Client zoneCZSeznam.cz

The GDPR and advertising on Seznam

What is the GDPR and how does Seznam protect its clients’ data?

The General Data Protection Regulation, known by its acronym GDPR, comes into effect on 25th May 2018. Its goal is to protect individuals’ personal data and to inform them better about how their data is handled.

How does Seznam.cz protect its clients’ data?

The GDPR will not involve any great changes for Seznam.cz in this regard. The rights and responsibilities associated with personal data processing within the framework of commercial cooperation are, as standard practice, defined in the contractual conditions with regard to the extent of the processing of personal data and the purpose, period and conditions for any such data processing, as well as the processor’s guarantees from the point of view of personal data protection.

Seznam.cz handles its clients’ data to the extent and for the purposes defined by the concluded contractual relations, which include the option of both parties being able to opt out of the data processing and the cooperation as a whole.



“The security of our users’ personal data has always been one of our priorities. As such, the changes based on the GDPR will not mean any dramatic changes to our approach to the protection of this data.” Pavel Zima, Deputy Chair of the Board of Directors


Seznam.cz does not provide its clients’ data to any third parties. And we will not do so in future, unless our clients request us to. Our clients can contact us at any time with requests for information concerning the extent of, and method used for, the processing of their personal data.

Seznam.cz is in compliance with the GDPR with regard to the protection of its clients’ personal data.

Can I use behavioural targeting in Sklik or during the direct display of the advertisement?

The segmentation of user preferences for the purpose of issuing behavioural advertisements in the form of “a man from Prague, 30–40 years of age, a cyclist” does not lead to the collection of any personal data on Seznam.cz or its other websites.

Seznam.cz evaluates the basic behaviour of a user or the user’s browser as identified by means of cookies (without any information or need for information about who specifically is involved) as part of its services. This therefore does not involve any user-entered data.

The targeting information is never linked to an account on Seznam.cz.

Seznam.cz only stores the processed data for a limited period of time and it anonymises it thoroughly. No source data is submitted to any third parties. The data is carefully secured and only accessible to employees on the basis of existing authorisations.

You can use behavioural targeting.

Can I use retargeting and dynamic retargeting?

The same as stated above for behavioural targeting generally applies to retargeting in Sklik. Information concerning the fact that a cookie from the user’s browser visited the television category at an e-shop and at the same time did not visit the thank-you page (the completion of a purchase) does not constitute personal data. It is necessary for the retargeting list to have at least 30 users in order for a targeted retargeting advertisement to be issued. This securely ensures that it is not possible to use retargeting to target individual users.

The retargeting and dynamic retargeting undertaken in Sklik cannot be combined with more detailed targeting using personal data. It can therefore be used after 25th May 2018 in the same way as it has been to date.

The users’ consent to the saving of cookies is not necessary for retargeting purposes for the reasons set out above. Czech legislation did not introduce an opt-in principle with regard to saving cookies in the amendment to the Electronic Communications Act, no. 127/2005 Coll. section 89, subsection 3 , Rather, it preserved the opt-out approach, which Seznam.cz respects. Other European countries have introduced the opt-in principle with regard to saving cookies.

Can identification be anonymous?

Imagine that you are going to a water park. At the entrance, you are given a chip bracelet which enables you to pass through the turnstile. Once you are in the facility, the chip bracelet is used to record all your refreshment purchases, which you then pay for when you hand in the bracelet. None of your personal data is processed before you enter the park, during your stay there or after you leave, because the identification chip is not in any way linked to your identity. The operator of the water park admittedly knows what a specific bracelet was used to pay for, but does not know who was using it.

And the targeted advertising and retargeting on Seznam.cz works in the same way. The user’s browser is labelled using a cookie, just like a patron who enters a water park. The e-shop can then use the cookie to record which products were displayed in the browser. If the user then revisits a website with our advertising system while using the same browser, there is a chance that the user will be shown an advertisement for goods which he or she has previously viewed. As in the case of the water park, this also involves no personal data processing, because the recorded data is not in any way connected with the accounts on Seznam.cz.

How does Sklik differ from global advertising platforms?

Sklik and Seznam.cz

  • do not work with names, email or postal addresses or telephone numbers.
  • do not enable the targeting of individual users.
  • do not work with any data entered by the user.
  • do not enable the targeting of an area smaller than a district.
  • only provide content in Czech which is focused exclusively on Czech users and they therefore conform to the laws of the Czech Republic.

What has to be modified on a website using Sklik retargeting?

No personal data is processed if you are using retargeting. It is therefore not necessary to request the user’s consent with regard to the processing of his or her personal data. The cookie “toolbars”, which you know from some websites, are not necessary.

It is, however, necessary to state this fact in the Privacy Policy of the website where the retargeting codes have been deployed. The notifications can then state, for example:

“Our website uses retargeting technology from the Sklik service which is operated by Seznam.cz, a.s. This enables us to show customers who have shown an interest in our products our advertisements within the Seznam.cz advertising network“

If you use several tools, it is not necessary to name them individually. It is sufficient to simply announce the processor category – for example,external advertising services..

Is Seznam.cz the processor or administrator of any personal data? Is it necessary to have a signed processing contract?

No processing contract is necessary thanks to the fact that Seznam.cz does not process any personal data during targeted advertising (see the answer above).

How can a user opt out of behavioural targeting or retargeting?

It is currently possible to opt out of targeted advertising at https://o.seznam.cz/ochrana-udaju/personalizovana-reklama/(czech only).

Where does Seznam stand with regard to the WP29 statement on online behavioural advertising?

The aim of the legally non-binding statement of June 2010 issued by the WP29 working group (WP29 is an independent European advisory body for data and privacy protection) was to clarify the legislative framework for the area of behavioural targeting. EU Directive 2002/58 on Privacy and Electronic Communications (ePrivacy) has become the document of departure for the assessment of advertising systems. In its statement, WP29 expressed the opinion that, even though it is always applied whenever cookies and other similar “information” are stored in or used from an internet user’s end device, this does not yet mean that this involves personal data. The stated case argues against any across-the-board, simple comparisons of existing solutions on the part of digital service providers. Each case of information processing needs to be considered independently, as does each service. In its statement, WP29 also admittedly supported the introduction of “opt-in” mechanisms for the acquisition of user consent, but here too this merely involved a recommendation and did not constitute a legally binding instruction setting out specific rights and responsibilities for its recipients. The WP29 view on behavioural targeting was also guided by the premise that this leads to the creation of detailed user profiles. As already stated above, the targeted advertising on Seznam.cz (behavioural and retargeting) does not work like that and, thus, the global application of this targeting recommendation to Sklik is not possible.

I have an e-shop. What does the GDPR mean for me in relation to my customers?

We have published a summary of recommendations for e-shops which use advanced conversion tracking and it is available at blog Zboží.cz.

The data which Seznam collects and requires

Seznam.cz collects information about cookies, the URL from which the cookies were visited and the IP address for the purposes of better targeted advertising. In the case of dynamic retargeting, the code also sends information about the ItemID of the viewed product or any viewed category. This data is not in any way connected to the user’s personal data.

Information about Sklik cookies

Retargeting

Technology partner Seznam.cz
Host sklik.cz
Country of data storage CZ
Period of data storage max. 540 days
List of processed and stored data timestamp, sid, retargeting id, category (optional), item id (optional), url, page type (optional)
Goal/Objective of data storage Retargeting
Used technologies (i.e. Cookie, Advertiser ID...) Cookie
Fallback technologies (i.e. Fingerprints ...)
Cookie names sid
Cookie lifetime 30 days
Integration type Javascript
List of collected data (all data which is not transmitted by advertiser but collected directly from users device) timestamp, sid, retargeting id, category (optional), item id (optional), url, page type (optional)
Purpose of processing collected data Retargeting

Conversion tracking

Technology partner Seznam.cz
Host sklik.cz
Country of data storage CZ
Period of data storage max. 540 days
List of processed and stored data timestamp, sid, conversion id, value (optional), view count, ad url, click timestamp
Goal/Objective of data storage Conversion tracking
Used technologies (i.e. Cookie, Advertiser ID...) Cookie
Fallback technologies (i.e. Fingerprints ...)
Cookie names Sklik-[advertiser ID]
Cookie lifetime 30 days
Integration type Javascript
List of collected data (all data which is not transmitted by advertiser but collected directly from users device) timestamp, sid, conversion id, value (optional), view count, ad url, click timestamp
Purpose of processing collected data Conversion tracking

The personal data protection principles (the Privacy Policy)

The Privacy Policy is available in the Business terms.