What is Tobiras?

Tobiras is designed to provide an efficient and automated means of connecting your 1st party data with your key partner campaign performance data and the platform data accessible only via data clean rooms. This aggregation and connectivity allows the surfacing of actionable insights across your key data points, providing deeper performance understanding and informing future media and creative strategies via a reporting dashboard.

What are Tobiras’ core functions?

  1. Connect: Ability for you to connect your hashed 1st party data with your campaign performance data and platform data in our partner cleanroom environments through the Tobiras user interface;
  2. Insights & Analysis: Ability for us to view your insights in aggregate form across multiple campaigns and sources within one dashboard; and
  3. Reporting, Efficiency & Effectiveness: Ability for us, on your behalf, to run campaigns more effectively and efficiently and in turn increase performance of ad campaigns.

How is data transferred within Tobiras?

Meta AA

Your hashed personal data will be uploaded via the Tobiras User Interface and stored initially in dentsu’s Amazon Web Server hosting (for no longer than 48 hours) in the region you select before being onward transferred to our partner’s cleanroom technology storage.  For a more detailed description, please reach out to your account manager for a copy of our  Client Facing Privacy Sheet.

Google ADH

Your hashed personal data is uploaded via the Tobiras User Interface and staged only within dentsu-controlled cloud environments. Data is initially uploaded to dentsu’s shared AWS S3 staging bucket in the United States for malware scanning and hash validation. Once validated, data is transferred to dentsu’s Google Cloud Storage (GCS) in the US and loaded into a client-specific BigQuery (BQ) dataset in the US. Google ADH reads the hashed personal data directly from BQ; the hashed data does not leave BQ or get stored in Google ADH at any time.

Data Transfers

Meta AA

Upon uploading your hashed personal data to Tobiras you are requested and responsible for selecting the most appropriate dentsu storage location for your data and are requested to acknowledge your understanding of such. The dentsu storage location options are:

US West (N. California);

EMEA (London); and

Asia Pacific (Tokyo, Singapore, Sydney, Mumbai, Jakarta or Hong Kong).

Please consult your legal and compliance teams in order to make the most appropriate decision and to ensure they fully understand that your data will be onward transferred from dentsu’s storage locations to our partner clean room storage locations (only Meta’s storage location is applicable to date). Meta sets out in its Meta AA terms where it intends to store your personal data based on where it is receiving your data from. For this reason, we have made some suggestions in the diagram below about the dentsu server location you may like to choose but would encourage you to consult your legal and compliance teams to validate your choice.

Google ADH

For Google ADH, when uploading your hashed personal data in the Tobiras UI, you must manually select and confirm the US region as the data storage location. The hashed first-party data will be transferred to the US for further processing as set out in the section above. For clients based outside the US, this workflow may constitute a restricted international data transfer under the applicable data protection laws because the data is processed and stored in the US.  

Data Storage and Retention

Meta AA

For the Tobiras platform:

  • The data is stored in the Tobiras AWS instance regional hosting location of your choice for a maximum of 48 hours before being deleted.
  • Where your data cannot be transferred to the partner cleanroom, e.g. insufficient or wrong ID inputs, it will be deleted after 48 hours. In order to proceed, you will need to repeat the upload.
  • Tobiras will show visualisation usage results from the queries run on the data in the partner cleanroom environment. These results do not contain personal data and will be deleted after 90 days.

Meta have confirmed that data:

  • Subject to the EU GDPR, will be initially stored in Ireland before being transferred to the US internally by Meta.
  • Subject to the UK GDPR, US privacy laws and APAC privacy laws, will be stored directly in the US by Meta.
  • Will automatically deleted as follows:
  • Client’s hashed 1st party data after 90 days (or suitably anonymised).
  • Aggregated data after 30 days.
  • Client’s platform data after 90 days.

Google ADH

Data is stored in dentsu-controlled environments when Google ADH is used:

  • Hashed first-party personal data is held in dentsu’s shared AWS S3 staging bucket in the US for up to 1 day for malware scanning and hash validation;
  • Hashed first-party personal data is moved to dentsu’s GCS (US) for up to 1 day;
  • Hashed first-party personal data is then loaded into a client‑specific BQ dataset (US) where it is retained for up to 14 days before automatic deletion; and
  • Client’s campaign data is not physically transferred to dentsu instance of Google ADH and instead Google ADH reads data from the relevant storage location of such campaign data.

Security

  • Our security team has conducted an assessment during the design phase. The assessment covers multiple areas including, Identity and access management, data and network security, secure development and application security testing.