Scope
All data subjects whose personal data is collected, in line with the requirements of GDPR.

Roles and Responsibilities
The data protection representative is responsible for ensuring that this notice is made available to data subjects prior to Who Targets Me Ltd collecting/processing their personal data.

All Staff of Who Targets Me Ltd who interact with data subjects are responsible for ensuring that this notice is drawn to the data subjects attention and their consent to the processing of their data is secured.

The controller of the processing is Who Targets Me Ltd.

The only other processor is Amazon Web Services, Inc. which provides hosting services for our technology using European AWS instances. You can find its privacy policy at the web page: https://aws.amazon.com/privacy/.

Privacy notice

Who are we?
“Who Targets Me” is a global initiative, established to monitor the use of dark advertising in elections. Our software informs citizens of the extent to which they are being targeted by campaigns. We work with local researchers and investigative journalists around the world to help us analyse the aggregated datasets, drawing insights about the demographics being targeted and the advertising political campaigners use to influence your vote.

Who Targets Me Ltd. is a private limited company registered in the UK.

Our data protection representatives can be contacted directly here:
privacy@whotargets.me

The personal data we would like to collect from you is:

Personal data type | Source
Age | Data subject (you) via the plugin form
Gender | Data subject (you) via the plugin form
Location (Postcode/Zip/County as relevant) | Data subject (you) via the plugin form
Stated political leaning (left/right) | Data subject (you) via the plugin form
Facebook adverts seen on Facebook | Data subject (you) via the plugin

The personal data we collect will be used for the following purposes:

Creating a personal profile based on the information you supply when installing our software. Personal profiles may also include: ethnicity, socioeconomic background, years of education, perspective on the future;
obtaining statistics about which advertisers are targeting the data subject;
creating reports about political campaigns on Facebook;
we do not use this data for marketing or commercial purposes.

Our legal basis for processing for the personal data:
- explicit consent expressed when signing up to participate via the form in the plugin.

The special categories of personal data concerned are:
- Specific political opinions or preferences;
- Religious beliefs.

Those sensitive data are not directly collected by Who Targets Me but may be inferred as a result of the adverts the data subject sees on Facebook, when this information is available.

Consent
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.

Consent is required for Who Targets Me Ltd. to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by removing the plugin (which will stop data collection) or by following the link “Delete my data” inside the browser plugin by “Who Targets Me".

1. Disclosure
Who Targets Me Ltd will pass the data collected to third parties such as universities and media outlets without asking again for your consent for research purposes, private study and review. However, data will be anonymised prior to sharing, so that no personally identifiable information about you will be sent to third parties.

2. Retention period
Who Targets Me Ltd will process personal data for the length of the research and anyway it will store the personal data for a maximum of 5 years in order to allow a comparison with the same kinds of data collected in subsequent political campaigns. However, Who Targets Me will anonymise the data collected if you decide to withdraw your consent, request the erasure of your personal data, or if identifiable information is no longer useful for the purposes stated.

3. Your rights as a data subject
At any point while we are in possession of or are processing your personal data, you, the data subject, have the following rights:

- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that Who Targets Me? Limited refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.

You can send any request regarding your rights via the contact form located on the “Contact” page of the website https://www.whotargets.me or by emailing privacy@whotargets.me.

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.3 above) in the processing of your personal data.

4. Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Who Targets Me Ltd (or third parties as described above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Who Targets Me Ltd’s data protection representatives.

The details for each of these contacts are:

Supervisory authority contact details
Contact Name: Information Commissioner’s Office (ICO)
Address: Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

GDPR Owner contact details
Who Targets Me Ltd.
privacy@whotargets.me

5. Privacy statement
Read more about how and why we use your data here https://whotargets.me/en/privacy-policy/

Online privacy statement
Personal data
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

How we use your information
This privacy notice tells you how we, Who Targets Me Ltd, will collect and use your personal data for creating a personal profile based on the pages viewed on Facebook, obtaining statistics about which advertisers are targeting the data subject and creating reports about political campaigns on Facebook.

Why does Who Targets Me Ltd. need to collect and store personal data?
In order for us to conduct our research on how advertisers are targeting the audience with political campaigns, we need to collect personal data to understand witch sponsored posts are shown to you match it against the other information you choose to share with us. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

In terms of being contacted for marketing purposes Who Targets Me Ltd would contact you for additional consent.

Will Who Targets Me Ltd share my personal data with anyone else?
We may pass your personal data on to third-party service providers contracted to Who Targets Me Ltd in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to further investigate or review our research. When they no longer need your data to fulfil this service, they will dispose of the details in line with Who Targets Me Ltd's procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

It is possible that the data collected will be shared with third parties like non-profit organisations, universities or journalists in order to verify and review our research. In this case, Who Targets Me Ltd will remove any personal information, sharing only the anonymous data useful for the analysis.

How will Who Targets Me Ltd use the personal data it collects about me?
Who Targets Me Ltd will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Who Targets Me? Limited is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Under what circumstances will Who Targets Me Ltd contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Can I find out the personal data that the organisation holds about me?
Who Targets Me Ltd at your request, can confirm what information we hold about you and how it is processed. If Who Targets Me Ltd does hold personal data about you, you can request the following information:

- Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Who Targets Me Ltd or a third party, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority.
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?
Who Targets Me Ltd accepts the following forms of ID when information on your personal data is requested: passport, national ID, driving licence, birth certificate.