PRIVACY POLICY – ADVERTISING ACTIVITY
Adot places particular importance on the processing, confidentiality, and security of your personal data.
This Privacy Policy aims to inform you clearly, simply, and comprehensively about how Adot collects and processes your personal data in the course of its activities, about any potential transfers of such data to third parties, and about your rights and options to control your personal information and protect your privacy.
A.Mob (or "Adot"), a simplified joint-stock company registered with the Bobigny Trade and Companies Register under number 801111659, with its registered office at 164 Rue Ambroise Croizat, 93200 Saint-Denis, is the data controller of the personal data collected, in accordance with applicable data protection regulations, in particular French Law No. 78-17 of January 6, 1978, known as the “Informatique et Libertés” law, and Regulation (EU) 2016/679 of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and the free movement of such data (hereinafter “GDPR”).
If you have any questions about the processing of personal data by Adot, you can contact our Data Protection Officer at the following email address: dpo@we-are-adot.com
You may also contact us by post at the following address:
Data Protection Officer – ADOT
164 Rue Ambroise Croizat
93200 Saint-Denis
France
Adot reserves the right to modify this Privacy Policy at any time and without prior notice, particularly in response to changes in applicable legislation or in the services offered by Adot. We encourage you to consult this Policy regularly on Adot’s website to stay informed of any changes.
Overview of Adot’s Activity and Its Role
Adot’s primary activity is to enable advertisers to tailor their campaigns and/or offers to the audiences they want to reach, with the content they wish to promote across websites, mobile applications, and other platforms in order to display advertisements that may be of interest to their users (you).
In this context, Adot acts as a joint controller together with its partners.
The collection of personal data and your consent takes place on the digital interfaces of the partners and publishers over which Adot has no control. Under Adot’s contractual agreements, partners are required to inform you of data processing occurring on their websites and mobile applications. They are responsible for collecting your consent for the collection and use of your data, in order to deliver personalized advertising and allow you to easily opt out of such data processing. You can also refer to Article 10 of this policy for information on how to directly manage Adot cookies and advertising identifiers.
1 - What Personal Data Is Processed?
Personal data is defined as any information relating to an identified or identifiable person, either directly (e.g., via their first and last name) or indirectly, such as through an identifier (e.g., an ID number, location data, online identifier, or other specific identifiers).
Adot does not use any data that would allow for your direct identification, such as your full name, mailing address, or plain-text email address. Instead, it processes a limited amount of data related to your browsing activity (e.g., products you have viewed, items added to your shopping cart, or items purchased on a partner advertiser’s website or mobile application).
This data is linked to a unique identifier, which may take the form of a cookie or similar technology (e.g., mobile advertising identifiers, non-cookie-based technologies, etc.).
2 – Types of Data Collected
As part of its activities, Adot may collect certain personal data about you, as outlined below:
| Category |
Data |
Retention Period |
| Information about the devices you use |
- Type of device used (smartphone, tablet, computer, etc.)
- Operating system of your device (iOS, Android, Windows, BlackBerry, etc.)
- Information about your Internet service provider
- Browser used (Safari, Chrome, Internet Explorer, etc.)
- Advertising ID associated with your mobile device’s operating system
- IP address of your device
- Your language settings |
Up to 13 months from the date of collection |
| Information related to the advertisements displayed to you and, where applicable, previously displayed to you |
- URL and/or content of the website or mobile app you have browsed where the advertisement may have been or was displayed
- Details of the advertisement(s) shown to you (advertiser identity, type of ad, etc.)
- Your behavior in relation to the ad(s) (time spent on the ad, clicks, if any, etc.)
- Number of times you received the same ad from Adot |
Up to 13 months from the date of collection |
| Socio-demographic information inferred from your online activity |
- Age or age group, gender, presumed socio-professional category, presumed interests based on the pages viewed, products browsed, searches performed, etc. |
Up to 13 months from the date of collection |
| Information related to trackers |
- Technical identifiers assigned to you by Adot and/or its partners (cookie IDs)
These IDs, which may vary depending on your browser or mobile app environment, are standardized by Adot to improve the relevance of advertisements shown to you, regardless of the device used. |
Up to 13 months from the date of collection |
| Location information |
- These geolocation data are obtained from:
1. Geo-event data purchased from two partners: Singlespot and Azerion
2. Our partners via their publisher clients when you use their apps on your mobile devices (via SDKs)
Contact us at dpo@we-are-adot.com to request the full list of our partners. |
Up to 6 months from the date of collection, and 2 weeks for reporting purposes |
3 – Different Methods of Data Collection
To collect the data mentioned above, Adot uses several methods:
3.1 When you visit the website, mobile website, or mobile application of a partner publisher, the publisher sends a real-time ad request to dedicated marketplaces, indicating that advertising space is available and up for auction to display a personalized (or non-personalized) ad.
Adot then decides whether to purchase the ad space by bidding on the available inventory.
Upon receiving the ad requests, Adot collects the information contained within the request, which includes a variety of details related to the available ad space, the medium where it appears, and information about you and your device.
To provide you with ads that match your interests, Adot processes audience and segmentation data derived from information you’ve previously shared with trusted third-party partners. This includes data related to your shopping habits, locations of interest (based on geolocation data), or products purchased in a physical store using our online marketing services.
3.2 Adot also collects data using trackers (cookies, tags, pixels) placed on websites or mobile sites of its advertiser clients or partners, or via Adot’s own SDK or third-party SDKs (especially for geolocation data processing) integrated into the apps of clients or partners.
3.3 Adot collects data from its partners (such as vente-privee.com, for example) in cases where you have consented to the sharing of your data.
You may contact dpo@we-are-adot.com to request the full list of our partners.
4 – For What Purposes and on What Legal Grounds Are Your Personal Data Collected and Used?
Your data is processed in order to:
-
Display personalized or non-personalized (contextual) advertisements tailored to your interests on the websites and mobile web pages you visit, within the mobile applications you use, and on the social networks you access.
-
Measure the performance of advertising campaigns (including campaign reports).
-
Conduct aggregated statistical marketing studies (including traffic measurement).
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Train predictive models to improve advertising campaign performance.
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Create user segments (including audience pools).
-
Match sales and attributions to identify user conversions (e.g., purchases, app installations, etc.) in relation to campaign events.
-
Troubleshoot incidents.
To deliver the most relevant ads, Adot performs profiling processes to establish user profiles that help us better understand your interests and provide more relevant advertising content.
Your geolocation data also helps to determine your preferences based on your location, such as identifying the nearest point of sale for a product or service or displaying ads relevant to places you’ve visited.
5 – Legal Basis for Data Processing
To collect and process your personal data as described above, Adot relies on your consent. Your personal data is only collected and processed for the purposes specified above when you have actively consented to the processing.
Since Adot does not have direct contact with individuals whose personal data is processed, it is the responsibility of Adot’s partners—whether they are publishers, data providers, or SSPs (Supply Side Platforms, which are entities responsible for selling ad space on websites or apps via real-time bidding, also known as RTB)—to collect your consent. To this end, Adot contractually requires its partners to collect your consent prior to any data collection and to be able to provide proof of that consent.
Furthermore, Adot is registered as a vendor within the IAB Europe Transparency and Consent Framework and is able to receive and interpret IAB consent strings sent by its partners in order to honor your consent choices. When you visit a website (desktop or mobile) or a mobile application, you are asked to set your preferences for the use of cookies and other trackers. The consent collection tool may be a Consent Management Platform (CMP) registered under the IAB framework. When you make your choices, a consent string is generated and shared with all participants in the advertising supply chain to confirm whether consent has been given for each specified purpose.
You may withdraw your consent at any time by returning to the consent collection tool where you initially made your choices or by emailing us at the following address: policy@we-are-adot.com.
6 – Who Are the Recipients of Your Personal Data?
6.1 Internal Recipients
The data we collect about you is only accessible internally to certain authorized members of our technical teams. Staff handling your personal data are subject to a strict confidentiality obligation and have been made aware of the importance of protecting your data. Only employees who need to access your data as part of their job responsibilities may do so.
6.2 Subcontractors
As part of our business operations, we use a hosting service provider that may have access to your personal data.
6.3 Partners
We may also share your personal data with:
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Business partners, including so-called “trusted third parties.” Some of our clients require that the effectiveness of the advertising campaigns displayed by Adot be verified by these third parties. These entities measure the impact of campaigns on traffic to our clients’ points of sale. To do this, we may share your data solely for the purpose of measuring campaign performance.
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Third-party partners tasked with verifying that the audience reached by our advertising campaigns matches the originally targeted audience. These partners may embed pixels in Adot’s ads to conduct this verification on behalf of our clients.
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Partners or clients (agencies or advertisers) who use Adot’s advertising services.
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Partners in the advertising ecosystem, publishers of solutions and/or platforms enabling the distribution of campaigns on social media platforms, to display personalized ads matching your interests — without the ability to directly identify you.
-
Third parties to comply with legal, regulatory, or contractual obligations, or to respond to requests from legally authorized authorities.
When Adot and third parties are joint data controllers, they agree to:
-
Ensure an adequate level of security and confidentiality for the shared processing and data at all times;
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Cooperate in carrying out Data Protection Impact Assessments or in consulting with supervisory authorities when required;
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Inform each other in writing, without delay, of any personal data breaches involving shared data that come to their attention.
6.4 Vente-Privée.com
This section is intended only for members of the Vente-Privée.com website.
6.4.1
On Vente-Privée.com, you may consent to the platform providing Adot with:
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Your identifiers (non-directly identifying data);
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Information about your devices;
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Your sociodemographic information;
-
Your browsing history;
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Your purchase history;
-
Your communication preferences.
6.4.2
When you agree to Adot placing a tracker on your device via the cookie banner, this is an identifying tracker.
Accepting both of these actions (data sharing and tracker placement) is necessary for Adot to combine this information with its own database and those of its partners in order to:
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Show you personalized ads tailored to your tastes and interests on websites and mobile sites, in mobile apps, on social networks, and on digital screens including connected TVs;
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Measure ad campaign performance;
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Conduct statistical marketing studies;
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Improve services (e.g., by training predictive models).
6.4.3
You may also consent to having your identifiers and usage data (browsing activity and order history) on Veepee matched and combined with other data in Adot’s or its partners’ databases. This allows for the display of promotional offers and relevant ads in the Veepee ecosystem, and the performance of traffic and usage analyses.
6.4.4
You may also allow Vente-Privée.com to share your geolocation data, which will be used for the purposes listed above.
In this context, Vente-Privée.com and Adot are joint data controllers and agree to:
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Ensure adequate security and confidentiality of shared data at all times;
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Cooperate to carry out data protection impact assessments or consult supervisory authorities when required;
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Not transfer your data outside the European Union;
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Inform each other in writing, without delay, of any personal data breaches involving shared processing. Both parties will promptly consult to determine whether the breach needs to be reported to a supervisory authority or to affected individuals.
Vente-Privée.com is responsible for notifying the appropriate supervisory authority and/or affected individuals, if necessary, in accordance with applicable data protection regulations.
You may withdraw your consent at any time on Vente-Privée.com:
-
In your account settings, for data sharing and geolocation;
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In your tracker settings, for the Adot tracker or advertising within the Veepee ecosystem;
-
Or by contacting:
You may also contact each entity directly to exercise your rights.
Each entity will notify the other to ensure your request is taken into account.
For more information, you can consult Vente-Privée.com’s privacy policy.
7 – Data Transfers Outside the European Union
Adot does not transfer your personal data outside the European Union.
However, if Adot’s relationship with its partners or data recipients involves international transfers, such transfers will be made using appropriate safeguards (contractual, technical, and organizational) in compliance with applicable data protection laws.
8 – Your Rights Regarding Your Personal Data
In accordance with applicable regulations, you have the following rights regarding your personal data:
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Right of access;
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Right to rectification;
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Right to erasure;
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Right to data portability;
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Right to object;
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Right to restrict processing;
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Right to define instructions regarding the handling of your data after your death (e.g., retention, deletion, or transfer to a designated third party).
You also have the right to lodge a complaint with a supervisory authority. In France, this is the Commission Nationale de l’Informatique et des Libertés (CNIL).
Parents or legal guardians of minors or persons under legal protection may also exercise these rights.
To exercise your rights, please contact Adot:
Since Adot processes only indirectly identifiable data, you must provide your identifier(s). There are two types depending on your device:
How to retrieve your identifier(s):
Where applicable, and in accordance with Adot’s contractual obligations, your request will be forwarded to relevant third parties. Adot will inform you of such transfers and provide any necessary information regarding your request.
9 – Data Security
Adot places the highest importance on the security of your personal data and implements appropriate technical and organizational measures to ensure its confidentiality and integrity.
When using subcontractors, Adot ensures that they apply equivalent levels of data protection. Only providers offering adequate guarantees regarding data protection are selected.
10 – Managing Cookies and Advertising Identifiers
10.1 Cookie Management
A cookie is a small file placed on your device (computer, smartphone, tablet, etc.) via your browser when visiting websites operated by Adot or its partners.
Adot uses advertising cookies with your consent to assign and detect your Adot-generated ID, collect relevant data, and, where applicable, determine if you have been previously identified by Adot’s clients or partners.
Cookies that are not strictly necessary require your prior consent. You may choose to reject cookies via your browser.
Browser settings for managing cookies:
10.2 Advertising ID Management
The advertising ID is a unique identifier on each mobile device used for ad personalization.
You can reset or disable this ID as follows: