Collective Shield: how data is used

1. What the network processes

Report contents

An IP address (and, for IPv6, its /64 network), which customer account and website saw it, the kind of signal, its weight, and the date. No device fingerprints, names, page content or ad details are pooled.

Signals

Bad bot, Tor exit node and known attack source (weight 3); IP rotation by a blocked device and tampered browser (2); click-rule, no-JavaScript-click and data-centre blocks (1); manual exclusion by the customer (0.5). The attack-source and tampering signals come from Fingerprint, a device-identification provider; the bot, Tor and data-centre signals come from our own checks, or from Fingerprint where the customer uses it.

Who contributes

Every account, including free trials and accounts without the add-on. Suspended and cancelled accounts stop contributing because they stop tracking. Addresses a customer has allowlisted are never reported.

Who receives listings

Only accounts that pay for the add-on, and accounts on the Patrol plan, which includes it.

When an address is listed

A 30-day score of at least 4 from at least 2 different customers, with no single customer adding more than 2; or a weight-3 signal confirmed by a second customer. One customer can never list an address alone.

Shared addresses

Mobile-network and carrier-grade NAT addresses, which many people share, are never listed automatically.

What customers see

Only whether an exclusion on their own account came from the network. Never scores, report counts, or other customers’ identities or data.

Effect of a listing

When a listed address clicks a subscriber’s ad, it is added to that subscriber’s Google Ads IP exclusions (on its campaigns, and on its account’s own list where that is switched on). It stops seeing their ads; nothing else happens to it.

Retention

Reports and customer feedback are deleted after 90 days, for every account. A listing expires 30 days after the last report, and subscribers’ network exclusions are then removed from Google Ads.

Corrections

When 2 different customers remove the same network exclusion within 30 days, the address goes to staff review and stops being applied. Staff can delist an address or permanently allowlist an address or range.

2. Why we do it: our legitimate interests assessment

A summary of our assessment, following the ICO’s three-part test.

Purpose

Preventing invalid and fraudulent clicks on customers’ ads. UK GDPR recital 47 recognises processing strictly necessary for preventing fraud as a legitimate interest. Customers benefit directly, and so do the ad networks and the wider advertising market.

Necessity

A single advertiser only sees an attacker after being attacked. Pooling lets an address caught by several advertisers be blocked for others before it costs them money. There is no less intrusive way to get that effect: the network holds only the IP address, signal, account and date, and no fingerprints or browsing details.

Balancing

The only effect on a person is that their IP address stops being shown some ads for a while. Safeguards: several independent customers before listing; one customer’s influence is capped; shared mobile and CGNAT addresses are never auto-listed; removals by customers trigger review; reports deleted after 90 days; listings expire after 30 days; staff delisting and allowlisting; an objection route.

3. Your rights

You can object to the network’s processing, or ask us to check or remove a listing for your IP address, by emailing support@clicktrap.co.uk. We will look into it within one month. You can also complain to the Information Commissioner’s Office at ico.org.uk.

4. For customers: wording for your privacy notice

Our terms ask you to tell visitors to your websites how their data is used for fraud prevention. You can add this to your privacy notice:

We use ClickTrap to protect our online advertising from fraudulent and invalid clicks. When you visit our website from one of our ads, it processes your IP address, information about your device and browser, details of the ad click, the pages you visit and how you interact with them (counts of scrolling, movement and clicks, never what you type) on our behalf. If your visit shows signs of fraud, your IP address may be reported to ClickTrap’s shared fraud-prevention network, which Lanyards Trader LTD trading as ClickTrap operates as a controller, and may be excluded from seeing our ads. Our legal basis is our legitimate interest in preventing advertising fraud. See https://clicktrap.co.uk/privacy for details.