The Weborama Privacy Commitment

Weborama attaches great importance to respecting the privacy of Internet users, as well as to the security and confidentiality of the data collected. Weborama adheres to the various initiatives of professional digital advertising organizations to inform the public about the collection and processing of data, allowing you to have control of your data

Introduction

Weborama considers the privacy of Internet users, as well as the security and confidentiality of all collected data, to be of the utmost importance, Weborama participates in the various initiatives of professional digital advertising organisations aimed at informing the public about data collection and processing and that allow you to control your data.

Weborama adheres to the Principles of the IAB Europe EU Framework for Online Behavioural Advertising.

 https://www.edaa.eu/

You can manage your cookie preferences via Youronlinecechoices

The purpose of this confidentiality policy is to describe our rules concerning the management, processing and storage of any personal data submitted in the course of our services.

The term “personal data” refers to any information concerning a physical person who is directly or indirectly identified.

Opt out

Users can choose to opt out of Weborama’s anonymous data collection program. Once users opt out, Weborama does not collect navigation data or create marketing profiles anymore.

Opting out does not prevent users from receiving online ads delivered by Weborama, but these ads are delivered randomly. They are not targeted to a user’s modelled interest or demographics, are not delivered in sequence or delivered according to any previous advertising interaction.

When users opt out, Weborama stores a specific cookie on their browser. Weborama’s opt-out cookie has to be downloaded on each computer and each browser used by users. If cookies are disabled, erased, or altered, and if browsers or operating systems are modified or upgraded, the opt-out process might need to be performed again.

Who are we ?

Weborama is the industry leader for using semantic data for a better scientific understanding of consumers. Weborama optimises corporate marketing strategies using technological solutions, data and expertise in data science.

In its professional activities, Weborama identifies the content, services and products corresponding to your centers of interest based on:

- Your browsing of our partners’ websites,

- Geolocation data collected by our partners’ mobile applications.

 

Since its foundation in 1998, more than 300 corporate clients have entrusted Weborama and its innovative solutions to drive and optimize their marketing investments in Europe as well as in North and South America.

 

What are the Weborama details?

Weborama, a limited liability company with a Board of Directors,

Registered with the Paris Companies and Trade Register under the number 418663894,

Represented by Mr. Daniel Sfez, CEO.

19 rue Clavel 75019 Paris - France

 

How to contact our data protection officer

Weborama has appointed a data protection officer who is responsible for ensuring that the company complies with all regulations in force as well as with professional rules of good conduct. Please contact this officer for any questions concerning our privacy policy:

- By email: privacy@weborama.com ;

- By mail: DPO - Weborama – 37 Bd des Capucines, 75002 Paris.

Which categories of personal data are collected by Weborama ?

Weborama collects no data that can directly identify a user (such as their surname, given name, email, telephone number, etc.) and does not structure any sensitive data that could reveal the state of health, racial or ethnic origins, religion, sexual orientation, political opinions or affiliation with a trade union.

Data collected using Internet browsers

Weborama collects data using IT programs (Tags) that websites place on their pages from Weborama when Weborama has the direct relationship with publishers to collect this data or from website partners authorized to collect this data.

This data is collected only if you accept the cookies for targeted advertising purpose.

Data collected on Internet are:

- The Weborama Cookie identifier,

- IP address,

- IP geolocation,

- The pages of the various sites visited,

- The time of your browsing on the various pages,

- The type and version of the browser with which you browse the Net,

- Cookie identifiers of partner technological platforms, which share the same goals, for which this data has been collected.

 

Data collected by Weborama can be enhanced by data from other intermediaries including our partners.  In particular, we enhance this data with that from people who participated in panels and who have replied to questionnaires aimed at helping us define the socio-demographic profiles of Internet users with a view to analysing or targeting advertising. This data is “pseudonymised” so that you cannot be directly identified.

Data collected via Mobile Application

To collect data using a mobile application, Weborama depends on different partners to collect the following data:

- The IP address,

- The mobile phone’s identifier for advertisers (IDFA for IOS devices and GAID for Android),

- GPS geolocation data (degree of precision),

- The model of mobile phone as well as its operating system (IOS, Android, etc.).

Data collected for our customers 

 Weborama may also collect data for its clients from their websites and mobile applications.

Weborama collects the following information for its customers (this information cannot be used to directly identify you):

- Data connected to your browsing of their websites,

- Data sourced from their customer databases,

- If applicable, the advertisement that was sent to you, 

- How you reacted to the targeted advertisement sent to you (clicks, conversions).

What is the purpose of the data processing Weborama does ?

Weborama collects data for the following reasons: 

- To deliver advertisements as well as marketing and sales offers to you that best correspond to your needs and preferences,

- To help advertisers and publishers better target their current and future customers in their loyalty building and commercial prospecting campaigns,

- To help businesses distribute non-intrusive advertising,

- To optimise distribution frequency of advertisements (marketing pressure) with a view to avoiding saturation,

- To develop studies for advertisers of various industries (automotive, real estate, distribution, etc.) in the interest, amongst others, of helping them to better understand consumers’ needs and their market as well as to analyse the performance of their loyalty building and commercial prospecting campaigns.

- Reconcile the different identifiers of various terminals in order to bring them closer to a profile in a probabilistic way.

What is the legal basis for processing personal data ?

We process your data on the following legal basis:

- Your consent, Art. 6 (1) a) GDPR

- For the performance of a contract with you, Art. 6 (1) b) GDPR

- Legitimate interests, Art. 6 (1) f) GDPR (see below)

When processing your data, we pursue the following legitimate interests:

- Improving our offer

- Protection against abuse

- Statistics


Data from Internet

Weborama collects and processes data relating to current and prospective customers of businesses that use Weborama services to improve their loyalty building, retention, and commercial prospecting operations.

To do this, Weborama considers legitimate interest as the legal basis. Weborama makes sure to not collect any personal data that can directly identify a person (surname, given name, email address) and to work only on the basis of pseudonym identifiers.

Weborama collects data through the networks of partner sites and requests them contractually to inform you of any data transfer and its purpose.

Weborama also makes certain to not structure any sensitive data and ensures that any data enhancement does not make it possible to deduce any sensitive data about the person.

In the event that one of our customers should wish to reconcile center of interest data collected by Weborama from its own nominative customer database, Weborama expressly demands, prior to any data reconciliation, that the customer informs and asks your consent or that the contract between yourself and the customer informs you of this possibility.

At any time, you can exercise your right to object to the collection of your browsing data by Weborama, notably by using the opt-out button.

Data from mobile applications

Weborama requests that its partners collecting data from mobile applications, and more particularly, the geolocation data from your cell phone, inform you and obtain your consent for the collection of this data and for the purpose of targeted advertising. You may at any time withdraw your consent and thereby no longer be geolocated.

Geolocation data collected is especially used in conjunction with the advertising identifier. The advertising identifier is a unique identifier attached to a mobile phone; this can be reinitialised at any time by the user by following this procedure:

For iOS: go to “Settings”, then tap on “Confidentiality”, then “Publicity” and finally on “Reinitialise the advertising identifier”;

For Android: go into “Google Settings” (or “Settings” then “Google”), then tap on “Adverts”.

What categories of intended recipients are there for collected data ?

Access to data within Weborama is limited to certain categories of employees whose access is justified by reason of their job. The employees concerned have absolutely no access to direct personal data (surname, given name, address, etc.). They are contractually bound to:  

- Respect the confidentiality of the information,

- Not set up any data processing that would make it possible to directly identify you.

We may share collected data with those of our customers (for the most part advertisers and publishers) who want to conduct marketing analyses and study statistics themselves, or those seeking to develop algorithms to identify opportunities for sending you relevant offers.

We may also need to transmit the data to our service providers, on condition that this is necessary for the provision and execution of the service they provide us (including our data hosting services), as well as to companies working to the same purpose as Weborama and that are platforms serving to distribute targeted advertising or communications to you by email or any other channel.

 

Data transfers outside of the European Union

The data is hosted within the European Union.

Should we find it necessary to transfer data to the United States, we make sure that the partner receiving the data is signatory to the “Privacy Shield”, which ensures you the same level of data protection as that required by the European Union.

How long is the data kept ?

 

The amount of time that data is kept depends on the purpose and necessity of keeping this data:

- 30  days for raw data collected from the Internet,

- 3 months for raw data collected from mobile applications,

- 13 months for center of interest data resulting from processing done by Weborama

 

How can you exercise your rights?

According to the applicable regulations, you have the following rights:

- Right to access any personal data,

- Right to demand rectification of your data if it is inaccurate,

- Right to request erasure of your data (right to be forgotten),

- Right to restrict processing of your data,

- Right to object to processing of your data,

These rights may be exercised by the guardian of a person under guardianship or by those persons exercising parental care over children under the age of 15. You may send all your questions concerning your rights to the data protection officer whose contact details can be found above.

In order for Weborama to process your request, we would need:

- To know your advertising identifiers,

- To have a copy of your ID,

- To receive a sworn and signed, handwritten statement guaranteeing that you are the only person to use the browsers and mobile devices corresponding to these identifiers

Your requests will be processed within 30 days, in accordance with the regulations.

Should Weborama not reply to your request in this timeframe, you can lodge a complaint with the relevant regulatory authority.

France CNIL (Commission National Informatiques et Libertés/French Data Protection Authority)

Managing your choices

You have the right to object to processing or to express your choice at any time.

Source of data

Data collected by Weborama comes from companies (data brokers or publishers) that collect or purchase data directly or provide services to publishers of websites and mobile applications.

Existence of automated decisions

Data processing by Weborama can lead to automated decisions, such as the distribution of targeted advertising. We make sure that these decisions do not result in adverse legal effects or consequences for you.

Security of your data

In providing its services, Weborama considers the security and integrity of the processed personal data to be of paramount importance. Weborama thus agrees to take all due precautions to safeguard the security of all data and, above all, to protect it against any accidental destruction, alteration, unauthorised distribution or access, as well as against any other form of unlawful treatment or communication to unauthorised persons.

To this end, Weborama implements security and organisational measures to protect personal data from any unauthorised disclosure. We use various security and operational measures such as data encryption and the use of identification tools.

In order to ensure optimal confidentiality and, in particular, to avoid all unauthorised access, as well as to guarantee the exactitude and proper use of the data, Weborama sets up the appropriate electronic, physical and management procedures to safeguard and preserve the data collected in the framework of its services.

Nevertheless, no one is completely safe from a hacking attack. For this reason, should we experience a data breach, we agree to inform you as soon as possible and to make every effort to take all steps to neutralise the intrusion and minimise the impact. In the event that you experience damages due to a security breach by a third party, Weborama commits to providing you with all our support in ensuring that your rights are enforced.

Modification of the Privacy Policy

Weborama reserves the right to revise this Privacy Policy at any time, particularly in application of any modifications made to the laws and regulations in force. We recommend that you verify yourself these regulations from time to time in order to remain informed of our procedures and rules relating to your personal information.

Welcome to www.weborama.com, published by Weborama. Weborama is the first European data company, specialized in data exploitation on the web.

This section is dedicated to our Privacy Protection Policy. Here you can learn more about the origin and use of the browsing data processed during your visit to our site as well as your related rights. This Policy is important for you in order to have the best possible experience on our site and maximize your confidence in our services. It is important for us in order to fully and accurately answer any questions you may have about your visit to our site and to fully understand your expectations.

While visiting our site, information about the browsing data we receive from your data terminal (computer, tablet, smartphone, etc.) may be stored in "cookies" installed on your device. This is subject to the choices that you have expressed about cookies which you can change at any time.

How are the cookies issued from this site used?

Only the issuer of a cookie is likely to read or change the information contained in such cookie. Cookies may be included in the advertisements appearing on our site. These advertising spaces displayed on your data terminal show advertising content from advertisers. These spaces contribute to the funding of the content and services we offer you.

The cookies we use on our site

Subject to your choice to allow cookies, when you open our site we may install various cookies in your data terminal allowing us to recognize your device's browser for the duration of the cookies' period of validity. Cookies that we issue are used for the purposes described below, and are subject to your acceptance of them, by way of the browser software settings when you visit our website which you can make known to us at any time (through http://www.youronlinechoices.com, see below « Expressing your choices online through multi-sector initiatives »).

We issue cookies that allow us to:

  • compile statistics and traffic volume and measure the use of the various sections of our site (headings and content visited, click streams) which helps us improve the value and usability of our services;;
  • customize the presentation of our site to the display settings of your data terminal (language, screen resolution, operating system, etc.) during your visit our Site, based on your data terminal's hardware, viewing software and video software;
  • customize our advertising spaces to the display settings of your data terminal (language, screen resolution, operating system, etc.) based on your data terminal's hardware, viewing software and video software;
  • customize the advertising content displayed on your data terminal in our advertising spaces based on the browsing data associated with your data terminal on our site;
  • customize the advertising content displayed on your data terminal in our advertising spaces based on your physical location communicated to us by your data terminal with your prior consent

Your choices regarding cookies

There are several ways to manage cookies. The settings that you use are likely to change your internet browsing experience and the conditions of your access to any services requiring the use of cookies.

You can choose to express or modify your acceptance of the use of cookies at any time as described below.

The choices available to you through your browser

You can configure your browser to allow cookies to be stored on your data terminal, to reject them automatically or to reject them from certain issuers. You can also configure your browser so that you are promptly asked to accept or reject cookies before a cookie is saved to your data terminal. For more information, see "How to exercise your choice in the browser you use"

(a) Accepting cookies
It is up to the user of a data terminal to decide whether or not cookies will be accepted on that data terminal. The user is free to make this choice and to modify it at any time through the settings associated with the browser used on the data terminal.

If the browser is set to accept cookies on your data terminal, then the cookies used by the web pages that you have visited will be stored temporarily in a dedicated space on your data terminal. They will be readable only by the issuer.

(b) Rejecting cookies
If you choose to reject cookies on your data terminal, or if you remove any cookies already stored, you will not be able to use a number of features that are necessary to browse certain sections of our site. For example, this would be the case for access to any of our content or services that require you to log in. This is also the case as concerns technical compatibility when we or our service providers cannot recognize the type of browser that you use on your
data terminal, its default language and display or the country from which your data terminal is connected to the internet.

If the browser is set to reject cookies on your data terminal, we assume no responsibility for consequences related to the degraded operation of our services resulting from us not being able to store or view the cookies necessary for the full functioning of our site and services.

(c) How to exercise your choice in the browser you use
Each browser has a different way of managing cookies and cookie settings. The configuration of your browser is described in its help menu which will inform you of how to change your cookie settings.
For Internet Explorer™ : http://windows.microsoft.com/fr-FR/windows-vista/Block-orallow-cookies
For Safari™ : http://docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html
For Chrome™ : http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
For Firefox™ : http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies
For Opera™ : http://help.opera.com/Windows/10.20/fr/cookies.html
etc.

"Flash"© cookies using "Adobe Flash Player"™

"Adobe Flash Player"™ is an application that enables the rapid display of dynamic content using the "Flash" computer language. Flash and other similar applications store settings, preferences and usage date using a technology similar to cookies. However, "Adobe Flash Player" ™ handles this information through the use of an interface different from that provided by your browser.

If your data terminal is likely to view content developed with Flash technology, please access your Flash cookies management tool directly from the Adobe website at http://www.adobe.com/fr/.

Expressing your choices online through multi-sector initiatives

The digital advertising professionals of the European Association EDAA (European Digital Advertising Alliance), managed in France by the Interactive Advertising Bureau France, offers a website at Youronlinecechoices

Here you will find a list of the companies that belong to this initiative and which offer you the opportunity to accept or reject the cookies used by these companies to customize their advertisements to your browsing data: http://www.youronlinechoices.com/fr/controler-ses-cookies/

This is a centralized European interface that is shared by hundreds of internet advertising professionals allowing you to express your acceptance or rejection of cookies which may be used to customize the advertisements displayed on your data terminal to your browsing data. Note that this does not preclude the display of advertisements on the websites you visit. It will not block the technologies that can customize advertisements to your interests.

The NAI Codes and opt-out page

The Digital Advertising Alliance Principles

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