Privacy Policy - Details of the "SmartBox" data source
Last update : July 19, 2022
Preamble
This document informs you of the manner in which the company 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 Enseigne clients, your personal data collected via the processing linked to the SmartBox in-store measurement device, 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 data is collected by Smart Traffik through this sharing?
The SmartBoxes are a measurement device in a physical space which, when installed in the participating shops of Smart Traffik’s retail customers, collects certain information about your smartphone, unless you object. These are:
- The MAC* address of your smartphone, anonymised. This means that even if you have the original data, this alone is not enough to find the corresponding data transformed by the SmartBox;
- The time and date of the connection to the SmartBox, as well as the relative distance of your smartphone to the SmartBox;
- Location (Store where SmartBoxes are installed).
* The MAC address is an identifier stored in a device with Internet access. Unless it has been modified by the user, it is unique in the world. Once transformed by Smart Traffik through its anonymisation process, however, it becomes data that has a significant collision rate, i.e. it can be shared in our data by a large number of identical identifiers.
Purpose of the processing
When used alone, SmartBox processing provides reports on the traffic to the retailer’s outlets. These reports allow him to know the visiting trends of his visitors. The purpose of the SmartBox processing is therefore to allow Smart Traffik’s Brand customers to:
- Take into account audience measurements in shops to adjust offers and adapt customer relations in a non-individualised manner;
- Improving the customer experience and therefore the attractiveness of a store;
When used in the context of OKube, the offline cookie constituted by the SmartBoxes constitutes a source of data for the OKube processing, making it possible to establish a statistical adjustment rate, in order to obtain more accurate and reliable measurements over time. The SmartBox processing is thus also in line with OKube’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. Under no circumstances is this data communicated to third parties or used for advertising targeting purposes.
Data controllers
Smart Traffik is co-responsible for processing with its customers, the Signs, as regards the processing of the SmartBox and OKube. Thus, each of the co-controllers at the source of the collection of the processed data undertakes to inform the customer of the processing and to offer them the means of exercising their rights, in particular concerning the right to information, access and opposition (see below).
In the case of this exchange of data relating to the MAC address, Smart Traffik and the customer sign a sticker at the entrance to the shop with information about the OKube processing and the data collected by the SmartBox, as well as the means to find out more and to object to the processing.
Legal basis chosen
Smart Traffik attaches particular importance to the protection of personal data, and in view of its purpose of counting simple and recurrent visits, the SmartBoxes collect little personal information. Moreover, the information collected (the MAC address) is anonymised within a short time. The evaluations carried out by Smart Traffik led it to consider that its SmartBox processing could be based on legitimate interest, while preserving and guaranteeing the rights and freedoms of individuals, in particular the protection of personal data.
As regards the Okube processing, of which the SmartBoxes are a source of data, 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
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.
Some partners and advertising actors (learn more) may also have access to Smart Traffik data (in the case of the SmartBox, it would not be directly the offline cookies, which are anonymous, but the reconciled pseudonymised mobile identifiers), within the strict framework of the use of these data to reach the performance measurement purpose of Smart Traffik, and without conservation of these 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 the data is kept
- The anonymised MAC address is retained for 24 months from the last interaction between the user and the Sign customer.
- Pseudonymised mobile advertising identifiers reconciled on off-line cookies, from Smart Traffik’s authorised partners and obtained with your consent, are kept for 13 months.
How to exercise your rights
The following rights (in addition to your right to information, to which Smart Traffik responds in particular through this page) apply:
- Right to object: you can object to the sharing of your data with Smart Traffik via the tools set up by the customer Sign and Smart Traffik in shop on the Smart Traffik sticker, by scanning the QR Code / or by placing your NFC phone on the sticker at the entrance of the shop or by entering your MAC address in the form below. You can also deactivate your Wi-FI before entering the shop.
- 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 of deletion: you can ask us to proceed with the deletion of your data, upon request to gdpr@smart-traffik.io (proof of identity will be requested). In such a case, Smart Traffik will endeavour to comply with your request, but please note that due to the pseudonymisation or anonymisation of the data, it may not be possible for Smart Traffik to trace your original MAC address among the offline cookies in a reliable manner.
Deleting your device information
The respect of your private life is at the heart of our concerns. Smart Traffik offers you the possibility to object to the collection of the MAC address of your smartphone.
To do so, validate the form* to delete the information concerning your smartphone.
The format accepted by the form is the following example 1A:2B:3C:4D:5F:5F. 12 characters separated by colons.
* If the form does not appear, consider disabling the content blockers activated on your device or browser.
What does a MAC address look like?
A MAC address is a 12-character identifier, consisting of the numbers 0 to 9, and the letters A to F (upper or lower case). It can be broken up by dashes or colons.
Examples:
1a-2b-3c-4d-5f-5F
1A:2B:3C:4D:5F:5F
How to find your MAC address?
iOS (iPad, iPhone, iPod Touch): Go to Settings > General > Information.
Android: Go to Menu > Settings > WiFi > Advanced Options. The MAC address appears in the “MAC address” line.
Alternative method
Menu > Settings > About phone > Status.
The MAC address appears in the “WiFi MAC address” line.
Blackberry
Go to Settings > Network Connections > WiFi > Advanced.
Select “Diagnostic Information” from the “Device Information” list.
The MAC address appears in the “Physical address” line.
Windows Phone
Make sure WiFi is enabled.
Go to Settings > About > More info.
The MAC address appears in the “MAC address” line.
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 pseudo-anonymisation measures 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 such an event 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, the co-controllers, and Smart Traffik acting as co-controller for its customers, and acting in accordance with the contractual terms and conditions set out in the defined co-control agreements.
With the consent of our clients, we reserve the right to publish aggregate data about all sites using Smart Traffik solutions. This aggregated data is used for the promotion of our solutions but does 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
- Lyon
6 cours André Philip – 69100 Villeurbanne
Tel : +33 (0)1 45 32 32 71
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
