End-Users Privacy Policy

Summary

Equativ (ex Smart AdServer) is a French company specializing in digital advertising. Our clients and supply partners (“Supply Partners”), in particular website publishers, mobile applications or ad monetization platforms partners, ask us to select and display ads on their environments, according to various criteria, such as your interests, your location, the type of device used, or the content of the page visited, etc.

We only process your personal data necessary for the personalization of the advertisements if you give us your consent (through the banners set up by the publishers). Your personal data  is protected according to security standards in compliance with applicable laws.

You will find on this page all the details on our operation and the various means to assert your rights.

1. Who are we?

Equativ (“Equativ”, “our”, “us”, “we”) is an ad monetization platform, Supply Side Platform (“Platform”) providing programmatic buyers with exclusive access to high quality premium publisher inventory, i.e. the websites you are visiting and/or services you are using. As an independent, publisher-focused platform, we help our Supply Partners monetize their digital inventories (“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 display ads on any connected devices you are using to deliver, tailor advertising to you, when permitted and for statistical reporting and analytics purposes, as explained below.

Equativ 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 privacy@equativ.com.

The purpose of this Privacy Policy is to explain what information we gather, for which purposes, how we use that information and what we do to protect it in the context of the provision of our services to our Supply Partners. This policy provides details about choices you can make with regards to how we gather and use information about you (“Personal Data”). This Privacy Policy applies when we receive your Personal Data when navigating on websites, mobiles and/or applications of our Supply Partners using our Services and/or on any connected devices. Our network of Supply Partners includes a large variety of companies among which Google ; please refer to Google’s website in order to understand how Google uses information from sites or apps that use their services as well as cookies and similar technologies used by Google in their advertising products. For more information regarding the processing of your Personal Data when navigating on our corporate website please read our Corporate Privacy Policy here. For more information on the cookies used when navigating on our corporate website, please check our Cookies Policy here.

Equativ participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies.Our identification number within the Framework is ID45.

2. How do we collect data?

Equativ 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 Equativ 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 Supply Partners to integrate Equativ to their mobile application (iOS and Android).

Web beacons are used to help our Supply Partners understand how visitors interact with their websites. Pixel tags are transparent images, iFrames, or JavaScript that are placed on a site. The use of a pixel tag allows a website to measure the actions of the visitor opening the page that contains the tag.

3. What data do we process?

When navigating on our Client’s websites, mobiles and/or application and/or on any connected devices (including connected TV) we may collect:

  • – your IP address;
  • – cookie information, for example your unique browser ID (Equativ ID; universal identifier when applicable);
  • – 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 name, your address, your place of work, your date of birth, your email address, or your phone number. We do not collect sensitive information as defined under the General Data Protection Regulation  (such as your religious affiliation, political opinions or health details). We do not create segments and do not specifically target children under 13 years old or 16 years old respectively according to applicable laws

Under US Privacy laws, we may process sensitive personal information such as precise geolocation only in in-app environments. 

4. For which purposes and on which legal grounds will Personal Data be processed?

a. Purposes

Equativ receives, collects or processes Personal Data for the following purposes:

  • – Store and/or access information on a device;
  • – Select basic ads;
  • – Select personalized ads;
  • – Measure ad performance;
  • – Develop and improve products;
  • – Ensure security, prevent fraud, and debug;
  • – Technically deliver ads or content;
  • – Use precise geolocation data, where applicable.

b. 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 either: i) User consent, if required; or ii) our legitimate interest.

When we are operating as a data processor, we are processing the data on behalf of our Supply Partners based on their instructions. Therefore, they are accountable for the establishment of an appropriate legal basis for the processing of the data. You can find this information in their own Privacy Policy available on their website.

5. To whom do we provide your Personal Data? Who can have access to your Personal Data?

We may share information, including Personal Data, to our affiliates and with trusted third parties that provide services for Equativ, such as hosting and internet connectivity, Demand-Side Partners (DSP), third-party data providers or advertisers, and anti-fraud tools providers. When permitted 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.

6. How long do we store the data?

The data we use to provide our Services is being kept up to thirteen months, depending on the cookie or tag storing it. For more details about the storage duration, please see the table below.

We may also store your personal data contained in our logs for up to 50 days.

7. Your GDPR privacy rights

When we are operating as a data controller, you can exercise your rights and address your request directly to Equativ. Please note that we process Personal Data on behalf of Publishers, which means that  in some cases, it may be appropriate for you to exercise your rights directly on the website of the concerned Publisher.

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 EquativID and/or mobile ID and we will be able to connect to this information with the Personal Data tied to this ID (see section: How to find your advertising ID below).

Your request should be addressed to privacy@equativ.com. 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 for any extension to you. If we deny your request, we will inform you of the reasons for 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 advertising ID

How to find your EquativID on a browser:

You have the possibility to oppose the deposit of cookies and to have access to a list of your cookies by configuring your browser.

  • – Chrome: Follow the primary instructions under “Delete cookies from a site” section. Search for equativ.com. Click on it and search for the cookie named “pid”. You can find your ID number under “Content”.
  • – Mozilla: Follow the primary instructions under “Delete cookies for a single site”. Search for equativ.com. Search and click on the “pid” cookie. You can find your ID number under “Content”.
  • – Opera: Follow the instructions under Configuring cookie settings and “Manage cookies”. Search for equativ.com. Search and click on the “pid” cookie. You can find your ID number under “Content”.
  • – Safari: Follow the primary instruction under “Remove stored cookies and data”. Search for equativ.com. Search and click on the “pid” cookie. You can find your ID number under “Content” in the pid.

The links above will also guide you for the management and erasure of cookies within your browser.

How to find your ID on mobile:

  • – If you are using an iOS system (IDFA): for iOS devices, the advertising ID is hidden from users by default by Apple but can be retrieved with third-party apps. In order to find your Apple IDFA, a third party tool is required. There is wide selection of apps that can show a device’s IDFA to users
    • – Adjust Insights by Adjust
    • – Branch Device ID Finder, by Branch
    • – My Device Identifiers, by Kochava
    • – Singular Device Assist, by Singular Labs
  • – If you are using an Android system (AAID): for Android devices, open the Google Setting app on your device and click on “Ads”. Your AAID will be listed at the bottom of the screen.

8. Your Privacy Rights under U.S Privacy laws

This section of the Privacy Policy aims at providing information on the relevant U.S Privacy laws and particularly the rights therein (under the California Consumer Protection Act (CCPA), Virginia Consumer Data Protection Act (VCDPA), Colorado Privacy Act (CoPA), Connecticut Data Privacy Act (CTDPA), Utah Consumer Privacy Act  (UCPA)

When you are navigating on our Client’s websites and/or using their apps on your devices, we may collect Personal Information, notably via the use of cookies or other tracking technologies as a Third Party, Processor, or Controller/Business as the case may be.

For information on the categories of personal data or information we collect, the sources from which such data or information is collected, the purposes of collecting such data or information and with whom we may share those, please refer to the sections above.

Under the abovementioned Privacy laws you have the following rights:

US Privacy lawsApplicable Privacy Rights
CCPAThe Right to know about the personal information we collect and how we use it. For more information please refer to the ‘what data do we process’ section above or contact us directly. 
The Right to Delete. Upon your request, we will delete the personal information we have collected about you ,subject to applicable legal exceptions. 
The Right to Opt-Out of the Sale or Sharing of your personal information. As we do not directly face End-Users, our client Publishers do, you will need to exercise such rights directly to such Publisher. You can also opt-out through the following link: 
The Right to Correct inaccurate personal information that we may have on you.
The Right to limit the use and disclosure of sensitive personal information collected, where and if applicable.
The Right to Non-Discrimination for the exercise of a Consumer’s Privacy Rights. We will not deny goods or services, charge you a different price, or provide a different level or quality of goods or services because you exercised your rights under the CCPA.
VCDPAThe Right to Confirm if we are actually processing your personal data and to Access such personal data.
The Right to Correct inaccuracies in your personal data that we have collected taking into account the nature of the personal data and the purposes of the processing 
The Right to Delete personal data provided by you or obtained about you,  subject to applicable legal exceptions. 
The Right to Obtain copies of the personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another controller without hindrance, where the processing is carried out by automated means.
The Right to Opt out of the processing of personal data for purposes of targeted advertising or the sale of personal data or, where and if applicable, profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
CoPAThe Right of Access and to Confirm  whether the processing of your personal data concerning you.
The Right to Correct any inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of such personal data. 
The Right to Delete your personal data, subject to applicable legal exceptions. 
The Right to Data Portability. When exercising the right to access personal data you also have the right to obtain the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance, provided such transfer shall not be required to reveal any trade secret. Please note that under Colorado Privacy law, you may exercise such right no more than two times per calendar year.  The Right to opt out of targeted ads, the sale of their personal data, or, where and if applicable, profiling in furtherance of decisions that produce legal or similarly significant effects on you. 
CTDPAThe Right to Confirm whether or not your personal data is being processed and Access such personal data, unless such confirmation or access would require us to reveal a trade secret. 
The Right to Correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing.
The Right to Delete personal data provided by, or obtained about you.
The Right to Obtain a copy of your personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means, provided such controller shall not be required to reveal any trade secret. 
The Right to Opt out of the processing of the personal data for purposes of targeted advertising, the sale of personal data, or, where and if applicable, profiling in furtherance of solely automated decisions that produce legal or similarly significant effects on you. 
UCPAThe Right to Confirm the processing of your personal data and to Access your personal data. 
The Right to Delete your personal data, provided legal exceptions. 
The Right to Obtain a copy of your personal data, in a format that: (a) to the extent technically feasible, is portable; (b) to the extent practicable, is readily usable; and (c) allows you to transmit the data to another controller without impediment, where the processing is carried out by automated means. 
The Right to Opt out of the processing of the consumer’s personal data for purposes of: targeted advertising or the sale of personal data.
Nothing in the exercise of such rights should be construed as a requirement for us to disclose any trade secret. 

When we are operating as a Data controller or Business, you can exercise your rights and address your request directly to Equativ by contacting us at privacy@equativ.com

Please note that we do not directly face End-Users, our client Publishers do, in such case, it may be appropriate for you to exercise your rights directly on the website of the concerned Publisher. For example, you can opt-out of the processing of your personal data or information for a sale, share or targeted advertising by clicking on the link “Do not sell or Share My Personal Information” or by directly contacting their privacy team.

To appeal our  decision regarding a request related to these rights, you may email us at privacy@equativ.com . 

9. Transfer of Personal Data outside of the European Union

Personal Data may be transferred to our affiliates or a partner located outside the EU/EEA including to third-countries for which the European Commission has not adopted an adequacy decision yet. With these partners, we ensure that appropriate safeguards are implemented to ensure an adequate level of protection including but not limited to the signature of standard contractual clauses adopted by the European Commission.

10. Opt-out and withdrawing of consent (GPDR)

For the sake of transparency, Equativ 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 Equativ 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.

You can also accept or reject some or all cookies (for example, blocking all third-party cookies) directly on your browser by adjusting your browser settings. However, please note that some websites may not be accessible or function properly if you decide to opt-out from all cookies. If you do not know how to do this, the links below set out information about how to change your browser settings for some of the most commonly used web browsers:

For mobile devices you can also refer to the following links:

11. How do we ensure the security of your Personal Data ?

In order to ensure and maintain the security of your Personal Data, we have implemented all technical and organizational measures at our disposal to prevent your data from being unintentionally and accidentally lost, used, altered, or made available to the public without your authorization.

Should such an event occur, we have implemented measures to react promptly and to inform you and the competent authorities when necessary.

12. Amendment of this Privacy Policy

We reserve the right to update this Privacy Policy from time to time in order to reflect any change to our products or services or to comply with changes in our legal and/or regulatory obligations. Please check this page for any updates.

13. More questions?

If you have questions about this Privacy Policy, you may e-mail us at privacy@equativ.com or contact our DPO at dpo@equativ.com.

Last update: April 202