Privacy Policy<p>
<em>Last update: 19/11/2020</em>
</p>
<p>Opti Digital offers technology solutions and consulting to publishers to help them monetize their digital media. </p>
<p>Amongst the solutions offered by Opti Digital is an advertising marketplace that proposes smart advertising services to publishers and advertisers.
This service gathers advertising demand including demand from other advertising buyer partners (hereafter referred to as “Opti Digital Ad Marketplace” or “our services” .
or “the services” in this document). </p>
<p>Advertisers or their intermediaries (e.g.
media agencies) display their advertising campaigns through Opti Digital advertising solutions on the websites of our publishers.</p>
<p>Opti Digital advertising technology collects and uses data to help make online advertising more relevant as well as for ad delivery and reporting purposes.</p>Introduction<p>Opti Digital SAS (hereafter referred to as “Opti Digital” or “We”, “Us”) recognizes the importance of privacy and is committed to providing transparency and control over the use of the data in online advertising. </p>
<p>Opti Digital has taken all necessary steps to comply with the provisions of the Regulation (EU) 2016/679 of the European Parliament and of the Council dated April 27, 2016 and applicable as of May 25, 2018 (the “GDPR”).
Opti Digital, when applicable, also adheres to the fullest extent to the IAB Europe’s GDPR Transparency &.
Consent Framework 2.0.</p>
<p>Opti Digital is a French company and falls within the competence of the French Privacy Authority, the Commission Nationale Informatique et Libertés (CNIL).</p>General scope of this Privacy policy <p>This privacy policy details Opti Digital’ data practices on how we collect, use, process and share the data we may collect through our advertising service “Opti Digital Ad Marketplace” as well as the ways in which individuals may exercise control over the use of information collected by us. </p>
<p>This privacy policy does not describe Opti Digital’ data practices relating to information Opti Digital collects through its website www.optidigital.com, and only applies to Opti Digital Ad Marketplace. </p>
<p>Your use of the services is also governed by the Collaboration Agreement between Opti Digital and our Publishers.</p>
<p>As used herein, “personal data” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Opti Digital customer or consumer or their household.</p>
<p>This privacy policy may be updated. .
If we make any material changes we will notify you by means of a notice on our website prior to the change becoming effective.</p>1.
User data<p>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 or (iii) sensitive targeting categories as defined by the European Interactive Digital Advertising Alliance (EDAA) in the European Economic Area (EEA) and under other applicable law (e.g.
religion, political opinion, health).</p>
<p>In order to deliver personalized ads as well as non-personalized ads, we use the following 3 methods to identify users depending on the device they use, whether they access our services on desktop or mobile, and depending on your operating system:</p>1.1.
Cookie-based identification<p>Opti Digital drops a cookie on the user web and/or mobile browser.
Cookies are alphanumeric identifiers that are created on your device through your web browser for record-keeping purposes.
Cookies are used to identify a user and store a randomly generated identifier to identify their browser across visits.
You may find the list of cookies dropped by Opti Digital here.</p>1.2.
Cookie-less environments<p>For users denying to give their consent to store and access a cookie on their device or in browsers setup which do not allow cookies to be dropped, Opti Digital uses an identification methodology based on IP address non-reversible encryption, browser, and device characteristics.
This method allows Us to identify a user in order to provide a quality level of service, such as reporting, contextual targeting and capping of the number of times the same ad is shown to the same user.</p>
<p>You can opt-out of the use of these technologies as described in Section 8.</p>2.
Data collected<p>We do not collect information about you directly, but we collect data through our web tags on publisher web pages.
We also automatically collect the information listed below about your use of Opti Digital Ad Marketplace through tracking technologies such as cookies, pixel tags, and embedded scripts.
These tools help us collect and measure session information, time spent on page, and page interaction information.</p>Automatically collected data<ul>
<li>
<strong>Identifiers: </strong>IP address</li>
<li>
<strong>Internet or other electronic network activity information:</strong>
<ul>
<li>Page URL</li>
<li>Browser Information (e.g.
Browser name and version)</li>
<li>Device Information (e.g.
Device type, OS)</li>
<li>Network carrier information (e.g.
Wifi, 4G or Wired connection)</li>
<li>User Interactions with ads displayed by Opti Digital Ad Marketplace</li>
</ul>
</li>
<li>
<strong>Geological Information:</strong>
<ul>
<li>Non-Precise Geolocation data: On desktop and mobile web, we collect non-precise location information at the country and/or city level that are derived from user IP Address.</li>
</ul>
</li>
</ul>List of cookies used by Opti Digital3.
Data use<p>We use the information collected for several purposes, including those described below: </p>
<ul>
<li>
<strong>Targeted advertising:</strong> We use the data to filter ad delivery according to the user profile, such as user interests, location, device used or page content;</li>
<li>
<strong>User frequency capping:</strong> We use data to prevent displaying the same ad to the same user too many times;</li>
<li>
<strong>Traffic and user interactions analisis: </strong>We use data to monitor and report the campaign delivery to advertisers and publishers and for internal business analysis;</li>
<li>
<strong>Ads delivery: </strong> We may communicate part of the user profile to programmatic buyers so that they can deliver their advertising campaigns;</li>
<li>
<strong>Solutions maintenance and improvement: </strong>We use data to improve our Service.</li>
<li>
<strong>Customer service:</strong> We may use data to resolve disputes or other issues related to Opti Digital Ad Marketplace to publishers and advertisers;</li>
<li>
<strong>Troubleshooting, debugging, error identification:</strong> We may use data to fix issues that affect the functionality and performance of our Service;</li>
<li>
<strong>Opti Digital rights and property protection and complying with law:</strong> We may use data to protect our rights and property and comply with our legal obligations, including to detect, investigate, and prevent fraud and other illegal activities and to enforce our agreements;</li>
<li>
<strong>Insights analysis:</strong> We may use the data to deliver aggregated insights, at advertising campaign level to advertisers and publishers or market levels.</li>
</ul>4.
Data disclosure 4.1.
Data communicated to Third Parties<p>In order to provide Opti Digital Ad Marketplace, we need to share data (including personal information) with third party vendors, bidders, service providers, contractors or agents who perform functions on our behalf, including the ones listed below.
Our service providers are authorized to use the information we provide only as necessary to provide these services to us.</p>
<ul>
<li>
<strong>Programmatic Buyers: </strong>We may send part of the user profile to programmatic buyers using demand side platforms such as Google Display &.
Video 360, who buy our ad placements through programmatic ad auctions.
Those companies are responsible as independent controllers of the data used to deliver their ads on Opti Digital’ network.</li>
<li>
<strong>Affiliates</strong>.
We may disclose the information we collect through our services to our affiliates or publishers for the purposes described in this privacy policy.
however, if we do so, their use and disclosure of your personal information will be subject to this privacy policy.</li>
<li>
<strong>Hosting partners</strong>.
We utilize third party hosting and data-center providers such as Google Cloud Platform to store data.</li>
</ul>Cookies deposit by Sirdata<p>Sirdata is a data marketing company that allows its Customers to send relevant and tailored offers based on Users’ interests.
The Data collected by Sirdata is kept for a maximum period of 365 days, depending on the processing, in accordance with applicable laws and the minimization principle.</p>
<p>
<strong>Find out more:</strong> https://www.sirdata.com/privacy/</p>
<p>
<strong>Disable your data collection by Sirdata:</strong> https://www.sirdata.com/object/</p>4.2.
Other Disclosures<p>We also may disclose information in the following circumstances.</p>
<ul>
<li>
<strong>Business Transfer.
</strong>If we are or may be acquired by or merged with another company, if any of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.</li>
<li>
<strong>In Response to Legal Process.
</strong>We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal processes, such as in response to a court order or a subpoena.</li>
<li>
<strong>To Protect Us and Others.
</strong>We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Collaboration Agreement with publishers or this Policy, or as evidence in litigation in which Opti Digital is involved.</li>
<li>
<strong>Aggregated and De-Identified Information.</strong> We may share aggregated or de-identified information about users with third parties for marketing, advertising, research or similar purposes.</li>
</ul>5.
Additional clauses for users located in Europe <p>If you are located in the European Economic Area or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data.</p>5.1.
Legal Basis for Processing<p>We will process your personal data in the following situations:</p>
<p>Opti Digital’s legal basis for processing your personal data depends upon the specific context in which we collect or use it.
We normally rely on our legitimate interests to collect and use personal data, except where our interests are overridden by your data-protection interests or your fundamental rights and freedoms.
Our legitimate interests are described in greater detail in the section 3 of this policy.
These legitimate interests include the operation of our Opti Digital Ad Marketplace and business and the provision of our online advertising technology services to our clients as required by our agreements with them.
In some cases, we may rely on your consent which is obtained for us by the operator of the Digital Properties that use our technology or use technology that interacts with our Opti Digital Ad Marketplace.
If we rely on consent to process your data, we will obtain such consent in compliance with applicable laws.
Additionally, we may have a legal obligation to process personal data.</p>5.2.
Data Subject Requests<p>You have the right to access personal data we hold about you and to ask that your personal data be corrected, deleted or transferred. .
You may also have the right to object to, or request that we restrict, certain processing.
If you would like to exercise any of these rights, you may contact us as indicated below.</p>6.
Data retention and security <p>We retain the data linked to a user up to 12 months from the date of collection.</p>
<p>We may also store aggregated and non-personal data for a longer period than 12 months for financial and statistical reasons.</p>
<p>Opti Digital cookie is kept up to 365 days after the last user interaction with our services.</p>
<p>Opti Digital uses generally accepted industry security standards to protect data.</p>
<p>Your personal information will be retained in accordance with our data retention policy which is designed to retain data for as long as needed for us to comply with our contractual obligations, employment obligations, and other business purposes, including global legal obligations to retain data.
We may retain some information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyse or troubleshoot programs, enforce our Collaboration Agreement with our publishers, or take other actions permitted by law. </p>
<p>We have implemented reasonable security measures to protect the information we collect from unauthorized access, exfiltration, theft, loss, misuse, disclosure, alteration, or destruction.
Please be aware that despite our best efforts, no data security measures can guarantee security.</p>
<p>You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private.
We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.</p>7.
Privacy policies of third-party partners<p>This privacy policy only addresses the use and disclosure of information and data by Opti Digital.
Publishers, advertisers and other websites that may be accessible through our services and have their own privacy policies and practices that govern the collection, use, and disclosure of your personal information when you interact with their services and use their products.
We encourage you to familiarize yourself with the privacy policies provided by all third parties prior to giving them information or taking advantage of an offer or promotion.</p>8.
Opt-out from personalised advertising <p>If you do not want us to show you personalized ads (based on your inferred interests) please follow the below instructions:</p>
<strong>To opt-out from your web browser in any devices</strong>
<p>If you opt-out, you will still see ads, including contextually tailored ads (i.e., ads tailored to the current website or app you are viewing) and ads based on your current location.
they just may not be relevant to your interests.</p>
<p>The opt-out mechanism will only opt you out of personalized advertising delivered by Opti Digital in this browser or in mobile applications on this device (e.g., phones, tablets).
It will not opt you out on other devices or in other browsers you use.</p>
<p>Most web browsers are set to accept cookies by default. .
If you prefer, you can usually choose to set your browser to remove or reject browser cookies.
Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our services.
Opt-out information is stored in a cookie for 5 years.
If you delete your cookies, this information will also be deleted, and you will need to renew your opt-out choices.</p>
<p>For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.youronlinechoices.com, www.aboutads.info/choices, and other similar sites. </p>9.
Opti Digital self regulation commitments <p>Opti Digital is committed to initiatives that intend to provide greater transparency and control for users and as such adheres to the following self-regulation initiatives:</p>
<p>Opti Digital belongs to the IAB Europe as a Global Vendor.
The IAB Europe offers consumers an online web opt-out platform and provides general information to consumers about privacy tools.</p>
<p>Opti Digital is also a member of the IAB Transparency and Consent Framework that allows the users to express their choice and inform the advertising supply chain operators about the user choice. </p>10.
Contact Opti Digital<p>Opti Digital has appointed a data protection officer (DPO) in accordance with Article 37 of the European Data Protection Regulation and can be contacted if needed under the following contact details: Email: dpo@optidigital.com or by post mail: Opti Digital, Vall’Up, 3 rue des Cortalets, 66400 Céret, France</p>