PRIVACY POLICY

This privacy policy explains how we collect, use and share your information in the frame of our activities including information we collect when you visit our website.

1.   Name of the data controller of the data collected through our software development kit (the "SDK") integrated into third party mobile applications and into our website

The data processor is Singlespot SAS, a simplified joint stock company registered with the trade and company register of Paris under number 809 644 347.

2.   What type of personal information does Singlespot collect?

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

Singlespot collects on third party applications the following data: 

  • Geolocation data;
  • IP adress; and
  • Advertising identifiers.

In the frame of advertisements that are delivered and/or have been delivered to you by Singlespot, we may also collect the following information:

  • The mobile applications uploaded on your mobile phone where the advertisement is likely to be or has been delivered to you;
  • The details of the advertisement that is/ has been delivered to you (as the case may be) (identity of the advertiser, type of advertisement, etc.);
  • Your behavior in respect of the targeted advertisement (as the case may be) (time spent on it, potential clicks on it, etc.);
  • The number of occurrences where you received advertisements delivered by Singlespot.

Singlespot also collects the language settings, the type and the operating system (iOS, Android) of your device.

The 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.).

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

Singlespot deletes all data which are not required to perform its business, and in particular, (i) all sensitive data (data related to health, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-unions membership, data concerning a person’s sex life or sexual orientation) and (ii) any identification of place which may reveal a sensitive information.

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 the collected personal data

a)   Personal data collected on the mobile applications

User data are collected to:

  • Enable advertisers, clients and publishers to serve personalized ads and allow our publishers to promote advertising, apps and content in their mobile applications;
  • Offer advertisements that better meet the expectations of consumers (as more personalized and relevant to the interests of the mobiles users);
  • Draft analytics study to the attention of our clients coming from various industries (retail, real estate, etc.) for marketing and/or targeted advertisings purposes.

Data collected gives you access, in most cases, to the content of the mobile applications at no cost.

Following the delivery of advertisements, we draw statistics and analytical reports (which are addressed to our clients) to measure the efficacy of the advertising campaigns managed by Singlespot. These reports and statistics are anonymous. You are therefore not identifiable on this basis.

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 data

a)   Personal data collected on the mobile applications

Singlespot collects and processes personal data from you where we have your consent to do so. Your consent is collected through a pop-up issued by our partner data providers (i.e. publishers) on their mobile applications.

Our publishers guarantee Singlespot that before obtaining consent they will inform mobile users about the purposes of data processing and their rights.

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.   Category of data recipients

a)   Personal data collected on the mobile applications

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

The data collected (including the advertisings IDs) may be transferred to partner where Singlespot purchases in real time advertising spaces on behalf of its customers (advertisers and agencies), (including the Demand Side Platforms).

The advertisings IDs may, in some cases, be transferred independently (without being related to other collected data), in a secure way, to a trusted third-party for a scoring purposes (the third party shall assess Singlespot technology in driving customers to physical retail stores).

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.

We may share the data collected on the mobile applications to (i) our partners with which we will elaborate mutual drive-to-store offer and/or which need our data to improve the users’ knowledge in order to elaborate drive to store offer (in particular) and/or (ii) with partners which enable us to better understand the users.

We may share report to our clients (advertisers and their clients) which include anonymous / statistics data only to prove the efficiency of our drive-to-store offers.

We may transfer the data to our services providers to the extent it is required to the provision of service.

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).

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

Transfers are, in any case, subject to security measures.

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

Data collected via Singlespot 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, 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,
  • Right of opposition in removing your consent,
  • Right of portability,
  • Right to bring a claim before the supervisory competent authority (in terms of personal data protection).

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.

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.

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.

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:
  • Two factor authentication of its relevant employees having access to the data collected on the mobile applications, to its data hosting solutions;
  • Protected access to the premises;
  • Our employees are made aware of security measures (obligation for each employee to turn off its computer (or to use password-protected screensavers) even in case they are away (even for a few minutes);
  • Use of updated firewall;
  • Protection against SQL injections;
  • Use of subnets behind our proxy servers, to limit the IPs having access to our data bases, to prevent the risk of direct connection to our data bases from a third party;
  • Any sensitive transfers involving our data bases are encrypted in accordance with the latest SSL encryption technology;
  • Implementation of a policy access right to our Information System (access to data collected on mobile applications is limited to our IT and data teams).

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: 4 September 2018