Privacy Policy

EFFECTIVE AS OF April 7, 2022

We, Piano Software Inc., Philadelphia, US and affiliated companies belonging to Piano group (collectively, “Piano”, “we”, “us”, “our”, or “we”), formerly known as Piano Media, Press Plus and Tinypass and now incorporating Newzmate, Cxense and AT Internet are committed, as data processor, to partnering with customers and users to help them understand and comply with data protection regulations (GDPR, ePrivacy, CCPA, LGPD …).

Piano provides online products for digital activities, as well as potential additional services on behalf, and based on instructions of the data controller, owners, and publishers of digital platforms – websites, mobile applications, or any other connected platform (“Publishers”).

We collect, process and store personal data and other information through our products – Composer , Analytics , DMP , VX , ID and ESP (“Platform”), or when providing our service to Publishers (“Service”). .

Personal Data Management on the Platform

To provide the Platform and/or perform the Service, Piano collect, process and store data on behalf of the Publisher. The answers to the following questions allow us to explain how we manage personal data on the Platform.

What kind of personal data do we collect?

Raw ID-type information: for instance, the user-terminal ID (cookie or mobile ID), that is transformed in a hashed visitor ID, or the IP address, that can be anonymized, to perform geolocation for instance
All standard business information provided by the products of the Platform: for instance, navigation data (browser and device type, type of events or content, …), behavior information (sources, navigation path, time spent on contents, …), information related to registered or subscribed users (first name, last name, email, …)
Additional and specific information that the Publisher can collect: based on the technology used to collect data (see following “How do we collect personal data?”), the Publisher can measure, collect, and analyze any business relevant information for him via our Platform

Composer, Analytics, and DMP collect by default pseudonymized information, but directly identifiable information can be added by the Publisher. VX, ID and ESP services are working with directly identifiable information.

We therefore consider by default all data collected, processed, and stored via our Platform as personal data according to GDPR art. 4.1.

What do we do with personal data?

We process the collected data to provide the information requested by the Publisher on the Platform: audience measurement data, content orchestration, account management, subscription processes, …

What are we not doing with personal data?

As data processor, and respecting the terms of contracts and the data processing agreement (DPA) signed with the Publisher acting as data controller, we do not:

Sell personal data to anyone;
Monetize personal data by other means;
Claim ownership over personal data;
Barter personal data for other services or products.

We do not knowingly process personal data relating to children less than 13 years of age (or 16 if the age of consent is higher in a particular country) or permit Publishers to provide us with such data. If we become aware that a Publisher has provided us with any personal data of children, we delete such data from our databases.

We do not knowingly process sensitive or special categories of personal data as defined in article 9 of the GDPR.

How do we collect personal data?

Personal data is collected via so called tagging libraries (mainly JavaScript on the web and SDK for native application) implemented by the Publisher on its online platforms. See Cookies and Similar Technologies below for further details on complementary data collection methods.

When a user/data subject visit a Publisher platform, and according to the legal basis chosen by the Publisher (see Purpose of Processing and Legal Basis below), https requests are sent to Piano servers to perform the service requested by the Publisher.

How long do we store personal data?

Depending on the product of the Platform, or regarding specific legal obligation to perform (e.g., for payment with VX), the data retention period can be different and always agreed in the contract with the Publisher acting as data controller. Analytics, for instance, has a predefined data retention period of 25 months with the opportunity for the Publisher to customize it.

For all products, all data is deleted at the end of the contract relationship with the Publisher.

Where do we store personal data?

Depending on the product used by the Publisher, the data collected from the end-user can be stored in different places. Please see the Piano Sub-Processors’ table in the Sub-processors and Affiliates paragraph below, to see where the data is stored/hosted.

Do we share personal data?

We, by default, do not share any data to anyone without the Publisher prior approval.

We, however, may share personal data, with all the adequate technical and organizational measures to protect it, in the following cases:

Intragroup: Only if necessary and for specific purposes, we may share personal data within affiliated companies belonging to Piano group (see Sub-processors and Affiliates below). Our employees might have access to personal data on a strictly need-to-know basis typically governed and limited by function, role, and department of the particular employee. All affiliated companies belonging to Piano group concluded an intra-group data processing agreement (DPA) with EU Standard Contractual Clauses.

Service providers: We use sub-contractors who might process personal data for us and to support us in providing the Platform and Services requested by the Publisher (see Sub-processors and Affiliates below).

Legal disclosures: We may have to release personal data and other information we possess when necessary or appropriate to comply with the law; cooperate with law enforcement or national security requirements; respond to lawful requests; protect the rights of Piano or a Publisher, other Piano customers, and users, and third parties; or to enforce our terms of use. However, in doing so, we may:

Dispute demands for release to the extent we believe, in our sole discretion, are unwarranted, illegitimate, or overbroad.
Will notify Publishers of any requests unless we have some contradictory orders.

Piano never had to disclose any personal data for legal purposes so far.

Cookies and Similar Technologies

To provide the products of the Platform, Piano is using trackers, especially cookies on standard websites, or mobile IDs on native applications. Local storage, server-to-server request, clear gifs, pixel tags, web beacons or other similar technologies may also be used in some cases.

You can access some information about the trackers used on and across all products (Composer, VX, ID, ESP, DMP, Analytics) under to the following link:

Piano Cookie Descriptions

Users can control the use of trackers on their devices via the following means:

Use the opt-out mechanism on the dedicated online platform provided by the Publisher
Use the device appropriate configuration (browser or cellphone Operating System – Apple or Android mainly – settings)

Our third-party partners may also use tracker, cookies, or similar technologies, to provide users advertising based upon user´s browsing activities and interests. Users can opt out of interest-based advertising click here , or if located in the EEA click here .

Purpose of Processing and Legal Basis

Publishers can use the Piano Platform and the associated Services for the following main purposes:

Understand the audience
Optimize content
Engage the audience
Monetize the online platform

Based on the main purposes observed in the digital marketing world, the following table synthesized for each purpose, what Piano product is by default aimed for, and what is the by default legal basis for seen on our side for this purpose:

Purpose	Product	Legal Basis
Audience and Analytics	Analytics, DMP	Consent under GPDR or Exemption under ePrivacy
Content Personalization or Performance	Composer, ESP	Consent under GDPR
Advertising (personalized or not)	DMP	Consent under GDPR
“One to one relationship” (account management, subscription, newsletter, …)	VX, ID, ESP	Consent or Contract under GDPR

IMPORTANT: as a data controller, the Publisher can decide to use one or several products of the Platform for other purposes that the one foreseen originally, as well as to choose whatever legal basis he interprets to be the best in his specific case.

Each Publisher signs a data processing agreement (DPA) with Piano to formalize these purposes and associated responsibilities.

International Data Transfers

Depending on the products of the Platform used by the Publisher, as well as the potential additional services requested by him, data may be transferred outside of original country where the data has been collected.

Please see the hosting option by product within the Piano Sub-Processors’ table in the Sub-processors and Affiliates paragraph below, as well as the ‘Do we share personal data?’ part of the Personal Data Management on the Platform above.

To meet with European requirements under the GDPR in terms of data transfers, Piano uses the following mechanisms:

EU Standard Contractual Clauses (SCC) through the data processing agreement (DPA) signed with the Publisher as well as with sub-processors;
Binding Corporate Rules (BCRs) approved for both controller and processors transfers;
Additional technical measures as encryption, pseudonymization or anonymization of the data.

To meet the guidelines of the PIPEDA in the applicable Canadian provincial legislation, Piano recognizes and has controls in place to ensure that the privacy of personal information about an “identifiable individual” used in the course of “commercial activity” is protected and managed in the appropriate way.

Check the adequacy decisions under the GDPR, as well as the data protection around the world here .

Data Subject’s Rights

The GDPR, as many privacy laws around the word, empower data subject rights on its personal data. Piano’s Platform enable Publishers to apply these rights to what is applicable regarding the data collected for their purposes (see Purpose of Processing and Legal Basis above).

The following table list all the main applicable rights regarding online data that and end-user can request to Publishers, and where Piano provide standard solutions to these Publishers.

Data Subject Right	Product	Mean
Information	All	Via Publishers’ information (CMP, Privacy Policy, …)
Access	All	Via a request to the Publisher’s DPO
Rectification	DMP, VX, ID, ESP	Via a request to the Publisher’s DPO
Erasure	All	Via a request to the Publisher’s DPO
Portability	All	Via a request to the Publisher’s DPO
Object	All	Via opt-out mechanism provided by the Publisher

Piano’s data protection team is able to support the process of applying a data subject right.

Please contact [email protected], or any other communication channel listed in Data Protection Officer and Point of Contact below, for any further information.

Data Breaches and Security Measures

Data Breaches

Piano maintains an incident response plan which governs the communication and process in the case of a data breach. Contractually this is covered between Piano and all Publishers, in the Master Service Agreement.

Security Measures

Piano security measures by pseudonymization and encryption of personal data; maintaining a detailed DRP to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services which in turn allows Piano to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident. Piano maintains a process for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.

For more information visit our Security documentation .

Sub-processors and Affiliates

Piano Sub-Processors

To support delivery of our Platform, we may engage and use data processors with access to certain Publisher’s Customer Data (“Sub-processor”).

The following table provides information about the identity, location, and role of core Sub-processors necessary to provide products of our platform:

Entity name	Sub-processing activities	Entity (hosting) country	Products
Amazon Web Services, Inc.*	Cloud Service Provider	USA (hosting option in the EU, US, Australia, and Japan)	Composer, VX, ID, ESP, Analytics (EU), SocialFlow
Braintree	Payment Provider	United States	Composer, VX, ID
Google Inc.	Cloud Service Provider (for logs only)	United States	Composer, VX, ID, ESP
Hetzner Online GmbH	Data center provider	Germany	DMP
Microsoft Azure	Cloud Service Provider (Operations)	United States (hosting EU, US, Japan)	ESP, DMP
Packet Host, Inc.	Data center provider	United States	DMP
Snowflake Computing, Inc.	Data platform solution	USA (hosted in the EU)	Analytics
SoftLayer Technologies, Inc. (IBM Cloud)	Data center provider	United States	DMP

* AWS is certified for following the CISPE code of conduct endorsed by the EDPB .

Piano may use the following Sub-processors to perform other services around the Platform:

Entity name	Sub-processing activities	Entity (hosting) country	Products
Agent Infinity, Inc.	Global technical support team	Philippines	All
Alchemer	Survey Collection for Strategic Consulting	United States	Composer, VX, ID for Strategic Services clients only
Enreach Solutions Oy	Data segmentation provider	Finland	DMP
Google Inc.	Cloud Service Provider	United States	Composer, VX, ID
Google Inc.	Analytics and reporting	United States	SocialFlow
Google Ireland, Ltd.	Data backup storage	Ireland	DMP
MailChimp, Rocket Science Group	Cloud-based Email Notification Services	United States	VX
Mailgun Technologies, Inc	Cloud-based Email Notification Services	United States	ESP
Mode Analytics	Analytics Visualizations	United States	Composer, VX, ID
Salesforce.com France SAS	B2B Marketing automation (marketing & product communications to prospects and customers)	United States	Analytics
Zendesk, Inc.	Cloud-based Customer Support Services	United States (hosted in the EU)	Composer, VX, ID, ESP, DMP, Analytics, SocialFlow
TextRazor	Link text analysis	United Kingdom	SocialFlow
Twilio	SMS for OTP codes	United States	SocialFlow
Sailthru	Transactional Email	United States	SocialFlow
Intercom	In-App communications	United States	SocialFlow
Sentry	Error reporting	United States	SocialFlow
WPEngine	Marketing site hosting	United Kingdom	SocialFlow

Prior engaging any third-party Sub-processor, Piano performs diligence to evaluate their privacy, security, and confidentiality practices, and executes an agreement implementing its applicable obligations.

Piano Affiliates

Piano has offices located around the globe who, depending on the Service required by the Publisher, may process its data:

Entity name	Entity country (EU transfer mechanism)
Applied Technologies Internet GmbH	Germany (EU)
Applied Technologies Internet SAS	France (EU)
AT Internet LTD	United Kingdom (adequate third country based on Commission Adequacy Decision )
Cxense Finland Oy	Finland (EU)
Cxense Holdings	United States (BCR)
Cxense, Inc.	United States (BCR)
Newzmate Sp. z o.o.	Poland (EU)
Piano Software B.V.	Netherlands (EU)
Piano Software, Inc.	United States (BCR)
Piano Software GmbH	Germany (EU)
Piano Co. Ltd.	Japan (adequate third country based on Commission Adequacy Decision )
Piano Software Norway NUF	Norway (EEA)
Piano Software Singapore PTE LTD	Singapore (BCR)
Piano Software, s.r.o.	Slovakia (EU)
SocialFlow, Inc.	United States

Piano affiliates don’t have automatic access to all Platform data. The access of Platform data is managed and strictly limited to what is necessary. BCR details are available here.

Data Protection Officer and Point of Contact

For all questions related to our privacy policy and how Piano collects, processes and stores personal data, please feel free to contact the appointed Data Protection Officer (“DPO”):

Email: [email protected]

Mail: Attn: Piano Software Group DPO

Štefánikova 14

Bratislava, 811 05

Slovakia (EU)

For specific request by legal authorities, courts, government agencies, or parties involved in litigation for customer data, disclosures should include the following information:

The requesting party;
The relevant criminal or civil matter;
A description of the specific Publisher’s data being requested, including the relevant Publisher’s name and relevant authorized user’s name (if applicable).

Requests should be prepared and served in accordance with applicable law. All requests should be narrow and focused on the specific customer data sought. All requests will be construed narrowly by Piano, so please do not submit unnecessarily broad requests.

Piano will notify the Publisher before disclosing any of its data so that the Publisher may seek protection from such disclosure unless Piano is prohibited from doing so or there is a clear indication of illegal conduct or risk of harm to people or property associated with the use of such Publisher’s data.