PERSONAL DATA PROTECTION POLICY
Advertising Processing
In this policy, the term “ASK LOCALA” refers to the company ASK LOCALA SAS, registered with the Paris RCS under number 534 318 415, with its headquarters located at 55 rue d’Amsterdam, 75008 Paris. Ask Locala has a Data Protection Officer, reachable at
privacy@asklocala.com.
ASK LOCALA develops an omnichannel digital advertising platform designed for major retail chains, restaurants, and car dealerships. ASK LOCALA enables real-time evaluation of store performance, identification of top nearby consumers, generation of in-store traffic, and measurement of return on investment to maximize the potential of each establishment.
ASK LOCALA also uses a proprietary solution that allows its clients to obtain detailed statistics on the traffic of geographic areas—including physical points of sale—whether as part of an advertising campaign or not (hereinafter the “Analytics Solution”).
This policy (the “Policy”) covers the processing of personal data carried out by ASK LOCALA SAS as part of the Platform (A) and the Analytics Solution (B).
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A. PROCESSING OPERATIONS CARRIED OUT WITHIN THE PLATFORM
Role of ASK LOCALA and Data Controller
The personal data processing operations carried out within the Platform and described below are conducted by ASK LOCALA as a data processor, acting on behalf of and under the instructions of its clients (media agencies and/or advertisers – the “Clients”). In this context, the data controllers are ASK LOCALA’s Clients.
By exception, ASK LOCALA acts as data controller for processing it carries out on its own behalf for the following purposes:
- Fraud detection.
- Improvement of ASK LOCALA’s products and services.
Data Subjects
Internet users who are visitors, prospects, or individual users of mobile applications, or individual visitors of a website/app through which we collect personal data (the “User(s)”).
Personal Data Collected
- Indirect identification and browsing data (e.g., unique mobile identifiers, IP address, device information—types, OS, screen sizes, local time/time zone, etc.), and information about ads viewed or clicked.
- Precise geolocation data (latitude/longitude). We may associate this data with specific areas/locations (e.g., catchment areas) and infer a User’s presence at a given time.
Purposes and Legal Bases of Processing
Processing under the responsibility of our Clients
| Purposes | Legal Bases |
|---|---|
| Deliver personalized advertising, including retargeting, based on Users’ browsing and/or profile. | Determined by each Client. |
| Measure advertising performance, including via precise geolocation data. | Determined by each Client. |
Processing under the responsibility of ASK LOCALA
| Purposes | Legal Bases |
|---|---|
| Fraud detection. | Our legitimate interest in ensuring the security and reliability of advertising campaign data. |
| Improvement of our products and services. | Our legitimate interest in providing innovative and competitive products and services. |
Retention Period
Under Clients’ responsibility: determined by each Client; by default 13 months within the Platform.
Under ASK LOCALA’s responsibility: determined by ASK LOCALA; by default 13 months within the Platform and our systems.
These periods do not preclude the exercise of the rights detailed in “Your Rights”.
Recipients of Personal Data
Processing we carry out on behalf of our Clients
We may share Users’ personal data with:
- Authorized personnel within ASK LOCALA.
- ASK LOCALA’s subcontractors (“subsequent processors”) acting on our behalf (e.g., hosting/maintenance providers).
- ASK LOCALA’s approved partners (the “Partners”) who are third-party controllers contributing to services provided via the Platform.
See for example Google’s partner-site policy: https://policies.google.com/technologies/partner-sites.
Other potential recipients under Clients’ responsibility are determined by the Clients.
Processing under ASK LOCALA’s responsibility
- Authorized personnel within ASK LOCALA.
- Subcontractors (hosting, IT maintenance, etc.).
- Judicial authorities where required by law.
- Public administrations legally authorized to receive certain personal data (e.g., tax, social security, pension bodies).
- Legal professionals (lawyers, bailiffs) in case of litigation.
- M&A/asset transfers: appropriate safeguards and security measures will be implemented.
International Transfers
Personal data processed as part of our services is hosted by our subcontractor Amazon Web Services (AWS) in the United States. This transfer complies with the EU-U.S. Data Privacy Framework (DPF) adopted by the European Commission in July 2023. AWS has adhered to the DPF and complies with its principles.
Questions: privacy@asklocala.com.
B. PROCESSING OPERATIONS CARRIED OUT WITHIN THE ANALYTICS SOLUTION
Data Controller
ASK LOCALA is the entity responsible for the processing carried out within the Analytics Solution.
Data Subjects
Prospects or individual users of mobile applications (the “User(s)”).
Personal Data Collected
- Indirect identification data: a unique identifier of the mobile device used (IDFA or GAID).
- Precise geolocation data: latitude/longitude; may be associated with specific areas/locations (e.g., Clients’ points of sale) to infer presence at a given time.
Purposes and Legal Bases of Processing
| Purposes | Legal Bases |
|---|---|
| Obtain detailed statistics on traffic in certain geographic areas (including specific points of sale), whether or not linked to a given advertising campaign. | User consent. |
| Improvement of our products and services. | Legitimate interest (innovation/competitiveness). |
Retention Period
Users’ personal data processed within the Analytics Solution is retained for three (3) months.
This does not preclude exercising the rights detailed in “Your Rights”.
Recipients of Personal Data
- Authorized personnel within ASK LOCALA.
- Subcontractors acting on our behalf (e.g., hosting/maintenance providers).
- Judicial authorities where required by law.
- Public administrations legally authorized to access certain personal data (e.g., tax, social security, pension bodies).
- Legal professionals (lawyers, bailiffs) in the event of litigation.
In the event of mergers, splits, or asset transfers, files containing personal data may be transferred to certain third parties or reviewed (e.g., audits) with appropriate safeguards.
International Transfers
Hosting with AWS (USA); transfer in line with the DPF. AWS adherent and compliant.
Contact: privacy@asklocala.com.
C. YOUR RIGHTS
Rights available to Users under applicable regulations
Users have the following rights:
- Access & Rectification: free access to your personal data and rectification where necessary.
- Erasure: you may request deletion when:
- processing is no longer necessary for the purposes collected;
- you exercise your right to object as described below;
- data has been processed unlawfully; or
- deletion is required to comply with a legal obligation.
- Withdrawal of consent: when processing is based on consent, you may withdraw it at any time for the future.
- Objection: you may object to processing based on legitimate interest for reasons related to your particular situation (unless there are compelling legitimate grounds overriding your interests/rights/freedoms, or for legal claims).
- Restriction: you may request restriction when:
- you contest the accuracy of your data (for the time needed to verify);
- processing is unlawful and you oppose erasure;
- data is no longer needed but must be kept for legal claims; or
- you object and we verify whether overriding grounds exist.
- Portability: for data processed based on performance of your contract.
Exercise your rights or ask questions anytime at
privacy@asklocala.com. If your request concerns processing under a Client’s responsibility, only that Client is legally responsible for responding; we will forward your request.
To help us process your request, use the subject: “Exercise of rights relating to my personal data.”
You may also lodge a complaint with the competent data protection authority.
Learn more about behavioral advertising & reset the mobile advertising ID
Learn more or opt out of certain types of behavioral advertising for third-party ad networks: https://digitaladvertisingalliance.org/.
Your mobile OS also provides ad-preference controls:
Apple Support /
Google Support.
Mobile advertising identifiers are device-specific, resettable by the user, and distinct from hardware serial numbers.
Types:
- Android: GAID
- Apple: IDFA / IFA
Resetting:
- iOS: Settings → Privacy → Advertising → “Reset Advertising Identifier”.
- Android: Settings → Google → Ads → “Reset Advertising ID”.
D. CALIFORNIA (USA) SPECIFIC PROVISIONS
- CCPA rights: access, deletion, opt-out of “sale”, non-discrimination.
- Information: categories collected; business/commercial purposes; sources; categories disclosed/sold in past 12 months; categories of third parties — as described in this Policy.
- Deletion: California consumers may request deletion in line with the CCPA.
- Non-discrimination: we do not penalize consumers for exercising privacy rights.
- Opt-out of “sale”: ASK LOCALA does not sell your personal data. When acting as a service provider for publishers, purposes are limited accordingly; publishers indicate this status.
E. MEMBERSHIP IN THE TRANSPARENCY & CONSENT FRAMEWORK (TCF) OF IAB EUROPE
ASK LOCALA is a member of IAB Europe’s TCF and complies with its specifications and policies. Subject to prior EU user consent, our technologies may automatically collect information about mobile devices. Consent is obtained by partner publishers. ASK LOCALA is identified under number 119 in the TCF.
F. CHANGES TO THIS POLICY
ASK LOCALA may update this Policy. We will inform you of material changes and encourage you to review it regularly.