UPDATED : 2019 JANUARY 16
Adloox SAS and its subsidiaries (“Adloox,” “we,” “us,” or “our”) is an Advertisement verification and measurement company that builds verification, optimization, and analytics solutions and sells Technology Solution to its Clients.
The protection and security of your data is an important concern for us and we know that you care about how your information and personal data (Personal Data) is collected, used, shared, and retained. We have therefore taken technical and organisational measures to protect your data from loss, destruction, deliberate manipulation and unauthorised access from third parties. In addition to this, we use your data exclusively in compliance with the relevant data protection regulations.
Data protection regulations means EU Directive 95/46/EC and EU Directive 2002/58/EC, as transposed into domestic legislation of each EU member state including the Data Protection Act 2018 and as amended, replaced or superseded from time to time, including by the EU General Data Protection Regulation 2016/679 (“GDPR”) and laws implementing or supplementing the GDPR;
In the following document, we will inform you on which personal data we collect and store, how this data is used and what rights you have regarding this.
I. WEB SITE AND ONLINE SERVICES
A. PERSONAL DATA WE COLLECT; PURPOSE OF COLLECTION AND USE; LEGAL BASIS AND DATA RETENTION
Personal Data we may collect from you through our Website and Online Services.
Contact Personal Data. We collect business contact information from visitors and clients who wish to obtain information or support, or to purchase our Technology Solutions. Contact information is provided via browser forms, online order forms, email, and during events via submission of business cards or physical forms and include first name, last name, business email address, job title, name of the organization, country, business phone number, and organization type.
Legal Basis and Retention Period. We only collect data for this purpose that you consent to communicate to us. We keep your Personal Data as long as your user account is active and during three years after your last login to your account or after your last contact with us.
Billing Personal Data. We collect billing and payment information from our clients, which may include a purchase order number, and account number, or instructions for wire transfers and/or ACH transfers. When payment is made by credit card, we use third-party credit card processors. The billing and payment Personal Data is used to prepare and send invoices, make and receive payments, and manage client accounts.
Legal Basis and Retention Period. We only collect Billing Personal Data that you consent to communicate to us. We keep your Personal Data as long as your user account is active and during ten years after your last transaction with us for tax and accounting purposes.
B. THIRD PARTY SERVICES AND CONTENT
1. Google Analytics
Google uses the information on our behalf to evaluate the way users interact with our website and to compile reports about this usage. User profiles, with pseudonyms, are created using this data. We only use Google Analytics with the IP address anonymisation function (anonymizeIP), which anonymises or hides the IP addresses before they are saved or processed. If you don’t wish to participate in Google Analytics, you can install a browser add-on to deactivate it.
He information generated by cookies and web beacons about the usage of this website (including your IP address) and the delivery of advertising formats are transmitted to a Google server in the USA and stored there. This information can be given by Google to contractors of Google. Google will not link your IP address with any other data stored by Google.
By using our website, you agree to the processing of data Google collected about you in the manner described above and for the above-mentioned purposes.
2. Social Media
Buttons for Facebook, LinkedIn and Twitter are integrated in to our Website. The logo of each company is used for the corresponding button. As soon as you actively click on one of these buttons, a new window opens and you will be forwarded to the page of our corresponding social media profile. This also establishes a direct connection between your browser and the social media’s server, and sends a message that your IP address has visited our website. If you are also a user of the social media provider and are logged in to your account, they are also able to see that your social media profile visited our website. We have no influence on the collection or use of your data carried out by the social media providers. For more information on their individual data protection policies, click here: Facebook, LinkedIn, Twitter.
C. YOUR LEGAL RIGHTS
On request, we can inform you if we have any personal data from you, and which data we have stored. You can also retract the processing and use of your personal data at any time. In accordance with legal requirements, we can correct, block, or delete your personal data.
If you would like to make use of your legal rights or if you have any questions regarding our data protection, send us an email: email@example.com
II. ADLOOX' TECHNOLOGY SOLUTION
A. Data We Collect; Purpose of Collection and Use; Legal Basis and Data Retention
Our accredited Technology Solutions serves both advertisers and media sellers by providing independent, third-party verification measurement. By analyzing information about ad impression delivery and website traffic on behalf of its Clients, Adloox verifies whether the media has met or failed expectations based on characteristics that include the brand safety of a webpage, the viewability of the ad placement, the existence of ad fraud, as well as additional contextual variables. Measurement is available across both browser and app environments for mobile and desktop devices. Adloox collects and surfaces this data to increase trust and transparency for its Clients. The data collected can be used by Clients to proactively prevent advertising on undesirable and/or low-quality inventory, monitor overall quality performance, and make future media planning decisions. We do not combine the collected data with any other data that would enable us to personally identify the user.
The following categories of Personal Data are collected when these technologies are deployed when providing Technology Solutions to our Clients:
• Browser and computer environmental information. This information is necessary to determine the viewability of an advertisement, which includes information such as the ad’s location in the browser viewport, size of the browser viewport, ad size, size of the display, application in focus, the browser tab in focus, and other data.
• Standard HTTP header information. This includes IP address, referring URL, user agent data (data transmitted by your browser about itself when submitting an HTTP request) and other data including browser configuration parameters, including browser type and language and session storage and local storage settings, and characteristics of your device such as the CPU class and time zone setting.
• Information contained within an advertisement. This is known as an “ad tag,” that includes information used to identify the advertiser displaying the ad and the media property that sold the impression.
• Mobile application and mobile device data. Examples include log-level data, Personal Data about users’ interactions with those applications (including IP address and time-stamp Personal Data), and Personal Data about users’ mobile devices (including device type, device make and model, operating system type and version, mobile identifiers such as Apple IDFA and Android Advertising ID and App Identifier).
For the purpose of identifying and preventing online ad impression fraud and invalid traffic and determining if advertisers and publishers are in compliance with their agreements, our Technology Solutions utilize the following additional technologies (in addition to the data described above):
• Device identification technology, which analyzes device parameters collected as described above, including IP address and browser header information, to probabilistically identify a particular device.
• Clickstream data including URLs and other data regarding the websites on which a particular browser has viewed advertising impressions we are analyzing.
• Clickstream data including mobile application identifier and other data regarding the mobile apps on which a particular user has viewed advertising impressions.
Mobile device tracking opt-out. Individual users that opt-out of mobile device tracking limit the Personal Data that is collected about them and/or how it is used. Individual users may opt-out of interest-based and demographic-based advertising using their mobile device settings. Individual users will need to follow the below instructions for Android and iOS applications.
Opt-out process for Android-based mobile devices:
• Open the Google Settings app on individual users’ device
• Select Ads
• Set the “Opt-out of interest-based ads” slider to individual users’ desired position
Optionally, Individual users may reset the advertising identifier associated with their device Opt-out process for iOS-based mobile devices:
• Open Settings
• Select Privacy
• Select Advertising
• Set the “Limit Ad Tracking” slider to Individual users’ desired position
Optionally, Individual users may reset the advertising identifier associated with their device
Please note that opting out through a website will not limit the collection of Personal Data on mobile devices, and opting out on Individual users’ mobile device will not limit the collection of Personal Data through Individual users’ computer’s browser. Opting out limits the collection of data but does not eliminate it completely. Some Personal Data will still be collected about Individual users’ use of websites or mobile applications after Individual users limit tracking on that platform.
Purpose of Collection and Use.
We use the data we collect to deliver our Technology Solutions for any lawful purpose, including:
• Examining impression data of advertising opportunities, using Adloox technology and client profile decisions, to determine if clients’ advertisements should or should not be displayed.
• Detailing contextual information about advertisements displayed in order to ensure its compliance with terms of our client or partner’s contracts, insertion orders that detail client campaigns, and/or profile decisions that clients make in our systems.
• Reporting viewability metrics of advertisements that indicate: qualified « Viewed Impressions » according to industry standards and/or clients’ criteria, time in which advertisements are displayed on consumers’ browsers, and properties of creative elements that are displayed on consumers’ browsers.
• Website and mobile apps visitation characteristics such as visitor quality, fraud identification, invalid traffic detection, and other quality characteristics necessary to determine agreement compliance.
• Our Technology Solutions include the detection and elimination of general invalid and sophisticated invalid traffic, including ad impression fraud, which we define in this policy as the management of ad serving, ad display, or traffic activity such that ad impression measurements are shown inappropriately because the ads cannot be viewed by a user, are not served within operationally viewable parameters or were displayed as a result of fraudulent machine-generated traffic. Our fraud and invalid traffic services are intended to address fraud for advertising measurement purposes.
Additionally, Adloox uses advertising impression information, mobile app information, and website traffic information including IP address and browser header information to:
• Identify traffic sources by their geographic location and determine if the location is correct and located within the advertiser’s campaign parameters or traffic settings
• Determine if traffic is being acquired is fraudulent, or if traffic acquisition practices that are out of compliance with an advertiser’s guidelines or contractual requirements.
• Determine if a middleware is attempting to misrepresent its operating characteristics to prevent the identification of fraud or other invalid traffic.
• Determine if traffic or ad impressions are originating from a server farm unlikely to be responsible for human-generated browsing activity.
Legal Basis and Data Retention
Adloox Technology Solution is based on Article 6. (1) f. GDPR.
We process pseudonymous Personal Data (notably your IP address) along with non-personal technical information when necessary to do so for fraud and invalid traffic prevention purposes or providing services related to advertising viewability and brand safety as discussed in this policy, when these interests are not overridden by your data protection rights.
We anonymise completely the IP information when it arrive into our servers, we don't store it. This process is being made when we retrieve the data with a strong encryption (bcrypt + salt key). We minimize our use of Personal Data by, for.
We retain our clients reporting data for up to 13 months.
III. PERSONAL DATA SHARED WITH THIRD PARTIES
Please allow us a reasonable time to process your request.
Disclosure to Public Authorities.We are required to disclose Personal Data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose Personal Data to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
IV. TRANSFER OF PERSONAL DATA OUTSIDE OF the EUROPEAN UNION.
Our servers are located in Europe. We do not transfer Personal Data outside of the EU.
V. YOUR RIGHTS
You have the right to request from us the access to and rectification or erasure of the Personal Data we hold on you or restriction of processing or to object to processing as well as the right to data portability.
European residents have the right to lodge a complaint at any time about our processing of your Personal Data with their local data protection authority.
VI. YOUR SECURITY
E-mail us at firstname.lastname@example.org
Call us at +1-646-278-4860
Or write to us at: ADLOOX SAS
40 rue du Louvre
75 001 PARIS