GDPR Statement

 

Silver Egg Technology (SET) fully supports user privacy and data rights as set forth in the GDPR and is committed to compliance.

 

SET’s enables its clients to provide item recommendations to visitors at their web sites.

To do so, SET is informed of each user’s behavior at our clients’ sites.

Behaviors tracked include browses, clicks, and purchases of specific items.

Behaviors are generally sent by Javascript embedded on the client’s web page.

[Behaviors may also be sent directly to SET by the client’s web servers, themselves.]

 

Visitor behavior is stored on SET servers in association with secret, randomly generated “cookie” id.

As far as you use encrypted connections and do not share your cookies, it is infeasible for a malicious party to violate your privacy.

[Any behaviors sent to us by client servers are associated with a client-provided id.]

SET retains this behavioral information until a customer opts out, as described below.

 

SET does not correlate cookie and customer ids with client or third party personal data – except as disclosed by our clients.

SET does not share individual behavior data it collects with third parties, or other visitors – except as specifically disclosed, otherwise.

SET does make summary statistics, based on the behavior data it collects, available to its clients.

SET does use individual behavior to train machine learning models to make better recommendations for other users.

User behavior is only indexed and accessible by the customer’s unique cookie or the client-assigned id.

In no case will SET make a user’s personal, identifiable behavior available to other parties without proper notice in violation of GDPR.

 

When customers visit a site, SET looks up a customer’s behavior from previous visits by cookie or customer id.

Behavior from the current and previous visits is used to decide which items are best to recommend.

Recommendations are made according to machine learning models trained on other customers’ previous behavior.

The objective of these models is to recommend items that maximize the likelihood of clicks and conversion.

Such recommendations can also be made off-site – when third party cookies are available to us.

SET may augment its recommendations using third party data – in compliance with the GDPR.

 

Consumers can always opt-out temporarily by setting their browser to refuse cookies.

Consumers can always opt-out permanently and be ‘forgotten’ by deleting their cookies.

Consumers can always request data associated with their cookie or customer id by contacting gdpr@silveregg.co.jp

Consumers can always request data associated with their cookie or customer id to be deleted by contacting gdpr@silveregg.co.jp

Consumers should refer to the client site’s GDPR policy in cases where the client uses customer ids.

 

Although — by design — it would not threaten the privacy of users, SET will nevertheless promptly disclose any data breach related to stored behavior data.