Last Updated: June 20, 2025
1. Overview
Transfon Ltd ("Transfon," "we," "us," or "our") is a technology company headquartered in the United Kingdom. We operate multiple software products and services spanning consent management, user authentication, advertising technology, and related solutions (collectively, "Products"). Transfon leverages various technologies to collect information about website traffic, online advertising, mobile app traffic, and connected device traffic to deliver products and solutions (collectively, "Solutions").
This Privacy Policy describes how our corporate website (www.transfon.com), our Products, and related services (collectively, "Services") collect, use, store, share, and process personal information on behalf of online advertisers, website owners, data providers, and other businesses that use our Services. Individual Products may maintain their own supplemental privacy policies with additional details specific to that Product’s data practices. Where a Product-specific privacy policy conflicts with this Policy, the Product-specific policy governs for that Product’s Services.
2. Information We Collect
2.1 Personal Information
We may collect personal information from you in several ways, including when you visit our websites, create an account, subscribe to our newsletter, complete a form, respond to a survey, or otherwise interact with our Services. The categories of personal information we may collect include:
- Identifiers: Name, email address, postal address, phone number, IP address, account credentials.
- Device and Technical Data: Browser type and version, operating system, device type, screen resolution, language preferences, Internet service provider, and referring URLs.
- Cookie and Tracking Identifiers: Unique cookie IDs, device advertising identifiers (e.g., IDFA, GAID), and pseudonymous identifiers derived from hashed email addresses or phone numbers.
- Usage Data: Pages visited, features used, click patterns, session duration, and interaction history.
- Location Data: Approximate geographic location inferred from IP address or, where you have granted permission, precise location data from your device.
- Commercial Information: Billing details, transaction history, and subscription information.
You may visit our websites without providing personal information. Where you decline to provide requested information, certain features or Services may be unavailable to you.
2.2 Information Collected Through Our Advertising Services
Through our advertising technology platform and related services, we may collect and process information on behalf of our clients (online advertisers, website owners, data providers, and other businesses) including:
- Unique cookie and device identifiers
- Mobile device advertising identifiers
- Pseudonymous identifiers derived from hashed email addresses or phone numbers
- IP addresses and approximate location data
- Web browsing activity associated with advertising impressions
- Inferred interest and demographic segments
- Browser and device characteristics
This information is collected through partner ad requests across websites, applications, and connected television devices; cookies and tracking pixels; data provided by clients and partners; and advertising delivery processes.
2.3 Cookies and Similar Technologies
Our websites and Services use cookies, pixels, web beacons, and similar technologies to enhance your experience, analyze usage, and support advertising functions. Our Products may use proprietary identifier cookies with defined lifespans and may engage in cookie syncing with advertising partners. Consent management cookies may also be used to store and honor your privacy preferences.
You may configure your browser to refuse cookies or alert you when cookies are sent. You may also manage cookie preferences through consent tools provided on websites using our consent management platform. Disabling cookies may affect the functionality of certain Services.
3. How We Use Your Information
We process personal information for the following purposes:
- Service Delivery: To provide, maintain, and improve our Products and Services, including personalizing your experience.
- Advertising Services: To personalize and deliver advertisements, perform frequency capping, measure ad effectiveness, generate campaign reports, and support purchase attribution on behalf of our clients.
- Communications: To send transactional emails, service updates, security alerts, and, where you have opted in, marketing communications such as newsletters, product announcements, and promotional content. You may unsubscribe from marketing emails at any time by following the instructions in each email or by contacting us.
- Analytics and Improvement: To analyze usage patterns, conduct research, and improve the quality and functionality of our Products and Services.
- Security and Fraud Prevention: To detect, prevent, and respond to fraud, abuse, security incidents, and technical issues.
- Legal Compliance: To comply with applicable laws, regulations, legal processes, and governmental requests.
4. Legal Bases for Processing (EEA, UK, and Switzerland)
If you are located in the European Economic Area ("EEA"), the United Kingdom, or Switzerland, we process your personal information on the following legal bases under the UK GDPR and EU GDPR:
- Consent: Where you have provided explicit consent for specific processing activities, such as receiving marketing communications or the use of non-essential cookies for personalized advertising.
- Contractual Necessity: Where processing is necessary to perform a contract with you or to take steps at your request prior to entering into a contract.
- Legitimate Interests: Where processing is necessary for our legitimate business interests (e.g., improving our Services, fraud prevention, network security, device association), provided those interests are not overridden by your rights and freedoms.
- Legal Obligation: Where processing is required to comply with applicable legal or regulatory obligations.
Controller and Processor Roles
Depending on the context, Transfon may act as either a data controller (when we determine the purposes and means of processing, such as creating interest segments or operating our corporate website) or a data processor (when we process personal information on behalf of and under the instructions of our clients). Where we act as a processor, the client’s privacy policy governs the processing of your data, and you should direct data subject requests to the relevant client.
5. How We Share Your Information
We do not sell, trade, or rent your personal identification information to third parties, except as described below or as part of our advertising Services where data sharing is integral to ad delivery.
- Service Providers: We engage trusted third-party service providers to perform functions on our behalf, such as hosting, analytics, email delivery, payment processing, and customer support. These providers are contractually obligated to use your information only as necessary to provide services to us and in accordance with this Policy.
- Business Partners and Clients: In connection with our advertising Services, we may share pseudonymous identifiers, device information, and aggregated demographic data with advertising partners, publishers, and clients to facilitate ad delivery, measurement, and reporting.
- Legal Requirements: We may disclose your information where required by law, regulation, legal process, or governmental request, or where we believe disclosure is necessary to protect our rights, your safety, or the safety of others, investigate fraud, or respond to a law enforcement request.
- Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.
- With Your Consent: We may share your information for other purposes with your explicit consent.
6. International Data Transfers
Transfon is headquartered in the United Kingdom. Your personal information may be transferred to and processed in countries other than the country in which you reside, including countries that may not provide the same level of data protection. When we transfer personal information from the EEA, UK, or Switzerland to other jurisdictions, we implement appropriate safeguards as required by applicable law, including:
- Standard Contractual Clauses approved by the European Commission or the UK Information Commissioner’s Office
- The UK International Data Transfer Agreement or Addendum, where applicable
- Adequacy decisions by relevant authorities
- Other lawful transfer mechanisms
7. Data Retention
We retain personal information for as long as necessary to fulfill the purposes described in this Policy, maintain our Services, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:
- Account Data: Retained for the duration of your account and for a reasonable period thereafter.
- Log and Analytics Data: Retained for up to one (1) year from the date of creation.
- Advertising Data: Retained in accordance with the applicable Product privacy policy and industry standards.
- Legal and Compliance Records: Retained for longer periods where required by actual or prospective legal, regulatory, or tax obligations.
When personal information is no longer required, we securely delete or anonymize it.
8. Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit and at rest, access controls, regular security assessments, and incident response procedures. While we strive to protect your information, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
9. Your Privacy Rights
9.1 Rights Under the GDPR (EEA, UK, and Switzerland)
If you are located in the EEA, UK, or Switzerland, you have the following rights regarding your personal information:
- Right of Access: You may request confirmation of whether we process your personal information and obtain a copy of that data.
- Right to Rectification: You may request correction of inaccurate or incomplete personal information.
- Right to Erasure: You may request deletion of your personal information, subject to certain legal exceptions.
- Right to Restriction of Processing: You may request that we restrict the processing of your personal information in certain circumstances.
- Right to Data Portability: You may request to receive your personal information in a structured, commonly used, machine-readable format and transmit it to another controller.
- Right to Object: You may object to the processing of your personal information where we rely on legitimate interests, including profiling based on legitimate interests.
- Right to Withdraw Consent: Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of prior processing.
- Right to Lodge a Complaint: You have the right to lodge a complaint with your local supervisory authority.
9.2 Rights Under the CCPA/CPRA (California Residents)
If you are a California resident, you have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:
- Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected, the categories of sources, the purposes for collection, and the categories of third parties with whom we share your information.
- Right to Delete: You may request deletion of personal information we have collected from you, subject to certain exceptions.
- Right to Correct: You may request correction of inaccurate personal information.
- Right to Opt-Out of Sale or Sharing: You may opt out of the sale or sharing of your personal information for cross-context behavioral advertising. We do not knowingly sell the personal information of minors under the age of 16.
- Right to Limit Use of Sensitive Personal Information: Where applicable, you may limit the use and disclosure of sensitive personal information.
- Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.
9.3 Exercising Your Rights
To exercise any of the rights described above, please contact us at [email protected]. We will verify your identity before processing your request and respond within the timeframes required by applicable law. You may also designate an authorized agent to submit requests on your behalf.
9.4 Advertising Opt-Out
To opt out of interest-based advertising delivered through our advertising platform, you may use the following industry tools:
10. Children’s Privacy
Our Services are not directed to children under the age of 16, and we do not knowingly collect personal information from children under 16. If we become aware that we have collected personal information from a child under 16 without parental consent, we will take steps to delete that information promptly. If you believe a child has provided us with personal information, please contact us at [email protected].
11. Third-Party Websites and Services
Our websites may contain links to third-party websites, products, or services that are not owned or controlled by Transfon. We are not responsible for the privacy practices or content of those third-party sites. We encourage you to review the privacy policies of any third-party sites you visit. Your interactions with third-party websites are governed by those websites’ own terms and policies.
12. Industry Framework Compliance
Transfon complies with the IAB Europe Transparency & Consent Framework ("TCF") and adheres to its specifications and policies for processing personal data in the digital advertising ecosystem. Our vendor identification number in the IAB TCF Global Vendor List is 1370.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, Products, legal requirements, or for other operational reasons. When we make material changes, we will update the "Last Updated" date at the top of this page and, where required by law, provide you with additional notice (such as via email or a prominent notice on our Services). We encourage you to review this Privacy Policy periodically. Your continued use of our Services after any changes constitutes acceptance of the updated Policy.
14. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:
Transfon Ltd
Email: [email protected]
General Inquiries: [email protected]
