PRIVACY POLICY

Singlespot is a company specialized in the processing of data for targeted advertising purposes and/or marketing and analytics reports purposes (in order, in particular, to better manage the location of the stores and/or improve the operations (from a logistics, business, etc. standpoint). 

Your personal data may be collected, subject to your consent, by the Software Development Kit (the “SDK” or “Software”) of Singlespot which is integrated into various mobile applications of publishers-partners (to the extent such mobiles applications are installed on your smartphones/devices). 

Singlespot may also collect some of your information when you visit its website. 

This privacy policy is meant to help you understand, in a transparent manner, the way Singlespot uses and processes some of your information in the frame of its activity. In particular, this privacy policy explains what information we collect, process and share, why we collect it, the security measures implemented to secure and protect it and how you can manage your rights with respect to your information.

1.   Name of the data controller of YOUR PERSONAL INFORMATION

When Singlespot processes your personal information collected by its Software integrated into mobile applications for the purposes listed in article 3A)hereafter, the data controller responsible for your information is Singlespot SAS, a simplified joint stock company registered with the trade and company register of Paris under number 809 644 347.

The data controller responsible for your information collected when you visit this website is also Singlespot. 

2.   type of personal information collectED BY SINGLESPOT

a)   Personal information collected through our SDK integrated into third party applications

Singlespot collects on third party applications your following data:  

·      geolocation data of the device;

·      IP address; 

·      MAC address of your device; and

·      advertising identifiers of your phone (IDFA (iOS devices) and AAID (Android devices)).

Singlespot also collects the language settings, the type and the operating system (ioS, Android) and the timestamp data (time and hours) of your device. 

You may at any time turn your device’s location on or off using the device’s settings app. 

Your geolocation data collected is connected to your advertising identifier. The advertising identifier is a unique identifier linked to your mobile phone, which may be reset by the user at any time as follows: 

-       on iOS: open "Settings", tap "Privacy", tap "Advertising" and tap "Reset Advertising Identifier";

-       on Android: open "Google Settings" (or "Settings" then "Google"), tap "Ads" and tap “Reset Advertising ID”.

Singlespot does not collect data enabling the direct identification of the users (as their name, surname, email, phone number etc.).

Furthermore, Singlespot deletes all data which are not required to perform its business.

Data collected by Singlespot may be enhanced by our partners and clients.  

b)   Data collected on our website

Information you have provided Singlespot with is used to meet your personal needs and requests (communication of white paper, newsletters and contact details). Singlespot undertakes in any case to protect your information. Your data will not be transferred, leased or traded.

The type of data collected by Singlespot on the contact form is only the following: name, surname, industry, company, email address and your request (as the case may be).

Furthermore, we may collect information about your behavior on our website through the use of cookies. A cookie is a small piece of information that is placed on your computer when you visit certain websites, read your e-mails or install or use a mobile application. When we refer to "cookies" we include other technologies with similar purposes, such as tags and identifiers.

The cookies used by Singlespot in its website are either (i) "first party" cookies (i.e. these are cookies collected by our website. These cookies are only used by Singlespot) or (ii) "third party" cookies (i.e. these are cookies coming from different third-party domains).

The "first party" cookies used by Singlespot are authentication cookies which are required to operate properly our website and to provide the user of our website with the service he/she may have requested.

The "third party" cookies on our website are cookies set by our partner HubSpot. To have an overview of all the relevant Hubspot cookies, please tap: here.

HubSpot is a U.S.-based software company with a subsidiary enterprise based in Ireland which provides a software solution for the management and realization of inbound marketing. Data collected through HubSpot are stored in the servers of our data processor, Hubspot Inc, in the USA. We have established the necessary requirement to be in line with EU data protection law. HubSpot, Inc. is committed to the EU – U.S. Privacy Shield Frameworks (a program recognized by the EU commission for the transfer of data from the EU to the US).

You can configure the settings of your browser software to block new cookies or erase those already stored.

The section « Support » of your browser provides information on how enable and disable cookies that website use to track your preference:

3.   Use of YOUR personal INFORMATION

a)   Personal data collected on the mobile applications

User data are collected to:

  • share / sell your data to Singlespot partners acting on their own behalf (for instance industrial companies) or on behalf of their clients (for instance advertising agencies or companies specialized in the processing of location data on behalf of their clients) for targeted digital advertising purposes increasing the relevance of the ads displayed to you; For instance, Singlespot may sell your information to an advertising agency which would like, on behalf of its client (being a hypermarket), send you, on the mobile applications page you are browsing in, personalized ads based on your past visits in retail firms;
  • share / sell your data to Singlespot partners acting on their own behalf (for instance industrial companies) or on behalf of their clients (for instance companies specialized in the processing of location data on behalf of their clients) for analytics/marketing or business study purposes (in particular, in order to improve the management and the location of the stores and/or the operations (from a business, logistics, etc. standpoint). For instance, Singlespot may sell your information to an automobile distribution company to help it improve the location of its stores;
  • draw up business, analytic and marketing studies/report to the attention of Singlespot clients coming from various industries (retail, retail estate, etc.) in order in particular to improve the management and the location of the stores and/or the operations (from a business, logistics, etc. standpoint). For instance, Singlespot may use your data to draw up an analytics report aiming at improving the location of the bus stops of a public transport company. 

Singlespot will only use your personal data for the purposes for which you have given your consent.

b)   Personal data collected on our website

Singlespot uses cookies to improve your browsing experience, which would be more personalized and secured.

In particular, and as mentioned above, cookies set by Hubspot are used by us to optimize our online marketing and to manage our website, including:

  • Reporting (e.g. traffic services, accesses etc.);
  • Contact management;
  • Provision of contact forms;
  • Email marketing (newsletter and automated mailing for instance).

HubSpot sets cookies on your computer to enable us to track your visit on our website. The collected information (e.g. IP address, the browser type, the duration of the visit and the pages viewed) is analyzed by HubSpot on our behalf in order to generate reports regarding the visit and the pages viewed by you. HubSpot helps us (i) analyze our website traffic and (ii) customize our marketing activity. We may use in particular your data to contact you, as user of our website, in order to promote relevant services based on your interests. In the event our website provides you with content, and/or you have subscribed yourself to receive information, we will be able through HubSpot to analyze your visits and your information to provide you with personalized content.

Finally, we use your e-mail address filled out by you in the contact form for connection, billing, communication (newsletters), commercialization and prospection purposes.

4.   Legal basis for processing your personal INFORMATION

a)   Personal data collected on the mobile applications

Singlespot collects and processes personal data from you where it has your consent to do so. Otherwise, your data is not processed by Singlespot.

Your consent may be collected through the Consent Management Platform of Singlespot, which is a platform developed by Singlespot which will inform you about the types of data Singlespot will collect, will ask for your consent for specific data-processing purposes (as mentioned in article 3a)above) and will transfer your decision to Singlespot data recipients (acting as data controller). 

Your consent may also be collected through the Consent Management Platform / a pop-up issued by Singlespot publisher-partners in the relevant mobile applications which will ask for your consent for specific data-processing purposes (as mentioned in article 3A)above) and will transfer your decision to Singlespot and its data recipients (acting as data controller).

We remind you that you may withdraw your consent at any time by following the indications provided for in the relevant mobile applications of Singlespot publisher-partners. In this case, the Software, which will remain integrated into the mobile applications of the relevant publisher, will not collect your data anymore.

b)   Personal data collected on our website

The "first party" cookies of Singlespot (i.e. authentication cookies) are required to operate our website properly. For this reason, these cookies may be collected without collecting the consent of the relevant user (i.e. it is in our legitimate interests to collect this data).

The "third party" cookies are processed by HubSpot subject to your prior approval.

In addition, by filling out our contact form, you give your consent to Singlespot to collect and process the information provided on it.

You will receive our communication (as the case may be) subject to your prior approval in the contact form.

Finally, and as mentioned in the contact form, Singlespot may use the information filled out in the contact form to promote its products and services. As such promotional activity will be carried out in the frame of a B-to-B relationship, we consider that the legal basis of such processing is our legitimate interest, in accordance with the applicable regulation.

5.   data recipients OF YOUR INFORMATION

a)   Personal data collected on the mobile applications

  • Data recipients within Singlespot:

Your personal data collected by the Software on the mobile applications installed in your devices is only accessible to a limited number of employees and freelances (in particular the data scientists) who need access to the information to perform their duties. The relevant employees and freelances are bound by an appropriate confidentiality undertaking. 

  • Data recipients outside Singlespot: 

Our business partners (together with a link to their privacy policy, the detail of information transferred and the purposes of the relevant processing) which may buy your information collected by the Software on the relevant mobile applications installed in your devices are the following: N/A

We may share your data (in particular location data and advertisings ID) collected on the mobile application(s) of a publisher to this specific publisher for its specific purposes (i.e. for targeted advertising purposes on their mobile applications or for the purposes of editorial optimization). 

Our business- and publishers- partners act, for their own purposes, as data controller of your personal data, and are therefore, subject to the EU data protection regulation. Our partners are bound by contractual obligations under which they are entitled to use your information for the purposes mentioned above only. They undertook also to comply with the EU data protection regulations and to pay particular attention to the security and confidentiality of your information.  

We may also transfer the data to our services’ providers to the extent it is required to the provision of service. These services’ providers act as data processor of Singlespot. We may for instance share your data with our data centers (Amazon Web Services) which are located in the European Union. A data processing agreement has been entered into between Singlespot and each services’ providers describing the technical and security measures implemented by the services’ providers to secure your information. Each data processor undertakes to use your information to provide the services to Singlespot only. 

In addition, Singlespot may transfer your information as required by any applicable law or regulation to a competent authority (in particular the French “CNIL”), or court or administrative body. 

Generally speaking, we ensure by contractual means that the process of your personal data is consistent with the purposes for which your data was collected. 

The data collected by Singlespot is processed within the European Union. Nevertheless, in the event that the relations of Singlespot with its partners would involve cross-border exchanges of personal data outside of the European Union (and in particular in the United States), Singlespot will ensure that such transfers offer a protection level in compliance with European requirements (by entering with its partners into the Standard Contractual Causes adopted by the European Commission, and/or by the adherence of such partners located in the United States to the Privacy Shield).

b)   Personal data collected on our website

Your personal data is only accessible to a limited number of employees who need access to the information to perform their duties. The relevant employees are bound by an appropriate confidentiality undertaking.

Data collected on our website is, as mentioned above, forwarded to our partner HubSpot. This data may be, under certain conditions, forwarded to our CRM system provider and/or eventually, to our marketing providers (which will all act on our own account and behalf).

6.   Retention period for personal data

a)   Personal data collected on the mobile applications

Singlespot applies different retention period. All your location data is retained for a one (1) month period and your points of interest (for instance your visits in stores) are deleted within a maximum period of six (6) months following the date of their collection.

b)   Personal data collected on our website

Your consent on cookies will have to be renewed at least every thirteen (13) months. Cookies have therefore a retention period of maximum thirteen (13) months as from their placement on your computer (following your consent).

Data collected on the contact form which is linked to prospect are retained for a maximum of three (3) years as from the last contact from the relevant potential prospect and/or as from their date of collection.

7.   Your rights in respect of the data processed by Singlespot

You have rights under the european Union (EU) data protection law with respect to the processing of your information, that can be freely exercised at any time.

In particular, you have, in respect of the data collected and/or processed by Singlespot, the following rights in accordance with the applicable regulation:

  • Right of access to your personal data,
  • Right of correction of your personal data,
  • Right of deletion of your personal data,
  • Right of limitation (limitation of the processing of your personal data on the basis of different purposes),
  • Right of opposition in removing your consent,
  • Right of portability (getting an electronic copy of your personal data).

You can exercise your rights directly to (i) the publishers of the mobile applications installed in your devices where the Software is integrated or (ii) to us directly. If your request is related to the processing of your information by our business partners (as listed in article 5A)herein), Singlespot will transfer your request to the relevant business partners as well. 

Holder(s) of parental authority for under-age users, or legal representatives for persons subject to a tutelage measure, may also exercise such rights and be the addressees of resulting information.

In the event your rights are exercised to Singlespot directly, the exercise of such rights shall be carried out by sending a request to our data protection officer (see below the relevant contact details).

In order to comply with the request of the mobile phone’s users, we will need your advertising IDs together with a description of your request (data and rights concerned by your request). Please attached to your request a pdf copy of your ID together with a duly signed statement under which you warrant that the advertising ID is yours.  

In order to retrieve your advertising IDs, the procedure is different on iOS and Android: 

  • for iOS: you may download the application the « Identifiers » that will give you access to your advertising IDs on your phone by following this link: https://itunes.apple.com/us/app/the-identifiers/id564618183?mt=8;
  • for Android: you may directly retrieve your advertising IDs in the settings of your mobile phone, by going into the « Advertising » section.

You may remove your consent at any time (the process of your personal data carried out prior to the withdrawal of your consent will remain valid). 

For any request linked to our website, we will need your ID and email address. 

In addition, in the event you are facing difficulties in enforcing your rights or you would like to bring a claim with respect to the processing of your personal data, you have the right to bring a claim before the supervisory competent authority (in terms of personal data protection), and in particular the French CNIL.

8.   Security

Singlespot makes continuous efforts to ensure a level of security appropriate to the risk associated with the processing of personal data. Singlespot maintains organizational, technical and administrative measures to protect personal data within its organization against unauthorized access, destruction, loss, alteration and misuse. 

Singespot in particular maintains the following measures to protect its data bases: multi-factor authentications, encryption, protection against SQLinjections, access right to the IT system restricted, logging of the incidents,use of updated firewall and antivirus software, use of subnets behind our proxy servers to limit the IPs having access to our data bases and to prevent the risk of direct connection to our data bases from a third party, etc. 

Furthermore, the access to the premises is protected and Singlespot employees are made aware of security measures and of the data protection regulations (organization of training session, IT charter enforceable against the employees, etc.). 

9.   Data protection officer

Singlespot has appointed, in accordance with the applicable regulation, a data protection officer (DPO). In case you have any query with respect to our privacy policy, please send a request to our DPO:

  • Either by email: privacy@singlespot.com ;
  • Or by mail: DPO – SINGLESPOT SAS: 33 rue La Fayette 75009 Paris (France).

10.   Unsubscribtion

You may at any time unsubscribe from targeted advertisements on your mobile phone in accordance with the following instructions:

You may still receive a similar number of advertisements. However, these advertisements should be less relevant, as they won’t be targeted according to your interests.

Furthermore, you may unsubscribe yourself from our marketing information by clicking on the « Unsubscribe » link provided for at the end of our email, or by sending a request by email to privacy@singlespot.com.

11.   Amendment of our privacy policy

Singlespot reserves the right to amend this privacy policy at any time by publishing a new online version. We advise you to review this privacy policy on a regular basis on our website to be informed of its possible amendment.

In case of contradiction between the English and French versions of this policy, the French version shall prevail.

Entry into force: 16 May 2019