Privacy Policy


1. Definition and nature of personal data


When using Mobsuccess’s solution (hereinafter referred to as: the “Solution”), 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 under the number 809 891 583, whose head office is located at 38 rue des Mathurins – 75008 Paris (hereinafter referred to as "us" or "we").



4. Data protection officer


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


Gilles Perrin
Mobsuccess SAS
38, rue des Mathurins 75008 Paris
dpo@mobsuccess.com
Tél. : (+33) 972200581 (from Monday to Friday 10am - 5pm)


5. Collecting personal data


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


(i) Your consent regarding

  • Data collected for the needs of the implementation of our technology suite for the purchase of advertising spaces;

  • The use of social network cookies, advertising cookies and Google Analytics cookies, as set forth in article 11;


(ii) The legitimate interest when we collect your personal data so as to allow you to access to our Platform, whether you are a prospect or a client.


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


Regarding the technology suite for the purchase of advertising spaces:


  • To diffuse you advertising contents, whether customized or not, 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.

  • 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, number of pages visited, visits on points of sale, the purchases, the installation of an application, etc.

  • 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.

  • To be sure about the reliability of the traffic delivered to our advertiser clients

  • 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.


Regarding your access to our Solution:



  • To manage your access to the services provided through the Solution and their use;

  • 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;

  • To constitute a file of registered members, users, customers and prospects;

  • 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;

  • To provide commercial and service use statistics;

  • To manage unpaid invoices and possible disputes about the use of our products and services;

  • To customize our answers to your information requests;

  • 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 transfer your identifier for advertiser under a hashed form to our subcontractors in charge of the recovery of data related to your visits on points of sale.



(ii) Regarding the technology suite for the purchase of advertising spaces


We can transfer to our subcontractors in charge of the enrichment of “Bid requests” through the use of the following data:

  • Your identifier for advertiser (IFA)

  • Your 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 of broadcasters

  • Your IP address

  • Website name or mobile application name you use

  • The point of sales related to the advertising contents



(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. Transfer / sale of personal data


Your personal data will not be exchanged with, transferred or rented to any third party.


8. Personal data storage period


(i) Considering the purchase of advertising spaces


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 (which can be discovered by crossing display data and clicks on advertising campaigns dedicated to a given age range or a specific gender.

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

  • 15 days for logs and connexion data

  • 2 months 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.


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.



(iii) Cookies:


The term of storage of the cookies set forth in article 10 is 13 (thirteen) months.




9. 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 provider, the company [to be completed], the measures of which may be viewed in article 10 this document.




10. Hosting


We inform you that your personal data are stored, for the term set forth above, on the servers of the company OVH and Amazon Web Services, located in in the European Union.


Your personal data shall not be transferred outside the European Union within the use of our services.





11. Cookies


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.


There are various types of cookies which do not have the same purposes:


  • Technical cookies are used throughout your browsing, in order to facilitate it and to carry out some of the functions. A technical cookie may be used, for instance, to memorize the answers you provided in a sign-up form or preferences relating to the language or the presentation of an internet site when such options are available.

    We use technical cookies


  • Social network cookies may be created by social platforms for purposes of enabling web designers to share their website content on said platforms. 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.

    We use social network cookies. These cookies are placed only with your consent. You have the possibility to have information on their nature, accept them or refuse them.

    Furthermore, we invite you to check the privacy policies of the social platforms 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 platforms.



  • Advertising cookies can be created not only by the website users are visiting, but also by other websites which provide advertisements, announcements, widgets or any other element on the displayed page. In particular, these cookies enable the use of the retargeting technique which is a marketing model whose purpose is to propose advertisements to the internet user that are adapted specifically for them.

    We also use advertising cookies. These cookies are placed only with your consent. You have the possibility to have information on their nature, accept them or refuse them.



  • We use Google Analytics, an audience analysis statistics tool that generates a cookie that enables us to measure the number of visits to our Platform, the number of page views and visitors' activity on the Platform. Your IP address is also collected to determine the city you are connecting from. This cookie is placed only with your consent. You have the possibility to accept them or to refuse them.


To all intents and purposes, you can refuse the installation of cookies in your browser settings. However, this refusal could prevent you from using the services offered on the Platform.





12. Access to 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: Gilles PERRIN, Mobsuccess SAS, 38 rue des Mathurins, 75008 Paris


Persons the data of which are processed on the basis of our legitimate interest, as specified in article 5, 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.



13. 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: Gilles PERRIN, Mobsuccess SAS, 38 rue des Mathurins, 75008 Paris


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.



14. 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.


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.




15. 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.



16. 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.



17. 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.




18. Coming into force


This Privacy policy came into force on 23th July 2019.