In this policy, “Ask Locala” refers to Ask Locala SAS, a company registered in Paris under number 534 318 415, whose registered office is located at 55 rue d’Amsterdam, 75008 Paris. Ask Locala has a data protection officer, whose contact details are privacy@asklocala.com.

Ask Locala develops an omnichannel platform for large retailers, restaurants, and car dealerships. Ask Locala enables retailers to evaluate the performance of their stores against their local competitors in real time, to identify the best consumer customers in their vicinity, to generate incremental traffic at the point of sale and to measure the return on investment to reach the maximum potential of each store.

Ask Locala also markets an exclusive solution that enables its customers to obtain detailed traffic statistics for geographic areas, including physical points of sale, whether or not they are part of an advertising campaign (the “Analytics Solution”).
This policy (the “Policy“) covers the processing of personal data by Ask Locala SAS in connection with the Platform (A) and the Analytics Solution (B).
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A. DATA CONTROLLING IMPLEMENTED IN THE FRAMEWORK OF THE PLATFORM 
1. Ask Locala role and data controllers 
2. Persons concerned 
3. Personal data collected 
4. Purposes and legal basis of control 
5. Retention periods of personal data 
6. Recipients of personal data 
7. International transfers 
B. DATA CONTROLLING FOR THE ANALYTICS SOLUTION 
1. Data controllers 
2. Persons concerned 
3. Personal data controlled 
4. Purposes and legal basis of control 
5. Retention periods of personal data 
6. Recipients of personal data 
7. International transfers 
C. YOUR RIGHTS 
1. Users’ rights under applicable regulations 
2. Learn more about advertising behavioral and reset the mobile advertising 
D. SPECIFIC DISPOSALS APPLICABLE TO CALIFORNIA STATE RESIDENTS (USA) 

E. ADHERENCE TO THE TCF IAB
F. POLICY MODIFICATIONS 

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A. DATA CONTROLLING IMPLEMENTED IN THE FRAMEWORK OF THE PLATFORM
1. Ask Locala role and data controllers

The processing of personal data of the Platform and described below is carried out by Ask Locala as a subcontractor, on behalf of and on the instructions of its clients (media agencies and/or advertisers – hereinafter the “Clients”). In this context, the data processors are the Clients of Ask Locala.

As an exception, Ask Locala acts as the data controller which it implements for its own account, for the following purposes:

• The fraud detection.
• Ask Locala products and services improvement.

2. Persons concerned

The persons involved in the data control of the Platform are Internet users who are visitors, prospects or individual; users of mobile applications or individual visitors to a website or application through which we collect personal data (hereinafter the “User(s)“).

3. Personal data collected

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

• Indirect identification and browsing data, including for example: mobile unique identifier, cookie or other tracker unique identifier, IP address, information related to the terminals used (types of devices, operating systems, screen sizes, terminal times, and time zones, etc.), information based on advertisements consulted or click on by 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., our Customers’ points of sale) and infer a User’s presence within those areas or locations at a given time.

4. Purposes and legal basis of control

• When the Client is a data controller:

• When Ask Locala is a data controller:

5. Retention periods of your personal data

• The Clients as a data controller: 

The retention period is determined by each of our Clients. By default, it is 13 months on the Platform.

• Ask Locala as a data controller:

The retention period is determined by Ask Locala. By default, it is 3 months on the Platform and our systems.

The above retention periods do not preclude the exercise of the rights detailed in Section 8 of the Policy.

6. Recipients of personal data

• Client as data controller:

As part of the data control for our Clients, we may share all or a part of Users’ personal data with the following persons:

• Authorized persons within Ask Locala, who need access to it for their duties.
• Ask Locala’s subtractors (so-called “subsequent subcontractors”) acting on our behalf and in accordance with our instructions: service providers in charge of hosting and/or maintenance of our computer systems
• Ask Locala’s authorized partners (“Partners”), who are third-party data controllers that help provide and enhance the services provided through the Platform. A list of our Partners is available here.

Our Partners should provide detailed information about the privacy and security measures they implement. Therefore, we invite you to consult the privacy policies and other information provided by our Partners, including the terms of use of personal data collected trought Websites and applications using our Partner Google, which can be consulted here: https://policies.google.com/technologies/partner-sites.

Our Clients are responsible for the other possible recipients for the determination of the personal data controlled.

• Ask Locala as a data controller:

• Authorized persons within Ask Locala, who need access to it for their duties.
• Ask Locala’s substractors acting on our behalf and in accordance with our instructions: service providers in charge of hosting and/or maintenance of our computer systems, service providers in charge of sending commercial prospecting emails.
• In cases provided by law: legal authorities.
• In the cases provided by law: public administrations authorized can receive communication about certain personal data about yourself (tax administration, social security and retirement organizations).
• Court officers (lawyers, bailiffs) in the event of litigation.
• We inform you that mergers, spin-offs or sales of our assets may involve the transfer of files with personal data to some third parties, as well as their examination, for example in the context of audits. In the event of such an operation, we will implement guarantees and security measures to ensure the confidentiality of your personal data.

7. International transfers

Amazon Web Services in the United States, our subcontractor is hosting the personal data processed on the Platform. These transfers are governed the conclusion of transfer agreement including standard contractual transfer clauses published by European Commission. A copy of these contracts is available by sending an email to privacy@asklocala.com.

B. DATA CONTROLLING FOR THE ANALYTICS SOLUTION
1. Data controller

Ask Locala is the data controller entity in the framework of the Analytics Solution.

2. Persons concerned

The data controlling concerns within the framework of the Analytics Solution are Internet users who are visitors, prospects or individual users of mobile applications or individual visitors to a website or application through which we collect personal data (hereinafter the “User(s)”)

3. Personal Data collected

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

• Indirect identification data: Unique identifier of the mobile terminal used (example: 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 Customers’ points of sale) and infer a User’s presence within those areas or locations at any given time.

4. Purposes and legal basis of control

5. Retention periods of personal data

The Users’ personal data controlled by the Analytics Solution are kept for a period of three months.
The retention period above, do not prevent you from exercising your rights as detailed in the article 8 of the Policy.

6. Recipients of personal data
All or a part of Users’ personal data may be communicated to the following persons:

• Authorized persons within Ask Locala, who need access to it for their duties.
• Ask Locala’s substractors acting on our behalf and in accordance with our instructions: service providers in charge of hosting and/or maintenance of our computer systems, service providers in charge of sending commercial prospecting emails.
• In cases provided by law: legal authorities.
• In the cases provided by law: public administrations authorized can receive communication about certain personal data about yourself (tax administration, social security and retirement organizations).
• Court officers (lawyers, bailiffs) in the event of litigation.

We inform you that mergers, spin-offs or sales of our assets may involve the transfer of files with personal data to some third parties, as well as their examination, for example in the context of audits. In the event of such an operation, we will implement guarantees and security measures to ensure the confidentiality of your personal data.

7. International transfers

Amazon Web Services in the United States, our subcontractor is hosting the personal data processed on the Platform. These transfers are governed the conclusion of transfer agreement including standard contractual transfer clauses published by European Commission. A copy of these contracts is available by sending an email to privacy@asklocala.com.

C. YOUR RIGHTS

1. Users’ rights under applicable regulations

In application to the personal data protection policy, you have the following rights:

• Access and modification: you have the right to access to your personal data free and, if necessary to request modifications.
• Removal: you may request the deletion for the removal of all or a part of your personal data in the following cases:
• When their processing is no longer necessary for the final purposes its been proceeded for;

1. When you exercise your right to object under the conditions indicated below;
2. When the data has been processed unlawfully; or
3. When their 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 in the future.
• Opposition: you may object, for reasons relating to your situation which it will be up to you to communicate to us, to processing with our legitimate interest as the legal basis.

If you exercise this right, we will cease to carry out the processing concerned, unless (i) there are compelling legitimate grounds for the processing which override your interests and rights and freedoms, or (ii) for the establishment, exercise or defense of legal claims.

• Limitation: You may request the limitation of the processing of your personal data, in the following cases:

1. If you dispute the accuracy of your personal data – for a period of time that allows us to carry out the necessary checks;
2. If the processing is unlawful, but you object to the deletion of the data and instead request the restriction of their use;
3. When the processing is no longer necessary for us but you wish us to keep the data for the establishment, exercise or defense of legal claims;
4. When you exercise your right to object – for the period required to verify whether we have compelling legitimate grounds for further processing.

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

You may exercise these rights at any time or ask any questions regarding Ask Locala’s personal data processing by sending an email to: privacy@asklocala.com. You may also send a letter Ask Locala, whose address is written in Section 1 of the Policy. To facilitate the processing of your request, please include in the subject line of your message or letter “Exercising my personal data rights”.

Finally, you also have the right to file a complaint to the French Data Protection Authority (CNIL).

2. Learn more about advertising behavioral and reset the mobile advertising

To learn more about behavioral advertising or the exclusion of certain types of behavioral advertising for third-party ad networks, the User may visit the Digital Advertising Alliance’s website: https://digitaladvertisingalliance.org/. In addition, a User’s mobile operating system (e.g., iOS or Android) should also provide the User with the ability to manage their advertising preferences (sometimes in the “Settings” function of the relevant device):
https://support.apple.com/fr-fr/HT202074
or https://support.google.com/ads/answer/2662856

Mobile advertising IDs are unique identifiers that are associated with individual mobile devices. They can generally be reset by the User and are distinct from hardware serial numbers. They are not permanently linked to a mobile device because Users can reset their mobile advertising ID at any time for added security or to disable ad tracking. As a result, the mobile advertising ID can no longer be easily linked to specific devices/users.

D. SPECIFIC DISPOSALS APPLICABLE TO CALIFORNIA STATE RESIDENTS (USA)

• Rights under the CCPA: If you are a California consumer within the meaning of 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 delete of your personal data, (iii) opt out of the “sale” of your personal data (within the meaning of the CCPA), and (iv) not being discriminated against for exercising your rights under the CCPA.
• Right to obtain information about Personal Data Collected and Disclosed: The CCPA requires us to disclose to California consumers the categories of personal data (as defined by the CCPA) that we collect ; our business and commercial purposes for collecting, using, or selling that personal data ; the categories of sources from which we collect personal data; the categories of personal data that we have disclosed or sold for business or commercial purposes in the past 12 months ; and the categories of third parties we share personal data with. We have provided this information in this Privacy Policy.
• Right to Request Deletion of Personal Data: Under the CCPA, we are required to allow California consumers to request the delete of their personal data.
• Non-discrimination of consumers exercising their privacy rights: At Ask Locala, we ensure that no consumer (not just California consumers) will be discriminated for exercising privacy rights conferred by the CCPA or any other local regulation.
• Right to Opt Out of “Sales” of Personal Data: Ask Locala is a third-party company which does not purchase any personal data, and more importantly, does not sell your personal data. In some circumstances, we will act as a service provider to the publishers in managing the data processed. In this case, we will limit the final purposes of the personal data processing. It is the responsibility of the publishers to inform us whether they consider us to be their service provider.

E. ADHERENCE TO THE TCF IAB

Consent required first ! ASK LOCALA participates in the IAB Europe Transparency & Consent Framework and is also a Member of IAB Canada. We comply with IAB TCF Specifications and Policies. We use our technologies to collect information automatically from end-users devices, subject to prior consent from EU end-users, collected by publishers who work with us, including through the IAB Transparency and Consent Framework, of which we are a member). ASK LOCALA identification number within this Framework is 119.

F. POLICY MODIFICATIONS

Ask Locala may change this Policy from time to time.
We will ensure that you are informed of any changes.
In any case, we invite you to consult our Policy regularly