PixelProse Privacy Policy

This privacy policy ("Privacy Policy") describes how we collect, use, store, and share information about end users of our Apps (referred to as "you," "your," and "yourself"). The Privacy Policy also describes certain choices you have regarding use, access to and correction of your information.

If you are a user located in the European Union, you might want to view your rights under the GDPR Section of this Policy.
If you are a user located in California, you might want to view your rights under the CCPA Section of this Policy.

What Information Do We Collect?

When using our Apps and Services we MIGHT collect certain information through or about the Device, in particular :

  • Precise Location Data, which means:

    • Geolocation of the Device, usually expressed by latitude-longitude coordinates obtained through GPS, WiFi data, cell tower triangulation and other techniques permitted by the Device’s operating system.
    • Dwell time near points of interest (or how long your device stayed at one place).
  • Relative Location Data, which means:

    • Bluetooth Low-Energy (BLE) sensors, or beacons.
    • Signals from the Internet of Things (IoT) devices.
    • Near-field Communication (NFC).
    • The GPS capabilities of our XDK allow it to receive signals from each of these technologies that show when a Device is close by. For example, many retail stores have beacons that detect when a Bluetooth-enabled Device passes by or goes into the store. Shopping malls, stadiums, restaurants, museums and other similar points of interest may also use beacons. The Relative Location Data we collect can be used for powering solutions in smart cities, government planning, security and law enforcement, financial or market research and technology ("Fin-tech"), or targeted advertising.
  • Advertising IDs (Android ID or iOS IDFA).
  • Time and Date Information.
  • Event information about your Device, which means:

    • Any crashes
    • System activity
    • Hardware settings.
  • Usage Data is automatically collected and cannot identify an individual user , which means:

    • Device type (i.e. iPhone 7).
    • Operating system version and type (i.e. iOS 13.2).
    • Device settings (i.e. whether or not you have enabled Location Services).
    • Device time zone.
    • Device carrier.
    • Current IP address.
    • Current Application

Our software may use anonymous, statistical or aggregated information collected and accessed through wireless and more specifically Bluetooth radios, by transmitting or otherwise communicating or making available such information to users of its Services, to the Services providers, partners and any other third party.

When Do We Collect It?

When the App is in use or running in the background is the associated permission is granted to the App AND only if you did not opt-out as described in Section "Consumer Choices & Opt-Out Options".

How Do We Use the Information We Collect?

When you download and use one of our App and have Location Services "On" and did not opt-out, both PixelProse SARL and our Trusted Partners can use the information collected by the App or received from Server to Server partners for any of the following purposes:

  • App functionalities
  • Inferences from Aggregated Data, such as Traffic Patterns and Research
  • Interest-Based Segments and Ad Targeting
  • Attribution
  • Audience Insights

Who Else Do We Share Information We Collect With?

We share the information we collect and receive both in order to operate our platform (such as with service providers) and in order to support the operations of our Trusted Partners. We may share the following information we collect from your Device:

  • With Our Trusted Partners:

    • We share Advertising IDs, Location Information, Usage Data, and interest segments created using that information, with our Trusted Partners.
    • Our Trusted Partners may include brands, data platforms, online advertising networks, and companies that perform research about consumer behavior, targeted or customized advertising, or human traffic patterns. You can learn more about our Trusted Partners here.
  • With Our Service Providers:

    • We contract with companies who help us with our business operations (for example, website and data hosting, fraud prevention, verification and reporting, data hygiene, marketing, and email delivery), as well as billing, collections, tech, Trusted Partner and operational support.
  • With Service Providers to Our Trusted Partners:

  • In Connection with Legal Proceedings or Process:

    • When we are under a legal obligation to do so, for example, to comply with a binding order of a court, or where disclosure is necessary to exercise , establish or defend the legal rights of PixelProse SARL, our Trusted Partners or any other third party or to satisfy in good faith any applicable law, legal process.
    • We likewise may disclose any information in response to a proper governmental request, a subpoena (whether civil or criminal) or a similar process.
  • To Investigate Wrongdoing and Protect Ourselves or Third Parties:

    • To enforce our rights and Terms of Service or other policies, or to investigate any potential violation of those Terms and policies, any potential violation of the law, or to protect ourselves, our Trusted Partners, or any third party from any potential harm (whether tangible or intangible).
  • In Connection with a Sale of Our Business:

    • If a third party acquires some or all of our business or assets, we may disclose your information in connection with the sale (including during due diligence in preparation for the sale).

Consumer Choices & Opt-Out Options

You may limit the disclosure of certain Information by your mobile device to PixelProse SARL and our Trusted Partners by adjusting the settings on your mobile Device. For iOS mobile devices, go to "Settings" from your Device’s home screen; scroll down to "Privacy"; select "Advertising"; and turn on "Limit Ad Tracking." For Android mobile devices, go to "Google Settings" on your device; select "Ads"; and check the box labeled "Opt Out of Interest-Based Ads.".

You may also prevent other information from being collected by our Apps directly from the App settings.

International Transfers

We may store and process your information in the European Union and the United States. By accessing our Apps Services, you understand that the information you provide to us may be stored in or (if applicable) transferred to the United States. You should be aware that certain privacy laws in the United States and the other countries regarding processing the information may be less stringent than in your country.

GDPR

The GDPR requires PixelProse SARL and those using our services to provide users with certain information about the processing of their "Personal Data" that identifies or can identify a particular unique user or device – for instance, names, addresses, cookie identifiers, mobile device identifiers, precise location data, and biometric data.

If you have any questions about PixelProse SARL data practices in the context of the GDPR, you may contact our Data Protection Officer at privacy@pixelprose.fr.

  • Legal grounds for processing your Personal Data: The GDPR requires us to tell you about the legal basis we’re relying on to process any Personal Data about you. The legal basis for us processing your Personal Data for the purposes set out in Sections 2 and 3 above (and Section 5 as to our corporate customer data) will typically be because:

    • You provided your consent. In order to provide our services that involve use of precise location information related to other Personal Data, (and to store and gain access to information stored on your device such as Advertising IDs), we rely on your consent. To obtain this consent, we rely on our own compliance steps and our web and mobile partners’ compliance steps, designed to ensure that consent is collected and passed on to partners, and to ensure that we only facilitate the collection of legally obtained data. We may choose to obtain consent in other cases as well, in which case we will adhere to applicable laws relating to such consent and its withdrawal. We also seek to obtain consent for certain partners with whom we work, who are often independent data controllers. We list these partners in our List of Partners, below.
    • The processing is in our legitimate interest. In some cases, we use legitimate interest as a legal basis for processing Personal Data. We rely on legitimate interest when we use Personal Data to maintain the security of our services, such as to detect fraud or to ensure that bugs are detected and fixed. We also rely on legitimate interest when we use our own customers’ data (or Visitors’ data) to communicate with them about our Services or analyze our own Site activity.
    • Contractual Relationships. Sometimes, we process certain data as necessary under a contractual relationship we have (such as our customer records and contact information).
    • Legal Obligations. Finally, some processing of data may be necessary for us to comply with our legal or regulatory obligations.
  • Transfers of Personal Data: When we transfer Personal Data outside of the EEA or Switzerland, we take steps to make sure that appropriate safeguards are in place to protect your Personal Data. In general, our data transfers of our Personal Data are safeguarded by European Standard Contractual Clauses and Data Processing Agreements where this is required by European Data Protection Law. Feel free to contact us at the contact information below for more information about the safeguards we have put in place to protect your Personal Data and privacy rights in these circumstances.

    • Personal Data Retention: As a general matter, we retain your Personal Data for as long as necessary to provide our Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. We generally retain Advertising IDs on the following schedule: we render Advertising IDs inactive for purposes of providing our services within 13 months from receipt of consent (or from any "refreshed" consent permitting us to continue to retain information), provided that we may retain data for longer periods, as needed, where we have fully de-identified such data in a manner so that it cannot be linked to Personal Data. Please note that we may retain this (and other) Information whenever and so long as we have a significant legal or operational need to do so, such as for auditing, corporate record-keeping, compliance accounting or security and bug-prevention purposes.
  • Your Rights as a Data Subject: The GDPR provides you with certain rights in respect of Personal Data that data controllers hold about you, including certain rights to access Personal Data, to request correction of the Personal Data, to request to restrict or delete Personal Data, and to object to our processing of your Personal Data (including profiling for online ad targeting).

    • Right to Access: If you wish to exercise your right to access Personal Data we process as a data controller, you may do so by requesting access through the e-mail address privacy@pixelprose.fr. When we receive your request, we will provide you with current, step-by-step instructions to follow in order to obtain access. As we are required to verify a requestor’s identity prior to providing Personal Data, we will assess requests to exercise certain data access rights on a case-by-case basis: in doing so, we consider (a) the difficulty of verifying whether data that we hold and data we have linked to it truly and solely belongs to the data subject making the request, along with (b) the potential adverse effects on disclosure of personal data to the wrong individual. Because such improper disclosure would likely adversely affect the privacy rights and freedoms of the data subject, we may limit the Personal Data we make available. Please note that we will only grant requests for access for Personal Data for which we are a data controller, as explained further in sub-section (e) below. Where we act as a processor for one of our customers, we will refer your request to that customer. Please identify the customer your request refers to (if possible), to simplify this process.
    • Right to Correct: If you wish to exercise your right to correct Personal Data, you may do so by contacting us at the contact information below.
    • Right to Object to Processing or to Withdraw Consent: By using the device-based "opt-out" signals described in Section 6 of this Privacy Policy, you may withdraw consent for processing on which we rely on consent. If you do so, we will cease processing your Personal Data for purposes of our services within 30 days or less. We either collect these opt-out signals ourselves or receive them from the mobile apps we work with.
    • Right to Erasure: You also have the right to obtain the erasure of Personal Data concerning you that we hold as a controller. The above opt-out process satisfies this right. When a user opts-out through our partners (or through mobile device settings), and we receive this signal, we no longer use Personal Data to provide our advertising services. We will also manually delete your Personal Data if prefer that we do so; please contact us and email your device to privacy@pixelprose.fr for further instructions if you wish to exercise this right manually. Please note, however, that we may retain copies of certain Personal Data on inactive or back-up files, for our certain important internal and purposes, such as auditing, accounting and billing, legal or bug-detection, for as long as is necessary to fulfill those purposes.
    • Right to Lodge Complaints. You have the right to lodge a complaint with a supervisory authority. However, we hope that you will first consult with us, so that we may work with you to resolve any complaint or concern you might have.
  • PixelProse SARL sometimes is a data controller and sometimes is a data processor. EU data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as "data controllers") and organizations that process Personal Data on behalf of other organizations (known as "data processors"). As noted above, we are not always a data controller of the data in our possession but are sometimes a data processor for other companies such as our Trusted Partners (for instance, when we receive or process personal data on behalf of our Trusted Partners). In such cases, we may direct your inquiry to the relevant data controller, since data controllers are the ones with primary responsibility for your Personal Data.

Children’s Data

Our Services are not intended for (and we do not intentionally collect data from) minors under the age of 16. If you are aware of any such data that we may have inadvertently collected or had transferred to us, please contact us at the contact information provided below.

Califrnia Rights and Choices (CCPA)

The California Consumer Privacy Act of 2018 ("CCPA") provides certain rights to residents of California. This section of the Privacy Policy applies if you are a natural person who is a resident of California ("California Consumer") and uses our Apps. This Addendum supplements the information Section is intended solely for, and is applicable only as to, California Consumers: if you are not a California Consumer (or a resident of California), this does not apply to you and you should not rely on it.

  • Category: Identifiers (e.g., online identifiers; IP address; mobile ad identifiers, other online or advertising platform identifiers)

    • We currently collect/use this category of Personal Information: YES
    • The sources we collect this category from:
    • Data analytics providers and data compilers
    • PixelProse owned and operated mobile applications and websites
    • We have "sold" this category of Personal Information in the past 12 months : YES
    • This category was shared with the following categories of third parties for business purpose(s):
    • Advertising networks (e.g., demand-side platforms, agency trading platforms)
    • Agencies and advertisers
    • Data compilers and resellers
    • Data analytics and providers
    • Financial institutions
    • Government entities and information services
    • App publishers ("customer categories")
  • Category: Identifiers (e.g., For our own marketing and customer contact purposes: name, address, e-mail address, phone number)

    • We currently collect/use this category of Personal Information: NO
  • Category: Internet or Other Electronic Network Activity Information (e.g ., information on a consumer’s interaction with a website or application)

    • We currently collect/use this category of Personal Information: YES
    • The sources we collect this category from:
    • PixelProse owned and operated mobile applications and websites
    • Data compilers
    • We have "sold" this category of Personal Information in the past 12 months : YES
    • This category was shared with the following categories of third parties for business purpose(s):
    • Customer categories
  • Category: Geolocation Data

    • We currently collect/use this category of Personal Information: YES
    • The sources we collect this category from:
    • Third party mobile applications and websites
    • PixelProse owned and operated mobile applications and websites
    • Data compilers
  • We have "sold" this category of Personal Information in the past 12 months : YES
  • This category was shared with the following categories of third parties for business purpose(s):

    • Customer categories
  • Category: Inferenced Data (e.g., inferences based on a device’s location or traffic history)

    • We currently collect/use this category of Personal Information: YES
    • The sources we collect this category from:
    • PixelProse owned and operated mobile applications and websites
    • Data compilers
    • We have "sold" this category of Personal Information in the past 12 months : YES
    • This Category was shared with the following Categories of Third Parties for Business Purpose(s):
    • Customer categories

We also may share any of the personal information we collect as follows:

  • Sharing for Legal Purposes: In addition, we may share personal information with third parties in order to: (a) comply with an official legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.
  • Sharing In Event of a Corporate Transaction: We may also share personal information in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.
  • Sharing With Service Providers: We share any personal information we collect with our service providers, which may include (for instance) providers involved in tech or customer support, operations, web or data hosting, billing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise assisting us to provide, develop, maintain and improve our services.
  • Sharing of Aggregate Information: We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device ("Aggregate/De-Identified Information"). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

Generally speaking, we collect and share the Personal Information for the following purposes (examples included), as we also have described in our Privacy Policy:

  • Online targeting:

    • Assisting advertisers, agencies and the platforms that they access (a) to deliver advertising and marketing to send, tailor, optimize and analyze advertising, in mobile apps and across other advertising channels and platforms and (b) to measure and analyze such advertising and marketing
    • Assisting Clients by creating "identity" graphs, to help locate users across various channels, such as connecting identities based on common personal, device-based, or network-based identifiers (e.g., IP address, email address)
  • Marketing and other research:

    • Providing information for research purposes related to human traffic patterns, disaster recovery, and including for purposes of market, health, financial or consumer research
  • Operating our services:

    • Improving, testing, updating, and verifying our own data and data services
    • Developing new products
    • Operating, analyzing, improving, and securing our services
  • Other internal purposes:

    • For internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance. We use the information collected from our own website, our owned and operated mobile apps, and third party mobile apps for the above, as well as for our own marketing purposes

California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions without being discriminated against for exercising any of these rights. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests, to the extent as act as a "business" (as opposed to a "service provider") for purposes of handling personal information. (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request).

  • Right to Opt-out of the Sale of Your Personal Information:

    • California residents may opt out of the "sale" of their personal information . California law broadly defines what constitutes a "sale" – including in the definition making available a wide variety of information in exchange for "valuable consideration."
    • We may act as a "business" or a "service provider" under the CCPA. When we act as a business under the CCPA, you may "opt out" of our "sale" of your personal information (as those terms are defined by the CCPA) by following the directions defined in our Privacy Policy or:
    • By using In Apps "Do Not Sell My Info" available in App settings
    • You may also submit a manual request to opt-out by emailing privacy @pixelprose.fr with the subject line "CCPA Opt-out"
  • Right to Request Deletion of Your Personal Information:

    • You may also request that we delete any personal information that we collected from you, such as if you have been a customer of ours. (Note that this is different from your right to "opt out" of us selling your personal information, which is described above). However, we may retain personal information for certain important purposes, such as:
    • To protect our business, systems, and users from fraudulent activity
    • To address technical issues that impair existing functionality (such as de -bugging purposes)
    • As necessary for us, or others, to exercise their free speech or other rights
    • To comply with law enforcement requests pursuant to lawful process
    • For scientific or historical research for our own internal purposes reasonably related to your relationship with us, or
    • to comply with legal obligations
    • Additionally, we need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services
  • Right to Request Access to Your Personal Information:

    • California residents also have the right to request that we disclose what categories of your personal information we collect, use, or sell. As a California resident, you may request access to the specific pieces of personal information that we have collected from you.
  • Exercising Your Rights & Submitting a Verifiable Consumer Request:

    • California residents may exercise their California privacy rights or learn more how to exercise any of these rights by:
    • Sending an email to privacy@pixelprose.fr
    • By using In Apps "Do Not Sell My Info" link available in app settings
    • However, we may withhold some personal information where the risk to you or our business is too great to disclose the information, or where we cannot verify your identity in relation to such personal information. (In addition, note that we generally retain personal information for no longer than 90 days, in any event).
    • Thus, for security purposes (and as required under California law), we will verify your identity – in part by requesting certain information from you — when you request to exercise certain of your California privacy rights. For instance, if you request categories or specific pieces of personal information we have received about you associated with a particular mobile ad identifiers, you may need to confirm your possession of that identifier.
    • When we receive a verifiable consumer request from you, we will send you additional instructions for verification within 10 days. Upon completion of the verification process, we will send you a notice that explains the categories of personal information we were able to locate about you, whether we (1) deleted, (2) deidentified, or (3) retained the information we collected from you. Certain information may be exempt from such requests under applicable law.
    • Once we have verified your identity, we will respond to your request as appropriate within 45 days:
    • Where you have requested the categories of personal information that we have collected about you, we will provide a list of those categories
    • Where you have requested the categories of personal information that we have "Sold" or disclosed to third parties, we will provide a list of those categories
    • Where you have requested the categories of sources that we have collected Personal Information from, we will provide a list of those categories
    • Where you have requested the categories of third parties that we have "Sold" or disclosed Personal Information to, we will provide a list of those categories
    • Where you have requested specific pieces of personal information, we will provide the information you have requested, to the extent required under the CCPA and provided we do not believe there is an overriding privacy or security concern to doing so
    • Where you have requested that we delete personal information that we have collected from you, we will seek to confirm whether your request is for an "opt out" or a "deletion": because "opt out" or "do not sell" rights enable us to maintain your information for "suppression" purposes – i.e., to prevent us from selling information about you in the future (which is what many consumers requesting "deletion" actually desire to occur), we try to explain this in order to ensure we are meeting consumers’ preferences. (In addition, "deletion" rights only apply to information that we have collected "from" consumers)
    • We encourage you to review and, as desired, employ the industry tools listed in our privacy policy and on the NAI (Network Advertising Initiative) page addressing how consumers may opt out of cross-app advertising. as we believe they may be more efficient, immediate and uniform – and easier to instantly access – than a more manual "opt out" process
    • If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request
  • Right to Non-Discrimination:

    • We do not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights
  • Information About Persons Under 16 Years of Age:

    • We do not knowingly collect personal information from minors under 16 years of age in California unless we have received legal consent to do so. If we learn that personal information from such California residents has been collected, we will take reasonable steps to remove their information from our database (or to obtain legally required consent)
  • Authorized Agents:

    • You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney

How to Contact Us

If you have any questions about this Privacy Policy or how we use information , or if you seek to exercise any of the rights outlined in this Privacy Policy , please contact us at privacy@pixelprose.fr

PixelProse SARL (842 987 463 RCS Annecy)
466 route de Ferrières 74350 Cuvat, France