Last edited on
Mar 22, 2022
Please note this disclaimer is solely for information purposes and does not constitute a fair processing notice in respect of particular data controllers using the ADLOOX Solution.
To review the full details regarding ADLOOX’s processing of personal data, please refer to the privacy notice here: https://adloox.com/en/privacy-policy.
ADLOOX SAS (“ADLOOX”) provides ad verification services via ui.adlooxtracking.com (THE “ADLOOX Solution”), which enables ADLOOX clients to control the efficiency of online targeted marketing campaigns. ADLOOX software runs analysis for example to check whether the advertisements have been broadcasted on broadcasters’ websites, in what country the advertisements have been broadcasted and whether they have been displayed in front of a real web user and not activated by a bot.
In respect of the personal data processed in connection with the ADLOOX Solution:
ADLOOX acts as a “data processor” on behalf of its clients; and
ADLOOX clients, (together with the broadcasting websites), act as the data controllers,
in each case for the purposes of the GDPR.
As data processor, ADLOOX processes personal data in connection with the ADLOOX Solution on the basis of its clients' instructions and for the lawful purposes our clients identify. More particularly, personal data are processed in the ADLOOX Solution in order to produce aggregated statistics as instructed by our clients. Such statistics are aggregated, hashed and anonymized following a robust process preventing any and all identification of web users before any storage in ADLOOX servers. ADLOOX shall not keep personal data (such as the IP address) and shall only provide its clients with statistical data relating to the country in which the advertisements have been broadcasted, the overall frequency and other statistical data relating to the broadcasting of clients’ campaigns.
II. How personal data is used for the Adloox SOLUTION
The Adloox Solution serves both advertisers and online media sellers and buyers by providing independent, third-party verification measurement.
Adloox’s clients are companies that run online advertising campaigns and are using the Adloox Solution in order to increase protection from ad fraud, non-viewable impressions and non-brand safe content, or to measure the quality of their advertising (for example to better understand how their campaigns have been interacted with or where a certain campaign has featured on a website) ("Clients").
By analyzing information about ad impression delivery and website traffic on behalf of our Clients, Adloox verifies whether the media where an ad was placed has met or failed Client expectations based on certain characteristics. Such characteristics 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 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 media, monitor overall quality performance, and make future media planning decisions. Adloox does not combine the collected data with any other data that would enable Adloox to personally identify individuals.
The Adloox Solution provides Adloox clients with reports containing only statistical information relating to such client’s advertising campaign performance. Such statistical information is aggregated, hashed and anonymised following a robust process preventing any and all identification of individuals before being provided to Adloox clients. Adloox therefore only processes personal data in connection with the Adloox Solution (see further below) for the short period of time required to apply such aggregation, hashing and anonymisation techniques.
The following categories of data (which may contain personal data) are collected when these technologies are deployed via the Adloox Solution:
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 users’ 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 Adloox 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.
Purpose of Collection and Use.
We use the data we collect to deliver our Adloox Solution for our Client’s lawful purposes, which may include:
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 Adloox Solutions includes 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 can use 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.
Our clients’ main use of the Adloox Solution is to obtain statistical information relating to the broadcasting of such clients’ advertising campaigns. As such, we aggregate, hash and anonymise any personal data following a robust process preventing any and all identification of web users before storing such data in our servers, and the reporting data sent to clients does not contain any personal data.
We retain our clients reporting data for up to 13 months subject to our client's instructions.
III. CONSUMER CONTROL AND 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
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:
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.
We may also disclose personal data to our affiliates in order to support marketing, sale and delivery of Adloox Solutions.
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.
V. TRANSFER OF PERSONAL DATA OUTSIDE OF THE EUROPEAN UNION.
Our servers are located in the EU. We do not transfer or store personal data outside of the EU.
Whilst transfers from the UK to the EU are not restricted under applicable data protection laws, we will nevertheless have appropriate safeguards in place to protect your personal data throughout such transfers. If you would like to find out more about the safeguards we use for these purposes, please let us know by writing to firstname.lastname@example.org.
VI. YOUR RIGHTS
You have a number of rights in relation to the way we process personal data about you. Where an individual makes a request in accordance with provisions of the GDPR, we aim to comply without undue delay, and within one month at the latest. Those data subject rights include the right to make the following requests:
to ask for confirmation and information about the personal data that we process about you, including a copy of data we are processing about you;
to have inaccuracies corrected or incomplete personal data made complete;
to ask us to restrict, stop processing, or to delete your personal data;
to request a machine readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
to not be subject to automated decision-making, including profiling; and
to make a complaint to the data protection supervisory authority in your jurisdiction.
To make a request to exercise any of these rights, please let us know by contacting us at email@example.com.
Please be aware that, while we make the security of our Adloox Services and your personal information a high priority and devote considerable time and resources to maintain robust IT security, no security system can prevent all security breaches. When you choose to share your personal information with us, you accept the aforesaid and provide your information at your own risk.
VIII. RETENTION OF PERSONAL DATA
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
Where we act as data processor on behalf of our clients, we will retain your personal data for the length of time specified by our clients as the data controller.
IX. LINKS TO EXTERNAL WEBSITES
X. HOW TO CONTACT US
E-mail us at firstname.lastname@example.org
Or write to us at ADLOOX SAS
34 Rue Laffitte
Attn: Data Protection Lead