Privacy Policy - Clarification of the "Audience" data source

Last update : April 28, 2022

Preamble

This document informs you of the manner in which E Retail Development – SAS RCS de Lyon n°751 652 934 – 6 Cours André Philip – 69100 Villeurbanne (acting under the trade name Smart Traffik) processes, in its capacity as joint controller with its Retailer customers, your personal data collected via its online measurement solution Audience, when used as a source of data within the framework of the “Omnichannel Audience Platform” (oKube) statistical measurement solution; the purpose of this processing, the responsibilities of the parties involved and how you can, if you wish, object to it.

What is the Audience service and what data does it collect?

Audience is an online performance measurement and data collection service placed on our retailer clients’ websites, allowing us to collect:

  • A Smart Traffik proprietary cookie only applicable to the domain name (e.g. ledomaine.fr) of the Enseigne client (it cannot be found on other domains, it is called “cookie-first”) and deposited within your browser.
  • A standard PHP session ID, deposited within your browser, that identifies a session.
  • A timestamp (time of data collection)
  • Information filled in on the site’s forms, which are also collected by the Sign customer as part of their online services (no other information from other forms can be captured). The difference, however, is that for Audience, this data is encrypted, i.e. the original data is transformed by the application of a technology that transforms the initial data into a string of random characters, with no possibility of returning to the original data without knowing the data “in the clear” and whose effectiveness is regularly reviewed. As Smart Traffik is a third-party performance meter for statistical processing, none of this data in clear is useful or kept. The input data that are encrypted can be those listed below, only if you fill them in and send them within the said forms:
    • First name
    • Name
    • Email
    • Telephone number(s)
    • Postcode, city
  • The IP address sent by a browser, protection measures (truncation and deletion at 24 hours, hash + salt) are applied to the data
  • Collect GPS coordinates from a browser
  • Collecting the amount of transactions made by users in the case of online commerce
  • Collect so-called fingerprint information, which is information available in a browser, enabling the anonymous identifier to be enriched for statistical processing. Most of these fingerprints are also encrypted (except for information with a high collision rate, i.e. it is shared by a large number of individuals and therefore cannot be used to isolate an individual) when ingested.
  • Audience can also in some cases be interfaced with a Retailer’s Google Analytics account to more easily identify interactions that may be initiated by a digital campaign (see below) and link campaign cost data to it for profitability calculations.

It should also be noted that the geolocation data collected by Audience is used to power a separate geolocation service, which does not track individuals’ information, and is used for user experience improvement or measurement purposes.

Finally, note that in certain cases (more information), Audience can be used to integrate the scripts of data partners, always with your consent, in order to share certain data with them, so that the partner (SFBX and Tapad in particular) can then send information to oKube to enrich the oKube omnichannel graph, including a mobile advertising identifier. In such a case, oKube may send these partners :

  • The cookie-first (client domain specific) generated within your browser
  • The URL visited
  • The user agent contained within your browser
  • The IP address, truncated, contained within your browser.

Smart Traffik’s partners (SFBX and Tapad) do not retain this data after its reconciliation operation.

The data collected by Audience are collected through the following sub-domains:

Purpose of the processing

The purpose of the Audience processing is to measure users’ interactions with a Brand customer’s website and to be able to link a user’s visit(s) to that website with prior exposure to a digital lever or advertisement, in order to measure online and in-store performance.

As a data source for oKube processing, the data collected via the Audience service is used to enrich the oKube omnichannel graph and/or to establish direct matches with other data, for example from CRM data (linked to checkouts) of Smart Traffik’s retail customers, or from Smart Traffik’s partners’ data. Audience is thus in line with the latter’s purpose (learn more about oKube processing), which is to allow Smart Traffik’s retail customers to:

  • Measuring the impact of online marketing levers on the performance of the brand/brand online and in-store;
  • Optimise marketing investment management through multi-touch attribution (i.e. understanding the contribution of different marketing efforts to omnichannel performance)
  • Visualise data on the basis of intelligible and accessible business indicators according to several levels of information;

Smart Traffik relies on the correlation of pseudonymised or anonymised data from online interactions (which may take place on different browsers and devices) and in-store interactions of end customers with its Retailer client, as well as data from Smart Traffik’s partners; all of which allows for the matching of data and/or (depending on the source of the data) the constitution of an omnichannel identifier (also known as an “omnichannel graph”) allowing for measurement.

oKube therefore produces aggregate statistics, without revealing any information about an individual, for the sole purpose of performance measurement. These statistics are made available in a dashboard for Smart Traffik’s retail customers, to help them better manage their marketing investments.

Data controllers

Smart Traffik is jointly responsible for the processing of data with its customers, the Signs, with regard to the Audience and oKube processes. Thus, each of the co-controllers at the source of the collection of processed data undertakes to inform the customer of the processing and to offer them the means of exercising their rights, in particular with regard to the right to information, access and opposition (see below). When Audience is deposited on the website of a Brand client, the latter refers to Smart Traffik and provides a link to this page in its privacy policies and/or tools.

Legal basis chosen

Smart Traffik attaches particular importance to the protection of personal data. When Audience is placed on a Retailer’s website, the latter obtains the consent of the user of its website to the placement of cookies by the Audience service, and therefore more generally to the triggering of the Audience service, via its cookie banner (and allows the user to object to the Audience processing via this same cookie banner) and/or via its Consent Management Platform. Smart Traffik also asks its Brand customers to include the necessary information in its terms of use / privacy policies and in certain forms.

With regard to the oKube processing, of which Audience is a data source, the assessments carried out by Smart Traffik led it to consider that it could be based on legitimate interest as a legal basis, while preserving and guaranteeing the rights and freedoms of individuals, in particular the protection of personal data.

Recipients of the data collected via Audience

E RETAIL DEVELOPMENT, a simplified joint stock company, whose registered office is located at 6 cours André Philip, 69100 Villeurbanne and registered under the number 751 652 934 RCS Lyon (“Smart Traffik”), is the recipient of this data.

Note that Smart Traffik’s retail customers have access to a dashboard presenting the aggregated statistical measures but cannot in any case have access to the data shared and transformed by Smart Traffik once transmitted, in order to avoid overlaps between encrypted data that will have been subject to statistical processing and unencrypted data without the authorisation of the persons concerned.

Certain partners and advertising companies (more information) may also have access to Smart Traffik data, strictly for the purpose of using this data to meet Smart Traffik’s performance measurement objectives, and without retaining this data following the necessary reconciliation operation. It should be noted that in the case of Facebook, this is the Facebook Ireland entity, which has subscribed to the Standard Contractual Clause (https://www.facebook.com/help/566994660333381 ) validated by the European Commission, and related to the protection of data that would be transferred to its parent company, outside the European Economic Area.

How long is this data kept?

  • Identification data (title, first name, surname, telephone numbers, postcode, town, registration number): 24 months from the last interaction between the user and the customer. Note that this data is ingested encrypted, so it is not in clear text in the Smart Traffik database.
  • Transaction data (e-commerce amount): 24 months from the last interaction between the user and the customer.
  • Connection data (Smart Traffik cookie and session cookie: 13 months from the last interaction between the user and the Enseigne customer.
  • Fingerprint data: 13 months from the last interaction between the user and the Enseigne customer. Note that most of this information is ingested encrypted.
  • Location data (IP location, hashed IP address + salt, HTML5): 13 months from the last interaction between the user and the Sign customer.
  • Google Analytics data (if applicable): 24 months from the last interaction between the user and the Sign customer (this data is not personal data but rather campaign configuration data).

How to exercise your rights

The following rights (in addition to your right to information, to which Smart Traffik responds on this page) apply:

  • Right to object: you may object to the collection of your data and the deposit of cookies via Audience within the cookies banner and/or the “Confidentiality” or “Privacy Management” section of the Brand’s website on which the Audience script is deployed. You can also deactivate tracking by cookies in your browser (you can consult the recommendations of the CNIL to this effect: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser). You can also contact gdpr@smart-traffik.io to request opposition to pseudonymised data entered in forms, if you think you have entered such data in the forms of our retail customers (see the “partners” section of our retail customers or the mentions under their forms).
  • Right of access: Smart Traffik can provide you with a copy of your processed data, upon request to gdpr@smart-traffik.io (proof of identity will be requested). Please note, however, that as Smart Traffik only uses encrypted (pseudonymised) data, we will need to have an original piece of data to be able to tell you if we can find it (by re-encrypting it), such as an email address.
  • Right to portability: you have the right to request the recovery of your data or their transfer to another service provider under the right to portability, upon request to gdpr@smart-traffik.io (proof of identity will be requested). Please note, however, that as Smart Traffik only uses encrypted (pseudonymised) data, we will need to have original data to be able to tell you if we can find it (by re-encrypting it), such as an email address.
  • Right of rectification: you have the right to rectify, correct and update your data at any time, upon request to gdpr@smart-traffik.io (proof of identity will be requested).
  • Right of limitation: you can also ask us to limit the processing operations to the sole conservation of your data, under certain conditions, under the right to the limitation of processing, on request to gdpr@smart-traffik.io (proof of identity will be requested).
  • Right to erasure: you can ask us to erase your data, upon request to gdpr@smart-traffik.io (proof of identity will be requested).
Smart Traffik is a member of the IAB and, as such, adheres to the use of the Transparency and Consent Framework proposed by the association. The Transparency and Consent Framework (TCF) proposes common rules to be adopted when processing personal data or accessing and/or storing information on a user’s terminal, such as cookies, advertising identifiers, device identifiers and other tracking technologies.

Your data and transfers outside the EU/EEA

Smart Traffik does not at any time transfer data outside the EU/EEA area on its Smart-Traffik.io website or within the current oKube solution.

However, the service providers and any subcontractors we use may transfer data outside the EU/EEA. Where this is the case, we ensure that such transfers are made on the basis of appropriate safeguards to ensure the security of your data.

How do we ensure the security of your data?

In addition to the encryption measures (data hashing) detailed above and in order to ensure and guarantee the security of your data, we have put in place all the technical and organisational measures at our disposal to prevent your data from being unintentionally and accidentally lost, used, altered, or made available to the public without your authorisation. The data collected by Smart Traffik is stored on servers that protect it by encryption.

Should an event of this nature occur, we have implemented measures to react promptly and to inform you and the CNIL when necessary.

Data ownership

The data collected and processed via our software solutions remain at all times the exclusive property of our customers as co-processors and of SMART TRAFFIK acting as co-processor of its customers and acting according to the contractual terms defined in the defined co-processing agreements.

 

With the consent of our customers, we reserve the right to publish aggregated data on all sites using SMART TRAFFIK solutions. These aggregated data are global statistics allowing us to promote our solutions but do not contain any personal data or commercial information.

Data of minors

We do not knowingly collect or request information from minors (date of birth or age of users is not collected. It is not possible to determine age). If we discover that we have collected personal data from a minor, we will delete it as soon as possible.

Contact us

If you have any questions or complaints about the protection of your personal data, you can contact us at the following address

  • Paris

41-43 rue Paul Bert – 92100 Boulogne-Billancourt

Tel
: +33 (0)1 46 55 55 24

contact@smart-traffik.io

  • Lyon

6 cours André Philip – 69100 Villeurbanne

Tel
: +33 (0)1 45 32 32 71

contact@smart-traffik.io

You can also contact Smart Traffik’s Data Protection Officer (DPO) at the following address

Smart Traffik

6 
cours André Philip – 69100 Villeurbanne

Phone: +33 (0)1 45 32 32 71

gdpr@smart-traffik.io

 

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Chicago

222 W Merchandise Mart Plaza
Floor 12, Suite 1212
CHICAGO, IL 60654
Phone : +1 312 620 1958
contactus@smart-traffik.io

Paris

41-43 rue Paul Bert – 92100
Boulogne-Billancourt
Phone : +33 (0)1 46 55 55 24
contact@smart-traffik.io

Lyon

6 cours André Philip – 69100
Villeurbanne
Phone : +33 (0)1 45 32 32 71
contact@smart-traffik.io