A. 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.

↑ Back to contents

B. Information we process

We process data about you that is associated with the mobile advertising identifier of your device. If you have
given 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 is obtained by the publisher operating the websites and apps you use.

• Consent data: the “consent string” to verify that you authorize us to process your data.
• Indirect identification data: MAID (mobile advertising ID), IP address.
• Browsing data: information about the devices or browsers used (device types, operating systems,
  device language, screen sizes, device time and time zones, etc.) and information about ads viewed or clicked
  (e.g., impressions, clicks).
• Precise geolocation data: latitude/longitude of the device; we may associate this with specific
  zones/locations (e.g., around a client’s store) and infer the presence of a user within those areas at a given
  time.
• Tracking tools: pixels or similar tools, used by us and our customers/partners if you consent.

This data does not directly identify you (we do not use your name, postal address, etc.).

↑ Back to contents

C. How do we use the information?

C.1 Dissemination of targeted or non-targeted advertisements

C.2 Audience creation

C.3 Measurement of in-store visits

C.4 Trend analysis

C.5 Selection of premium advertising inventories

C.6 Compliance with our legal obligations

The retention periods above do not preclude the exercise of the rights in Section E, insofar as they can be
legally exercised.

↑ Back to contents

D. Information sharing

1. Data recipients

ASK LOCALA may give access to your data to the following categories:

• ASK LOCALA staff who process your data as part of their duties;
• The ASK LOCALA group, including subsidiaries and affiliates;
• Partners and service providers, including performance measurement providers;
• SSP platforms involved in RTB processes;
• Clients (advertisers or media agencies) acting as independent controllers under their own privacy policies;
• Authorized third parties under law/regulation, and our advisors;
• In corporate transactions (e.g., merger/acquisition), potential buyers/investors under contract.

2. International transfers

Personal data processed as part of our Services may be transferred outside the EU as some hosting servers are in
the United States. Our host is Amazon Web Services (AWS), certified under the Data Privacy Framework (DPF),
considered by the European Commission to provide an adequate level of protection for EU-US transfers. If we engage
other processors/partners outside the EU, we will do so only after adopting appropriate measures to ensure an
equivalent level of protection and security. For questions, see I. Contact us.

↑ Back to contents

E. Your rights

1. User rights under applicable regulations

You may exercise the following rights by contacting us via the details in I. Contact us:

• Access: obtain free access, a copy of your data, and information on processing.
• Rectification: request correction of your personal data.
• Restriction: request restriction where (i) you contest accuracy (for verification time); (ii)
  processing is unlawful and you oppose erasure; (iii) processing is unnecessary for us but you need the data for
  legal claims; (iv) you object (pending verification of overriding grounds).
• Withdrawal of consent: where processing is based on consent, you may withdraw it at any time.
• Objection: object to processing based on our legitimate interests for reasons relating to your
  particular situation (subject to compelling legitimate grounds or legal claims).
• Portability: for data processed based on contract performance.
• Deletion/erasure: where (i) processing is no longer necessary; (ii) you withdraw consent or
  object; (iii) data were unlawfully processed; (iv) erasure is required by law.

To facilitate handling, please state “Exercise of rights relating to my personal data” in the subject line.
We will respond within one (1) month of receipt. If your request is imprecise or incomplete, we may ask for
additional information. You also have the right to lodge a complaint with the French Data Protection Authority
(CNIL), 3 Place de Fontenoy – TSA 80715 – 75334 Paris Cedex 07.

2. Behavioral advertising & mobile advertising identifier

We use information to help our customers deliver advertising that is of interest to users (targeted advertising).
To learn more or opt out of certain third-party behavioral advertising, visit
digitaladvertisingalliance.org.

Mobile advertising identifiers are unique to devices (e.g., AAID for Android; IDFA/IFA for Apple).

Manage preferences:

• iOS: Settings → Privacy & Security → Apple Advertising → disable “Personalized Advertising”.
  To manage app data access, see Apple’s “Manage sharing and access”.
• Android: Settings → Google → Ads → “Delete ad ID”. To manage app data access, adjust app
  permissions (Google Support).

Following these steps will stop partners from collecting data via your mobile advertising ID and stop our ads from
being displayed on your mobile device. You can also contact us via
this form
or the details in I. Contact us to withdraw consent you previously gave.

To locate your device ID:

• Android: Settings → Google → Ads (see your device’s ad ID).
• iOS: ID is no longer shown natively; use a third-party app (e.g., “My Device ID by AppsFlyer”).

↑ Back to contents

F. Adherence to the IAB Europe Transparency & Consent Framework (TCF)

ASK LOCALA is a member of IAB Europe’s TCF and complies with its specifications and policies. In line with TCF
principles, we automatically collect information about mobile devices, subject to prior end-user consent in the EU.
That consent is collected by partner publishers and transmitted to us as a “consent string”, per TCF standards.
ASK LOCALA is identified under number 119 within the TCF.

↑ Back to contents

G. Specific provisions applying to residents of California (USA)

• Rights under the CCPA: request access and details on practices; request deletion; opt out of
  “sale” of personal data; no discrimination for exercising rights.
• Disclosure duties: categories collected; business/commercial purposes; sources; categories
  disclosed/sold in the past 12 months; categories of third parties (as described in this Policy).
• Deletion: the ability to request deletion of personal data.
• Non-discrimination: we do not discriminate for exercising privacy rights.
• “Sales” of data: ASK LOCALA does not sell your personal data. Where we act as a service
  provider for publishers, purposes are limited accordingly; publishers inform us of that status.

↑ Back to contents

H. Changes to this Policy

We may modify this Policy. We will inform you of material changes; we nevertheless invite you to review it
regularly.

↑ Back to contents

I. Contact us

ASK LOCALA has a Data Protection Officer (DPO).

For questions about this Policy, contact us:

• Email: privacy@asklocala.com

• Post: LOCALA – Attn: DPO, 55 rue d’Amsterdam, 75008 Paris, FRANCE.

↑ Back to contents