- 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,
Numberly is a member of the Network Advertising Initiative (NAI) and complies with the 2020 NAI Code of Conduct.
You may opt out of Numberly and other NAI members on the NAI website, (see section 3.5 below).
- Definitions and applicable law
- Applicable law and control mechanisms
- Browsing data processed by Numberly
- What is Browsing Data?
- What technologies do We use?
- Cross-Device and Cross-App Technology
- What type of information do We collect?
- What do We use it for?
- For adapting electronic mails to receiving Users’ interests
- For making Our Services secure
- For Our Services’ analytics and invoicing purposes
- For adapting electronic advertising displayed on Devices
- How Information is shared?
- User’s rights with regard to use of their personal data
- Browsing software settings
- Data retention
- Our policy regarding children
- Opt-out Mechanisms
- Cookies opt-out
- Email opt-out
- Changes to this Policy
- About us
1. DEFINITIONS AND APPLICABLE LAW
“Numberly” designates a registered trademark of Numberly, a French stock corporation.
“Numberly”, “We”, “Us”, “Our”, “Website(s)”, “Service(s)”, “Publisher”, “Numberly (1000mercis Group)”, or “Group”, designates the companies of Numberly 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 Numberly, their Service Providers and Third Parties, bound to Numberly 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.
1.2. APPLICABLE LAW AND CONTROL MECHANISMS
Numberly protects the Personal Data and Browsing Data of Users in accordance with the strictest applicable European and French laws. 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” / cnil.fr). You can contact our DPO for any further information, at any time, by contacting firstname.lastname@example.org.
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.
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.
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 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 to use it for Personalized Advertising purposes.
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.
2.5.2. 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.
2.5.3. 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. 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.
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.
2.5.4. 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 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. 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 and aggregate data which cannot be associated to any individual Device for up to three years.
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.
3.4. 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.
3.5. OPT-OUT MECHANISMS
3.5.1 .COOKIES OPT-OUT
You may directly opt out of Numberly’s Interest-Based Advertising by clicking the link https://mmtro.com/privacy/en/
Please note that:
- When You opt-out, it only concerns the browser on the Device You’re opting-out from. You need to repeat this action on every browser of every Device You wish to opt-out from.
- If You clear your Cookies from Your browser, You will need to opt-out again.
You may also opt out of Numberly and other NAI members on the NAI site.
3.5.2. EMAILS OPT-OUT
A user can opt out of Our use of its email adress by writting to Us at: email@example.com
4. CHANGES TO THIS POLICY
5. ABOUT US
1000Mercis Inc. (Numberly) is incorporated under the laws of the state of New-York.
Address: 109 South 5th Street, NY 11249Phone: +1 917 562 7636
Email: 1000mercis Inc. (Numberly) may be contacted for any questions by writing to firstname.lastname@example.org