Updated: December 15, 2022
illumin is committed to transparency, and we want you to have access to personal data that we may have about you and/or the devices that you may use to access the Internet in accordance with applicable law.
YOUR ACCESS RIGHTS
If you make a subject access request as set out in this policy, you are entitled under applicable law to see or delete the personal data that we have about you including any digital identifiers such as cookie IDs and mobile advertising IDs that illumin may store.
We will provide you with the ability to see the personal data that we have by providing you with a copy of that data. And we will delete the data upon request so long as we are not prohibited from doing so by applicable law and/or the information is not required for us for billing, fraud prevention or security purposes.
Please note that the information we process as part of the services we provide is owned and/or controlled by our clients as controllers of that data. Where we are merely the agents and/or processors of data (e.g., re: the data we process via the illumin Platform), we may be prohibited from processing this data except as directed in writing by those Clients. If that’s the case, we will submit your request to the applicable Client and await their written instructions. Also, if we are unable to locate any of the information you have requested, we will let you know.
ADDITIONAL INFORMATION ABOUT ACCESS RIGHTS FOR EU, UK AND SWISS DATA SUBJECTS
EU data subjects also have the right to port that data to a different entity than illumin, although we can’t guarantee that others will be in position to ingest this data. We will also provide EU data subjects with the ability to correct errors in the data, but reserve the right to simply delete data which you’ve indicated may contain errors or inaccuracies. We will restrict or cease processing of this data upon request and offer you the ability to object to our processing of this upon request.
ADDITIONAL INFORMATION ABOUT ACCESS RIGHTS FOR CERTAIN U.S. DATA SUBJECTS
If you make a subject access request as set out in this policy, you are entitled to see and delete the personal information that we have about you. We will confirm your request within 10 days and make a good faith attempt to fulfill your request within 45 days unless applicable law requires us to fulfill your request more quickly.
Under California law, your request to see the personal information that we have about you may include: (1) specific pieces of personal information that we may have about you; (2) categories of personal information we have collected about you; (3) categories of sources from which the personal information is collected; (4) categories of personal information that we sold or disclosed for a business purpose about you; (5) categories of third parties to whom the personal information was sold or disclosed for a business purpose under the CCPA; and (6) the business or commercial purpose for collecting or selling personal information.
You may make an access or deletion request via an authorized agent by having such agent follow the process below. Please note that we will request any authorized agent demonstrate that they have been authorized by you to make a request on your behalf. And we will attempt to verify your request. We require any authorized agents to provide us with contact details such as an email address and phone number so that we may ensure a timely response.
MAKING A DATA SUBJECT ACCESS REQUEST
Step 1: Locating Your Information
Providing us with your email address and telephone number should be relatively straightforward. Please note that we will send you an email to the address(es) provided in order to help us authenticate your request.
Here’s what you need to do in order to share your digital identifiers.
Please keep in mind that different cookies are placed on each browser that you use to access the Internet. As a result, if you use multiple browsers (for example, Google Chrome and Mozilla Firefox), you will need to locate the “auid” cookies for each browser. Your browser’s help section should provide an overview of how to locate your cookies. An internet search of how you may find cookies in your browser may also be helpful. If you need more assistance locating these cookies for your browser, please feel free to email us for assistance at firstname.lastname@example.org
Additionally, certain mobile devices (for example, mobile phones or tablets using the iOS or Android operating systems) generate persistent a “Advertising Identifier” per device, which, among other things, can be used by third parties for purposes of providing you with targeted advertising. On iOS devices, your Advertising Identifier may be referred to as an “IDFA,” “IFA,” or an “ID for Advertising.” On Android devices, your Advertising Identifier may be referred to as an “Advertising ID.” Please follow instructions from your mobile device manufacturer on how to locate your specific Advertising Identifier.
Step 2: Authentication of the Information Provided
In order to make sure that we are only providing personal data to the correct person, we also will need to take reasonable steps to authenticate your request. We request that you provide screen shots of any cookies and mobile Advertising Identifiers for which you are submitting a request. We also reserve the right to send you an email to any addresses you provide in order to authenticate that portion of your request. We also request that you fill out and sign the affidavit we’ve prepared this PDF. By filling out and signing the affidavit, you’re promising illumin that you’re the person listed on the affidavit, and proof to demonstrate that you are indeed connected to the personal data and digital identifiers you located in Step 1.
Step 3: Contacting illumin
Once you have located your Digital Identifiers and can provide us with verification of those Digital Identifiers, you should reach out to us. The easiest way to do so would be to email us at email@example.com.
Please make sure to include the following information in your email:
- Your full name
- The EU country (or U.S. State) in which you are located at the time you are making your request
- A signed affidavit, linked in Step 2
- The screenshots providing supporting proof of the Cookie IDs and Mobile Advertising IDs, as described in Step 2
Data subjects may also make a subject access request by mail, by sending a written request with all of the above-listed information to the following address:
70 University Ave, Suite 1200
Toronto, ON, Canada