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Privacy Policy (US)

Welcome to Numberly’s privacy policy (hereinafter the “Privacy Policy“).

 

This Privacy Policy applies to information collected by Numberly from third party websites and mobile apps via Our technologies and from other sources in connection with Our Services. It also describes the choices available to You regarding Our use of Your browsing information and how You can opt-out of the delivery of ads or commercial offers using Your browsing information (see section 3.5 below).

 

This Privacy Policy applies solely to data collected in connection with Numberly’s Services.

 

This Privacy Policy contains information, explanations, and our commitments allowing You to know more about:

  • The origin and use made of the Personal and Browsing Data processed by Us,
  • The measures We take for the confidentiality and protection of this Data,
  • Your rights within the framework of Numberly Services and this Privacy Policy.

 

This Privacy Policy is therefore important to You, since You wish to have a positive and confident experience of interactive advertising. It is also important to Us, since We wish to answer Your questions in a precise and appropriate manner and take Your expectations into account while respecting Your choices and Your rights.

 

  1. Definitions and applicable law
    1. Definitions
    2. Applicable law and control mechanisms
  2. Browsing data processed by Numberly
    1. What is Browsing Data?
    2. What technologies do We use?
    3. Cross-Device and Cross-App Technology
    4. What type of information do We collect?
    5. What do We use it for?
      1. For marking Our Services secure
      2. For Our Services’ analytics and invoicing purposes
      3. For adapting electronic mails to receiving Users’s interests
      4. For adapting electronic advertising displayed on Devices
    6. How Information is shared?
  3. User’s rights with regard to use of their personal data
    1. Browsing software settings
    2. To exercise all Your rights
    3. Prior consent from the User
    4. Data Retention
    5. Security
    6. Our policy regarding children
    7. Opt-out
  4. Intellectual Property
  5. Changes to this Policy
  6. About us

1. DEFINITIONS AND APPLICABLE LAW

1.1. DEFINITIONS

“You”, “Your”, “Yours”, “User(s)” designates any natural person who accesses, uses or is registered with one of Our services governed by this Privacy Policy, who consults, or is a member of one of Our Partners’ services and whose Personal Data and/or Browsing Data are processed by us, while respecting this Privacy Policy and its governing law.

 

“Numberly” designates a registered trademark of Numberly, a French stock corporation.

 

“Numberly”, “We”, “Us”, “Our”, “Website(s)”, “Service(s)”, “Publisher”, or “Group”, designates the companies of Numberly Group and their Service Providers which may, under certain conditions described below, collect, use, store or share Browsing Data and Personal Data created or modified on these occasions: Your access to or Your use of the Website or of Our services, the receipt of an offer or advertisement issued by one of Our services, or a visit to one of Our Partners’ electronic communication services using Our Services.

 

“Service Provider(s)” designates any company that may process Data on Our behalf, in accordance with Our instructions.

 

“Partner(s)” designates any company other than those composing the Numberly Group, their Service Providers and Third Parties, bound to the Numberly Group by a contract related to one of Our Services.

 

“Third Party”, “Third” designates any company(s) or public entity or entities (judicial power or administrative authority) other than Us, Our Service Providers, and Our Partners.

 

“Device(s)” designates the equipment (computer, smartphone, telephone etc.) that You use in order to access the Website, to use one of Our Services, to receive offers or advertisement issued by Our Services, or to consult one of Our Partners’ electronic communication services.

 

“IP Address(es)” designates the identification number allocated by Your Internet access provider to Your Device at the time of its connection to the Internet via the Internet protocol (TCP/IP: Transfer Control Protocol/Internet Protocol), which We may process when You consult the Website, one of Our Services, or one of Our Partners’ electronic communication services using Our Services.

 

“Cookie(s)” designate(s) a text file that can be recorded, subject to Your rights resulting from the Privacy Policy, in a dedicated area of the hard disk of Your Device, when You consult one of Our services or one of Our Partners’ electronic communication services using Our Services. A Cookie file allows its issuer to identify the Device on which it is recorded, throughout the period during which the Cookie is valid or recorded.

 

“Browsing Data” or “Browsing” designates data relating to the connection of a Device to the Internet or to an electronic communication service at a given moment. We may process Browsing Data under the conditions set out under this Privacy Policy, even if We do not necessarily know which Device You are using, or who You are at a given moment.

 

“Personal Data” designates, within the framework of Our Privacy Policy, data relating solely to You at a given moment, independently of the Device You use.

 

1.2. APPLICABLE LAW AND CONTROL MECHANISMS

Our Users’ rights, governed by Our Privacy Policy, are related to the processing of Personal Data and Browsing Data performed by Numberly, which principal place of business is settled in the French territory, and are subject to French law and to the international texts and treaties applicable in France.

 

The Numberly Group protects the Personal Data and Browsing Data of Users in accordance with the strictest applicable European and French laws (i.e. the GDPR and French Act No. 78-17 of 6 January 1978 as amended, known as the “Loi Informatique et Libertés” (French Data Protection Act)). The processing of Personal Data carried out within the framework of Our Services is subject to continuous internal compliance controls performed by our appointed Data Protection Officer (“DPO”) to the French Data Protection Authority (“Commission Nationale de l’Informatique et des Libertés” / www.cnil.fr). You can contact our DPO for any further information, at any time, by contacting dpo@numberly.com.

 

This Privacy Policy does not apply to services or Data processing implemented by Our Partners, or to Third Parties services outside of the Numberly Group.

2. BROWSING DATA PROCESSED BY NUMBERLY

Since its creation, Numberly has always strived to foresee consumers’ and Internet users’ expectations, both with regard to the protection of their privacy, and in commercial matters. Our ultimate ambition is to send offers or advertising contents to Our Users which can indeed interest them and which are more consistent and less frequent than those distributed by our competitors.

 

Thus, We may process Browsing Data attached to Your Device(s) and to the web browsers You use on Your Device(s).

2.1. WHAT IS BROWSING DATA?

It concerns, in particular,

  • the IP (Internet Protocol) address of the Device connected to Internet,
  • the date and time of connection of a Device to an electronic communication service,
  • the URL (Internet address) of the web page from which (“referrer”) the Device accesses an electronic communication service,
  • the URL (Internet address) of the Internet page accessed by the Device consulting an electronic communication service,
  • the type of operating system used by the Device (Windows, Mac OS, Linux, Unix, BeOS. etc.),
  • the type and the version of the web browser used by a Device (Internet Explorer, Safari, Firefox, Chrome, Opera, etc.),
  • the language of use of the web browser used by the Device,
  • the identifier and the content of a Cookie file stored for the purposes of Our Services in the Device.

We use Cookies to determine how often You’ve visited a website or seen an ad by assigning an anonymous identifier to Your browser. We do not use Cookies to access other data on Your Device.

2.2. WHAT TECHNOLOGIES DO WE USE?

Technologies such as Cookies, beacons, pixels, tags, and scripts are used by Numberly and our affiliates, or analytics, or Service Providers (e.g., video providers and email service providers to send email on our behalf) for the provision of Our Services. These technologies are used in analyzing trends, Users reactions, interactions and interests, location and movements, to gather demographic information about Users as a whole, and for Our Services management purposes. We may receive and establish report based on the use of these technologies by Us or by these companies on an individual, as well as and aggregated basis.

 

Additionally, some of our Third Party Service Providers, with whom We Partner, may use Flash Cookies to collect and store information to better provide You with video content. Cookie management tools provided by Your browser will not remove Flash Cookies.

 

As is true of most websites, We may also gather certain Browsing Data automatically and store it in log files.

 

Some of Our Partners or the website publishers with whom We work may place their own Cookies on Your Device or your browsing software outside of our Services. However, We have no access to or control over these Cookies, which are not governed by this Privacy Policy.

2.3. CROSS-DEVICE AND CROSS-APP TECHNOLOGY

We, Our Third Party Service Providers and Our Partners may use technology that establishes deterministic or statistical correlations among related Devices (such as smartphones, tablets, and computers) to deliver more relevant advertising to You and for advertising analytics and reporting purposes. For example, Numberly, Our Third Party Service Providers, and our Partners may match Your Devices if You log into the same online service on multiple Devices or web browsers, or if Your Devices share similar attributes that support an inference that are used by the same person or household. This means that information about Your use of websites or applications on Your current Device may be combined with information from Your other Devices. This allows, for example, ads You see on Your tablet to be based on activities You engaged in on Your smartphone.

 

We may partner with Third Parties to provide such cross-Device technology to Our customers, and We may share anonymous identifiers (such as Cookies or Your mobile Device’s IDFA or Google Advertising ID) with those Third Parties to make connections among related Devices. We may also use Your Device’s IP address to infer connections among related Devices within the same household.

 

We, Our Third Party Service Providers and Our Partners, may collect information about Your activity across multiple unaffiliated Third-Party websites or mobile applications. We may share this information with Our Partners to help them predict the types of ads that may interest You and to display advertising to You based on that information. For example, if You use a travel app, We or Our Partners may display travel-related ads to You on another app. We, Our Third Party Service Providers or Our Partners may combine this information with a mobile advertising identifier (such as Your mobile Device’s IDFA or Google Advertising ID).

2.4. WHAT TYPE OF INFORMATION DO WE COLLECT?

Numberly collects a variety of Browsing Data to help target online advertising to You or Your Device based on Your interests. This includes information about Your Device’s hardware and software attributes and Your online behavior on our Services or on Our Partners’ electronic communication services using Our Services, including Your browser type and version (e.g., Firefox or Internet Explorer), operating system (e.g., Macintosh or Windows), Internet provider (e.g., Verizon or Comcast), Your IP address and domain name, the pages that You visit on Third-Party services, and the actions that You take on those services, the date and time of Your visits to such Third-Party services, and whether You respond to an online ad or electronic offer sent by e-mail or text message.

 

To provide relevant advertising for mobile Users, We may also collect, Device type, make and model, operating system, mobile advertising identifiers, operating system Device identifier (for example, IDFA for iOS and Android ID for Android), and information about the apps You or You Device use. We may also use the GPS location of Your Device if You have opted-in to provide it to one of Our Partners.

 

Our Services are not designed or intended to collect sensitive data, which may include information related to health data, Social Security Number, insurance plan numbers, financial accounts numbers, and User’s sexual orientation.

2.5. WHAT DO WE USE IT FOR?

2.5.1. FOR MAKING OUR SERVICES SECURE

Legally, certain pieces of Browsing Data have to be kept in order to allow Us to ensure the security of Our electronic communication services and to detect, avoid, and find attempted cases of criminal intent, computer system intrusion, or violation of the conditions of use of Our Services. This is the case with regard to the IP address and the dates and times of connection of a Device to one of Our Services.

2.5.2. FOR OUR SERVICES’ ANALYTICS AND INVOICING PURPOSES

We may process Browsing Data based on Your receipt or consultation of electronic mails or online advertising resulting from Our Services and to measure the receipt and reading of Our e-mails. This Browsing Data may result from the Cookies We use within the electronic mails that We distribute, subject to the choices expressed by the Users concerned in their web browsers and to Us.

We may process Browsing Data when We receive or consult an electronic survey that We have sent to a Member. This Browsing Data may result, in particular, from the storage and/or reading of Cookies that We operate within emails distributed by Us, subject to the choices expressed by the Member concerned in their browser software and with Us.

This Browsing Data allows Us:

  • to count the Devices receiving and accessing electronic messages sent by Us or by our Partners to Our Services’ Users,
  • to establish statistics of receipt and consultation by the Users of the electronic messages that We or our Partners send to them and,
  • to establish reports and base for invoicing Our Partners for Our services.

2.5.3. FOR ADAPTING ELECTRONIC MAILS TO RECEIVING USERS’ INTERESTS

We may process Browsing Data concerning the reaction of Users to electronic mails (e-mail, SMS, MMS) that We or our Partners have sent them.

This Browsing Data, associated with a Cookie issued by Us or one of our Third Party Service Providers, also concerns consultation of Our Partners’ electronic communication services via Users’ Devices.

We might also use Browsing Data in combination with our Partners’ customer relationship management data including Personal Data, as the case may be.

However, when a User’s Device is used by several persons, and when the same Device possesses several web browsers, We cannot make sure that the electronic messages sent to the Users correspond to their own use of their Device and not to the use of their Device by a third party.

If necessary, sharing use of their Device with other persons comes within the User’s free choice and responsibility. In addition, the Users’ management of the parameters for the protection of their privacy offered by their Device’s web browser(s), comes within their free choice and their sole responsibility.

2.5.4. FOR ADAPTING ELECTRONIC ADVERTISING DISPLAYED ON DEVICES

The Browsing Data allows Us to adapt the content or display of an electronic advertising to the User’s Device, while determining:

  • the language used by the User’s Device,
  • the display resolution of the content of the electronic mail (banner, inventory, interactive offers, products or services recommender, e-mail, SMS, MMS) that We send, according to the screen of the addressee User’s Device,
  • the contents that the User’s Device can display or read, according to the graphics card and the display or reading software that the Device possesses.

2.6. HOW INFORMATION IS SHARED?

We may share Personally Identifiable Information (“PII”) or Personal Data as well as Non-PII or Browsing Data with certain Third Parties Service Providers selected by Us to help support Our operations, including improving Our website, software, or the Services We provide to Our Partners. These Third Parties may have access to Your information only for purposes of performing tasks on Our and Our Partners’ behalf, and We contractually require them to protect Your Personal Data consistent with this Privacy Policy.

We may share the Non-PII that We receive from our Partners’ websites with the Partner that permitted Us to collect the information.

We sometimes make our Non-PII or Browsing Data available, in aggregated or anonymized format, To our advertising clients, business customers and business Partners, and other Third Parties, for data analysis purposes.

We may also transfer all or some of the information discussed in this policy in connection with a corporate merger, acquisition, sale of assets, bankruptcy, or other change in corporate status.

Finally, We reserve the right to disclose information We receive to government, law enforcement officials, or to private parties as We, in our sole discretion, believe necessary (i) to satisfy or comply with any applicable law, regulation, or legal process; (ii) to respond to lawful requests, including subpoenas, warrants, or court orders; (iii) to protect our property, rights, safety and the rights, property, and safety of Third Parties, or of the public in general; and (iv) to prevent or stop activity We consider to be illegal or unethical.

3. USERS’ RIGHTS WITH REGARD TO USE OF THEIR PERSONAL DATA

3.1. BROWSING SOFTWARE SETTINGS

The recording of Cookies in Devices is subject to the wishes of the User of the Device. The latter can express and change these wishes at any time via the choices and settings offered to a User by his web browser.

If, in Your web browser, You have refused the recording of Cookies on Your Device, or if You delete the Cookies that We have recorded there, We will not be (or will no longer be) able to carry out the processing of Your Browsing Data described above.

3.2. TO EXERCISE ALL YOUT RIGHTS

In accordance with applicable regulations, You have the right of portability and the right to access, rectify, delete, limit and oppose the Processing by Numberly of Your Personal Data and Browsing Data and profiling of Your data.

You may exercise these rights at any time by contacting Numberly and the Data Protection Officer at the following address: dpo@numberly.com.

We will respond to Your requests within a maximum of one (1) month from receipt of Your request.

3.3. PRIOR CONSENT FROM THE USER

In accordance with the applicable regulations, Numberly informs Users, by means of an information banner that will appear when they first visit the Website, that by continuing to browse the Website, Users accept the use of Cookies to provide adapted services and offers in line with their areas of interest.

Users may be informed about the Use of Cookies and refuse such use by clicking the link provided or by consulting this Charter.

The User’s consent is valid for 13 months. At the end of this period, the information banner relating to Cookies will be displayed again to reobtain the User’s consent.

Cookies will not be stored or read if the User goes to the Website and does not continue browsing, this lack of action constitutes implicit refusal to use Cookies.

The same applies if the User clicks the link in the information banner to set Cookies and if necessary, refuses the storage of Cookies.

If You have accepted the registration of Cookies in Your Terminal within Your browser, the Cookies that We issue may be temporarily stored in a dedicated area of Your Terminal. In these cases, We may process Your Browsing Data as described above.

If, prior to Your visit to the Website, You used Your browser software to refuse the storage of Cookies in Your Terminal, Numberly Cookies will not be activated when You visit the Website.

3.4. DATA RETENTION

Our Cookies recorded expire after thirteen months or less. After thirteen months, We expire the unique ID and targeting segments that are associated with Your web browser or Device. We retain Browsing Data and log-level data for up to thirteen months and maintain aggregate data (which cannot be associated to any individual Device) for up to three years.

3.5. SECURITY

We use physical, administrative, and technical safeguards that are designed to protect the Personal Data that We collect and maintain. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse.

3.6. OUR POLICY REGARDING CHILDREN

Numberly does not knowingly collect or solicit information from anyone under 13 years of age. Our services are not directed to children under 13. Our Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information of a child under 13 without parental consent, We or our Partners will delete such information. If You believe that We might have any information from a child younger than 13, please contact us as set forth below in Section 5 below.

3.7. OPT-OUT

You may directly opt out of Numberly’s Interest-Based Advertising by clicking the link https://mmtro.com/privacy/en or, by configuring Your browsing software: to find the options offered by your browsing software and the methods of accepting, refusing, reading or deleting Numberly Cookie files or those of their Providers, We invite you to read the following pages depending on the browsing software that You use:

 

Finally, to opt out of Numberly’s Interest-Based Advertising in mobile applications, please download the AppChoices mobile application for your Device operating system and set your preferences in the application.

4. INTELLECTUAL PROPERTY

The layout and all elements of the Website, including trademarks, logos and photographs, domain names and graphic elements, belong exclusively to Numberly and are protected by intellectual property laws.

The provisions of this Charter are also protected by copyright and are the exclusive property of Numberly. They may not be reproduced or used, in whole or in part, for the purposes of any professional activity other than journalism or legitimate public information, without Numberly’s prior written permission.

5. CHANGES TO THIS POLICY

We may update Our Privacy Policy to reflect changes to Our data management practices. If We make any material changes to this Privacy Policy, We will notify You by means of a notice on this website prior to the change becoming effective. We encourage You to periodically review this page for the latest information on our privacy practices.

6. ABOUT US

1000Mercis Inc. (Numberly) is incorporated under the laws of the state of New-York.

 

Address: 134 N 4th St, Brooklyn, NY 11249

 

Phone: +1 646 619 1138

 

Email: 1000mercis Inc. (Numberly) may be contacted for any questions by writing to dpo@numberly.com

 

Numberly may act, depending on the situation, as the Processor for Our Partners who entrust us, under their responsibility, with the mission of processing Your Data on their behalf and under their instructions, as part of the Services that we provide to them. In the latter case, the legal basis on which Numberly processes Your Personal Data is the one under which Our Partner is likely to Process Your Personal Data.

 

The website numberly.com is hosted by Amazon Web Services LLC, P.O. Box 81226, Seattle, WA 98108-1226, https://aws.amazon.com.

 

 

Latest update: 04/19/2023