Privacy Policy

I Introduction

SIA Thisberry (“Thisberry”) is the owner of the website located at (the “Website”). This policy (this “Privacy Policy”) describes the personal information we may collect from you when you access or use our Services, and how we may use that information.

By having provided your consent to these terms you allow us to process your personal data to the extent the purposes of processing have been explained to you in this policy.

For questions specifically concerning this Privacy Policy or our use of your Personal Information, cookies or similar technology, please contact us by email at You may also write to us at the following address: SIA Thisberry, Ventspils iela 65A – 66, Rīga, Latvia, LV-1046.

This policy is current as of 08 September 2018 and implements the changes required by the EU’s Directive 2016/679 (“GDPR”).

Personal Information.

Personal information is information that can be associated with a specific person and could be used to identify that specific person (“Personal Information”). Personal Information does not include information that has been made anonymous or aggregated so that it can no longer be used, whether in combination with other information or otherwise, to identify a specific person (“Non-Personal Information”). We may sell Non-Personal Information to third parties from time to time.
Personal data is furthermore defined by EU Directive 2016/679 as follows:

‘personal data’ means 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;

Legal basis for data processing

Within the EU and for EU customers the legal basis for data processing is Article 6, sections (a), (b), and (c) of EU Directive 2016/679 (“GDPR”).

For customers outside of the EU the legal basis for data processing are our Terms & Conditions of service provisioning. The security of data for EU and non-EU customers is safeguarded by the same high standard of our ISO 27001/27018 compliant combined DPMS/ISMS.

For customers in Switzerland the legal basis for data processing is the Federal Data Protection Act.

II Types of Personal Information We May Collect.

Depending on how you interact with Thisberry’s online services, either as a connected Publisher or as an end user, we may collect the following types of Personal Information from you when you access and use our Services:
your name, postage or billing addresses, telephone numbers and e-mail addresses;
geo-location information;
IP addresses from which our website(s) are accessed;
demographic information including your age, gender, interests and favorites;
your posts on our Website and your correspondence with us; and
additional information we are required by applicable law to collect.

This data is used for the following purposes:

User Type PII Process and Purpose Description
End User IP Addresses We may use IP addresses to analyze trends, administer the Services, track your movement, and gather broad demographic information for aggregate use.
We also use the user’s IP Address in order to be able to verify that our services respect the Brand Safety standards and Fraud Detection procedures.
End User Geo-Location Information Used to determine from where customers and partners use or services. Geo-location is used in aggregated per-country form. No exact geo-location is sought or used.
Connected Publisher your name, postage or billing addresses, telephone numbers and e-mail addresses; Used for billing and correspondence purposes
Connected Publisher demographic information including your age, gender, interests and favorites; Used for general demographic purposes to fine-tune our offering and to fine-tune relevant advertising.
Connected Publisher your posts on our Website and your correspondence with us Used for correspondence purposes and to react to your demands and interests.
Connected Publisher additional information we are required by applicable law to collect. Used strictly within the legal requirements that information is sought for.


III How We Use Personal Information.

You agree that we may use your Personal Information to:

  • provide you use of and access to our Services;
  • operate, improve, and personalize our Services;
  • give you access to your account information;
  • provide you with customer service or customer support;
  • contact you to resolve disputes, collect fees, and troubleshoot problems with your account or our Services and for other purposes authorized by law and consistent with this Privacy Policy;
  • customize our advertising and marketing communications with you;
  • customize, measure, and improve our content and advertising based on your ad customization preferences;
  • deliver targeted marketing, service updates, and promotional offers based on your communication preferences;
  • prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities;
  • and enforce our Terms of Use or other applicable policies.

We retain your Personal Information as long as it is necessary and relevant for our operations. In addition, we retain Personal Information from closed accounts to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Use and take other actions permitted by law. When it is no longer necessary for us to retain your Personal Information, we dispose of it in a secure manner.

IV Your Rights

(1) You have the right to be informed on how we use your data:
This information is provided in section II and III of this Privacy Policy. Should you have any further questions, please, do not hesitate to get in contact with us (cf. above, section I, for contact details).

(2) You have the right to know who your counterpart is:
SIA Thisberry, Ventspils iela 65A – 66, Rīga, Latvia, LV-1046.

(3) You have the right to know for how long we store your data
Generally, we will store your data for as long as it is operationally necessary. Your data will be deleted once you terminate your business relationship with us and no obstacle for deletion, such as a legal requirement, interferes. All our data is reviewed for usefulness every 5 (five) years.

(4) You have the right to complain to a data protection authority:
If you are an EU citizen or an EU resident please complain to the data protection authority of your home country. Please try to get in contact with us first, we will always try to seek amicable dispute resolution.
Please note that, if you are not an EU citizen or EU resident, none of these rights apply to you. Your data, however, will be held to the same secure technical standard.

(5) You have the right to ask us about what data we store:
In order to make use of this right, please get in contact with us as stated in section I.

(6) You have the right of correction:
You can request changes to the Personal Information we keep on you by sending a request to or to SIA Thisberry, SIA Thisberry, Ventspils iela 65A – 66, Rīga, Latvia, LV-1046. We will respond to your request upon verification of your identity within a reasonable period of time, and to the maximum extent practical.

(7) You have the right of deletion:
You have the right that we delete all your data, once its usefulness is no longer there or it is no longer needed for fraud prevention or other legitimate purposes.

(8) You have the right of restriction of processing:
If you want to make use of this right, please, get in contact with us, as making use of this right poses some particular challenges that need to be discussed with you on a case-by-case basis.

(9) You have the right of data transferability:
You have the right to receive your basic data in an electronic format for transfer to another provider.

(10) You have the right to withdraw consent:
If you wish to withdraw consent please get in contact with us to ensure that you are properly aware of the ramifications of a withdrawal of consent.

V Sharing Information with Others.

You agree that we may share your Personal Information with third parties as necessary to:

  • provide you with the Services which you elect to use, including the processing of payment for such Services;
  • enforce the terms and conditions of the Terms of Use made available on the Website;
  • comply with laws and regulations or respond to litigation;
  • allow for a change of ownership of Thisberry (including, but not limited to, an acquisition by or merger with another company) and related transfer of all Personal Information to the new owner, in which case any information provided prior to such change remains protected in accordance with this Privacy Policy;
  • allow advertising audits and analysis;
  • allow us to engage a third party to perform surveys measuring your experiences and use of our Services;
  • or allow designated third parties to assist with transactions, disputes and other matters regarding your use of the Services.


Please note that the provisioning of contextual videos leads to automatic decisions made by the auctioning system and that it is not possible in advance to determine which particular entity your data will be shared with. Please also note that only data relevant for the selection of an appropriate video will be shared and that all other data will not be affected.

VI Feedback and Posted Information.

Certain features of the Services may enable you to submit communications, suggestions, ideas, comments, questions, or other information to us (collectively, “Feedback”) as well as post information to the Website for review by all users of the Services (“Posted Information”). Feedback and Posted Information become public information and are submitted at your discretion. When you submit Feedback and Posted Information, you expressly consent to our collection, use and disclosure of such information in any manner.

VII Do Not Track Disclosures.

We may track users over time and across third-party websites to provide targeted advertising, and we do not respond to Do Not Track (DNT) signals. We may also work with third parties that use tracking technologies on our Services to collect information about your online activities over time and across different websites when you use our Services.

VIII Data and Information Security

We take a number of steps to keep your Personal Information secure from unauthorized access. For example, we ask you to use a unique and strong password and not to share this information with anyone. In addition, we use a reasonable level of encryption to limit access to the systems that store your Personal Information. Further, we respect and comply with applicable legislation on data protection. operates an GDPR compliant data protection management system as well as an information security management system comprising a total of 231 measures to safeguard your data.

IX Links.

We may display links to third-party websites. Please note that we cannot control and cannot be held responsible for the privacy policies of such websites. You should always read the privacy policy of a website to find out more about how Personal Information is collected and processed.

X Cookies.

We may also store information about you using cookies (files which are sent by us to your computer or other access device) that we can access when you visit or use the Services in the future. We collect information about the pages you view, the links you click, and other actions you take using our Services, or within our advertising or e-mail content. We do this to help improve the user experience of the Services. If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies. Please note that by deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of the Services.

XI Social Media Sites.

We may allow you to share information with third-party social media sites, or use social media sites or other sites to create or connect to your account. Those social media sites may give us access to certain Personal Information stored by them (e.g., content viewed and information about the advertisements within the content you have been shown or may have clicked on, etc.) from your interaction with the online services. You control the Personal Information you allow us to have access to through the privacy settings on that third-party website and the permissions you give us when you grant us access. By associating an account managed by a third party with your Thisberry account and authorizing Thisberry to have access to this information, you agree that Thisberry may collect, use and store the information provided by these sites in accordance with this Privacy Policy.

XII IP Addresses

Every computer connected to the Internet is given a domain name and a set of numbers that serve as that computer’s “Internet Protocol” or IP address. When you request a page from any page within the Website, our web servers automatically recognize your domain name and IP address. The domain name and IP address reveal nothing personal about you other than the IP address from which you have accessed the Website. We may use IP addresses to analyze trends, administer the Services, track your movement, and gather broad demographic information for aggregate use.

XIII Changes to This Privacy Policy.

We reserve the right to make changes to this Privacy Policy but acknowledge that any substantial change will require renewed consent for those parts that require your consent.

This Privacy Policy was updated on: 29 November 2018