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.

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,

- 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),

- 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).

How long is the data kept?

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

- 60  days for raw data collected from the Internet,

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

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 its partners collecting data from mobile applications to inform you about the collection of this data for the purpose of targeted advertising.

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 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.

To exercise your rights, please contact our data protection officer:

- By email: privacy@weborama.com ;

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

TOP