17 January 2018,
Dr Banner, hyperlocal programmatic platform, offers a direct access to online advertising to its clients.
Dr Banner details hereafter the various processes used to analyze data as part of its advertising activity, as well as the owner’s rights concerning data coming from websites, mobile websites and applications displaying advertising managed by Dr Banner.
This document relating to personal data protection is available at the following URL : www.drbanner.com/fr/privacypolicy
The Dr Banner service is operated by the Dr Banner S.A.R.L.U., which has a share capital of 2000€, is located at 17 rue Louis Rouquier, 92300 Levallois-Perret and is registered 521 147 546 at the Nanterre RCS.
Dr Banner collects the following information during the users’ sessions on Dr Banner’s partner websites and applications via cookies usage amongst other means.
Collected data categorization; finality, duration and purpose of these processes :
A – Personal data processing
The following information are collected by Dr Banner in order to purchase ad spaces from publishers (or their advertising networks) and broadcast its advertisers advertising campaigns :
- Closest IPv4 address from the device
- IPv6 address
- IP address’ date and timestamp
- IFDA (Apple’s mobile advertiser identifier)
- Android Advertising ID (Google’s mobile advertising identifier)
This processing is based on the editor’s legitimate interest in selling advertising spaces in the most optimized manner possible, on Dr Banner’s legitimate interest in buying these spaces to display their advertisers’ ads for their benefit, within the boundaries of the users’ interests and fundamental rights on these websites and applications.
These IP addresses and mobile advertising identifier are kept for a 6 months period. They are deleted at the end of this period.
This data are destined to programmatic advertising platforms and/or relevant publishers.
B – Advertising cookies
This processing is based on the user’s consent, in accordance with the article 32 of the law “Informatique et libertés”. It requires an information banner warning users that navigation on the publisher’s website will authorize the set up and reading of advertising cookies.
The user also must be able to revoke his consent via an easily accessible “opt out” at all times.
This opt out is available for the following websites and mobile websites :
on the following link : http://www.youronlinechoices.com/fr/controler-ses-cookies/
On mobile device, users can revoke their consent on a targeted ad :
- On IOS, in the “settings”, by activating “limited ad tracking” in the “confidentiality” section
- On Android, in the settings, by disactivating “interest based advertisements”
Here are the information collected via cookie usage :
User data terminal :
- User agent
- Device language
- Internet provider or operator
- Connexion type (e.g. WiFi, Ethernet, 3G, 4G, etc.)
- Device advertising identifier
- Platform identifier (Android or iOS for example)
- Advertiser ID (string associated 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 system version (3.1.2 for example)
- Device type (e.g. mobile, PC, etc.)
- Flash engine version
Geo-location data, only available if the user opted in
- Signal soure (GPS, mobile network, etc.)
- Zip code
- UTC offset
User data :
- User identifier (given by the technical advertising sales provider, called SSP)
- Key words representing potential categories of user interests (e.g. cars, sports), excluding any sensitive data
- Websites visited prior to the user’s arrival on the editor’s website (browser history)
- Currently visited website or application (application name, domain name)
- Visit timestamp, viewed pages, activity and user actions on the website
- Birth date
The date collected via cookie usage aim to :
- Adapt the broadcasting to the user’s screen characteristics (language, display settings, operating system)
- Suggest ads on the publisher’s website depending on the user’s browsing history
- Suggest ads according to the location data given with the prior consent of the user
- Broadcast advertising depending on the on the interest segments expressed by the users.
User profiling is done by creating language segments (e.g French, English), geolocal segments (e.g. Paris, Bordeaux), interest segments (e.g. sport, automotive, etc.) and/or segments based on the terminal’s technical configuration (e.g. Apple, Android). This processing is based on Dr Banner’s and the publisher’s legitimate interest in selling and purchasing relevant advertising inventories for the advertisers, depending on the user profile, as long as this profiling doesn’t violate any of the user’s liberties or fundamental rights.
Information collected during an advertising campaign cannot be reused by other advertisers, save for geo-location data and users’ mobile advertising identifier.
No sensitive data is collected, and no sensitive data may be used for data profiling.
This data is stored for a maximum of 13 months.
Recipients of this data are real time digital advertising platforms, and website publishers whom the users gave consent to set up and read cookies.
The user can cancel his consent by following this procedure : http://www.youronlinechoices.com/fr/controler-ses-cookies/
C – Data processing relative to technical broadcasting
Dr Banner processes the following data when broadcasting ads on a publisher’s website or application (adserving) :
- IP address for websites
- Advertising ID for mobile applications
- Data from cookies
This process is based on Dr Banner’s and the publisher’s legitimate interest in broadcasting advertising content on the page requested by the user wishing to visit the publisher’s website or application.
D – Other processing
Dr Banner processes collected mentioned in paragraphs A and B to :
- Upgrade its own service (R & D)
- Keep proofs of advertising purchases execution, regarding applicable law
- Activity reports (ad performance, traffic forecasting)
- Security, identification and fraud management
It should also be mentioned that Dr Banner may be obliged to transmit personal information following a judiciary or administrative decision according to applicable law.
Likewise, Dr Banner and its eventual subcontractors and personal data recipients may have to transmit personal data to the competent authorities in order to combat fraud or protect Dr Banner’s users.
Access, rectification, opposition and suppression right :
Users and website and application visitors from whom Dr Banner collected data can ask each website or mobile application editor an access right to the personal data they’re processing.
They can also use their acces, rectification and suppression right with Dr Banner, which is responsible for the processing quality, through the address email@example.com
Users should be warned that since Dr Banner’s stored data do not contain the user’s last and first name, additional information will be asked from the user in order to provide an answer to his request.
The user has the possibility to cancel his consent 1. In his phone setting for mobile applications, 2. in the settings of the currently used browser for websites.
Cookies and advertising
The user is able to revoke his consent to avoid seeing an ad targeting his interests by using the following procedure : http://www.youronlinechoices.com/fr/controler-ses-cookies/
This opt out aims exclusively at stopping ad broadcasting relative to the users interests. The user will still see ads. Moreover, this opt out must be done on each browser used on a same device.
It should be noted that the opting out process functions by using cookies to indicate the user doesn’t want to see any targeted ads. If the user decides to delete all the cookies present on his computer, he will then have to go through the opting out procedure again in order for it to work on his computer or browser again.
On mobile devices, the user can also limit targeted ads in his settings : His advertising identifier will then not be accessible to applications download by the user.
This doesn’t exclude all visible ads contextualization : they may still be contextualized, depending on the contents of the visited page, but without any user profiling.
Dr Banner shall put in place every technical and organizational measures appropriate in order to guaranty a level of security equivalent to risks involved, most notably :
- Pseudonymisation and lettering of IP addresses and device ID
- Means of guarantying confidentiality, integrity, availability and constant resiliency of processing systems and services
- A process aimed at testing, analyzing and regularly evaluating the efficacy of the technical and organizational measures used to guaranty security processing
Dr Banner sets up standard protection clauses adoption by the Commission between it different entities around the world.
The conditions of a personal data transfer defined above are applicable even for ulterior transfers of personal data from a third party country to another third party country or another international entity.
- Email at the following address : firstname.lastname@example.org
- Regular mail at this 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 2.0 on the date 16/01/2020