Privacy Policy EU

Website's Privacy policyServices Privacy PolicyCookies Policy

Type of data collectedObjectives
  • Device/browser information;
  • Browser version and language ;
  • Operating systems;
  • Referrer URL;
  • Website pages visited; and
  • Internet Protocol (IP) address.
  • Provide a seamless user experience when accessing our Website.
  • Content personalization: The information collected can be used to personalize the content of e-mails or web pages according to the user behavior. This allows us to provide a more targeted and relevant experience.
  • Measuring conversions: Cookies are often used to track conversions, whether it's the purchase of a product, the completion of a form or any other action requested.
  • Improving Azira France's user experience and services regarding the use of its Website.

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Type of data collectedObjectives
  • First and last name
  • Business e-mail address
  • Company name, if applicable
  • Position within the company, if applicable
  • Phone number
  • Country and region
  • Your need to use Azira France products and services
  • Answer your questions when you contact us.
  • Provide you with more information about our products and services when you contact us.
  • Send you marketing e-mails.

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Type of data collectedObjectives
  • Email address
  • Open email
  • Date and time of email opening
  • IP address: Pixels may record the IP address of the computer opening the e- mail. This can be used to identify the approximate geographical location of the user.
  • Email client information (Outlook, Gmail, etc.).
  • Device used (computer, smartphone, tablet).
  • Operating system (Windows, macOS, iOS, Android, etc.).
  • Interaction time: Some pixels can measure the time during which an e-mail is opened.
  • Behavioral information: Depending on the configuration, pixels can track clicks, mouse movements and other actions performed by the user in the e-mail.
  • Device information: pixels can record specific details about the device, such as screen resolution, system language, etc.
  • Geolocation data: Depending on configuration and permissions, some pixels may collect geolocation data.
  • Engagement tracking: Web beacons can be used to track user engagement with emails.

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Services Privacy Policy

Effective: 16 April 2024

We are Azira, SAS (“AZIRA FRANCE”).If you have any questions about this policy, including any requests to exercise your legal rights, please contact us at privacy@azira.com or write to our Data Protection Officer, Prof. Dr. Christoph Bauer, CEO at:

  • ePrivacy GmbH, Große Bleichen 21, 20354 Hamburg, Germany; or
  • Azira SAS, 4 RUE AUBER 75009 PARIS, FRANCE

1. When does this policy apply?

This policy describes how we collect and use information collected from third party publishers, advertisers, data partners, and third-party ad exchanges (Partners) about consumers for our mobile advertising, data intelligence analytics, data enrichment, visualization and measurement tools services (Services).

This policy also explains what personal data we collect about you, how we use your personal data, who is it shared with and what rights you have in relation to the same.

Please read this policy to understand how we comply with our obligations under various privacy regulations, including the French Law No 78-17 of 6 January 1978 on Data Processing, Data Files and Individual Liberties and French Law No 2018-493 of 20 June 2018 on the protection of personal data and the General Data Protection Regulation (GDPR) applicable in the European Economic Area (EEA).

2. Are there any other policies I should be aware of?

3. You use my personal data and for what purposes?

We may use your personal data for all or some of the following purposes:

  • Targeted advertising services. We help our advertising and publishing customers provide more relevant advertising and content that is aligned with users' interests (“Targeting”). For example, we group users into audiences (“Targeting Segment”): sports fans, car enthusiasts, movie goers, travellers, and measure the effectiveness of campaigns. We also refine Targeting Segments to implement an additional Targeting Segment for users of social networks who have the same Mobile ID as that contained in the Targeting Segment (“Targeting Segment Bis”).
  • Delivery of advertising services. We assist our Partners to provide you with personalized ads based on your preferences and your browsing habits (“Delivery”).
  • Data intelligence services and reporting. We transform MAIDs, approximate geolocation information and the other data we collect (detailed above) into actionable insights for our customers. We provide customers with trend and statistical analyses, such as for identifying and optimizing trade areas and business locations, and for helping our customers make informed business decisions about consumer behaviour with trend and movement information. We provide actionable insights, patterns and commonalities to enable our customers to evaluate products and services they offer, such as enabling engagement with audiences and improving user experience of their apps and websites (“Reporting”).
  • Improving our services, as a secondary purpose. We use your personal data to improve the way we work, improve our services (“Analytics”).

4. With Whom You Collect And Process My Data?

Your personal data are processed for the for above mentioned purposes by AZIRA FRANCE as data controller.

For Targeting, AZIRA FRANCE is jointly determining the purpose and means of processing with Publishers, IAB Europe and Consent Management Platforms (CMP) acting as joint controllers within the meaning of Article 26 of GDPR.

For Delivery and Reporting, AZIRA FRANCE is jointly determining the purpose and means of processing with its clients acting as joint controllers within the meaning of Article 26 of GDPR.

You may ask to be provided with the essence of the arrangement between AZIRA FRANCE and the other joint controllers by contacting us at privacy@azira.com.

5.What personal data do you collect?

When you use an app or visit a website that uses advertising software placed by us or our Partners, we and our Partners may collect your mobile advertising identifier (MAID) from your device, internet protocol (IP) address, cookies, location data (including latitude data / longitude data), browser type, device type, connection type, carrier, time stamp, operating system and version, language preference, environment, SSP, your consent, the names of other mobile apps you use and how you browse the app or website.

6. Where do you receive my personal data from?

We receive data from our Partners' apps and websites, including:

  • For Targeting: your personal data are collected via a Consent Management Platform (CMP) implemented on a publisher’s (owners and sellers of digital advertising space) website, APIs or mobile app. personal data may also be provided by AZIRA FRANCE’s Partners. We also collect data from other trusted third-party providers and publicly available sources such as social media sites, census data providers and certain public directories.
  • For Delivery: your personal data is the Targeting Segment and the Targeting Segment Bis implemented by AZIRA FRANCE during the Targeting purpose.
  • For Reporting: your Personal Data is the Targeting Segment, the Targeting Segment Bis but also the Personal Data provided by real-time bidders providers or other Partners concerning the performance of the delivery campaigns.
  • For Analytics: your personal data corresponds to the personal data collected in the three above mentioned purposes (Targeting, Delivery and Reporting).

7.What lawful basis do you rely on for using my personal data?

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

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Purpose/ActivityLawful basis for processing
Targeting
Consent
DeliveryConsent
ReportingNecessary for our legitimate interests to assess the performance of the ad campaigns 

Analytics

(Secondary Purpose)

Necessary for our legitimate interests to assess the good performance of the Services and to improve our Services.

Such improvement may also positively impact the data subject by providing them with better and personalized ads adapted to their personal interests

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8. How is my personal data protected?

  • Where feasible, we shall encrypt your personal data where it is in transit or at rest. By default, AZIRA FRANCE database system is encrypted at rest.
  • We replace MAIDs with hashed identifiers, aggregate our other data points and cluster location data so that it is pseudonymised.
  • For operational purposes, location precision is reduced, and data is aggregated, along with strict retention delays.
  • We retain MAIDs internally in their original form to cater to our customers' request for targeted advertising, measurement and matching. This data is stored separately from the pseudonymised data.
  • We do not seek to create analytics based on sensitive personal information (for example, religion or credit worthiness).
  • Data used to Targeting Segment is pseudonymised. We may assign our own "Azira ID" to replace your MAID in our internal systems for your browser, computer or mobile device when we serve an advertisement to it or we identify it on a Partners' website or app.
  • We require all our customers that we share user data with to comply with applicable data protection laws. We also do not permit any customers to use our services for (a) employment, credit or health care eligibility checks; (b) insurance eligibility, underwriting, or pricing services; or (c) unlawful tracking or surveillance of individuals.
  • We follow a practice of “Least Privilege Access”. This principle is the practice of limiting access rights for users to the bare minimum permissions needed to perform required job functions, and thus differs from job-to-job and employee-to-employee.
  • Data is filtered and removed to ensure that fraudulent data falsely attributed to data subjects is removed and that GDPR rights are observed. Data retention policies ensure that only adequate data is retained and for a limited time. Location accuracy is reduced at the end.
  • Access to raw data is limited by role and business need. This data is only used in the context of building audiences for advertising, after being aggregated.
  • We have executed a Data Processing Agreements (DPA) with all our data processors to ensure that they all implement sufficient technical and organizational measure and comply with the highest standards on IT security.

9. Who do you share my personal data with?

  • Customers, for the provision of our Services. Where our customers need MAIDs for the purposes of serving targeted advertising, measurement and matching, we will provide MAIDs in their original form for this purpose.
  • Business partners, suppliers and subcontractors for the performance of the contract we enter into with them, for example for website hosting and email delivery services, running campaigns or to perform campaigns analytics. Third parties that support us in targeted advertising include: Google Cloud, Google Workspace, Meta, SSP, Adsquare, Bidswitch, KairosFire or E RETAIL DEVELOPMENT.
  • Regulators/ Authorities/ Enforcement Agencies if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our clients or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
  • Prospective buyers of our business under our legitimate interest to ensure our business can be continued by the buyer. If AZIRA FRANCE is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your information, as well as any choices you may have regarding your information.

10. Where do you store and transfer my personal data?

We store your data on our servers in France and within the EEA .

For individuals in the EEA, we may need to transfer your personal data outside of the EEA towards our data processors to provide our products and services.

Whenever we transfer your personal information outside of the EEA, we ensure it receives additional protection as required by law, including by entering into approved standard contractual clauses. To keep this policy as short and easy to understand as possible, we haven’t set out the specific circumstances when each of these protection measures are used. You can contact us at privacy@azira.com for more information on this.

11. How long do you keep my personal data for?

We will only retain your personal data for as long as we need it for the purposes it was collected, unless we are required to keep it for longer to comply with our legal, accounting or regulatory requirements.

  • For Targeting: your Personal Data is stored as raw stored for 5 days in AZIRA FRANCE’s database then minimized and aggregated. It is then stored as aggregated data for 90 days. After the retention period define herein, raw data is definitely deleted from AZIRA FRANCE’s databases.
  • For Delivery: your Personal Data is stored for 180 days in AZIRA FRANCE’s database. At this level, AZIRA FRANCE stores your Personal Data after minimizing and aggregating. After the retention period define herein, your Personal Data is definitely deleted from AZIRA FRANCE’s databases.
  • For Reporting: your Personal Data is stored for 180 days in AZIRA FRANCE’s database. At this level, AZIRA FRANCE stores delivery data after minimizing and aggregating to serve the Reporting purpose. After the retention period define herein, your Personal Data is definitely deleted from AZIRA FRANCE’s databases.
  • For Analytics: your Personal Data is stored as raw stored for 5, 90 or 180 days depending on the level of granularity and minimization of Personal Data in AZIRA FRANCE’s database. After the retention period define herein, raw data is definitely deleted from AZIRA FRANCE’s databases.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, and we may use this anonymised information indefinitely without notifying you. We use this anonymised information to improve the way we work, improve our services.

12. Does AZIRA FRANCE collect personal data relating to children?

AZIRA FRANCE does not knowingly collect personal information from anyone under the age of 18 through our Services and our Services are not targeted at children.

If you are below the age of 18 years, you must not use our Services or provide any information about you to our Partners and to us.

If we are made aware that we have received personal information from someone under 18 years of age, we will use reasonable efforts to immediately delete that information from our records.

13. What are my rights under data protection law?

You have various other rights under applicable data protection laws, including the right to:

  • access your personal data (also known as a “subject access request”);
  • correct incomplete or inaccurate data we hold about you;
  • ask us to erase or delete the personal data we hold about you;
  • ask us to restrict our handling of your personal data;
  • opt-out of our sharing or selling your personal data;
  • opt-in to the processing of any sensitive information we hold about you;
  • ask us to transfer your personal data to a third party;
  • object to how we are using your personal data; and
  • withdraw your consent to us handling your personal data; and
  • provide us with instructions concerning the use and disclosure of your personal data (retention, erasure, third party transfer, etc.) after your death.

You can contact us to ask about exercising your rights at any time at privacy@azira.com. Please keep in mind that privacy law is balanced with other important legal requirements, and these rights will not always be available to you all of the time.

You also have a right to lodge a complaint against a supervisory authority such as the Commission Nationale de l’Informatique et des Libertés, “CNIL” in France

We do not carry out any automated decision-making that produces legal effects or similarly significantly affects you.

14. Will there be changes to this policy?

We may update this policy from time to time and will use reasonable efforts to notify you of any significant changes. We encourage you to revisit this page for the latest information on our privacy practices.

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