ADWAYS PRIVACY POLICY

Adways is an advertising marketplace that proposes innovative advertising solutions to website and/or content publishers (the “Publishers”), as well as advertisers and/or their intermediaries such as media agencies (the “Advertisers”) all over Europe, USA, Latin America and Asia.

Publishers use Adways advertising solutions to monetize their ad spaces either directly or through Adways advertising demand including other advertising buyer partners.

Advertisers or their intermediaries (eg. media agencies) display their advertising campaigns through Adways advertising solutions on the websites or apps of our publisher partners.

Adways advertising technology collects and uses data to help make online advertising more relevant as well as for ad delivery and reporting purposes. Our ads are placed contextually as an overlay or around video editorial contents to be more relevant for you than standard advertising you would receive otherwise.

In the context of the implementation of our advertising solutions, the data we collect may include some of your personal date, the process of which is detailed herein.

 

Scope of this privacy policy

Adways SAS, together with its affiliates (“Adways”, “we”, “us”, or “our”) recognizes the importance of privacy and is committed to providing transparency and control over the use of the data in online advertising.

We collect and process your personal data in compliance with the French law N° 78-17 dated 6th January 1978 on Information Technology, Data Files and Civil Liberties (the “French Data Protection Act”), as well as the regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR”).
 

Adways is a member of IAB Europe’s Transparency and Consent Framework. This protocol enables us to respect your choices and provide you with quality information.

 

This privacy policy details Adways data practices on how we collect, use, process and share the data we may collect through our advertising services as well as the ways in which individuals may exercise control over the use of information collected by us.

 

1. User identification Adways does not collect or process any information that allows identifying a particular individual directly.

We do not collect or process information related to (i) name, user address, place of work, date of birth, email address, or phone number (ii) hardware-based identifiers such as UDID or MAC Address and (iii) sensitive information (such as religion, political opinion, health…).

We do not create segments to specifically target children under 16 years old.

Cookie-based identification

In order to deliver personalized ads as well as non-personalized ads, Adways uses the Cookie-based identification method to single out users.

To this end, Adways drops a cookie on the user web and/or mobile browser. Cookies are used to single out a user and store a randomly generated identifier to identify his browser across visits.

 

2. Information we collect

We collect data through our web tags on publisher web pages.

Collected data are:

Page URL

Browser Information (eg: Browser name and version)

Device Information (eg: Device type, OS)

User Interactions with Adways Ad (eg: clicks or video views)

IP address

Country Location Information

 

3. Data use

We use the information we collect for the following requirements:

User frequency Capping: We use data to prevent displaying too many times the same ad to the same user.

Analytics: We use collected data for monitoring and reporting the campaign delivery for Advertisers and Publishers and for internal business analysis.

Delivery Algorithm training: We use collected data in order to improve our service and technology.

Such requirements arise from our agreements concluded with Advisers and Publishers, under which the same ads must not be displayed to the same users and are subject to statistical reporting. We therefore use the data we collect on the legal basis of our legitimate interest resulting from the fulfillment of our contract obligations.

 

4. Recipients of the data we collect

The persons who have the right to access to your data are our personnel, the services in charge of control (including external auditors) and our subcontractors, including companies specialized in campaign measurement such as MOAT or IAS in order to verify that our ads are viewable.

In addition, we may give access to your data to government agencies, for the sole purposes of meeting legal requirements, or to representatives of the law, ministerial officers and/or organizations in charge of debt collection.

 

5. Data collection and processing by our partners

Your personal data will not be exchanged with, transferred or rented to any third party.

In particular, our partners, including those acting as “Programmatic Buyers” that use Demand Side Platforms for purposes of purchasing our ad placements through programmatic auctions ad, directly collect your data and are solely responsible, as data controllers, of their processing in order to deliver their ads on Adways network.

If you do not want us to use your IP to count the number of times you have seen the same ad, please follow the instructions below.

 

To opt-out from your web browser

If you opt-out, you will still see ads, but not capped; we will not be able to control the frequency of occurrence of a given ad.

The opt-out mechanism will only opt you out of the capping on this browser or mobile applications on this device (e.g., phones, tablets). It will not opt you out on other devices or in other browsers you use.

You can opt-out from Adways partners personalized advertising by clicking here

You can as well refer to their policy

Name

Purpose

Policy link

Criteo

Advertising sourcing

https://www.criteo.com/privacy/

Outbrain

Advertising sourcing

https://www.outbrain.com/legal/privacy#privacy-policy

Adux

Advertising sourcing

http://www.adux.com/en/privacy/

triplelift

Advertising sourcing

https://triplelift.com/privacy/

Antvoice

Advertising sourcing

https://www.antvoice.com/en/privacypolicy/

Xandr

Adserver/ SSP

https://www.appnexus.com/fr/platform-privacy-policy

 

6. Data retention and storage

We retain the data linked to a user, as well as the cookie set forth in section “Cookie-based identification”, up to 12 (twelve) months from the date of collection. We may also store aggregated and non-personal data for a longer period than 12 (twelve) months for financial and statistical reasons.

 

7. Security measures

We take all necessary precautions, as well as all appropriate organizational and technical measures, to maintain the security, the integrity and the confidentiality of your data, including to prevent that they should be distorted or damaged and that any unauthorized third-party should access to them.

To this end, Adways uses generally accepted industry security standards to protect data

 

8. Hosting

Data are stored for the term of storage set forth above, on the servers of the company Amazon Web Service (AWS), which are located in the European Union.

They shall not be transferred outside the European Union.

 

9. Exercising your rights

In compliance with the French Data Protection Act and the GDPR, you have the following rights:

(i) you have the right to access, rectify and delete any of your data;

(ii) you have the right to request restriction of the processing of your data when one of the following applies:

Within the period of verification that we carry out, if you contest the accuracy of your personal data;

When the processing of these data is unlawful et you request the restriction of this processing, instead of erasing your data;

When we no longer need your personal data, but you require their maintenance for the exercise of legal claims;

Within the period of verification of the legitimate interests, if you have objected to the processing of your personal data.

(iii) you have the right to object to the processing of your data.

We may however carry on with this processing if there are legitimate reasons for it that should prevail over your rights and freedoms or if it is required in order to establish, exercise or defend our rights before courts.

(iv) you have the right to submit a complaint before the CNIL (French Data Protection Authority) or any other supervisory authority competent in your place of ordinary residence, your place of work or the place in which your rights were infringed, if you consider that the data processing under this Privacy Policy is a violation of the applicable regulations.

You may exercise these rights by sending us a request through the addresses indicated in section “Contact Us”.

 

10. Miscellaneous

 

Changes to our privacy policy

Please note that we may update or change this privacy policy. If we revise our privacy policy, we will post those changes to this privacy statement, and to other places we deem appropriate, so that you are aware of what information we collect, how we use it, and under what circumstances, if any we disclose it. If we make any material changes we will notify you by means of a notice on this site prior to the change becoming effective.

 

Adways Self Regulation commitments

Adways is committed to initiatives that intend to provide greater transparency and control for users and as such adheres to the following the IAB France. 

 

Legitimate interest (measurement)

Adways relies on the legal basis of legitimate interest for purposes relating to measuring the performance of advertising campaigns and site content.

For Adways, this legitimate interest is justified by the need to provide a quality service to its customers. Indeed, Adways must be able to process the data collected in order to compile accurate statistics on its customers’ advertising campaigns.

 

The processing of personal data enables us to provide advertisers, agencies and publishers with aggregated campaign statistics and, in some cases, individual data enabling these statistics to be calculated.

 

Adways ensures that safeguards are in place to ensure that users’ fundamental rights are not violated: 

 

– Adways only processes pseudonymous, indirectly identifying data.

– Adways does not process data that could be used to deduce sensitive information about individuals, nor discriminate against them in any way whatsoever.

– Adways implements the technical and organizational measures required to preserve the confidentiality and security of the personal data processed

– Adways has put in place the necessary procedures to enable individuals to exercise their rights and thus to object to the processing carried out by Adways, access them, delete them, etc.

– Adways informs you transparently about the data processing carried out.

 

Contact Us

Upon request, Adways will provide you with information about whether we hold any of your personal information. You may exercise your rights provided in section “Exercising your rights” by contacting us as described below. We will respond to your request within a reasonable timeframe.For any questions about this Privacy Policy or our data practices, you can contact Adways:

By email: dpo@adways.com

By mail: Legal Department (DPO) -Adways – 36-40 rue Raspail – 92300 Levallois-Perret – France