Privacy Policy Advertising – Group

PRIVACY POLICY 

ASK LOCALA

ASK LOCALA is developing an omnichannel digital advertising platform, primarily aimed at major retail chains, restaurants, and car dealerships. ASK LOCALA enables clients to evaluate the performance of their points of sale in real time, identify the best local customers, generate in-store traffic, and measure return on investment to maximise the potential of each establishment. ASK LOCALA delivers targeted advertising to consumers during their use of mobile apps or websites accessible via mobile devices, participating in real-time bids.

ASK LOCALA also provides a proprietary solution that allows its clients to obtain detailed statistics on foot traffic in specific geographic areas—including physical points of sale—whether or not in connection with an advertising campaign. 

This policy (the “Policy“) covers the processing of personal data carried out by ASK LOCALA in connection with the services described above. It is intended to explain in detail how we handle your data and applies to you if you are located in the European Union. 

If you are located outside the European Union, the applicable policy is available via the following links: 

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  1. WHO IS THE DATA CONTROLLER? 1
  2. INFORMATION WE PROCESS 2
  3. HOW DO WE USE THE INFORMATION? 2
  4. INFORMATION SHARING 5
  5. Data recipients 5
  6. International transfers 6
  7. YOUR RIGHTS 6
  8. User rights under applicable regulations 6
  9. Behavioral advertising and mobile advertising identifier 7
  10. ADHERENCE TO THE IAB EUROPE TRANSPARENCY AND CONSENT FRAMEWORK (TCF) 8
  11. SPECIFIC PROVISIONS APPLYING TO RESIDENTS OF THE STATE OF CALIFORNIA (USA) 8
  12. CHANGES TO THIS POLICY 9
  13. CONTACT US 9

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  • WHO IS THE DATA CONTROLLER? 

The processing of personal data in connection with the services described above is carried out by ASK LOCALA, a simplified joint-stock company with a single shareholder, registered with the Paris Trade and Companies Register under number 534 318 415, with its registered office at 55 RUE D’AMSTERDAM, 75008 PARIS, acting as the data controller.

  • INFORMATION WE PROCESS 

We process data about you that is associated with the mobile advertising identifier of your mobile device. 

If you have given your consent, our partners provide us with information collected via your mobile advertising identifier (such as IDFA for Apple or AAID for Android) when you use mobile apps or websites. Your consent to the use of this information is obtained by the publisher operating the websites and mobile apps you use.

The categories of data processed in this respect by ASK LOCALA are as follows:

    • Consent data: consent string to verify that you authorize us to process your data.
  • Indirect identification data: Mobile unique identifier (MAID), IP address.
  • Browsing data, including, for example, information related to the devices or browsers used (device types, operating systems, device language, screen sizes, device time and time zones, etc.), and information about the advertisements viewed or clicked on by users (e.g., number of impressions, ad clicks, etc.).
  • Precise geolocation data, derived from the connection used by the device, including the latitude and longitude of the device.We may associate this precise geolocation data with specific zones and locations (for example, the area around a client’s store) and infer the presence of a user within these zones or locations at a given time.
  • Tracking tools: ASK LOCALA and its customers or partners may use tracking tools (e.g., pixels) if you have consented to this.

This data does not identify you directly (ASK LOCALA does not use data such as your name or postal address).

  • HOW DO WE USE THE INFORMATION? 

We process your data for the following purposes: 

  1. Dissemination of targeted or non-targeted advertisements
Processing name Processing purpose Legal basis Duration of storage
Delivery and targeting of advertising via our own platform (Fusio DSP) or via third-party DSP platforms Deliver targeted advertising campaigns through a real-time bidding (RTB) system on our proprietary DSP or third-party DSPs according to our advertiser clients’ criteria Consent 13 months
Measure the performance of advertising campaigns via our Fusio DSP platform Measure advertising campaign performance (ad serving) to produce reports. This includes tracking ad impressions, tracking in-ad user actions (in-ad events), and the number of clicks. Consent 13 months
Pre-bid filters with third-party partners via our Fusio DSP platform (IAS, DoubleVerify) Optimize campaigns by applying filters before deciding to participate in a bid. These filters take into account the visibility of the ad placement, fraud risks, and consistency with the advertiser’s brand image (brand safety) Consent 13 months
Media buying optimization algorithms Adjust bids in real time based on publisher performance. Consent 13 months
Configuration of “capping” conditions via our Fusio DSP platform Set a maximum ad display repetition per ad ID (IDFA, AAID) to limit the number of times an ad is shown to the same user Consent 60 days
Use of third-party audiences via Fusio DSP (Adsquare) Use audience segments to decide whether to participate in a bid when the user matches the targeted audience Consent 13 months
Drive-to-store measurement (Adsquare) via Fusio DSP Evaluate the impact of campaigns on physical in-store visits via the Adsquare tool Consent 13 months
Centroid detection algorithms Use mobility data to identify suspicious or inconsistent locations (fraudulent latitude/longitude coordinates). Legitimate interest 3 months

  1. Audience creation 
Processing name Processing purpose Legal basis Duration of storage
Custom audience creation Create segments (groups of users with common characteristics) for ad targeting Consent Daily calculation rolling 30-day window
Integrate custom audiences into the Fusio DSP platform. Build audience segments for ad targeting based on information provided by our customers Consent 13 months
Retarget users who have already seen or clicked on an advertisement (click impressions), thanks to the campaigns broadcast via our Fusio platform Build audience segments for ad targeting based on exposure or clicks recorded during previous campaigns managed via Fusio DSP. Consent 13 months

  1. Measurement of in-store visits
Processing name Processing purpose Legal basis Duration of storage
Drive-to-store measurement (Locala) Evaluate the impact of campaigns on physical in-store visits of users with the Locala tool Consent 13 months

  1. Trend analysis
Processing name Processing purpose Legal basis Duration of storage
Trend analysis via the planning platform Provide studies to improve clients’ strategies by using mobility data flows to produce statistical trend reports, media strategies, and target audience descriptions Consent Raw data: 120 days

  1. Selection of premium advertising inventories
Processing name Processing purpose Legal basis Duration of storage
Curated Deal Inventory curation based on publishers, geotargeting and/or custom audiences to maximize campaign performance and deliver premium advertising campaigns, optimized to appear on the right sites, with the right audiences and in the right geographic areas Consent 13 months

  1. Compliance with our legal obligations
Processing name Processing purpose Legal basis Duration of storage
Manage requests to exercise rights Manage requests to exercise your rights under data protection regulations to ensure your choices and rights are respected, including managing an opt-out list Legal obligation 5 years from the closure of the exercise request 
Manage the opt-out list Maintain an opt-out list to identify MAIDs that oppose the processing of their data Legal obligation Until the opt-out is withdrawn
Verify consent string validity Verify the consent given by the user to ensure that the processing associated with their data is only activated if the user has previously consented to it Legal obligation 13 months for DSP Fusion

120 days max for mobility data 

The retention periods referred to above do not preclude the exercise of the rights detailed in point E of the Policy, insofar as these rights can be legally exercised. 

  • INFORMATION SHARING

  1. Data recipients

As part of the processing of your data, ASK LOCALA may give access to your data to the following categories of persons: 

  • ASK LOCALA staff members responsible for processing your data as part of their duties;
  • The entire ASK LOCALA group, including its subsidiaries and affiliates;
  • Where applicable, to our partners and service providers, including performance measurement providers;
  • SSP (Supply Side Platform) platforms involved in the real-time bidding process for advertising spaces;
  • Our clients (advertisers or media agencies). In this case, our clients act as independent data controllers under the conditions set out in their own privacy policies; 
  • Authorized third parties who may obtain access to data under a legal or regulatory provision, as well as our legal advisors;
  • in the event of a merger, acquisition of our business or assets or other similar event, to a potential buyer or investor of our business or assets with whom we have a contractual relationship.
  1. International transfers

Personal data processed as part of our Services may be transferred outside the European Union as some of our hosting servers are located in the United States. Our host is Amazon Web Services (AWS), certified in accordance with the Transatlantic Agreement (Data Privacy Framework (DPF)), considered by the European Commission to guarantee an adequate level of protection for personal data transferred between the European Union and the United States. 

If Ask Locala uses other subcontractors or partners located outside the European Union, it will only do so after having taken the necessary and adequate measures to ensure a level of protection and security of personal data equivalent to that offered in Europe. If you have any questions about these transfers or would like more information, you can contact us at the address given in point G below.

  • YOUR RIGHTS 

  1. User rights under applicable regulations

In accordance with the regulations on the protection of personal data, Users have the following rights, which you can exercise by contacting us at the contact details indicated in point H: 

  • Access: You have the right to access your personal data free of charge, to obtain a copy of the processed data and information on how we process this data. 
  • Rectification: You have the right to request the rectification of your personal data.
  • Restriction: You can request the restriction of the processing of your personal data, in the following cases: 
  • When you dispute the accuracy of your personal data—for a period of time that allows us to carry out the necessary checks; 
  • When the processing is unlawful but you oppose the erasure of the data and instead require the restriction of its use; 
  • When the processing is no longer necessary for us but you want us to keep the data for the establishment, exercise or defense of legal rights; 
  • When you exercise your right to object—while verifying whether we have compelling legitimate grounds to continue processing.
  • Withdrawal of your consent: When we process your personal data on the basis of your prior consent, you have the right to withdraw it at any time and for the future.
  • Objection: You can object, for reasons relating to your particular situation that you will have to communicate to us, to the processing based on our legitimate interest. 

In such cases, we will stop processing the relevant data unless (i) there are compelling legitimate grounds for processing that override your interests, rights, and freedoms, or (ii) the processing is required for the establishment, exercise, or defense of legal claims.

  • Portability: You may request the portability of your personal data when processing is based on contract performance.
  • Deletion/erasure: You can request the deletion of all or part of your personal data in the following cases: 
  • When processing is no longer necessary for the purposes for which it was collected; 
  • When you withdraw your consent or exercise your right to object as described above; 
  • When the data has been the subject of unlawful processing; or 
  • When its erasure is required to comply with a legal obligation to which we are subject.

You can exercise these rights at any time, or ask any other question relating to the processing of your personal data, by contacting us at the contact details indicated in point G below. In order to facilitate the processing of your request, we invite you to write the subject of your message or your mail by specifying “Exercise of rights relating to my personal data“. We will respond to any request received from you within one month from the date of receipt of your message. If your request is not sufficiently precise or does not contain all the elements required to respond to your request, ASK LOCALA may ask you to provide additional information.

Finally, you also have the right to lodge a complaint with the French Data Protection Authority (CNIL), 3, Place de Fontenoy – TSA 80715 – 75334 Paris Cédex 07.

  1. Behavioral advertising and mobile advertising identifier

We use information to help our customers deliver advertising that is of interest to Users, i.e., targeted advertising. 

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

This type of advertising is based on mobile advertising identifiers, which are unique identifiers associated with mobile devices. 

There are two types of mobile advertising identifiers:

  • The Android identifier is called GAID  
  • The Apple identifier is called IDFA or IFA.  This is an Apple device identifier launched with iOS 6 which is an application/publisher identifier.

You can refuse the use of your advertising identifier and/or disable location-based targeted ads by following the steps below:

  • iOS: to control personalized ads on Apple services, go to “Settings”, “Privacy and Security”, “Apple Advertising” and finally disable the “Personalized Advertising” option (see demo on Apple Support). In addition, if you want to control the data that the apps installed on your device have access to, you can follow the procedure “Manage sharing and access” (option two) (see demo on Apple Support)
  • Android: to control personalized ads on Google services, go to “Settings”, “Google”, “Ads”, then “Delete ad ID” (see demo on Google Support). In addition, if you want to control the data that the apps installed on your device have access to, you can change the permissions granted (see demo on Google Support). 

Following these steps will stop our partners from collecting data via your mobile advertising identifier and will stop our advertising campaigns from being displayed on your mobile device. 

You can also contact us directly via this form or at the address indicated in section I if you wish to withdraw the consent you gave us to process your data.

To process your request, we may need your mobile advertising identifier so we can identify you: 

If you have an Android: please go to Settings -> Google -> Ads. You will find the unique advertising identifier of your device.

If you have an iOS mobile: Apple no longer natively displays your ID in the settings. You will need to use a third-party application designed for this purpose, such as My Device ID by AppsFlyer (free on the App Store).

  • ADHERENCE TO THE IAB EUROPE TRANSPARENCY AND CONSENT FRAMEWORK (TCF)

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

In accordance with the principles of the TCF, we use our technologies to automatically collect information on the devices of mobile users, subject to the prior consent of end users in the European Union. This consent is collected by the partner publishers with whom we collaborate and is transmitted to us in the form of a “consent string”, in accordance with TCF standards.

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

  • SPECIFIC PROVISIONS APPLYING TO RESIDENTS OF THE STATE OF CALIFORNIA (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 request additional details about our information practices, (ii) request the deletion of your personal data, (iii) opt out of the “sale” of your personal data (within the meaning of the CCPA), and (iv) not be discriminated against for having exercised 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 such 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 with whom we share personal data. 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 deletion of their personal data.
  • Non-discrimination of consumers for exercising their privacy rights: At ASK LOCALA, we ensure that no consumer (from California or otherwise) will be discriminated against for exercising privacy rights conferred by the CCPA or any other local regulations.
  • Right to opt out of “Sales” of personal data: ASK LOCALA is a third-party company to which personal data is not sold and, more importantly, which does not sell your personal data. In certain circumstances, we will act as a service provider for publishers in the management of processed data. In this case, we will limit the purposes for which the personal data will be processed. It is up to the publishers to tell us if they consider us their service provider.

  • CHANGES TO THIS POLICY 

ASK LOCALA may modify this Policy.

We will ensure that you are informed of these changes. 

In any case, we invite you to regularly consult our Policy. 

  • CONTACT US

ASK LOCALA has a Data Protection Officer (“DPO”). 

For any questions regarding this privacy policy, you can contact us either: 

  • by email: privacy@asklocala.com
  • By mail to the following postal address: LOCALA, Attn: DPO, 55 rue d’Amsterdam 75008, Paris, FRANCE.

Our DPO will take care of your request.

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