Privacy Policy

Last update : April 2, 2021

Preamble

This privacy policy (the “Policy”) 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) treats, in its capacity as data controller, your personal data collected on the website https://okube-attribution.com (hereinafter the “Website”), as well as those collected in the context of the oKube processing.

Smart Traffik is a specialist in the development of omnichannel solutions that it offers to various brands and retailers, enabling them to improve and maintain their relationship with consumers throughout the buying process. Smart Traffik develops omnichannel customer engagement, models the entire online and offline consumer journey, and provides real ROI on marketing campaigns.

Smart Traffik also publishes the website https://www.blog-to-store.com/ which offers information on the online marketing sector (the “Blog”).

If you have any questions about this Policy or about the use of your data, please contact our Data Protection Officer (DPO) at gdpr@smart-traffik.io.

What are your rights and how can you exercise them?

Under the terms of the GDPR and the French Data Protection Act (“Loi Informatique et Liberté”), you have certain rights in relation to the processing of your personal data.

You thus have the right to request information on the processing that we carry out as well as a copy of your processed data.

Thanks to the right of rectification, you have the possibility to rectify, correct and update your data at any time.

You also have the right to object to the processing of your information in certain cases through the right of objection.

You may also ask us to limit processing operations to the retention of your data, under certain conditions, under the right to limit processing.

With the right to deletion, you can ask us, in certain cases, to delete your data.

Under certain conditions, you have the right to request the recovery of your data or its transfer to another provider under the right to portability.

In addition, you have the right to define directives concerning the fate of your personal data after your death and the right to lodge a complaint with the CNIL.

We also inform you that we do not make any automated decisions, including profiling, using your data.

The exercise of these rights is free of charge and can be done at any time, subject to proof of identity, by writing to gdpr@smart-traffik.io.

Your data and transfers outside the EU/EEA

Smart Traffik does not transfer any data outside the EU/EEA area.

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.

Data collection on the okube-attribution.com website and newsletter

What data do we collect on our website okube-attribution.com?

As part of your registration and account creation on the Website, we collect various information about you. We also collect and process some of your data when you have requested to be contacted for information about our products or when you enter a form to access a resource. All such data includes:

  • Your full name;
  • The name of the company to which you belong;
  • Your email address;
  • Your telephone number, only if you wish to be contacted by telephone;
  • Data relating to your activity on the Website through the use of cookies.

As part of your subscription to the oKube newsletter, we also collect and process your email address to keep you informed of our latest news and other information that may be of interest to you.

Cookies

Browsing the Website may result in several cookies being deposited on your connection terminal.

A cookie is a file consisting mainly of letters and numbers, of limited size, stored on the browser or hard drive of your computer.

These cookies are used for statistical purposes in order to:

  • Measure the audience of our website;
  • Help us distinguish between new and returning visitors to our website;
  • Help us measure and study the effectiveness of our content.

We also use cookies so that we can contact and/or offer relevant content to visitors, and to help us personalise the content that appears when you visit the Website.

These cookies are kept for a period of 13 months from the time they are placed on your connection terminal.

You can refuse to have them installed by setting your browser to do so or by customising your preferences when you arrive on the Website.

Newsletter

You can subscribe to the oKube newsletter at any time by entering your email address in the space provided. By clicking on “OK” you give us your consent to receive information, commercial or otherwise, about oKube news and the various contents published on our Blog.

You may withdraw your consent at any time and unsubscribe from our mailing list by clicking on the unsubscribe link provided.

Why and how do we collect your data?

We collect your data on the basis of your consent in order to
:- Allow you to subscribe to our newsletter to receive all the latest news about oKube and the new products we are developing; 
- Allow us to contact you in the event of an enquiry.

You may withdraw your consent at any time by deleting your account or by writing to us at gdpr@smart-traffik.io.

The processing of your data may, in certain cases, also be necessary in the context of the execution of a contract concluded with Smart Traffik if you are a customer of Smart Traffik.

The data and information we collect about you may in some cases be shared with our partners who offer complementary solutions to oKube. When this is the case, you will be informed of this when you validate the collection form.

How long are they kept?

In connection with the use of the services offered on the okube-attribution.com website, we retain your data for up to three years after you stop using the services we offer on the website.

The data collected when you subscribe to our newsletter is kept for a period of 1 year after you unsubscribe.

In the event of an enquiry or other contact with Smart Traffik, we will retain your data for a period of three years after your last interaction with us.

How do we ensure the security of your data?

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 permission.

Should such an event occur, we have implemented measures to react promptly and to inform you and the French Data Protection Authority, the CNIL, when necessary.

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.

Data collected on behalf of Smart Traffik's retail customers, via the oKube solution

Preamble

This section 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, as joint controller with its Retail customers, your personal data collected jointly with its Retail customers in the context of the oKube statistical measurement solution; of the purpose of this processing, the responsibilities of the parties involved and the way in which you may, if you so wish, object to it.

Smart Traffik is a specialist in the development of omnichannel 
solutions that it offers to various brands and retailers, enabling them to improve and maintain the relationship with consumers throughout the purchasing process. Through its oKube solution, Smart Traffik models the entire online and offline consumer journey and gives the real ROI of marketing campaigns.

Purpose of processing oKube

The purpose of the oKube processing is to allow Smart Traffik’s Brands customers to :

  • Measuring the impact of online marketing levers on the performance of the brand/brand online and in-store
  • Optimise marketing investment management with multi-touch attribution
  • 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.

It is therefore a question of producing global aggregated statistics, revealing no information relating to an individual, made available within a dashboard for Smart Traffik’s Retail Clients, to help them better manage their marketing investments. Under no circumstances will this data be sold to third parties or used for advertising targeting purposes.

Legal basis for oKube processing

The oKube platform attaches particular importance to the protection of personal data, and in view of its purpose of measuring the impact of advertising and marketing investments, only collects and processes pseudonymised or anonymised data. Given oKube’s low-intrusive purposes and the fact that the data is used neither for advertising targeting nor for sending commercial communications, Smart Traffik’s evaluations led it to consider that its oKube processing 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. However, the collection of data by Smart Traffik and the transmission of data to Smart Traffik are done in several cases with your consent only.

Thus, for each of the subcontractors constituting oKube’s sources (see the section below on “oKube’s data sources and measures to protect your data” for more details):

  • SmartBox: Legitimate interest of Smart Traffik and of the customer Sign, as it is an anonymised data at short notice.
  • Audience: Consent to the data collected through the use of the Sign client’s cookie banner and/or their CMP (Consent Management Platform) forwarding proof of consent to Smart Traffik, as well as the use of disclosures in the Sign client’s T&Cs/user policies and under certain forms. In some cases, Smart Traffik’s Retail customers may share with Smart Traffik access to campaign data (e.g. via Google Analytics), to facilitate campaign identification and measurement.
  • CRM Data: data collected lawfully from the Brand(s) of which you are a customer, generally collected by the Brand customer on the basis of your consent as part of a loyalty programme, or in some cases of the legitimate interest of the Brand customer, while preserving and guaranteeing the rights and freedoms of individuals, in particular the protection of personal data
  • Data transmitted to Smart Traffik by mobile data partners: this data is collected by Smart Traffik’s partners and transmitted to Smart Traffik for measurement purposes on the basis of your consent.
  • Data transmitted to Smart Traffik by advertising agencies for measurement of their campaigns: this data is collected by Smart Traffik’s partners and transmitted to Smart Traffik for measurement purposes on the basis of your consent.

oKube data source and measures to protect your data

The oKube service, when deployed in Smart Traffik’s retail customers, relies on several data sources to measure the interactions of the retailer’s customers and prospects with their digital (website(s)) and physical (shops equipped with Smart Traffik’s SmartBoxes) ecosystems.

The following subcontractors are therefore oKube’s data sources and enable the achievement of its purpose.

Smart Traffik is based on two types of data:

A. First” data, obtained directly from Smart Traffik’s retail customers (website, CRM program, shops):

  • Online measurement solution Audience: a script placed on the Brand customer’s website allowing the placement of a cookie applicable to the Brand customer’s domain only (cookie-first) online, the collection of pseudonymised personal data (i.e. transformed, with no possibility of returning to the original data, unless the original data is available, which is not the case with Smart Traffik) submitted within forms, data contained within your browser (IP address, so-called fingerprint data) to which protective measures are also added, and GPS coordinates. The data collected via the Audience service is used to enrich oKube’s omnichannel graph for measurement and/or to establish direct matches with other data, for example from CRM data (linked to checkouts) of Smart Traffik’s retail customers. 
Details: oKube and privacy: Audience
  • In-store measurement solution SmartBox: a device (sensor) installed in shops that generates anonymised data (called “offline cookie”) from the MAC address of your mobile phone at short notice. It is not possible to trace the original data (even if you are in possession of it). This anonymised data is placed in a dataset called a “filter” in which it has attributes in common with other data, thus generating a collision rate that further enhances anonymisation. This “offline cookie” is used to match other mobile data, obtained via Smart Traffik’s data partners (see below) based on your consent only (Smart Traffik does not seek to link to data you have not consented to), in order to enhance the accuracy and scope of the measurement of shop visits.
 Details: oKube and privacy: SmartBox
  • Exchanges of data related to your in-store transactions and the sharing of your personal data known to the retailer customer (e.g. CRM loyalty programme), always in encrypted form with no possibility of returning to the original data. The amount (sometimes in the form of equivalence), product information, time and place of the transaction are transmitted in clear text. This information can be used by Smart Traffik to match data from its omnichannel graph and/or partners for measurement purposes.
  Details: oKube and privacy: CRM data exchange

B. Third party” data, obtained from Smart Traffik’s partners or advertisers on which the measurements are based:

As part of its oKube solution, Smart Traffik also receives so-called third-party data from mobile advertising companies, which can be used for oKube measurements.

Details of the data partners and advertisers concerned:

a. Data shared with Smart Traffik by its mobile data partners, or exchanged between Smart Traffik and its partners, with your consent only:

  • Adsquare :
    • Data concerned:
      • Pseudonymised mobile advertising identifiers
      • Timestamp
      • Data transmitted within the perimeter of a geolocation corresponding to the locations of the shops of Smart Traffik’s customers
    • Length of time Smart Traffik keeps this data: 2 months
    • Scope: offline match for measurement only
    • Privacy policy and opt-out
  • SFBX :
    • Case 1: Sharing of data located near the shops of Smart Traffik’s customers
      • Data concerned:
        • Pseudonymised mobile advertising identifiers
        • Hashed email or phone number
        • Geolocation data (data transmitted within the perimeter of a geolocation corresponding to the locations of the shops of Smart Traffik’s retail customers) and time stamp data
      • Length of time that Smart Traffik keeps this data: 13 months; it should be noted that SFBX also sends Smart Traffik the list of advertising identifiers that have objected to Smart Traffik’s processing, so that Smart Traffik does not carry out any further processing on them.
      • Scope: offline match for measurement and enrichment of the oKube omnichannel graph
    • Case 2: Reconciliations of advertising identifiers on Smart Traffik’s Audience service cookies-first:
      • Data concerned:
        • Smart Traffik, by integrating SFBX into its Audience script, allows SFBX to collect :
          • The browsed URL
          • The user agent
          • Your IP address truncated
          • A timestamp
          • The cookie-first filed by Audience
          • SFBX does not keep this data after the reconciliation operation
        • SFBX, after reconciliation, shares at Smart Traffik :
          • Mobile advertising identifiers linked to cookie-first
          • Length of time that Smart Traffik keeps this data: 13 months; it should be noted that SFBX also sends Smart Traffik the list of advertising identifiers that have objected to Smart Traffik’s processing, so that Smart Traffik does not carry out any further processing on them.
          • Scope: enrichment of the Smart Traffik omnichannel graph for performance measurement purposes
        • Privacy policy and opt-out
  • Tapad :
    • Data concerned:
      • Smart Traffik, by integrating Tapad into its Audience script, allows Tapad to collect :
        • The browsed URL
        • The user agent
        • Your IP address truncated
        • A timestamp
        • The cookie-first filed by Audience
        • Tapad keeps this data for 14 months and then deletes it
      • Tapad, after reconciliation, shares with Smart Traffik:
      • Mobile advertising identifiers linked to cookie-first
        • Duration of retention of this data by Smart Traffik: 14 months; it should be noted that Tapad also sends Smart Traffik the list of advertising identifiers that have objected to Smart Traffik’s processing, so that Smart Traffik does not carry out any further processing on them.
        • Scope: enrichment of the Smart Traffik omnichannel graph for performance measurement purposes
      • Privacy policy and opt-out

b. Data shared with Smart Traffik by the advertising actors on which the measurement is based, or exchanged between these actors and Smart Traffik, with your consent only:

  • S4M :
    • Data concerned:
      • Hashed mobile advertising identifiers
      • Geolocation and time stamp data
      • Campaign ID
    • Length of time Smart Traffik keeps this data: 2 months
    • Scope: provision of this data for performance measurement of S4M campaigns only
    • Privacy policy and opt-out
  • Facebook (Measuring offline conversions)
    • Data concerned:
      • Smart Traffik shares with Facebook Ireland certain pseudonymised personal data from some of the data sources listed above (Audience, CRM data, data from its data partners), collected with your consent:
        • First name, Last name
        • Email
        • Telephone number
        • Mobile advertising identifier
      • Smart Traffik does not receive any personal data from Facebook in return, but counts the number of people exposed to Facebook campaigns, among the matches made on these data
      • Retention period: Facebook does not retain this data after the counting operation
      • Reach: measuring the estimated impact of Facebook campaigns on in-store visits, or even on in-store purchases
      • Facebook Privacy Policy (generic)
      • Conditions relating to the data matching service, in particular with regard to the non-preservation of data (Article 2)
  • Pinterest (Measuring offline conversions)
    • Data concerned:
      • Smart Traffik shares with Pinterest Europe Ltd. certain pseudonymised personal data from some of the data sources listed above (Audience, CRM data, data from its data partners), collected with your consent:
        • First name, Last name
        • Email
        • Telephone number
        • Mobile advertising identifier
      • Smart Traffik does not receive any personal data from Pinterest in return, but counts the number of exposures to Pinterest campaigns, among the matches made on this data
      • Retention period: Pinterest does not retain this data after the counting operation
      • Reach: measuring the estimated impact of Pinterest campaigns on in-store visits and even in-store purchases
      • Pinterest Privacy Policy (generic)
      • Conditions for advertising 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.

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 they have been 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 (SFBX, Facebook, mentioned above) may also have access to Smart Traffik data, strictly in the context of the use of this data to meet Smart Traffik’s performance measurement objectives. It should be noted that Facebook Ireland 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. Similarly, Pinterest Europe Ltd. will only transfer data from the EEA to a country that does not provide an adequate level of protection if adequate security measures are in place to protect your information, such as the standard contractual clauses (https://policy.pinterest.com/fr/privacy-policy#section-residents-of-the-eea).

How to exercise your rights

As oKube is a processing operation that relies on several subcontractors to which users are not systematically exposed and which have different practical procedures for exercising their rights, especially with regard to opposition, these measures are detailed for greater clarity within each subcontractor, so please refer to the previous section “oKube’s data sources and measures to protect your data“.

Note that regardless of the source of oKube data, you have the right to exercise the following rights:

  • Right of access: the right to request information about the processing we carry out and a copy of your processed data.
  • Right of rectification: you have the right to rectify, correct and update your data at any time.
  • Right of objection: you also have the right to object to the processing of your information through the right of objection.
  • Right to restrict processing: you may also ask us to restrict processing operations to the storage of your data under certain conditions, under the right to restrict processing.
  • Right to erasure: You may ask us to erase your data in certain cases.
  • Right to portability: you have the right to request the recovery of your data or its transfer to another provider.

We also inform you that we do not make any automated decisions, including profiling, using your data. Finally, we remind you that the vast majority of the data collected by Smart Traffik is ingested in an encrypted manner or protected by other means. We will therefore be obliged to ask you for clear data in order to be able to retrieve clear data and proceed with your request.

The exercise of these rights is free of charge and can be done at any time, subject to proof of identity, by writing to gdpr@smart-traffik.io.

Your data and transfers outside the EU/EEA

Smart Traffik does not at any time transfer data outside the EU/EEA area in the context of its current oKube solution. However, the service providers, partners 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 pseudonymisation and 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 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, the co-processors, and Smart Traffik acting as co-processor for its customers, and acting in accordance with the contractual terms and conditions set out in the defined co-processing 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

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

oKube latest news

Coming soon...

Interested by oKube capabilities ?

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