EFFECTIVE AS OF JULY 1ST 2020
Summary: Introduction 1. Fusio Platform data processing 2. User rights 3. Ask Locala Corporate Website and Social Networks: data processing 4. Ask Locala Corporate Website Cookies Policy 5. General provision 6. Glossary
- The Platform owned by Locala (the “Company”, “we” or “us”);
- The following websites: s4m.io, www.yanco.io, www.fusio.io, www.success4mobile.com, and any subsidiary websites owned by Locala or its affiliates (“Website”);
- The following social networks:
- Herein named all together “Locala Tools”.
- Digital professional such as Media Agencies and Advertisers (“Customer(s)”), Ad networks and other partners (“Partner(s)”)
- End-users, who are visitors, prospects or users of our Website and/or Social Networks, individual users of mobile, tablet applications or individual visitors of a mobile website or app (herein “User(s)” or “You”)
- How Locala processes information collected via its Platform, Website and Social Networks,
- How Locala protects the collected information as well
- Inform You how Locala collects and processes information about You, and the way to exercise Your rights in respect with data protection
Advertising and Media industry standardsLocala and its affiliates are member of the main industry’s associations. Hence, Locala and its affiliates comply with the applicable industry standards, guidelines and best practices.
Moreover, Locala asks its Partners and sub-contractors to comply with those standards and our business ethical requirements.
1. FUSIO PLATFORM: DATA PROCESSING
1.1 Purpose of data processingThe data is processed to allow our Customers to buy and release behavioral advertising and measure its performance through our Platform. Behavioral advertising means information collected across multiple web sites, in app, that you visit in order to predict your preferences and to show you ads that are most likely to be of interest to you On request of our Customers, Locala can also perform cross-device attribution. It is the measurement and reporting of conversions of ads as they take place after multiple engagements across different devices. For example, a User may click on an ad on one device, but will finish the desired action on another device. Processing data also allow us to improve the technical functionality of our Platform, as well as our products and services.
1.2 Type of data processedGeneral. Locala only processes data that are relevant for the performance of its Platform’s services, whether by nature or volume. By delivering an ad to you via the Platform, Locala collects data about your mobile device (such as smartphone, tablet etc) using specific technology, as explained below. The Internet. Locala services are provided thanks to the Internet. Hence, the use of Locala services includes the processing of data found in every communication sent over the Internet, such as: browser type (e.g., Chrome or Internet Explorer); User-agent string (e.g operating system; operating system version); browser language (e.g., English or French); referrer addresses, Internet Protocol (IP) address. A browser is a software application for retrieving, presenting, and traversing information resources on the World Wide Web. Platform customers’ data. When the Customer or Partner register to the Platform we ask for basic registration information, such as name, company, position, address, email address, phone, and other contact information. We may ask for voluntary personal information at other times, including but not limited to when Customer or Partner report a problem with the Platform. This type of information is deemed personal data and is used to contact Customer or Partner or determine its specific identity. When other information is linked to this information, it also becomes personal data. We may also automatically receive and record information in our server logs from Customer or Partner’s browser type (e.g., Chrome or Internet Explorer); User-agent string; browser language (e.g., English or French); device timestamp and time zone; Device screen size; Internet Protocol (IP) address, and other generally-accepted log information. We may also record page views (hit counts) and other general statistical and tracking information. Customer or Partner can access or correct certain personal information, such as applicable passwords, directly in the Account sections of the Platform. If Customer or Partner have provided personal data, such as his/her e-mail address when registering for our Platform, Customer or Partner may modify that information at any time by visiting your Account settings. Notably, since we may use its User name as the account identifier, Customer or Partner may not be able to change its User name. In addition, Customer or Partner can delete its account at any time. In a such case, Locala acts as Controller (having the meaning set forth under article 4 of GDPR) and its legal basis is the conclusion of the contract with its Customer and/or Partner Users data processed through the platform, including geolocation data. When an User views an ad on a site or app which uses our services, we collect information about the ad that he/she has viewed (e.g. advertiser’s name, type of advert, etc) and the web site or the app where the ad was delivered. This information does not enable us to work out any Users identity in real life but does enable us to recognize from which advertisements Users are coming from thanks to the following main data collected: device timestamp and time zone, device type, network provider, Mobile advertising ID, IP address, the geolocation of used device such as Lat/long, user-agent string, operating system, operating system version, and screen size. Depending on domestic regulation, these data may be considered as personal data, for example, like under the GDPR. We may specifically collect the information about the ad Users have viewed or clicked on. We collect some or all of the following information about the ad Users have viewed, clicked on: (i) the content type of the ad (what the ad is about, e.g. games, finance, entertainment, news); (ii) the ad type (e.g. whether the ad is a text, image, rich media or video based ad); (iii) where the ad is being served (e.g. the address of the website on which the ad appears); and (iv) certain information about post-click activity in relation to the ad (e.g. whether you proceed to fill-in form, purchase the product or service advertised). We may also collect information of the specific places (mostly area) that Users have visited during the period of the advertising campaign to measure the performance of the ads. In some cases, we can collect, on behalf of our Customers your name, email address and other direct personal data when you fill out a questionnaire with such information. IIn a such case, Customers, for whom the ad campaign is released by S4M, act as Controller and Locala acts as Processor (having the meaning set forth under article 4 of GDPR). Cross Device Tracking. To measure and report conversions of ads as they take place after multiple engagements across different devices, our third-party service providers, may set and/or access cookies or other data collection technology which collect information (not including your name, address, email address or telephone number) about your visits to this and other websites, mobile websites and/or mobile applications across your various devices, in order to provide content and advertisements about goods and services of interest to you across those various devices. Our Partners are using a probabilistic model by matching anonymous signals to try and identify a User. These signals include:
- Location (IP addresses)
- Conversion Type
- Device IDs
- Landing Page
- Interests and web history
1.3 Role of Locala as a Controller or ProcessorIf you are located in one of the countries of the European Economic Area, Locala may act a “controller” as defined under applicable law when processing your personal data. Locala may also act as a “processor” as defined under applicable law to the extent that it processes your personal data on behalf of and at the instruction of another party, for example one of our Customers. We are a data controller when we receive personal information:
- from our measurement pixels on an advertiser website. This is because we use this data for product improvement. In this instance, we are an independent data controller with the advertiser
- from the bid requests coming from a publisher website. This is because we use this data for fraud detection and product improvement. In this instance, we are an independent data controller with the publisher
1.4 How data is collectedIn order to serve our Customers, Locala collects data from the publishers through the RTB protocol (Bidstream) in order to display the ads. TheBidstream allows processing data that are directly related to the advertising campaign. For example, Locala does not collect geolocation data on a permanent basis. Locala processes data that are adequate, relevant and limited to what is necessary for the purposes of behavioural advertising which is why they are processed. Locala is not an audience provider, instead Locala relies on Bidstream information and, upon Customer’s request, external data provider who are either already working with our Customers or one of our qualified Vendors. Finally, for ads performance measurement and tracking, upon Customer’s request, Locala can use:
- 3rd party data from our qualified Vendors
1.5 How data is shared and processedLocala is a member of IAB Consent and Transparency framework and bases the consent obtention and verification on the IAB consent signal provided via the Bidstream by publishers selling their inventory. This new organization allows us to check our Partners’ position and track the consent chain as well. Data is shared with and processed by authorized person such as:
- Platform Customers, who are Advertisers and their media agency, that use the platform to deliver advertisements for their own purpose (or on behalf of the advertiser);
- Locala qualified Partners, who are companies contributing to improve the service (e.g. audience measurement, viewability measurement, fraud detection);
- Locala authorized employees, who are the people who operate the Platform or process information disclosed from Locala Corporate Website and Social Network
1.6 RetentionData retention is decided by the Customer when it acts as Controller. Locala undertakes not to keep any said data beyond the agreed term. In the case where this information is not provided by the Controller, Locala deletes by default the data processed through the Platform within 13 months.
1.7 Data transferLocala is an international group with its offices in Europe, United States and Asia. To this end, the Platform is supported by a technology that enables Locala to perform its services worldwide. Depending on the service used, the Platform is hosted in Ireland or in United States with relay servers in Singapore. Hence, the information that we collect from You and about You may be transferred to and stored in a country other than Your country of residence. However, Locala ensures to comply with relevant regulation and takes appropriate measures to keep your personal data protected. Especially, Locala ensures to comply with GDPR requirement regarding lawful transfer mechanism. The Platform is hosted by Amazon Web Services, that complies with the principles of the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield. This framework protects the fundamental rights of anyone in the EU whose personal data is transferred to the United States for commercial purposes. More information about EU-US Privacy Shield on the Official European Commission site.
1.8 SecurityLocala takes all reasonable measures to protect the security of Your personal data during transmission. We also take reasonable measures to safeguard personal data and to protect against unauthorized access, alteration, disclosure or destruction of such information through our data collection, storage and security practices. However, no transmission of data over the Internet is guaranteed to be completely secure. You should take further precautions to protect your personal data, such as safeguarding your User name and password or limiting the use of shared computers.
1.9 Limitation of liabilityLocala makes its best efforts to protect User privacy. However, Locala does not control the privacy practices of, and shall not be liable for the Ad Networks, Publishers, Advertisers and Social Networks. For details regarding their own privacy policies, we recommend visiting or contacting them directly.
2. USER RIGHTS
2.1 Your rightsAs per the applicable law, especially GDPR, you can exercise the following rights by contacting Locala Data Protection Officer at this email: firstname.lastname@example.org or as explained under section 5.3.
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to object
2.2 How to reset Mobile Advertising IDMobile advertising IDs are unique identifiers that are associated with individual mobile devices. They usually are user-resettable and are separate from hardware serial numbers. They are not permanently tied to a mobile device, as Users can reset their Mobile advertising ID at any time for added security or opt out of ad tracking. As a result, the Mobile advertising ID can no longer be easily linked to specific devices/users Types of mobile advertising IDs:
- Android ID is named GAID
- Apple ID is named IDFA or IFA is an Apple Device ID released with iOS 6 and is a cross application / publisher identifier.
- IOs: go to “Settings” then “Privacy”, then “Advertising” and then “Reset Advertising ID” (see demo on Apple Support)
- Android : go to “Settings” then “Google” then in “Ads” then “Reset Advertising ID” (see demo on Google Support)
2.3 How to disable cookiesThe “Help” section of the browser indicates how to set and disable cookies. Your browser may be: Internet Explorer, Firefox, Safari or Chrome.
3. Locala CORPORATE WEBSITE, SOCIAL NETWORKS AND CORPORATE TOOLS – DATA PROCESSING
3.2 RetentionPersonal data processed by Locala through contact email address or Press contact form are deleted from Locala database within 13 months after the end of the business relationship and/or the end of the service provided.
3.3 CookiesPlease refer section 4 below.
3.4 Your rightsLocala acts as Controller for personal data that are processed through the Locala Corporate Website. In respect with applicable law, especially GDPR, you can exercise the following rights with S4M, by contacting Locala Data Protection Officer as explained under section 5.3.
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to object
3.5 International UsersThe Locala Corporate Website is hosted in France. If you access the Website from the European Union, Asia, United States or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from French laws, please be advised that through your continued use of the Website You are transferring your personal data to France and You are consenting to that transfer.
A cookie is a small piece of information (i.e., program code) that is stored on a browser for the purpose of identifying that browser during audience activity and between visits or sessions. Cookies are typically set to expire. Some cookies are intended to remain on the browser temporarily (for example, during a session) and some are persistent in that they are intended to be retained for longer periods.
4.1 Cookie banner.In respect with Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector (Directive on privacy and electronic communications), except cookie that are deemed essential to the proper use of the service, Locala does not place any cookie, without your consent. To this end, when you first visit our Corporate Website, a banner informs You about the purpose of such cookie deposit and requests and collects your consent.
4.2 Cookie processing.A cookie is a small text file that a website saves on your computer or mobile device when You visit the Locala Corporate Website. Cookies that are installed by Locala are relating for two specific uses:
- Services cookies: required to ensure the proper functioning of the Website (essential).
- Functional cookies: used to determine Your usage and improve user experience (not essential).
- to adapt the presentation of the Website to the display preferences of the terminal (display resolution, operating system used, etc.) during visits, according to the hardware and software of the terminal concerned;
- to memorize information related to the contact form filled in by the Website’s User;
- if necessary, to allow the Website’s User to access the reserved and personal areas without registering at each visit;
- to establish statistics and volumes of use and use of the various elements composing the Website, to better understand the behavior of Locala Website’s Users;