This Policy is important for the User who wishes to have a positive and serene browsing experience. It is also important for Sirdata, anxious to be transparent in the way it collects Data and preserves its confidentiality.

Sirdata wishes to answer in a precise and adapted way the questions and expectations of each one while respecting their choices and their rights. Here, it invites all Users to take the time to discover its practices and the purposes pursued as a Data Controller and more rarely as a Processor, within the meaning of the European Regulation on the Protection of Personal Data (RGPD) and the California Consumer Privacy Act. (CCPA).

In this objective, Sirdata makes a lexicon of terms and a themes section available to the User at the end of the Policy.

In the event of any divergence or inconsistency between the French version and any other language version of this policy or supporting document, the French version will prevail, be deemed authoritative and take precedence.

Sirdata uses various technologies, including placing Cookies and other similar technologies, to collect and store exclusively not direct Personal Identifiable Information, when a User views the Site of one of our Sites Operators, or uses on of its services. Find out more

When a User views the Site of one of our Sites Operators, or uses one of its services, Sirdata may use Cookies and other similar technologies to manage and store information about privacy notices they have received and their privacy choices and its choices in terms of Tracers and processing of Personal Data. Sirdata does this pursuant to the policies and technical specifications of the IAB Europe Transparency & Consent Framework.

Sirdata collects exclusively non-direct Personal Identifiable Information. It means the Data collected by Sirdata does not enable a User to be identified directly such as the unencrypted collection of their surname, first name, email or even telephone number could allow.

Sirdata does not process any Sensitive Personal Data nor combines any Data to create it. In addition, no category or segment of Data is created to specifically target minors under the age of 18.

User’s Personal Data collected through the Sites of the Sites Operators by Sirdata are mainly browsing, interaction and some demographics Data:

Data Type	Exemples
Browsing and interaction Personal Data	Number of accessed webpages, viewed products, researches done by the User
Non-nominative demographics Personal Data non directly Identifiable Information.	The age range, the age or birth date of the User communicated by way of declaration via a form or when creating an account, or the district code

Through Sites Operators, Sirdata also collects :

• A hash of the User’s pseudonymized email address forming a technical key associated with cookies. This non-reversible form of encryption does not allow Sirdata to know the email address. Find out more
• The estimation of the User’s geographical information based on the IP address and connections (for example, enabling the detection of the country but no more accurate than the city of connection or the district code). Find out more

The data collected through Sites Operators are pseudonymised, i.e. converted or manipulated via identifiers in the form “c52c40bb75bc6b3209cffac354d81b7a” or “20171120_XXXX6b25e5164555f79bbb95865XXXX” which means that the User cannot be identified directly.

• By Sirdata

Sirdata is a company specializing in data marketing, whose activity consists primarily of

• Collecting and
• Processing of sociodemographic, browsing and interaction data.

With some information that might seem innocuous, such as product research or the reading of an article on the Site of a Site Operators, Sirdata:

• Analyses, assesses and qualifies the areas of interest or probable intentions of the User.

This enables Sirdata to

• Segment Users according to demographics, interest or intent criteria
• Distribute or make available or allow the use of this information for advertising purposes through Audience Segments to its Customers and Partners, whose purposes are described hereunder. Find out more about Audience Segments

It seems important to specify that Sirdata does not operate any direct marketing operation and does not hold any file containing Directly Identifying Personal Information in its systems on behalf of its Customers or Partners. Sirdata does not send any advertisement and/or marketing offers by email, mail or phone to the Users.

• By Sirdata, its Clients, Partners and Partner’s clients

Sirdata allows its Customers, Partners or the customers of its Partners to enrich their marketing experience and target Users with relevant offers and ads that match their areas of interest.

As a result, the data Sirdata collects then allow its Customers, Partners and their customers to:

• Serve consumers adapted and personalised contents and/or offers through marketing campaigns managed by them or Sirdata and :
  • Using Audience Segments Find out more about Audience Segments
  • Using audience based on modelling Find out more about Modelled Audiences
• Improve their consumer knowledge and relationship
• Carry out audience analysis and statistical measurements
• Optimise and improve their products and services
• Fight against fraud

For example, when the User browses on a Site, his navigation and interaction data (such as the consultation of a product) may be collected. This data can then be used by Sirdata, its Partners and their clients in subsequent User’s web surfing session to display content and advertisements that match their areas of interest as closely as possible (for example related to the viewed product).
Find out more and consult other examples for data uses

Find out more about our Partners

Across Europe, in accordance with the the General Data Protection Regulation (GDPR) and the ePrivacy Directive, as well as any equivalent European laws or by imposing higher standards of protection, Sirdata relies on User’s consent for the following activities and data processing :

• Store and/or access information on a device (e.g : use of cookies)
• Apply market research to generate audience insights (e.g.: to verify that Sirdata is not mistaken in determining that a User likes “fashion”)

The User’s consent can be expressed and modified at any time through all the methods available to him to exercise his choices… The Site Operators are responsible for obtaining the informed consent of the User prior to the registration and access of Sirdata's Cookies in their Device when they browse their Sites or use their services.

Furthermore, still according to the regulations applicable in Europe, data processing by Sirdata data is sometime based on the legal basis of the legitimate interests, as follows:

• Select and serve basic ads
• Create a personalised ads profile (e.g.: determine from a web navigation that a User enjoys “fashion” to later on serving him a relevant ad)
• Select personalised ads (e.g.: displaying an ad or allowing a partner to send a discount coupon by text for a “fashion” brand to a User who likes “fashion”)
• Select personalised content (e.g.: allowing a merchant site to suggest an item of clothing rather than a refrigerator to a User who has previously allowed Sirdata to determine he likes “fashion”)
• Create a personalised content profile (e.g.: determine from a web navigation that a User enjoys “fashion” to later on suggesting him a relevant content)
• Select personalised content (e.g.: allowing a merchant site to suggest an item of clothing rather than a refrigerator to a User who likes “fashion”)
• Measure campaigns performance (e.g. in order to stop the campaigns if they do not seem relevant to the User)
• Develop and improve products (e.g. so as not to annoy the User with an ad format that unintentionally disrupts his navigation)

The User may oppose it at any time through all the methods available to him to exercise his rights. The Site Operators are responsible for duly and clearly notifying the User of these purposes and such processing and of the use of the legal basis of the legitimate interest, including, where applicable, beforehand and independently of the consent to the storage of the Sirdata Cookies in its Terminal and for the collection of Data when he browses their Sites or uses their services.

In specific countries or under specific agreements with Partners, Clients or Site Operators data processing these purposes can be performed based on the prior consent of the User instead of relying on Sirdata’s legitimate interest.

Finally, for this final category of processing, Sirdata relies on the legal basis of legitimate interest without the possibility of opposition because it is necessary and essential for the proper functioning of its services:

• Provide security, prevent fraud and debug
• Technically deliver the advertisements or content

It is essential for Sirdata to enable the User to make informed choices and exercise their rights in full knowledge of the facts.

RIGHT TO OBJECT

In Europe, Sirdata does not collect nor proceed to any Users Personal Data treatment for its own ends without the User giving its consent prior to it through any mechanisms available on websites of Sites Operators.

This being clarified, if the European User no longer wishes any or all of their Data to be gathered and processed by Sirdata, they can withdraw their consent and exercise their right to object and deactivate the use of tracers and the processing of their Personal Data by Sirdata..

Everywhere else in the world, the User, and even when local regulations do not comply, Sirdata guarantees that the User can also exercise their right to object to deactivate the collection of his personal data by Sirdata.

Sirdata wishes to draw the User’s attention to the following elements:

• Exercising the right to object will not prevent the advertisement at the broad sense. Only advertisement and/or marketing operations using Sirdata’s personalisation services will cease.

In other words, the User will no longer be shown offers that reflects their areas of interest through the use of Sirdata Cookies, but will continue to be shown advertisement and/or marketing offers whose content will no longer necessarily match their areas of interest, and may be dubious.

• The memorization of your choices or the exercising of the right to object proceeds through the placing of an objection cookie saved on the Internet Browser of the User. The exercising of the right to object must be operated on each Device and each Browser the User employs if the latter had previously given his consent to Sirdata on several Browsers and / or several Terminals.

• Deleting Cookies will remove the information needed by Sirdata to memorize the choices and to process the User’s objection. The same may apply when Browsers are changed or updated. If the Cookies are deleted or if the Browsers are changed/updated with deletion of Cookies, the User will therefore have to reconfirm their decision to exercise their right to object.

• By withdrawing their consent or by objecting to the collect of their Data by Sirdata using Cookies, the User is informed that Sirdata’s Partners and Customers will no longer save Cookies on their Device by means of Sirdata. The latter will nevertheless be able to place Cookie without the use of Sirdata. The User can access more information related to personal data protection by Sirdata’s Partners by clicking hereunder.

Exercice the right to object to Sirdata's services

Sirdata integrates User objection management in California via the IAB Tech Lab CCPA compliance framework. 

The User may also exercise their choices directly in their Internet Browser. The procedure for managing Cookies and Cookie preferences varies slightly between Browsers. The User can view the steps for managing cookies in their Browser’s help menu.
 

• For Internet Explorer™
• For Safari™
• pour Chrome™
• For Firefox™
• For Opera™

For more information with regards to targeted advertising in Europe and how to unsubscribe with their browser or another terminal, the User can access the YourOnlineChoices.com site.

For more information with regards to targeted advertising in the United States and how to unsubscribe with their browser or other terminal, the User can access the DAA verification module and the desactivation of interest-based advertising NAI.
 

RIGHTS TO ACCESS AND ERASURE

In accordance with the GDPR and the CCPA, Sirdata allows the User the right to access and erase their Data.

Sirdata wishes to draw User’s attention to the fact that it processes exclusively non-direct identifiable Personal Information. It means Sirdata does not process any unencrypted information on the User in its systems such as the first name, last name, postal address nor the email address.

The gathering of Data by Sirdata relies indeed on the placing of Cookie in the User’s Devices.

Therefore, in order to fulfill requests for access and erasure, Sirdata asks the User to provide the relevant credentials listed below using the dedicated form :

1) The Identifier of the Sirdata Cookie.

• The Cookie is not associated with any first name, last name or unencrypted email address but with an identifier that does not allow the User to be directly identified.

• Without this technical information, Sirdata is unable to compare the Data it hold with a User who wishes to exercise a right of access or erasure.

• The User can click here, to find the identifier associated with the Internet Browser of the Device they are currently using.

2) A statement on their honor that the User is the only one utilising the Device or has the exclusive control over the use of the Device whose Data may have been collected by Sirdata.

• The Device (computer, smartphone, tablet or any connected media) can be of collective use (by the User, their partner, family, friends etc.). Therefore, the Data collected by Sirdata is not necessarily limited to the User’s.

• If it is likely that said Device may have been used by a third party with the User’s agreement or without any objection, the latter must also undertake to obtain the agreement of said third parties in writing for Sirdata to satisfy the request, insofar as said request is likely to reveal information about the browsing history of said third parties.

3) A valid identity credential.

• Without all these information, Sirdata can not ensure of the authenticity of the identity communicated by the User and can not satisfy the request. This is a legal obligation.

Why does the User need to provide Sirdata with all credentials ?

Indeed, Sirdata ensures that User’s Personal Data is processed in strict confidence and implements the necessary or mandatory measures to prevent unauthorised third parties from viewing, using, disclosing, modifying, damaging or destroying said Data.
Erasing by mistake the Personal Data of a User at the request of another User would be a serious breach of the GDPR for example. Thus, in order to protect Privacy everywhere in the world, Sirdata guarantees a right of access, rectification and deletion in accordance with the highest standards in the world such as the GDPR and the CCPA to all users, with the same level of security.
While Sirdata is not able to identify directly the User to satisfy their requests for access and erasure, and in accordance with the regulation, Sirdata makes sure the User prove their identity and that they act within their own rights.

As to illustrate how this procedure is paramount, the User will find hereunder a practical example that Sirdata would like to avoid :

Paul wishes to access the sites viewed by his 23 years old son James, that Sirdata stores and protects and is linked to the cookie on the family computer. He completes and sends over a request to Sirdata using his son’s name James and indicates the identifier of the Cookie saved in the Browser of the family computer. His specific requirement is to be informed about all information related to any browsing behavior Sirdata would have gathered thanks to this Cookie. Sirdata will refuse this request.

Indeed, if Sirdata was to satisfy his request without verifying the identity and statement of honor, James’ Personal Data would be disclosed to his father without his authorisation. Sirdata, on the other hand, will not notify James of his father's move or pass this information on to James if he later requests access himself.

• Data Conservation

All the Data collected are retained for a limited time, based on the purposes they were processed for and in accordance with the regulations in effect. Sirdata’s Cookies are valid for a maximum of 365 days.

Sirdata then permanently deletes all Data in its database and storage servers.

• Data Transfer

The Data Sirdata collects may be processed on servers located within or outside the European Union. In the event of a transfer of Data, Sirdata provides guarantees that they are compliant with European Union law and require and ensure that a high level of Data protection is implemented by its Subcontractors, Sites Operators, Partners or Customers around the world. Although no regulations impose it, Sirdata guarantees this level of security for all the Data it stores, transfers and processes around the world. Find out more

• Data Security

Sirdata undertakes to process the Data it collects in strict confidence.

Sirdata places particular importance on the security of the User’s Data by using technologies that provide security in line with the most demanding standards, using SSL, hashing/encryption and firewall technologies.

Sirdata does everything possible to ensure the confidentiality of the Data it collects and to prevent unauthorised third parties from viewing, using, disclosing, modifying, damaging or destroying said Data. Find out more

• Data Sharing and Disclosure

Sirdata does not share the User’s Data with businesses, organisations non-Partner or non-Customer third parties unless it believes that there is a reasonable justification for accessing, using or disclosing said Data:

• To its subsidiaries and service providers
  

Sirdata may, in the context of its activities, transfer Data to its subsidiaries or Subcontractors that process the Data collected on its behalf, and in accordance with its instructions and this Policy. Under no circumstances may its Subcontractors appoint another Subcontractor without its prior authorisation in writing or use the Data for any purpose other than those described in this Policy.

• In response to a request from an authorised public body
  

In response to court summons or orders, judicial or administrative procedures or any other request issued by the competent authorities to which Sirdata must submit, or to establish or exercise its rights, or to defend itself against legal proceedings;
To protect itself from any infringement of Sirdata’s or Users’ rights, property or security pursuant to and in accordance with the law;
To avoid, reveal or deal with fraudulent activities, security breaches or any technical problem that might affect Sirdata’s servers.

This Policy may be subject to change. Any change to the rules of this Confidentiality Policy will be accessible as soon as it comes into effect on this page.

If, despite the educational efforts deployed in this Personal Data Protection Policy, there are still questions, Sirdata invites Users to take a look at the sections “Lexicon” and “Themes” hereunder for more detailed information about some practical terms or topics.

Otherwise, please contact Sirdata using the following form , and a dedicated team will do its best to answer within a maximum of one month.