Retail Media Hub (RMH) provides digital retail media services, managing advertising campaigns for brands and agencies on the digital platforms and channels of partner retailers, including loyalty apps, online environments, social and other retailer channels. This notice applies to Retail Media Hub SRL in Romania and to Retail Media Hub sp. z o.o. in Poland.

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The core principle of this notice: in these services RMH does not collect, does not hold, does not store and does not access personal data of shoppers. Shopper personal data is collected and controlled by the partner retailer, which acts as data controller. RMH receives only aggregated, non-identifying reports.

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1. Our role and the role of the retailer

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The partner retailer owns the relationship with shoppers, collects their data, determines the purposes and the means of the processing, obtains consent and hosts the data. The retailer is the data controller of the shoppers' personal data.

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RMH manages and configures campaigns on the retailer's platform. RMH does not process personal data of the shoppers and receives only aggregated campaign reports. RMH is outside the chain of processing of the shoppers' personal data.

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2. What personal data we collect and for what purpose

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Within the digital retail media services, RMH does not collect personal data of the shoppers. RMH does not receive, does not store and does not process individual identifiers, for example device identifiers, application IDs, addresses, or other data that could identify a person.

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Targeting, ad delivery and measurement take place on the retailer's platform, using the retailer's first-party data. RMH configures campaigns and audience structures within the retailer's platform, without accessing the underlying personal data.

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As a result of the campaigns, RMH receives only aggregated and non-identifying reports, for example totals of impressions, views, clicks, units sold, revenue, number of shoppers reached and ROAS. This data does not identify individuals.

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The personal data that RMH itself processes is limited to the professional contact data of the representatives of our partner retailers, and the contact data of advertisers and of their representatives, in relation to which RMH acts as an independent controller.

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3. Legal basis

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Since RMH does not process personal data of the shoppers within these services, the legal basis for the processing of shopper data, including the consent for personalised advertising, lies with the retailer in its capacity as controller. Consent is obtained by the retailer when the user enrols in its loyalty programme.

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For the business contact data described above, RMH relies on its legitimate interests in establishing and managing the commercial relationship and, where applicable, on the performance of a contract.

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4. Who we share data with

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RMH does not hold personal data of the shoppers and therefore does not share it. In the relationship between RMH and the retailer, the personal data remains with the retailer. The aggregated reports received by RMH do not contain personal data.

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In the course of its activity RMH may work with suppliers and subcontractors. None of them receives shopper personal data.

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5. Your rights

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Because the personal data of the shoppers is held and controlled by the retailer, requests concerning that data, meaning access, rectification, erasure, objection, restriction, portability and withdrawal of consent, are handled by the retailer, which has the necessary access and systems.

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For the business contact data for which RMH is the controller, you can exercise these rights by contacting us at dpo@rmh.agency. We respond without undue delay and within one month of receipt, extendable by two further months where necessary.

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6. Retention periods

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The retention periods and the deletion of the shoppers' personal data are determined and executed by the retailer. RMH does not set retention for, and does not keep, personal data of the shoppers. Business contact data is retained for the duration of the relationship and thereafter only for the periods required for contractual, accounting, tax and legal purposes. The aggregated, non-identifying reports may be retained by RMH for reporting and business purposes.

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7. Data security

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The personal data of the shoppers is secured by the retailer, on its own platform. RMH applies its own organisational and security measures to its systems and to the aggregated reports that it handles, including access limited to authorised personnel through individual accounts, confidentiality obligations for staff, and a documented security incident procedure.

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8. Data location and transfers

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The personal data of the shoppers is hosted by the retailer within the European Union. The aggregated, non-identifying reports handled by RMH are stored within the European Union.

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9. Cookies and tracking technologies

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Within the retail media services, RMH does not use third-party cookies, tags or its own tracking pixels. Creatives are received as simple image files, for example JPEG, with no embedded tracking. Campaign measurement is performed natively on the retailer's platform.

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10. Contact

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For questions about this Privacy Notice, or to exercise your rights in relation to data for which RMH is the controller, please contact us at dpo@rmh.agency.

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For requests concerning shopper personal data collected through a retailer's platform, please contact the respective retailer, in its capacity as data controller.