Personal data received from the Data Subject
- The IP address from which the device accesses a client’s website or app
- HTTP user agent
- HTTP referer [sic] (when available)
Personal data optionally relayed to Triton Digital by the Data Controller
In some cases, audio publishers may instruct Triton Digital to collect specific categories of personal data in addition to the list above:
- First-party cookie containing a unique identifier (when available)
- Information about the unique identifiers assigned to a mobile device, such as Apple's Identifier for Advertisers (IDFA) and Google's Advertising ID for Android devices (AAID) (when available)
- The approximate GPS coordinates made available by the player or device
- Demographic characteristics shared by the listener such as zip or postal code, gender, and year of birth
- Free-form content, not interpreted by Triton Digital (may or may not be known to be personal data by Triton Digital)
- Inferences or information about Data Subjects’ interests that are created, acquired, bought, sold, or used by publishers to target ads to Data Subjects (commonly known as "interest-based segments" or "segment data")
Does the Data Triton Digital Processes Qualify as "Personal Data" Under the GDPR?
The GDPR considers any person in the EEA (not just citizens or permanent residents) to have rights and freedoms relating to their personal data.
Article 4 of the GDPR defines a "Data Subject" as a person "who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity".
Every connection initiated by audio players and devices to Triton Digital systems is assigned a Triton UUID (e.g., 1234567890) before the connection is accepted. The UUID is technically required by Triton Digital systems in order for the service to be provided to the listening player or device, as per the Data Controller’s instructions.
While Triton Digital cannot identify which individual (or individuals) are using the device or browser in the real world, this unique identifier could possibly be combined with other sources of information (e.g., cookie IDs, mobile device IDs, IP addresses with full 4 octets, latitude and longitude coordinates with greater than 3 decimal places of precision).