of 18, in which case we will take appropriate steps to delete it.

Information Collected by Customers and their Partners

Please note that funnKEY’s customers sometimes include their own (or their partners’) ad-tags, pixels or similar technologies within advertisements that funnKEY serves to websites, in order to set and read their own cookies which funnKEY does not control. In addition, those customers may collect on their sites, APPs and social networks additional information about your visit beyond the information described in this privacy policy, or may also allow other companies (such as web analytics services) to collect information.

funnKEY is not responsible for and cannot control the data collection and use practices of its customers or their partners. You should read the privacy notices of the websites you visit and the online services and interactive ads that you use to understand what information companies collect and how they use that information.

Sharing of Information with Customers

We may share the information collected from our advertising technologies with our customers and partners, or with customers’ service providers, for their lawful advertising purposes. We use reasonable efforts to require our customers and partners to treat the information we share with them in accordance with applicable laws, the terms of the contracts we may have with them, and their own privacy policies, but cannot control their use of this information.

At the request and on behalf of a customer, funnKEY may collect personal information supplied voluntarily by consumers through their interaction on customer websites (such as email, etc.). This personal information is provided directly to the customer on whose behalf the information was collected, or the customer’s service providers, and is processed by The Platform only to the extent and as long as is necessary to provide the advertising services for which the personal information was collected.

Our customers are limited by contract to use this personal information solely for the purposes identified within the advertisement to provide consumers with requested goods, services, or information as established within that customer’s privacy policy. funnKEY is not responsible for its customers’ use of this voluntarily supplied data. funnKEY does not distribute this personal information to any party other than those indicated within the advertisement or, at the customers’ direction, their service providers. funnKEY never associates any of this personal information with any other data (such as behavioral information) gathered or used in the delivery of advertisements.

Links to Other Sites

Our site and the advertisements we serve on behalf of customers may contain links to other sites whose information practices may be different from ours. In addition, there may be links to other sites provided within the body of advertisements on other websites. We do not have control over the information that is submitted to, or collected by, these third parties. You should consult the privacy policy of these other sites to learn how your privacy is protected.

Data Security and Retention

We have reasonable technical and organizational security measures in place to help protect the personal information that is submitted to us voluntarily through our web site or collected through interactions with our services. However, no system can be completely secure, and we make no guarantees as to the safety or security of any information transmitted to or from this site or through our services.

Our Use of Cookies and Similar Advertising Technologies

This section provides additional information about the various technologies that funnKEY uses to deliver ads to you and services to our customers, including services that collect information when you interact with our customers’ ads or the sites and applications where their ads are provided.

  • Cookies: We use cookies to provide our website and also to deliver our advertising services to our customers. To learn more about the cookies we serve when you visit the funnKEY website (including how to opt-out of them), please visit our Cookie Policy.
  • Log files: As all websites, we gather certain information about your use of the funnKEY website and services automatically and store it in log files. This information includes internet protocol (IP) addresses among other technical information. We only use this information, which does not allow us to determine your actual identity, to analyze The Platform technical performance and state.
  • Pixels: We or third party advertising services providers selected by our customers may employ advertising pixels on websites and advertisements that interact with some of our services. Pixels work with cookies to record the interactions of users with websites and advertisements. We do not tie the information gathered by pixels to users’ personal information.
  • Statistical Identifiers: We may employ statistical identifiers to collect various information about your device, such as your screen resolution, browser type, operating system and so on. We do not tie the information gathered through the use of them to users’ personal information.

Opt-Out & Your Choices & Do Not Track Disclosure

To learn more about how to manage your choices and opt-out, click here.

International Data transfers

We may disclose your personal information to service providers that support us to deliver services to you or to our customers, but ensure that such service providers are contractually required to protect your personal information at all times. In cases of onward transfer to such third parties of data of EU or Swiss individuals received pursuant to the EU-US or Swiss-US Privacy Shield, respectively, funnKEY US is potentially liable if such third parties do not provide the same level of protection as the Privacy Shield Principles. In addition, we may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. If we choose to sell all or a substantial part of our business or assets, then please note we may also disclose your personal information to the third party buyer that acquires our business or its assets.

Your rights to access, update and delete personal information

You have the right to access, update, correct, delete or transfer your personal information. You can exercise these rights by contacting us through the contact form providing a valid ID card in order to verify your identity.

Changes to this Document

funnKEY reserves the right to change, modify, add or remove portions of this policy at any time and without notice, provided that any such changes do not materially adversely affect you. We encourage you to review this page periodically for the latest information on our privacy practices.

Publication date: 22/09/2022