Privacy Policy

1. Definition and nature of personal data

When using Mobsuccess’s solution (hereinafter referred to as: the “Solution”), or your exposure to our technology suite for the purchase of advertising spaces and the diffusion of advertising campaigns, we can ask you to provide us with some of your personal data, in order to enable you to use our services.

The term “personal data” used in this privacy policy refers to every kind of data which can permit to identify a person, such as your name, first name, email address, pseudonym, age, gender, IP address, logs, location data, identifiers for advertising (IFA) (e.g. IDFA on iOS, GAID on Android), or any other information you may choose to provide us.

2. Purpose of the Privacy Policy

The purpose of this privacy policy is to inform you of the means that we use to collect and process your personal data, with the strictest respect for your rights.

In this regard, we inform you that we collect and process your personal data in compliance with the French law N° 78-17 dated 6th January 1978 on Information Technology, Data Files and Civil Liberties (hereinafter referred to as the “French Data Protection Act”), as well as the regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 as from its entry into force, namely 25th May, 2018 (hereinafter referred to as the “GDPR”).

3. Identity of data controller

The entity responsible for collecting and processing your personal data is the company Mobsuccess, registered with the Registry of Trade and Companies of Paris in France under the number 809 891 583, whose head office is located at 25 rue du 4 Septembre – 75002 Paris – France (hereinafter referred to as "us" or "we").

When we transfer your data to advertisers who have ordered the diffusion of advertising campaigns (see article "Recipients of collected data"), we may be placed with them in a co-contracting situation, that is to say that Mobsuccess and the advertiser concerned are then jointly responsible for the processing of your personal data. Mobsuccess remains however your point of contact for any request relating to your data as well as for any request to exercise your rights (see below).

4. Data protection officer

We have appointed a data protection officer, who can be contacted at the following address:

WE ARE BOLD

Le Garage Central, 19 rue des Petites Écuries, 75010 PARIS, France

dpo@mobsuccess.com

Tél. : (+33) 1 53 42 63 00

5. Collecting personal data

The legal basis of our processing of your personal data is the following:

(i) Your consent

  • when we collect your personal data for the needs of the implementation of our technology suite for the purchase of advertising spaces and the diffusion of advertising campaigns;

  • when we collect your personal data so as to diffuse you a personalized advertising content;

  • regarding the use of social network Cookies, advertising Cookies and Google Analytics Cookies, as set forth in our Cookie Policy in the appendix;


(ii) The legitimate interest of our company

  • when we collect your personal data so as to allow you to access to our Platform, whether you are a prospect or a client;

  • when we collect your personal data so as to set up our advertising campaigns and to struggle against fraud for incentive advertising campaigns (“incentive advertising” means advertising which invites the user to take action to get a reward. She/he does the action, She/he receives the promised reward);

  • when we collect your personal data during the diffusion of non-personalized advertising content, to technically distribute the advertising content, ensure the reliability of the traffic delivered on behalf of our advertising customers, measure its performance and debug our Solution.

Your personal data are processed to meet one or several of the following purposes:

Regarding the technology suite for the purchase of advertising spaces and the diffusion of advertising campaigns:


(i) To show you “Standard” (non-personalized) advertising contents, based on the content you are viewing, the app you are using, your approximate location, or your device type. To this end, we can:

  • Use real-time information about the context in which the advertising content will be shown, to show the advertising content, including information about the content and the device, such as: device type and capabilities, user agent, URL, IP address;

  • Control the frequency of advertising contents shown to a user;

  • Sequence the order in which ads are shown to a user;

  • Prevent an advertising content from serving in an unsuitable editorial (brand-unsafe) context.


(ii) To create or to update personalized advertising profiles for the purpose of distributing personalized advertising contents. To this end, we may collect information about you, including a user’s activity, interests, visits to sites or location. We can also use data segments purchased from partners or create segments from them.


(iii) To implement our real-time bidding system, which permits to diffuse advertising campaigns through the acquisition of advertising spaces on mobile applications or mobile websites where the advertising campaigns are diffused.

To that extent, we process “Bid requests” originating from real-time bidding system containing personal data.


(iv) To show you personalized adverting contents according to advertising campaigns entrusted to us. For instance, some campaigns are deemed to be diffused on a restricted geographic area. In such a case, we diffuse advertising contents only to the persons who consented to the collection of their location data and who are located in the given geographic area.

(v) To measure and optimize the efficiency of the said advertising campaigns, in particular through the recovery of interest actions made in relation to the campaign. The actions can be clicks on the campaign, time passed on the advertising content, number of pages visited, visits on points of sale (whose data is provided to us by partners who use either beacons in the points of sale or geolocation data from other applications), the purchases, the installation of an application, etc.


(vi) To diffuse advertising contents the most likely to interest you, through the retargeting, i.e. through the diffusion of the advertising contents according to the actions you made. Profiling is implemented through the collection of visited areas, interest actions on the trademark or on the product.

(vii) To be sure about the reliability of the traffic delivered to our advertiser clients.


(viii) To use market research to generate audience data. Market research can be used to learn about audiences who visit sites / use apps and see advertising contents. To this end, we can:

  • Provide aggregate reporting to advertisers or their representatives about the audiences reached by their advertising contents, through panel-based and similarly derived insights;

  • Provide aggregate reporting to publishers about the audiences that were served or interacted with content and/or advertising contents on their property by applying panel-based and similarly derived insights;

  • Combine this information with other information previously collected, including from across websites and apps;

(ix) Ensure security, prevent fraud and debug. Your data can be used to monitor for and prevent fraudulent activity, and ensure systems and processes work properly and securely, in particular:

  • Ensure the reliability of the traffic delivered on behalf of our advertising clients;

  • Fight against fraud and ensure the rewards are correctly attributed to users who have taken the appropriate for incentive advertising campaigns;

  • Ensure data are securely transmitted;

  • Detect and prevent malicious, fraudulent, inappropriate or illegal activities;

  • Ensure correct and efficient operation of systems and processes, including to monitor and enhance the performance of systems and processes engaged;

(x) To display advertising contents technically.

To provide information and respond to technical calls, we can:

  • Use a user’s IP address to deliver an advertising content over the internet;

  • Respond to a user’s interaction with an advertising content by sending the user to a landing page;

  • Use information about the device type and capabilities for delivering advertising contents or content, for example, to deliver the right size advertising creative or video file in a format supported by the device;


We may associate data obtained offline with data collected online in support of one or more of the above purposes.

Regarding your access to our Solution:

(i) To manage your access to the services provided through the Solution and their use;


(ii) To carry out operations necessary for the management of customers with regard to the contracts, orders, deliveries, invoices, fidelity programs, follow-up of the customer relations;

(iii) To constitute a file of registered members, users, customers and prospects;


(iv) To send newsletters, entreaties and promotional advertisements. In case you do not wish so, you have the possibility to opt-out of receiving such communications when your data are collected;

(v) To provide commercial and service use statistics;


(vi) To manage unpaid invoices and possible disputes about the use of our products and services;


(vii) To customize our answers to your information requests;


(viii) To respect our legal and regulatory requirements.


We also inform you that we may process indirectly your data, either from organizers of events in which you participate, who give you access to our services, or from other users of our services.

6. Recipients of collected data

(i) Regarding the recovery of the visits on points of sale:

We can transfer your identifier for advertiser (IFA) under a hashed form to our subcontractors in charge of the recovery of data related to your visits on points of sale. We can also transfer to them your time-stamped location data (latitude and longitude) associated with your advertising identifier (IFA) collected in the « Bid Request » before the advertisement impression.

(ii) Regarding the technology suite for the purchase of advertising spaces and the diffusion of advertising campaigns:

We can transfer to our subcontractors in charge of the enrichment of “Bid requests” through the use of audiences or to the operators of sites or social networks on which we diffuse advertisements the following data:

  • Your identifier for advertiser (IFA)

  • Your time-stamped location data (latitude and longitude)

  • Website name or mobile application name


We can transfer to advertisers who ordered the diffusion of advertising campaigns or to their subcontractors the following data:

  • Your identifier for advertiser (IFA)

  • Your identifier as a user on the website or on the application you use

  • Your IP address

  • Website name or mobile application name you use

  • The point of sales related to the advertising content

(iii) Concerning the access to our Solution as a user or prospect:

Access to your personal data will be provided to our personnel, the services in charge of control (including external auditor) and our subcontractors.

We may also give access to your personal data to government agencies, for the sole purposes of meeting legal requirements, or to representatives of the law, ministerial officers and organizations responsible for the collection of debts.

7. Personal data storage period

(i) Considering the purchase of advertising spaces and the diffusion of advertising campaigns:

Your personal data are stored for a period strictly necessary to every purpose listed in the article “Collecting personal data”.

These data are collected under the following conditions:

  • The following types of data are deleted directly after their use (strictly limited to the selection of the advertising contents): age, gender (but can be discovered by crossing display data and clicks on advertising campaigns dedicated to a given age range or a specific gender).

  • 3 days for time-stamped location data stemming from requests from “real-time bidding” system

  • 90 days days for logs and connexion data

  • 90 days for displays, implying IP address, identifier as a user, identifiers for advisers (IFA), the website or the application visited, the related point of sales

  • Up to 2 years for the clicks: IP address, identifier as a user, identifiers for adviser (IFA) the website or the application visited, the related points of sales

The storage period for the clicks can last up to two years so as the advertising contents cannot be displayed to you several times.

(ii) Data concerning current and potential customer management:

Your personal data shall be stored no longer than the time strictly necessary for the management of our commercial relations with you. However, any data providing the proof of a right or a contract and that must be stored in compliance with a legal obligation shall be so for the period stated by the legislation currently in force.

With regard to possible promotion operations towards customers, their data may be stored for a period of three years from the end of the commercial relations with them.

The data used to establish proof of a right or a contract, which must be kept for compliance with a legal obligation, will be kept for the period provided for by the law in force.

Personal data relating to potential customers may be stored for a period of three years from their collection or the last contact from the potential customer.

Beyond that three-year period, we may contact you again to find out if you still wish to receive commercial solicitations.

8. Safety

We inform you that we take all necessary precautions, as well as all appropriate organizational and technical measures, to maintain the security, the integrity and the confidentiality of your personal data, including to prevent that they be distorted or damaged and that any unauthorized third-party access to them.

In this respect, we inform you that we respect the security measures implemented by our data hosting providers, which may be viewed in article “Hosting”.


9. Hosting

We inform you that your personal data are stored, for the term set forth above, on the servers of the following companies:

  • OVH, 2 rue Kellermann - 59100 Roubaix - France

  • Amazon Web Services, P.O. Box 81226, Seattle, WA, United States 98108-1226

In both cases, we have selected servers located in the European Union in France and in Germany.

10. Transfer outside the European Union

Within the framework of our activity, your data may be subject to transfers to subcontractors or partners located outside the European Union (see article “Recipients of the data collected”). The transfer of your data in this context is secure using the following tools:

  • Either these data are transferred to a country which has been deemed to offer an adequate level of protection by the European Commission;

  • Or we have concluded with them a specific contract governing the transfer of your data outside the European Union, on the basis of standard contractual clauses between a data controller and a processor approved by the European Commission.


11. Cookies

For more information on Cookies, we refer you to our Cookie Policy in the appendix.

12. Advertising identifiers

The personal data collected by Mobsuccess is linked to the advertising identifier.

Each mobile phone has its own advertising identifier, which allows advertisers to deliver targeted advertising contents.

Android and Apple platforms enable mobile users to control privacy by blocking targeting advertisements and by resetting their advertising IDs.

This disables the link between advertising history and future navigation.

You can deactivate and reset at any time your advertising identifier, if you no longer wish to receive targeted advertisements:

On iOS: go to "Settings", then to "Confidentiality", then to "Advertising" then to "Reset the advertising identifier";

On Android: go to "Google Settings" (or "Settings" then "Google"), then in "Ads".

You will likely receive the same amount of advertisements, but they will be less relevant.

General instructions on how iOS users can enable Limit Ad Tracking : https://support.apple.com/en-us/HT205223

General instructions on how Android users can Opt Out of Interest-Based Ads : https://support.google.com/ads/answer/2662922?hl=en


13. Access, rectify, delete of your personal data

In compliance with the French Data Protection Act and the GDPR, you have the right to access, rectify and delete any information concerning you. You can exercise this right and have the information concerning you by contacting us at the:

  • Email Address: dpo@mobsuccess.com

  • Postal Address: Mobsuccess SAS, 25 rue du 4 Septembre, 75002 Paris, France

Likewise, you can also withdraw your consent for the processing of personal data which is based on consent, by contacting the contact details above.

Persons the data of which are processed on the basis of our legitimate interest, as specified in article “Collecting personal data”, are reminded that they have the possibility to object to the processing of their personal data at any time. We may however carry on with this processing if there are legitimate reasons for it that should prevail over your rights and freedoms or if it is required in order to establish, exercise or defend our rights before courts.

It may take up to a month to take into account the exercise of this right.

14. Rights to define instructions related to the processing of data after your death

You have the right to define instructions with regard to the storage, the erasure and the communication of your personal data after your death.

These instructions may be general directions, which are focused on all personal data concerning you. In such case, they must be registered with a digital trusted third party who is certified by the French data protection authority (CNIL).

These instructions may also be specific to the data processed by our company. You are then required to provide these instructions to us at the:

  • Email Address: dpo@mobsuccess.com

  • Postal Address: Mobsuccess SAS, 25 rue du 4 Septembre, 75002 Paris, France


It may take up to a month to take into account the exercise of this right.
By providing to us these instructions, you hereby expressly consent that they be stored, transmitted and carried out on the terms and conditions set forth herein.


You have the right to appoint in your instructions a person in charge of their execution. After your death, this person shall be entitled to take knowledge of these instructions and to request to us their implementation. Failing to such appointment, your heirs shall be entitled to take knowledge of these instructions and to request to us their implementation.

You may modify or revoke your instructions at any time, by writing to us at the above mentioned contact addresses.

15. Portability of personal data

When accessing to our platform as a client or a prospect, you have a right to portability of the personal data you have entrusted to us, understood as the data you have actively and deliberately declared when accessing to and using our services. You are reminded that portability right does not apply on data that were processed on another basis than consent or the execution of a contract between us.

This right may be exercised free of charge, at any time, including when closing your account on the website, so that you may recover and store your personal data.

It may take up to a month to take into account the exercise of this right.


In this context, we shall provide your personal data, by any appropriate means, in an open standard, currently used and machine-readable format, in compliance with the state of art.

16. Submission of a complaint before a supervisory authority

You are informed that you have a right to submit a complaint before a supervisory authority which is competent in the member State in which your ordinary residence, your place of work or the place in which the infringement of your rights was committed (in France, the French Data Protection Authority – CNIL), if you consider that the personal data processing under this Privacy policy is a violation of the applicable regulations.

This complaint submission may be exercised without prejudice of other legal action before any administrative or judicial court. In fact, you have also a right to effective administrative and judicial redress if you consider that the personal data processing under this Privacy policy is a violation of the applicable regulations.

17. Restriction of processing

You have the right to obtain restriction of your personal data’s processing where one of the following applies:

  • Within the period of verification that we carry out, if you contest the accuracy of your personal data;

  • When the processing of these data is unlawful et you request the restriction of this processing, instead of erasing your data;

  • When we no longer need your personal data, but you require their maintenance for the exercise of legal claims;

  • Within the period of verification of the legitimate interests, if you have objected to the processing of your personal data.

It may take up to a month to take into account the exercise of this right.


18. Modifications

We reserve the right, at our sole discretion, to modify this Privacy policy, in whole or in part. Any changes will be effective from the time of publication of the new Privacy policy. Your use of the Platform after the changes have been implemented implicitly expresses your acknowledgment and acceptance of the new Privacy policy. Otherwise, and if the new Privacy policy does not suit you, you must no longer use the services.


19. Coming into force

This Privacy policy came into force on November 22, 2021

Appendix – Cookie Policy


1.What is a Cookie ?


During your browsing on internet (desktop or mobile), cookies, pixels and other tracers (hereinafter collectively referred to as “Cookies”) are placed on your browser or your terminal.


Cookies are often encrypted small lines of text that are stored in your web browser. They are created when a user’s browser is loading one website: this website sends information to the browser which creates a text file. Each time the user is visiting this website, the browser retrieves this file and sends it to the website’s server. Thus, each time you visit the site or application, the browser is recognized.


The deposit of these Cookies is likely to allow us to access your navigation data and / or personal data concerning you.


2.Types of Cookies


Technical and functional Cookies


Technical and functional Cookies (Cookies that are strictly necessary) are Cookies needed for the proper performance of our websites, in order to facilitate your browsing and to carry out some of the functions.

For example, a technical Cookie can be used to check the quality of traffic and to ensure that it is not generated by a robot.

We use the following technical and functional Cookies:


Name Function Storage period

CRAFT_CSRF_TOKEN functional 18 minutes (session duration)

PHPSESSID functional 18 minutes (session duration)

tarteaucitron technical (keep your choices regarding third-party cookies) 1 year

email technical (remember your connection to our platform) 1 year

password technical (remember your connection to our platform) 1 year

log technical (check the traffic quality, detect fraud) 1 year


Other Cookies


  • Advertising Cookies


Advertising Cookies can be created not only by the website users are visiting, but also by other websites or applications which provide advertisements, announcements, widgets or any other element on the displayed page.

These Cookies can in particular be used to personalize and measure the performance of advertising or to carry out advertising targeting.


  • Social network Cookies


Social network Cookies may be created by social networks for purposes of enabling web designers to share their website content on said networks. These Cookies may be used by social platforms for purposes of tracking net surfers’ visit on the relevant website, whether they use or not these Cookies.

These Cookies allow users, for example, to share content from the websites concerned, their opinion or their use of these sites by clicking on links such as “like” and “share”. These Cookies can also be used to track user navigation.

Furthermore, we invite you to check the privacy policies of the social networks that created these Cookies, in order to be acquainted of the purposes for which they use the browsing information they collect through these Cookies, as well as of the procedures for exercising your rights with these networks.


  • Analytical Cookies


Analytical Cookies allow us to measure the number of visits, the number of page views and user activity. If necessary, they can collect your IP address to determine the city from which you are connecting. Analytical Cookies allow us to generate traffic and navigation statistics in order to improve our performance. These Cookies also identify navigation problems and ultimately resolve them.


We can use advertising, social network or analytical Cookies. You will be informed of this on your first visit to the web page using these Cookies. You will then be invited to accept or refuse them in accordance with the procedures described below.



3.Your Cookie preferences


  • Cookies that can be placed without consent


Some Cookies do not require your consent, such as technical and functional Cookies which are strictly necessary for the operation of our Solution.


  • Accepting or refusing Cookies subject to your express consent


All other Cookies require your consent. These are advertising, social network or analytical Cookies. You can freely choose to accept or refuse the use of these Cookies.


You can accept these Cookies, refuse them and, depending on the sites and applications, modify your preferences at any time while browsing by clicking on the link provided for this purpose. 

  • Configuration of your browser


It is also possible to configure your browser to accept or refuse certain Cookies.

Each browser offers different configuration methods, some examples:


  • Internet Explorer: go to the "Settings" menu, then "Internet Option". Click on "Confidentiality" then on "Advanced confidentiality settings";


  • Chrome: go to the "Settings" menu then click on "Advanced Settings", then "Confidentiality and Security". Finally click on "Sites settings" and "Cookies and site data";


  • Safari: go to the "Settings" application then go to Safari. Click the "Privacy and Security" tab. You can now choose to block all Cookies;


  • iOS: go to the "Settings" menu, then "Safari", click on "Cookies". You can now choose to block all Cookies;
  • Android: go to "Chrome", click on the " ...  " tab at the top right of the screen, then "site setting" and then "Cookies". You can now choose to accept or block Cookies.


At Mobsuccess, the protection of your personal data is a priority.

When browsing our websites

or when exposed to our technology suite for the purchase of advertising space and the dissemination of advertising campaigns, we may collect your personal data.

The purpose of this policy is to inform you about how we process this data in accordance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the "GDPR") and French Data Protection Law No. 78-17 of 6 January 1978 (together the "Applicable Regulations").

We use the legal basis of legitimate interest for some of our processing. You can find the Legitimate interests assessment here.

1. Who is the data controller?

When you are exposed to our technology suite for the purchase of advertising space and the dissemination of advertising campaigns,

  • Mobsuccess, a French simplified joint-stock company (SAS), registered with the Paris Trade and Companies Register under number 809 891 583, having its registered office at 25 rue du 4 Septembre, 75002 Paris ("Mobsuccess" or "We") and
  • Vectaury, a single-member simplified joint-stock company, registered with the Paris Trade and Companies Register under number 799 256 730 having its registered office at 42, rue de Maubeuge, 75009 Paris ("Vectaury") act as joint controllers alongside
  • our client, the company that wishes its advertising to be disseminated (the "Advertiser").

In practice, this means that we determine together the terms of the processing of your personal data in the context of these advertising campaigns. However, Mobsuccess remains your point of contact for any request relating to your data as well as for any request to exercise your rights (see below).

2. Data Protection Officer

We have appointed a Data Protection Officer (DPO), whose contact details are as follows:

Ms Viktorija Jankovskaja

Mobsuccess, 25 rue du 4 Septembre – 75002 Paris, France

dpo@mobsuccess.com

3. Collection of personal data

Personal data is data that makes it possible to identify an individual directly or by cross-checking with other data.

According to our various services, you will find below, on what legal basis, for what purposes and for how long we retain your personal data.

· Advertising on applications

As part of this processing, Internet users are exposed to advertisements when browsing on mobile applications. Advertisements may or may not be personalised, depending on the consent given via the mobile application. Advertisements may be incentivised, i.e. the Internet user exposed to the advertisement may receive a reward for watching the message in its entirety, answering a question or clicking on the advertising message.

In order to deliver these advertisements, we may either use mobile application broadcasters directly, or go through intermediaries that are themselves linked to broadcasters. These broadcasters and intermediaries then act as data processors of Mobsuccess when they collect your data.

As part of this data processing, the recipients of the data are: the Advertiser, the broadcasters /intermediaries and, where applicable, the Advertiser's Mobile Measurement Partner ("MMP").

Purposes

Legal bases

Dissemination of advertising (personalised or not)

Your consent

Measuring the performance of the advertising

Checking the frequency of dissemination of advertising to the same user: the goal is not to expose the user to the same advertisement

Defining the order in which the advertisements are displayed to a user

Retargeted advertising (we record the fact that an Internet user has been interested in an advertisement in order to offer them similar advertisements)

Crediting the Internet user according to the action taken (in the case of incentivised advertising)

Our legitimate interest

Remunerating broadcasters or broadcasting intermediaries (the media on which the advertisement is seen by the Internet user)

Prevent and detect fraud: we pay attention not to credit an Internet user who has not respected the rules of incentivised advertising


Data processed

Retention period

IP address

30 days from receipt for Internet users who have not converted (those who have not completed the action requested to benefit from the offer)

2 years from receipt for Internet users who have converted (completion of the requested action)

MAID (Mobile Advertising ID)

Browser features

Actions relating to the advertising offer

2 years from data collection

Age

Deletion as soon as the advertisement has been selected

Sex/Gender (Male or Female)

Geolocation


· Advertising via a Real Time Bidding (RTB) system

As part of this processing, we use the programmatic advertising system known as "RTB" to deliver the advertisements of our Advertiser.

In this context, when an Internet user browses the internet and advertising space is available, we receive a call for tenders from the publisher who owns this available space ("Bid Request"). The Bid Request is accompanied by information about the Internet user (in particular if they have given their consent to be exposed to personalised advertising, see Article "How do we obtain the consent of data subjects?").  Based on this information, we choose whether to bid or not. If the bid is won, the advertisement of our Advertiser is displayed.

As part of this processing, the recipients of the data are: the Advertiser, the broadcasters (data processors in charge of data collection), the performance measurement providers (ADSQUARE, KAIROS) and the MMP.

Purposes

Legal bases

Determining if the Internet user matches an advertiser's target and bidding

Your consent

Measuring the performance of the advertising

Creating a geolocated profile of the Internet user

Checking the frequency of the delivering of advertising to the same user: the goal is not to expose the user to the same advertisement

Defining the order in which the advertisements are displayed to a user

Retargeted advertising (we record the fact that an Internet user has been interested in an advertisement in order to offer them similar advertisements)

Prevent and detect fraud and debugging

Our legitimate interest


Data processed

Retention period

IP address

4 days from the Bid Request

If an advertisement is displayed: 60 days from collection in active database and 90 days in archives

Browser features (in particular location data, internet service provider data)

MAID

4 days from the Bid Request

If an advertisement is displayed: 60 days from collection in active database and 90 days in archives

If the advertiser indicates that he wants to do retargeted advertising : the data may be retained for up to 6 months and will in any case be retained for 90 days in archives

Actions related to the advertisement (for example: clicking on it)

By default: 30 days from the action

If the advertiser indicates that he wants to do retargeted advertising : the data may be retained for up to 6 months and will in any case be retained for 90 days in archives

Geolocation (precise geolocation under 500m)

4 days from the Bid Request

60 days from collection after the display of the advertisement and 90 days in archives

Consent string (this data tells us if you have given your consent, see Article "How do we obtain consent from data subjects?")

4 days from the Bid Request

60 days from collection after the display of the advertisement and 90 days in archives


· Profiling & Segmentation

This processing consists of the creation of user profiles in order to best personalise the advertising according to the information collected on the user. Profiling is carried out using data from Bid Requests as well as data that we purchase from partners (Singlespot and Madvertise).

We also create audience segments, i.e. groups of people that have similar characteristics. Data about you may be used to determine which segment you belong to and to enable us to deliver tailored advertising to each segment.

We can also use a segmentation provider (Adsquare).

Purposes

Legal bases

Profiling

Your consent

Checking whether the Internet user corresponds to a set audience segment: Mobsuccess identifies whether the Internet user corresponds to a previously determined audience segment, in order, where appropriate, to deliver to them an advertisement tailored to their profile.

Optimising campaigns


Data processed

Retention period

MAID

1 year from collection

Information on the audience segment

Mobile application / website visited

Timestamp

Geolocation

Features of the phone / browser


· Dissemination of campaigns via advertising agencies  

As part of this processing, Mobsuccess uses third-party advertising agencies : Facebook, Google (which includes advertisements on Youtube and Waze) and TikTok to deliver advertising campaigns.

The recipients of the data are: the Advertiser, the advertising agencies (Facebook, Google, TikTok), as well as the performance measurement providers (integrated into the advertising agencies).

Purposes

Legal bases

Delivering personalised advertising

Your consent

Measuring the performance of the advertising

Retargeted advertising (we record the fact that an Internet user has been interested in an advertisement in order to offer them similar advertisements)

As part of this processing, we do not retain any personal data. The processing is carried out directly on the media of the advertising agencies.

· Performance measurement  

As part of this processing, we use service providers (Kairos and Adsquare) as well as advertising agencies (Facebook, Google, TikTok), in order to measure the effectiveness of advertisements intended to encourage Internet users to go to the store (drive-to-store).  The service providers will therefore make it possible to identify Internet users exposed to the advertising and who have visited the store or the identified points of sale and to derive performance statistics from this.

The purpose of this processing is therefore to measure the performance of advertising campaigns and the legal basis is the consent of the users concerned.

The recipients of the data are the Advertisers, the advertising agencies (Facebook, Google, TikTok), as well as our performance measurement partners (Kairos and Adsquare).

Data processed

Retention period

MAID exposed to the advertising campaign carried out by Mobsuccess, identified within the defined scope

Processing related to ADSQUARE : The data are stored by Mobsuccess for 60 days from their collection in active database.

The data are then retained for a maximum of 90 days in archives.

Processing related to KAIROS : the data are retained for the time necessary for the preparation of the statistical report sent to Mobsuccess.

MAID exposed to the advertising campaign carried out by Mobsuccess

Processing related to ADSQUARE : The data are stored by Mobsuccess for 60 days from their collection in active database. The data are then retained for a maximum of 90 days in archives.

Processing relating to KAIROS : the data are retained for the time required to recognize the MAIDs identified within the defined scope and having been exposed to the advertising campaign.

Time required for downloading data on advertising agencies (Facebook or Google depending on the case).

MAIDs identified in the defined scope

MAIDs identified in the defined scope

Processing related to KAIROS : the data are retained for the time required to recognize the MAIDs identified in the defined perimeter and having been exposed to the advertising campaign.


· Market intelligence

As part of this processing, we analyse our clients' market using several criteria. In particular, we analyse the competition, draw up catchment area statistics, and measure location-based performance. Our goal here is to help our clients get a better perception of the market in which they operate. To do this, we purchase data from our partner Singlespot.

Purposes

Legal bases

Offering market analyses to clients enabling them to have a better understanding of local markets and to adapt their commercial and/or advertising strategy

Your consent

Optimising campaigns


Data processed

Retention period

Geolocation

1 year from collection

Home and workplace GPS coordinates

Data relating to consent

Data relating to visits to points of interest (location of the visit, date and time of the visit, duration, accuracy, data relating to the establishment visited, driver's ID)

MAID

Features of the phone / browser

Profile data

We do not send any personal data to our clients, only aggregated data in the form of statistics.

· Managing our Websites

This processing corresponds to the personal data collected on the Websites of Mobsuccess and its commercial brands Widely and Farly on which we present our services and our business.

Purpose

Legal bases

Drawing up statistics (browsing, the audience of the Websites ) and improving the Site's features through the deposit of audience measurement cookies

Your consent

Measure the performance of our advertising campaigns

Your consent

Drawing up a lead file

Our legitimate interest

Sending newsletters, canvassing and promotional messages by email

Our legitimate interest in retaining and informing our customers and prospects of our latest news

Responding to your requests for information

Our legitimate interest in responding to your requests

Managing requests to exercise rights

Our legitimate interest in responding to and following up on your requests


Data processed

Retention period

Browsing data (IP address, pages viewed, date and time of connection, browser used, operating system, user ID, MAID)

Data from cookies and trackers on our websites : 2 years.

Data concerning prospects : 3 years from the last contact with them (for example, a click in a newsletter).

Identification data (surname, first name, email and postal address, telephone number)

Any information you wish to send us as part of your contact request.

4. How do we obtain the consent of data subjects ?

Mobsuccess is registered with the IAB Europe as a "Vendor" and participates in TCF v.2.2 (Transparency & Consent Framework) in order to obtain the consent of Internet users on the various media used to deliver advertising campaigns via consent collection banners.

Consent is given in the form of a character string in the format defined by the IAB called "consent string". We only process the personal data of Internet users who have consented to the purposes relevant to the processing carried out.

Mobsuccess thus ensures that it complies with its IAB Europe specifications and policies. The Mobsuccess identification number in this context is 663.

As part of the processing related to the dissemination of advertisements on applications and RTB, Mobsuccess relies on the legal basis of legitimate interest for the following purposes :

  • Crediting the Internet user according to the action taken ;
  • Crediting the broadcaster or the broadcasting intermediary ;
  • Combating fraud and debugging.

The legitimate interests pursued by Mobsuccess are therefore those of (i) being able to carry out its activity and (ii) securing its activity and the services it offers to its clients. These interests are lawful, necessary and do not conflict with the reasonable expectations of the data subjects. Mobsuccess complies with IAB Europe's policies and for more intrusive purposes (such as targeted advertising), we chose consent as the legal basis. Mobsuccess has also taken care to document the legitimate interests pursued.

5. Hosting

Your data are stored on the servers of the following companies :

  • OVH, 2 rue Kellermann - 59100 Roubaix - France
  • Amazon Web Services, P.O. Box 81226, Seattle, WA, Etats-Unis 98108-1226

In both cases, we have selected servers located in the European Union, in France and Germany.

6. Transfer outside the European Union

As part of our activity, your data may be transferred to processors or partners located outside the European Union. The transfer of your data in this context is secured in the following way :

  • either the data are transferred to a country or to a company that has been the subject of an adequacy decision by the European Commission, in accordance with Article 45 of the GDPR: in this case, the recipient of the data ensures a level of protection deemed sufficient and adequate under the provisions of the GDPR;
  • or the data are transferred to a country or company whose level of data protection has not been recognised as adequate under the GDPR: in this case, these transfers are based on appropriate guarantees set out in Article 46 of the GDPR, adapted to each service provider, including but not limited to the conclusion of standard contractual clauses approved by the European Commission, the application of binding corporate rules or under an approved certification mechanism ;
  • or the data are transferred on the basis of one of the appropriate guarantees described in Chapter V of the GDPR.

7. What are your rights guaranteed by the GDPR?

You have the following rights over your personal data :

  • Right to information: this is the very purpose of this privacy policy. You have the right to be informed about how your personal data are processed. This right is provided for in Articles 13 and 14 of the GDPR.
  • Right of access: you have the right to access all your personal data at any time, pursuant to Article 15 of the GDPR.
  • Right of rectification: you have the right to rectify your inaccurate, incomplete or obsolete personal data at any time in accordance with Article 16 of the GDPR.
  • Right to restriction: you have the right to obtain the restriction of the processing of your personal data in certain cases defined in Article 18 of the GDPR.
  • Right to erasure: you have the right to demand that your personal data be erased, and to prohibit any future collection on the grounds set out in Article 17 of the GDPR.
  • Right to lodge a complaint with a competent supervisory authority (in France, the CNIL), if you consider that the processing of your personal data constitutes a violation of the applicable laws, in accordance with Article 77 of the GDPR.
  • Right to set guidelines relating to the storage, erasure and communication of your personal data after your death.
  • Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR states that you may withdraw your consent at any time. This withdrawal will not call into question the legality of the processing carried out before the withdrawal.
  • Right to portability: under certain conditions specified in Article 20 of the GDPR, you have the right to receive the personal data you have provided to us in a standard machine-readable format and to require their transfer to the recipient of your choice.
  • Right to object: under Article 21 of the GDPR, you have the right to object to the processing of your personal data. Note, however, that we continue to process them despite this objection, for legitimate reasons or the defence of legal claims.

You can exercise these rights by writing to our DPO at the contact details mentioned in Article 2 of this policy. We may ask you to provide us with additional information or documents to prove your identity. 

8. Cookies

For more information on cookies, we refer you to our Cookie Policy.

9. Advertising ID

The personal data we collect are linked to the advertising identifier (MAID).

Each mobile phone has its own advertising identifier that allows advertisers to deliver targeted advertising.

Android and Apple allow mobile users, in the settings, to control their privacy which makes it impossible to link their advertising history to their future browsing activity. You can deactivate and reset your advertising identifier at any time if you no longer wish to receive targeted advertising:

On iOS: go to "Settings", then to "Privacy and security", then to "Tracking" then disable "Allow app tracking requests". Only applications authorised to follow you will be able to access your advertising identifier;

On Android: Go to "Google Settings" (or "Settings" then "Google"), then "Ads".

You will probably receive the same number of advertisements but they will be less relevant.

Instructions for limiting advertisement tracking on iOS: https://support.apple.com/fr-fr/HT205223

Instructions for disabling targeted advertising on Android: https://support.google.com/ads/answer/2662922?hl=fr

10. Changes

We reserve the right to amend this charter, in whole or in part, at any time. These amendments will enter into force from the publication of the new charter. Your use of the Solution following the entry into force of these amendments will constitute recognition and acceptance of the new charter. You are therefore requested to regularly review the latest version of this policy. Nevertheless, we will keep you informed of any significant changes to this privacy policy.

11. Entry into force

This charter will enter into force on 01st of November 2023.



Appendix – Cookie Policy


1.What is a Cookie ?


During your browsing on internet (desktop or mobile), cookies, pixels and other tracers (hereinafter collectively referred to as “Cookies”) are placed on your browser or your terminal.


Cookies are often encrypted small lines of text that are stored in your web browser. They are created when a user’s browser is loading one website: this website sends information to the browser which creates a text file. Each time the user is visiting this website, the browser retrieves this file and sends it to the website’s server. Thus, each time you visit the site or application, the browser is recognized.


The deposit of these Cookies is likely to allow us to access your navigation data and / or personal data concerning you.


2.Types of Cookies


Technical and functional Cookies


Technical and functional Cookies (Cookies that are strictly necessary) are Cookies needed for the proper performance of our websites, in order to facilitate your browsing and to carry out some of the functions.

For example, a technical Cookie can be used to check the quality of traffic and to ensure that it is not generated by a robot.

We use the following technical and functional Cookies:


Name Function Storage period

CRAFT_CSRF_TOKEN functional 18 minutes (session duration)

PHPSESSID functional 18 minutes (session duration)

tarteaucitron technical (keep your choices regarding third-party cookies) 1 year

email technical (remember your connection to our platform) 1 year

password technical (remember your connection to our platform) 1 year

log technical (check the traffic quality, detect fraud) 1 year


Other Cookies


  • Advertising Cookies


Advertising Cookies can be created not only by the website users are visiting, but also by other websites or applications which provide advertisements, announcements, widgets or any other element on the displayed page.

These Cookies can in particular be used to personalize and measure the performance of advertising or to carry out advertising targeting.


  • Social network Cookies


Social network Cookies may be created by social networks for purposes of enabling web designers to share their website content on said networks. These Cookies may be used by social platforms for purposes of tracking net surfers’ visit on the relevant website, whether they use or not these Cookies.

These Cookies allow users, for example, to share content from the websites concerned, their opinion or their use of these sites by clicking on links such as “like” and “share”. These Cookies can also be used to track user navigation.

Furthermore, we invite you to check the privacy policies of the social networks that created these Cookies, in order to be acquainted of the purposes for which they use the browsing information they collect through these Cookies, as well as of the procedures for exercising your rights with these networks.


  • Analytical Cookies


Analytical Cookies allow us to measure the number of visits, the number of page views and user activity. If necessary, they can collect your IP address to determine the city from which you are connecting. Analytical Cookies allow us to generate traffic and navigation statistics in order to improve our performance. These Cookies also identify navigation problems and ultimately resolve them.


We can use advertising, social network or analytical Cookies. You will be informed of this on your first visit to the web page using these Cookies. You will then be invited to accept or refuse them in accordance with the procedures described below.



3.Your Cookie preferences


  • Cookies that can be placed without consent


Some Cookies do not require your consent, such as technical and functional Cookies which are strictly necessary for the operation of our Solution.


  • Accepting or refusing Cookies subject to your express consent


All other Cookies require your consent. These are advertising, social network or analytical Cookies. You can freely choose to accept or refuse the use of these Cookies.


You can accept these Cookies, refuse them and, depending on the sites and applications, modify your preferences at any time while browsing by clicking on the link provided for this purpose. 

  • Configuration of your browser


It is also possible to configure your browser to accept or refuse certain Cookies.

Each browser offers different configuration methods, some examples:


  • Internet Explorer: go to the "Settings" menu, then "Internet Option". Click on "Confidentiality" then on "Advanced confidentiality settings";


  • Chrome: go to the "Settings" menu then click on "Advanced Settings", then "Confidentiality and Security". Finally click on "Sites settings" and "Cookies and site data";


  • Safari: go to the "Settings" application then go to Safari. Click the "Privacy and Security" tab. You can now choose to block all Cookies;


  • iOS: go to the "Settings" menu, then "Safari", click on "Cookies". You can now choose to block all Cookies;
  • Android: go to "Chrome", click on the three vertical dots " ...  " at the top right of the screen, then "site setting" and then "Cookies". You can now choose to accept or block Cookies.