Last Update : February 5, 2025

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, who can be reached 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 their store performance, identification of top nearby consumer clients, 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 referred to as the “Solution Analytics“).

This policy (the “Policy“) covers the processing of personal data carried out by ASK LOCALA SAS as part of the Platform (A) and the Solution Analytics (B).

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1. PROCESSING OPERATIONS CARRIED OUT WITHIN THE PLATFORM 2
2. Role of ASK LOCALA and Data Controller 2
3. Data Subjects 2
4. Personal Data Collected 2
5. Purposes and Legal Bases of Processing 3
6. Retention Period of Personal Data 3
7. Recipients of Personal Data 3
8. International Transfers 4
9. PROCESSING OPERATIONS CARRID OUT WITHIN THE ANALYTICS SOLUTION 5
10. Data Controller 5
11. Data Subjects 5
12. Personal Data Collected 5
13. Purposes and Legal Bases of Processing 5
14. Retention Periods for Personal Data 5
15. Recipients of Personal Data 5
16. International Transfers 6
17. YOUR RIGHTS 6
18. Rights available to Users under applicable regulations 6
19. To learn more about behavioral advertising and reset mobile advertising identifier 7
20. Specific provisions applicable to residents of the state of California (USA) 8
21. MEMBERSHIP IN THE TRANSPARENCY AND CONSENT FRAMEWORK (TCF) OF IAB EUROPE 8
22. CHANGES TO THIS POLICY 9

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• 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 – hereinafter referred to as the “Clients“). In this context, the data controllers are ASK LOCALA’s Clients.

As an exception, ASK LOCALA acts as the data controller for processing operations it carries out on its own behalf, for the following purposes :

• Fraud detection
• Improvement of ASK LOCALA’s products and services.

• Data Subjects

The data subjects of the processing operations carried out within the Platform are internet users who are visitors, prospects, or individual users of mobile applications, or individual visitors of a website or application through which we collect personal data (hereinafter referred to as the “User(s)“).

• Personal Data Collected

The following categories of personal data are collected and processed within the Platform :

• Indirect identification and browsing data, including, for example: unique mobile identifiers, IP addresses, information about the devices used (device types, operating systems, screen sizes, device times and time zones, etc.), information related to advertisements viewed or clicked on by the Users.
• Precise geolocation data, including the latitude and longitude of the device used. We may associate this precise geolocation data with specific areas and locations (e.g., adherence to a catchment area) and deduce the presence of a User within these areas or locations at a specific time.

•  Purposes and Legal Bases of Processing

Processing under the Responsibility of Our Clients:

Processing under the Responsibility of ASK LOCALA :

• Retention Period of Personal Data

• Processing under the Responsibility of Our Clients:

The retention period is determined by each of our clients. By default, it is set to 13 months within the Platform.

• Processing under the Responsibility of ASK LOCALA:

The retention period is determined by ASK LOCALA. By default, it is set to 13 months within the Platform and our systems. The retention periods mentioned above do not preclude the exercise of the rights detailed in Section C of the Policy.

• Recipients of Personal Data

• Processing operations we carry out on behalf of our Clients : 

As part of the processing operations we carry out on behalf of our Clients, we may share all or part of the Users’ personal data with the following entities:

– Authorized personnel within ASK LOCALA, who require access to such data as part of their job responsibilities.

– ASK LOCALA’s subcontractors (referred to as “subsequent processors”) acting on our behalf and under our instructions, including but not limited to service providers responsible for hosting and/or maintaining our IT systems.

– ASK LOCALA’s approved partners (hereinafter referred to as the “Partners”), who are third-party data controllers contributing to the provision and improvement of services offered via the Platform. 

Partners are required to provide detailed information about the confidentiality and security measures they implement. Therefore, we encourage you to review the privacy policies and other informational notices made available by our Partners, including the terms of use for personal data collected through websites and applications using our Partner Google, which can be found here: https://policies.google.com/technologies/partner-sites.

Other potential recipients of personal data processed under the responsibility of our Clients are determined by those Clients.

• Processing under the Responsibility of ASK LOCALA : 

– Authorized personnel within ASK LOCALA who require access to the data as part of their job responsibilities.

– Subcontractors of ASK LOCALA acting on our behalf and under our instructions, including but not limited to service providers responsible for hosting and/or maintaining our IT systems.

– Judicial authorities, in cases provided for by law.

•  Public administrations, in cases provided for by law, authorized to access certain personal data concerning you (e.g., tax authorities, social security, and pension organizations).

– Legal professionals (lawyers, bailiffs) in the event of litigation.

• Business transactions: We inform you that operations involving mergers, splits, or asset transfers may require the transfer of files containing personal data to certain third parties and their review, for instance, during audits. In such cases, we will implement appropriate safeguards and security measures to ensure the confidentiality of your personal data.

• International Transfers

The personal data processed as part of our services is hosted by our subcontractor, Amazon Web Services (AWS), located in the United States. This transfer is carried out in compliance with the requirements of the EU-U.S. Data Privacy Framework (DPF), adopted by the European Commission in July 2023, ensuring an adequate level of protection for personal data transferred between the European Union and the United States.

Amazon Web Services has adhered to the EU-U.S. Data Privacy Framework and complies with its principles, thereby providing appropriate safeguards for the protection of transferred data.

For any questions regarding these transfers or to obtain more information, you can contact us at privacy@asklocala.com.

• PROCESSING OPERATIONS CARRID OUT WITHIN THE ANALYTICS SOLUTION

• Data Controller 

ASK LOCALA is the entity responsible for the processing operations carried out within the Analytics Solution.

• Data Subjects

The data subjects of the processing operations carried out within the Analytics Solution are prospects or individual users of mobile applications (hereinafter referred to as “User(s)”).

• Personal Data Collected

The following categories of personal data are collected and processed within the Platform:

• Indirect identification data: A unique identifier of the mobile device used, such as IDFA or GAID.
• Precise geolocation data, including the latitude and longitude of the device used. We may associate this precise geolocation data with specific areas and locations (e.g., our clients’ points of sale) and infer the presence of a User within these areas or locations at a given time.

• Purposes and Legal Bases of Processing

• Retention Periods for Personal Data 

The personal data of Users processed within the Analytics Solution is retained for a period of three (3) months.
The retention periods mentioned above do not preclude the exercise of the rights detailed in Section C, “Your Rights,” of the Policy.

• Recipients of Personal Data

Nous We may share all or part of the Users’ personal data with the following entities:

• Authorized personnel within ASK LOCALA who require access to the data as part of their job responsibilities.
• ASK LOCALA’s subcontractors acting on our behalf and under our instructions, including but not limited to service providers responsible for hosting and/or maintaining our IT systems.
• Judicial authorities, in cases provided for by law.
• Public administrations, in cases provided for by law, are authorized to access certain personal data concerning you (e.g., tax authorities, social security, and pension organizations).
• Legal professionals (lawyers, bailiffs) in the event of litigation.

Finally, we inform you that mergers, splits, or asset transfer operations may require the transfer of files containing personal data to certain third parties and their review, for example, during audits. In such cases, we will implement appropriate safeguards and security measures to ensure the confidentiality of your personal data.

• International Transfers

Personal data processed as part of our services is hosted by our subcontractor, Amazon Web Services (AWS), located in the United States. This transfer is carried out in compliance with the requirements of the EU-U.S. Data Privacy Framework (DPF), adopted by the European Commission in July 2023, ensuring an adequate level of protection for personal data transferred between the European Union and the United States.

Amazon Web Services has adhered to the EU-U.S. Data Privacy Framework and complies with its principles, thereby providing appropriate safeguards for the protection of transferred data.

For any questions regarding these transfers or to obtain more information, you can contact us at privacy@asklocala.com.

• YOUR RIGHTS 

• Rights available to Users under applicable regulations

In accordance with personal data protection regulations, Users have the following rights :

• Access and Rectification : You have the right to access your personal data free of charge and, where necessary, request its rectification.
• Erasure : You can request the deletion of all or part of your personal data in the following cases :

– When the processing is no longer necessary for the purposes for which the data was collected;

– When you exercise your right to object, as described below ;

– When the data has been processed unlawfully ; or

– When deletion is required to comply with a legal obligation to which we are subject.

• Withdrawal of Consent : When we process your personal data based on your prior consent, you have the right to withdraw it at any time for the future.
• Objection : You can object to the processing of your personal data based on legitimate interest for reasons relating to your particular situation, which you must communicate to us.
  If you exercise this right, we will cease the processing unless (i) there are compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or (ii) the processing is necessary for the establishment, exercise, or defense of legal claims.
• Restriction : You can request the restriction of the processing of your personal data in the following cases :

– When you contest the accuracy of your personal data—this restriction applies for the time necessary for us to verify the data ;

– When the processing is unlawful, but you oppose the erasure of the data and instead request its restricted use ;

– When we no longer need the data for processing but you wish us to retain it for the establishment, exercise, or defense of legal claims ;

– When you exercise your right to object—this restriction applies during the period necessary to verify whether we have overriding legitimate grounds to continue the processing.

• Portability : You can request the portability of your personal data processed based on the performance of your contract, as indicated in Section 4 of the Policy.

You can exercise these rights at any time or ask any other questions about the processing of your personal data by sending an email to : privacy@asklocala.com. If your request concerns processing under the responsibility of one of our Clients, they are solely legally responsible for responding to you, and we will forward your request to them.

To facilitate the processing of your request, we encourage you to specify the subject of your message or letter as “Exercise of rights relating to my personal data.”

Finally, you also have the right to lodge a complaint with the competent data protection authority.

• To learn more about behavioral advertising and reset mobile advertising identifier 

To learn more about behavioral advertising or to opt out of certain types of behavioral advertising for third-party ad networks, Users can visit the Digital Advertising Alliance website: https://digitaladvertisingalliance.org/.

Additionally, a User’s mobile operating system (e.g., iOS or Android) should provide the option to manage advertising preferences (often found in the device’s “Settings” function):
https://support.apple.com/en-us/HT202074
or https://support.google.com/ads/answer/2662856.

Mobile advertising identifiers are unique identifiers associated with individual mobile devices. They can typically be reset by the user and are distinct from hardware serial numbers. They are not permanently tied to a mobile device because Users can reset their advertising identifier at any time for enhanced security or to disable ad tracking. Consequently, the mobile advertising identifier can no longer be easily linked to specific devices or users.

Types of Mobile Advertising Identifiers:

• Android Identifier : Called GAID.
• Apple Identifier : Called IDFA or IFA. This is an Apple device identifier introduced with iOS 6, used for applications/publishers.

If you wish to modify the profile used for behavioral advertising services, you can reset your mobile advertising identifier by following the steps below:

• iOS : Go to “Settings,” “Privacy,” “Advertising,” and then select “Reset Advertising Identifier” (see demo on Apple Support).
• Android : Go to “Settings,” “Google,” “Ads,” and then select “Reset Advertising Identifier” (see demo on Google Support).

•  Specific provisions applicable to residents of the state of California (USA)

• Rights under the CCPA: If you are a California consumer as defined by the CCPA, you may have the right to: (i) request access to your personal data and additional details about our information practices, (ii) request the deletion of your personal data, (iii) opt-out of the “sale” of your personal data (as defined by the CCPA), and (iv) not be discriminated against for exercising your rights under the CCPA.

• Right to obtain information about collected and disclosed personal data: The CCPA requires us to disclose to California consumers the categories of personal data (as defined by the CCPA) we collect, our business and commercial purposes for collecting, using, or selling this personal data, the categories of sources from which we collect personal data, the categories of personal data we have disclosed or sold for business or commercial purposes in the past 12 months, and the categories of third parties with whom we share personal data. This information is provided in this Privacy Policy.

• Right to request the deletion of personal data : Under the CCPA, we are required to allow California consumers to request the deletion of their personal data.

• Non-discrimination for exercising privacy rights: At ASK LOCALA, we ensure that no consumer (not just California consumers) will be subject to discrimination for exercising their privacy rights granted by the CCPA or any other applicable regulation.
• Right to opt-out of the “Sale” of personal data : ASK LOCALA is a third-party company to which personal data is not sold and, more importantly, does not sell your personal data. In certain circumstances, we act as a service provider for publishers in managing processed data. In such cases, we will limit the purposes for which personal data will be processed. It is the responsibility of the publishers to indicate whether they consider us as their service provider.

D. MEMBERSHIP IN THE TRANSPARENCY AND CONSENT FRAMEWORK (TCF) OF IAB EUROPE

ASK LOCALA is a member of the Transparency and Consent Framework (TCF) of IAB Europe and is committed to complying with all specifications and policies defined within this framework.

In adherence to the principles of the TCF, we use our technologies to automatically collect information about mobile users’ devices, subject to the prior consent of end users in the European Union. This consent is obtained by the partner publishers with whom we collaborate.

ASK LOCALA is identified under number 119 within the TCF of IAB Europe.

• CHANGES TO THIS POLICY

ASK LOCALA may update this Policy. We will ensure that you are informed of any changes. 

In any case, we encourage you to review our Policy regularly.