17 January 2018,
Dr. Banner, programming platform specialized in hyper local advertising, offers direct access to on line publicity to their clients.
Dr. Banner details the the data processing carried out as part of its advertising activity as well as the rights of the people whose data is processed on websites, mobile sites and mobile applications where the advertisements generated by Dr. Banner appear.
This document on personal data protection is available at the following website: www.drbanner.com/fr/privacypolicy
Dr. Banner service is operated by Dr. Banner LLC with a social capital of €2000 and headquarters located on 17, rue Louis Rouquier 92300 Levallois-Perret, and registered with the Nanterre Trade and Companies Register under the number 521 147 546.
Dr. Banner collects the following information, including via cookies, from Dr. Banner’s websites and partner applications when website users visit them.
Categories of data collected; purpose, duration and basis of processing:
A – Processing of personal data:
Dr. Banner collects the following information, in order to buy advertising space with publishers (or their managers), and broadcast their advertising campaigns:
– The closest IPv4 address
– IPv6 address
– Date and time of IP
-IDFA (identifier for advertisers)
– Android Advertising ID
This processing is based on the publisher’s legitimate interest to sell advertising space in an optimized way and on Dr. Banner’s Legitimate interest to buy spaces to benefit advertisers and publish their adverts in return with respect to the interests or freedoms and fundamental rights of the users of these websites and applications.
The IP address and mobile advertising identifiers are collected for 6 months. They are then destroyed.
The recipients of this data are programming advertising platforms and/or the relevant publishers.
B – Advertising cookies
This processing is based on the consent of the user, in accordance with article 32 II from the Data Protection Act. It requires the presence of an information banner which informers website users that further surfing (via clicking or scrolling) of this publisher’s site will authorise the installation and reading of advertising cookies.
In addition, the website user must be able to withdraw their consent at any time via an easily accessible “opt out” button.
This opt out button is available for both websites and mobile websites:
on the following link: http://www.youronlinechoices.com/fr/controler-ses-cookies/
On a mobile site, the website user can withdraw their consent on targeted advertisements:
- On iOS, in “settings”, by activating “limit ad tracking” in the “privacy” section
- On Android, in “settings”, by deactivating “interest based advertisements”
The information managed via cooks are as follows:
User terminal data
– user agent
– device’s language
– Internet access provider or operator
– connection type (e.g. WiFi, ethernet, 3G, 4G, etc.)
– device’s advertising identifier
– platform identifier (Android or iOS for example)
– advertiser ID (string assigned to terminal or Internet browser)
– device brand (e.g. Apple)
– mobile operator (MCC-MNC code)
– model (e.g. iPhone)
– operating system (e.g. iOS or Android)
– operating version system (e.g. 3.1.2)
– device type (e.g. Mobile, PC, etc.)
– Flash Player version
Geo-location data, after opt in button is pressed by the website user
– Signal source (GPS, mobile network, etc.)
– Post code
– UTC offset
Website user data:
– Website user identifier (awarded by the advertising technical service provider, referred to as SSP)
– Key words representing potential categories of interest to website user (e.g. cars, sports), not including any sensitive data.
-site visited prior to the website user coming to the publisher’s site (browser history)
-Application or website currently visited (app name, domain name)
-date and time of the visit to web page, pages viewed, website user’s activity and actions on the site,
– date of birth
Data collected via cookies is used for:
-Adapting the advertisement delivery to the website user’s screen specifications (language, display settings, operating system).
– Recommending relevant advertisement delivery with browsing history on publisher’s site
– Recommending relevant advertisement delivery with respect to location data transmitted with website user’s prior consent.
– Displaying advertisements according to segment interests displayed by website users.
User profiling is done by creating segments related to language (e.g. French, English), geo-tracking (e.g. Paris, Bordeaux), interests (e.g. Cars, Sport) and/or technical configuration of terminal (e.g. Apple, Android). This treatment is based on the legitimate of the publisher and Dr. Banner to buy and sell relevant inventories to advertisers, based on user profiles, to the extent that profiling does not infringe on the user’s freedoms and fundamental rights.
The information collected during an advertising campaign is not reused to benefit other advertisers expect for the geo-tracking information and mobile advertising identifier used by the website user.
No sensitive data is collected and no profiling interferes with sensitive data.
This data is kept for a maximum of 13 months.
The recipients of this data are (i) real-time digital sales platforms, and (ii) the website publisher of the website on which the users consented to the installation and reading of these cookies.
The user can withdraw their consent by using the procedure available here:
C – Processing linked to the technical broadcast of adverts
As part of their technical broadcast of adverts on publisher’s websites or application (ad serving), Dr. Banner processes:
- IP address for websites
- Advertising ID for mobile application
- Data contained in cookies
This processing is based of the legitimate interest of Dr. Banner and the Publisher to broadcast advertising content on the page clicked on by the website users by visiting the publisher’s website or application.
This data is stored for the same length of time as mentioned in paragraphs A and B.
D – Other processing
Dr. Banner also processes the data collected in paragraphs A and B in order to:
- Improve their service (research and development)
- Evidence of the purchasing of advertising space made under the applicable law.
- Activity reports (advertisement performance, traffic forecast)
- Security, identification and fraud management
In addition, on ant judicial requisition or legal or administrative decision, Dr. Banner can hand over personal information in accordance with the applicable law.
Similarly, Dr. Banner, as well as any sub-contractors ad recipients of personal data, may pass on such data to the competent authorities in order to fight fraud or protect Dr. Banner’s assets.
Access, rectification, opposition and deletion rights:
The users, visitors to websites and mobile applications have theright to request that the controller grant them access to, rectify or delete their personal data or put a limit on the processing of their data. They also have the right to oppose the processing.
The users, visitors to websites and mobile applications , whose data was collected by Dr. Banner, can request access to their personal data from each website or mobile application responsible for processing their data.
The users can also exercise their right to access, rectify or delete their personal data via Dr. Banner, in their capacity as data controller, by firstname.lastname@example.org
Attention, the data held by Dr. Banner does not identify the user by first name or surname, complementary information will be requested from the user to be able to respond to their request for access.
The user has the possibility to withdraw their consent (i) in their phone settings for mobile applications, (ii) for web browsing, in the settings of the browser used.
Cookies and advertisements
The user can withdraw their consent in order not to receive advertisements based on their interests by using the procedure available here:
This opt out exclusively aims at stopping the diffusion of advertising according to the user’s interests. The user will continue to see advertisements. In addition, this opt out must be carried out on each browser used on the same material.
Attention, the opt out process itself is based on a cookies used to indicate that the user no longer wants to receive targeted advertisements. If the user decides to cancel all cookies on their computer. then they will have to repeat the opt out procedure so that it is taken into account on this computer or this browser again.
On a phone, the user can also limit targeted publicity in their settings: in this case, the advertising identifier will not be accessible by applications downloaded by the user. This does not exclude any contextulisation of the visible advertisements: these can be contextualized, in particular with regard to the contents of the visited page, but without profiling of the user.
Dr. Banner will implement the appropriate technical and organizational techniques to guarantee a level of security adapted to risk, and specifically:
- a) pseudonymization and encryption of IP address and device ID
- b) the means to ensure confidentiality, integrity, availability and resilience of processing systems and services.
- c) a procedure for regularly testing, analyzing and evaluating the efficiency of technical and organization measures to guarantee that the processing is secure.
Dr. Banner puts in place protection clauses adopted by the Commission between different entities around the world.
The personal data transfer conditions defined above are applicable, including for subsequent data transfers from the third-party country to another third-party country or another international entity.
- Via email: email@example.com
- Via postal address : 17, rue Louis Rouquier 92300 Levallois-Perret
Any data subject has the right to lodge a complaint with a supervisory authority, in particular in the Member State in which they normally reside, place of work or the place where the infringement is alleged to have occurred, if they consider that the processing of their personal data constitutes a violation of the applicable rules.
For France, the address for the French Data Protection Authority (CNIL) is 3 Place de Fontenoy 75007 Paris
Version 1.0 on the date 17/01/18