Smart (“Smart”, “our”, “us”, “we”) is a fully transparent ad monetization platform, Supply Side Platform (“Platform”) providing programmatic buyers with exclusive access to high quality premium publisher (“Clients”) inventory. As an independent, publisher-focused platform, we help our Clients monetize their websites (“Services”) so that they can continue offering users (“Users”, “you”, “your”) content.
Our technology gathers User information to optimize the delivery of digital advertising to you. We use this information to effectively tailor advertising to you and for statistical reporting and analytics purposes, as explained below.
Smart AdServer is located at 66 rue de la Chaussée d’Antin, 75009 Paris, France. If you have any questions regarding privacy, you can contact us at email@example.com.
Smart uses technologies like cookies, tags, and mobile SDKs to collect the data and store it on a user’s device.
Cookies are small text files that contain a string of characters, stored in the user’s device. They allow us to recognize and remember the user’s browser, preferences and other information.
The Smart tag is a small piece of code that is inserted into a Client’s website source code, which allows them to have access and manage our services.
An SDK, or Software Development Kit, is the software used by our Clients to integrate Smart to their mobile application (iOS and Android).
-cookie information, for example your unique browser ID;
–technical information about the device: browser, operating system, screen size;
–information about the geographic location of the device when it accesses a website;
-pseudonymous ID of audience segmentation (if the website uses this type of system);
-information about other identifiers assigned to the device (IDFA, AAID);
-information about the user’s activity on the device, including web pages and mobile apps visited or used.
Please note that as part of our Services we do not collect any information that could directly identify you. This means we do not know who you are. We do not know your address, your place of work, your date of birth, your email address, or your phone number. We do not collect sensitive information (such as your religious affiliation, political opinions or health details). We do not create segments to specifically target children under 16 years old.
Smart does not receive, collect or process information unless it is used for the following purposes:
–to perform our Services to our Clients, including providing, operating, managing, maintaining and enhancing our Platform;
-to improve our performance;
-to perform interest-based advertising and increase the relevancy of the ads being displayed to you;
-to perform optimization in respect to a campaign, including to limit the number of times you see a particular ad;
-to customize ads to a particular location;
-to show ads related to the content of the concerned web page;
–to report aggregated statistics (for example, to understand the effectiveness of an online advertising campaign);
-to secure, amend and improve our Services;
In some cases, if our Client requests it, and if you gave your clear and informed consent during the course of our Services, we will analyze your information to build individual profiles. These profiles will be used to predict future interests and display targeted advertisements, with the aim of providing you with relevant and interesting offers. The profiling is based on your behavior on our Client’s website. As we do not collect information to directly identify you (your name, for example), we expect that our Services will have no further impact, other than providing you with a good user experience when visiting our Clients’ websites.
2. Legal Grounds
When we are operating as a data controller, meaning that we determine the purposes and the means of the processing, we rely on:
i) user consent, if required; or
ii) our legitimate interests to
-decide which buyer and creative wins an auction to purchase advertising inventory;
-optimize the real-time purchase and sale of advertising inventory.
We may share information, including Personal Data, with trusted third parties that provide services for Smart, such as hosting and internet connectivity. We may also share data with trusted business partners in order to perform or enhance our products and services.
We may also disclose information if:
-we are required by national or international law or legislation to do so;
-we must comply with an authorized request or demand;
-it is necessary in order to defend our own rights or interests.
Finally, we may transfer your data to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.
The data we use to provide our Services is being kept between two days and thirteen months, depending on the cookie or tag storing it. For more details about the storage duration, please see the table below.
Once the duration period has been reached, the data is then no longer active. For security and regulatory purposes it is stored in our archive databases in compressed form for a maximum of 36 months.
When we are operating as a data controller, you can exercise your rights directly to us.. Please note that we do process Personal Data on behalf of Publishers. In some cases, it may be appropriate for you to exercise your rights directly on the website of the Publisher of your choice.
You may ask us at any time:
-to confirm your Personal Data is being processed and/or to provide you a copy of your Personal Data;
-to rectify your Personal Data if it is inaccurate or incomplete;
-to withdraw your consent;
-to erase your Personal Data, for instance if it is unlawfully processed or if you withdraw your consent;
-to opt out the process of any data;
–to restrict the processing of your Personal Data, (i) if the information is inaccurate, (ii) the processing is unlawful, (iii) you need us to retain the information after the retention for a legal claim, or (iv) you have objected to the processing and a verification of our legitimate interests is pending;
–to provide you with an electronic file of your Personal Data, or to transfer your Personal Data to a third party, if technically feasible (portability).
Before sending any requests, please note and consider that it is not feasible for us to provide Personal Data that is tied to your identity. Instead, you can provide us with your Smart AdServer ID and we will be able connect this information with the Personal Data tied to this ID (see section: How to find your Smart AdServer ID below).
Your request should be addressed to firstname.lastname@example.org. We will respond within one month. If permitted under applicable legislation, we may extend the response period to two months if such is necessary due to the complexity and number of requests. We will notify and explain the reasons of any extension to you. If we deny your request, we will inform you of the reasons of such denial.
If you consider your rights have been infringed upon according to the current privacy regulation, or regarding the denial of a request, you may lodge a complaint towards your local competent supervisory authority.
|How to find your Smart AdServer ID|
You have the possibility to oppose the deposit of cookies and to have access to a list of your cookies by configuring your browser.
The links above will also guide you for the management and erasure of cookies within your browser.
Personal Data may be transferred to a partner located in a third country not providing adequate protection regarding data protection. With these partners, we sign standard contractual clauses adopted by the European Commission to ensure an adequate level of protection.
When Personal Data may be transferred in the United States of America, we ensure that the other party is complying with the Privacy Shield Framework, regarding the collection, use and retention of personal information transferred from the European Union to the United States, respectively.
For the sake of transparency, Smart has adopted a cookie opt-out policy, allowing each Internet user to opt out from our advertising network. This ensures that your browser will no longer be identified by our system. Please note that for us to acknowledge your desire to opt-out, one cookie will be placed on your device in order to ensure the performance of your opt-out. Moreover, this opt-out will only be available for the device on which it was created.
If you wish to opt-out, click here. A blank page will open, confirming the opt-out process has been completed and Smart will no longer place cookies on your computer.
You can withdraw your consent, as the case may be, at any time directly on the website.
Last updated on: 05/22/2018