Last updated January 2021
VECTAURY is a company specialised in digital marketing on mobile phones more specifically in the area of drive-to-store advertising and advertising adapted to the geographical position of smartphone users (hereinafter the "Users"). VECTAURY also offers its clients marketing studies to help them make decisions, for example concerning the opening of new points of sale or to better position themselves in relation to competing points of sale. VECTAURY also offers its clients the possibility of measuring the impact of their mobile or OOH/DOOH advertising campaigns on traffic in their points of sale, whether these campaigns were displayed by VECTAURY or a third party.
The data controller is VECTAURY, a simplified joint-stock company with a shared capital of €250,000, registered with the Paris Trade and Companies Register under number 799 256 730, whose registered office is located at 42 rue de Maubeuge 75009 Paris, France
In accordance with the requirements of Article 37 of Regulation
(EU)
2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of
individuals
with regard to the processing of personal data and on the free movement of such data and
repealing
Directive 95/46/EC (hereinafter "the GDPR"), VECTAURY has appointed a Data Protection
Officer (hereinafter
"DPO").
You may contact our DPO if you have any question regarding the processing of personal
data implemented by VECTAURY and request the exercise of your rights set out in Article 8
of this Privacy Policy by writing to the following address:
In order to implement the purposes of processing (i.e. the activities carried out by VECTAURY and, more specifically, the purposes for which the personal data collected is processed) described below, VECTAURY collects data via two means of collection :
The personal data collected via these two mechanisms are as follows:
| Data collected | Data retention period |
|---|---|
| Advertising ID of the user's smartphone | Immediately deleted (in less than a second) after transformation into an internal identifier which is kept for 12 months |
| Data about the user's smartphone from which data is collected: brand, phone model, version, phone language, OS type, OS version, truncated IP address. | 12 months from collection |
| Advertising execution context data: Application identifier, application name and type, application IAB category, application version, timestamp. | 12 months from collection |
| On the “mini site” to which the user is redirected when he clicks on an advertisement displayed by VECTAURY: page views, various actions, timestamps, etc. | 12 months from collection |
| Geolocation data: GPS position immediately transformed into a 600m² surface area. | The GPS positionss are immediately deleted (in less than a second) and the surfaces are kept for 12 months from the date of their collection |
VECTAURY collects the personal data set out above for the purpose of displaying
advertisements adapted to the User's geographical position within the mobile applications
opened by him.
In order to be able to display advertisements adapted to the interests of these Users,
VECTAURY carries out profiling processing in order to deduce information relating to the
centres of interest of Users, but also socio-demographic data such as their gender, age
group, living and working locations
This profiling processing is a necessary prerequisite for VECTAURY to implement its
purpose of carrying out marketing studies. Although the report provided to its customers
only
contains aggregate statistical data, VECTAURY must have the information mentioned above
in order to provide its customers with studies to enable them to better understand the
profile
of their visitors at points of sale and to have access to relevant geomarketing
information.
At last VECTAURY collects data via its SDK and the advertising space purchasing system
via real-time auctions in order to offer its customers the performance measurement of
advertising campaigns displayed by VECTAURY or third parties.
In order to carry out processing operations for the purposes of
profiling,
displayof targeted advertising adapted to the location of Users and their centres of
interest, carrying
out marketing studies and measuring the effectiveness of media campaigns, VECTAURY uses
the legal basis of the User's Consent.
In order to collect the consent of Users, VECTAURY ensures that its partner publishers
integrating its SDK validly collect the consent of Users thanks to a Consent Management
Platform registered within the transparency and consent framework of the IAB (the
Interactive Advertising Bureau). Publishers integrating the VECTAURY SDK contractually
guarantee that they have validly informed Users and collected compliant consent.
To do so, they can integrate the VECTAURY CMP or a third party CMP once VECTAURY has
audited and considered this CMP compliant thanks to an audit grid validated by the CNIL
(the french data protection authority).
The CMP is a consent management tool that enables VECTAURY to collect the consent of
Users so that VECTAURY can implement its activities legally and collect free, specific and
informed consent. VECTAURY has decided to use only CMPs referenced within the
Transparency and Consent Framework of the IAB Europe, which it has previously audited
and whose compliance has been validated, to collect Users' consent.
The CMP allows application vendors to collect user consent in a fair manner. Thanks to this
CMP, the user is informed, as soon as the application is opened, of the personal data
collected, the purposes of processing and can also access the partners receiving his data as
well as their purposes of processing and their privacy policy. The CMP allows users to
consent or not to consent to the collection of their personal data for each of the stated
purposes. They can, from the first page, configure their choice by purpose or accept or
refuse all the purposes
In order to collect valid consent from users when VECTAURY collects data through the
purchase of advertising space via the Real time bidding system, VECTAURY ensures that
the CMPs through which users have given their consent genuinely allow valid consent to be
collected. To this end, VECTAURY has implemented a process enabling it to audit the CMPs
used and to collect data only from those considered to be legally compliant. VECTAURY
detects the IAB ID number of the CMP on which the user has made his or her consent
choices, which then enables it to retrieve and audit it using the audit grid mentioned
above.
The Consent strings associated with the data collected in the advertising requests allow
VECTAURY to respect the consent of the users.
VECTAURY respects the requirement of consent traceability by storing the consent strings
generated when the user sets his choices on the CMP.
On our website, you can contact our team by clicking on the
"contact us"
tab. You will then be directed to a contact form asking you to fill in the following
information: your
name, first
name, email address, company for which you work and optionally your telephone numbers
and quality.
This data is only used to respond to your request, and/or to contact you about our products
and services and is kept for 1 year from receipt. You may at any time request their deletion
or access to these data by exercising your rights as explained in Article 8 hereof.
Apart from the data provided in the contact form, VECTAURY may collect data via cookies
placed on the www.vectaury.io website. A cookie is a tracer deposited or read on the user's
terminal (e.g. a computer or smartphone), for example when consulting a website, reading
an e-mail or installing or using a software or mobile application.
If you accept the placing or reading of cookies on our website, we may collect certain
personal data via so-called "first party cookies", i.e. cookies placed and read by our
website.
Some third party cookies may also be deposited and read by servers of a domain name
distinct from our website and collect data.
The data collected via first party cookies are intended for internal use only. The cookies
for
which your consent is requested are those listed in the table below:
| Cookie name | why we use the cookie | link to privacy policy | cookie lifetime |
| Cookie first party | |||
| Google Analytics _ga _git |
Cookie dedicated to the analysis of the navigation, the audience and the uses of the website by the users | https://privacy.google.com/businesses/adsservices/ | 12 months from the deposit of the cookie |
| Cookie Third party | |||
| Youtube | it is a cookie deposited by Youtube's servers that makes it possible to play the videos published on our website | https://policies.google.com/privacy?hl=fr&gl=fr | see in their privacy policy |
Other cookies are deposited and read on our website to allow its proper functioning, these are the following cookies:
| Cookie name | why we use the cookie | link to privacy policy | cookie lifetime |
| Cookie first party | |||
| Cookie Bar | Cookie to save your cookie consent choices | https://cookie-bar.eu/privacy/ | 12 months from the deposit of the cookie |
| Cookie third party | |||
| CloudFlare | it is a cookie deposited by the Cloud Flare servers allowing the proper functioning of our website: it ensures the functioning of the sliders, for example | https://www.cloudflare.com/fr-fr/cookie-policy/ | See in their privacy policy |
The categories of data collected by the cookies deposited or read on the VECTAURY website are connection data such as identifiers, logs, data relating to pages viewed, country of the device, language of the device, ...
First party Cookies are also deposited on the Vectaury Solution platform through which we are likely to collect your data, these are the following cookies:
| Cookie name | why we use the cookie | link to privacy policy | cookie lifetime |
| Session Cookie | User authentication cookie used for the operation of the tool. If it is not accepted, the user will not be able to connect and use our services. This cookie is installed once the user connects to his account. | Cf. Vectaury's privacy policy | The authentication system expires after 12 hours of inactivity. |
| Google Analytics Cookie | tool installed on our platform dedicated to the analysis of navigation, audience and user usage. | https://privacy.google.com/businesses/adsservices | 12 months from the deposit of the cookie |
| Cookie Crisp | Tool installed on our platform dedicated to customer relations and user support | https://crisp.chat/fr/privacy/ | 12 months from the deposit of the cookie |
| Axeptio | Сookie used to save the platform users' choices regarding consent to cookies | https://www.axeptio.eu/en/legal-mentions | 6 months from the deposit of the cookie |
The categories of data collected by the cookies deposited or read on the platform are in particular a session identifier for the Session Cookie and the Cookie Crisp and then connection data for the other cookies such as identifiers, logs, data relating to pages viewed, country of the device, language of the device, etc.
(i) Internal Recipients
The personal Data collected through our SDK and through the system of purchasing
advertising space in real time on mobile applications is accessible internally by certain
authorised employees of our technical team, who are subject to an obligation of
confidentiality. Only employees who need access to this data for their professional activity
are entitled to access this data
(ii) External recipients
a- Data processor
For the needs of our activity, we use a data processor with whom we have verified that it
offers sufficient guarantees regarding the implementation of appropriate technical and
organisational measures so that the processing meets the requirements of the Regulation on
the protection of personal data (Law No. 78-17 of 6 January 1978, known as the Data
Protection Act and the EU Regulation (EU) No. 679/2016 General Data Protection of 27 April
2016) and guarantees the protection of your rights. Access by our data processor to your
personal data is based on contracts concluded with VECTAURY that mention the obligations
of the data processor in terms of data protection, security and confidentiality of personal
data. Our data processor whose identity is indicated below, is also prohibited from using
your personal
data for purposes other
than those specified by us and from transmitting your data to any third party.
Hosting provider : OVH SAS, company of french law, domiciled at 2 rue Kellermann 59100
Roubaix, et
inscrite au RCS de Lille Métropole au numéro B424 761 419.
b- Partners
Our advertiser and retailer clients for whom we display advertising campaigns within mobile
applications require that the performance of our advertising campaigns be monitored by
companies commonly referred to as "trusted third parties". These companies to whom we
may share your personal data verify the good impression of the campaigns as well as the
effectiveness of the campaigns on the traffic generated in their points of sale. To this
end,
we have concluded contracts with these companies in order to supervise the processing
they carry out using the personal data we make available to them to study the effectiveness
of our advertising campaigns.
Each of the companies mentioned below acts as data controller and is contractually bound
to VECTAURY. As such, they are subject to regulations relating to the protection of personal
data and, more specifically, to the obligations specific to those of the data controllers.
These
companies are prohibited from processing your data for purposes other than those
mentioned above and are subject to strict obligations in terms of the confidentiality and
security of your personal data. They are also prohibited from transmitting this data to
third
parties.
We may share your personal data with commercial partners such as HAPPYDEMICS, a simplified joint stock company, registered with the Paris Trade and Companies Register under number 810 129 478 and having its registered office at 73 rue de la Plaine, 75020, Paris. This company acts at the request of our clients and displays questionnaires to users who have been exposed to advertising displayed by VECTAURY in order to carry out marketing studies and evaluate the performance of our advertising campaigns
The personal data collected on the VECTAURY website is accessible to our internal teams
and more particularly to employees who need to know this data in order to carry out their
professional activity and who are subject to an obligation of confidentiality. This data is
used
to better understand how visitors to the VECTAURY website use it and to respond and
communicate with the people who have used the contact form.
As indicated in article 4 of this privacy policy, the website www.vectaury.io uses the
Google
analytics cookie from Google to analyse your use of our website, the CloudFlare cookie to
enable it to function properly and the Youtube cookie to enable the videos published on the
website to be played.
As such, the data generated by these cookies placed on your terminal (computer,
smartphone, tablet, etc.), are collected by the following companies so that they can provide
us with the service for which the cookie is set (see Article 4):
The personal data collected on the VECTAURY SOLUTION platform is
accessible
to our
internal teams and more particularly to employees who need to know it in order to carry out
their professional activity and who are subject to an obligation of confidentiality.
This data is only used to improve our VECTAURY SOLUTION platform and to study our
Clients' browsing on it.
Like the website, the VECTAURY SOLUTION platform uses the Google analytics cookie
(see article 5 of this privacy policy) as well as the Crisp cookie. The data generated by
these
cookies placed on your terminal (computer, smartphone, tablet, etc.) are collected by the
following companies so that they can provide us with the service for which the cookie is set
(see Article 5):
The processor mentioned in Article 6 (ii) b- is located in
Belarus, so there
is a transfer of
your personal data outside the European Union. As such and to ensure an optimal level of
protection of your personal data and in accordance with the Regulation, our processor is
subject to the obligations set out in the standard contractual clauses validated by the
European Commission and establishing a level of data protection similar to that of the
GDPR
The Subcontractor in question is the company CEDON BLR located at 25-203 Yanki Kupaly
Street, 220030 Minsk BIELORUSSIA, represented by Mr Ongan Mordeniz.
No other transfer of personal data is carried out by VECTAURY outside the European Union,
as the data is hosted in France.
In accordance with the GDPR, you have rights to your personal data:
You may exercise these various rights by going to VECTAURY's privacy centre accessible
via the clickable (i) information present on the advertisements displayed to you by
VECTAURY in mobile applications or directly on VECTAURY's website via the following link:
https://creative.v3ty.com/vectaury/201704/campaign1/www/page/index2.html
You may also exercise these rights by writing a letter to VECTAURY's postal address or by
sending an e-mail to the following address: legal@vectaury.io.
You may withdraw your consent to the processing of your personal data for the purposes of
profiling and displaying targeted advertisements adapted to your location at any time. You
may simply withdraw your consent to the processing of your data for location-based
advertising purposes by VECTAURY via the Consent Management Platform ("CMP"), which
is accessible in the application settings. Furthermore, the CMP is accessible at any time in
the application settings, so you can change your consent choices at any time.
The user is validly informed of the purpose of the processing, the identity of the data
controller, the data collected and the possibility of withdrawing consent by means of the
CMP used by our partner publishers and publishers monetizing the advertising spaces
available in their applications via the real-time auction system. VECTAURY ensures that
users are validly informed so that they can give specific free and informed consent to the
processing of their personal data by auditing the CMP as explained in article 3.3.
Users may also access, via the CMP used in the application concerned, VECTAURY's
privacy policy in order to obtain further information on the processing activities carried
out.
They may also access via the list of partners to whom the data are sent, the purposes of the
processing and their privacy policy
Android and Apple allow Users to control their privacy in the
settings,
making it impossible to
link their ad history to their future browsing.
The personal data collected by VECTAURY is linked to the advertising identifier. Each
mobile phone has its own advertising identifier which enables advertisers to display
targeted
advertising. It can be reset at any time by the user:
The User will probably receive the same amount of ads but they will be less relevant
In addition, the User can activate the function "limited ad tracking" or "disable ad tracking" :
If you do not want cookies to be placed on your terminal while you are browsing our website or platform, you can follow the instructions below to disable cookies:
VECTAURY implements appropriate technical and organisational security measures to
ensure the security and confidentiality of the personal data processed. The same level of
security is imposed on our processors.
The security measures implemented are set out in VECTAURY's Information Systems
Security Policy and the technical and administrative teams ensure that these measures are
scrupulously respected.
We may need to modify the content of this Privacy Policy to update our practices and the
applicable Regulations. In this regard, we advise you to consult it regularly; you can
easily
determine the last date on which this policy was updated at the top of the document.
We inform you that in the event of any contradiction between the French and English
versions of the Privacy Policy, the French version shall prevail.