Last Updated: August 2020

 

PREAMBLE

 

Welcome to Predicio’s Privacy Policy.

 

This Privacy Policy will inform you as to how we look after your personal data when:

 

 

 

Thereinafter together referred to as our “Partner(s) App”.

 

For the purposes of this Privacy Policy, we refer to those individuals browsing our website or using a mobile application integrating our Product as “End User(s)” or “you”.

 

This Privacy Policy also provides you with details about the personal information we collect from or about you, how we use your personal information and your rights to control personal information we hold about you (such as your right to opt-out from selling of your personal data).

 

  1. ACCEPTANCE

 

Please read this Privacy Policy carefully – by accessing or browsing our website or using a Partner App, you confirm that you have read, understood and agree to this Privacy Policy in its entirety. If you do not agree to this Privacy Policy in its entirety, you must not use this website or any relevant Partner App.

 

  1. WHO ARE WE?

 

Predicio is a company registered in Paris, France, under registration number 838 190 924, and whose registered office is at 99 rue de Sèvres 75006 Paris.

 

Predicio respects your privacy and is committed to protecting your personal data in accordance with the EU General Data Protection Regulation 2016/679 (“GDPR” - when collecting data from citizen of the European Union) , as well as the provisions of the California Consumer Privacy Act 2018 (“CCPA” – when collecting data from consumers residing withing the State of California, United States).

 

To this effect, we have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about how we collect, store and use your personal information, or if you have any other privacy-related questions, please contact our DPO by any of the following means:

 

  1. WHAT DO WE DO?

 

Predicio is a company based in France, specializing in collecting and refining mobile data. We analyze data, some of which may be deemed personal data, derived from publishers or developers’ mobile applications:

 

 

This allows us to provide our clients or business partners with statistics and insights with respect to their audience.

Alternatively, we may also share your data with selected third parties so that you can see adverts for products and services which are targeted, based on how you use your Partner App.

We may either collect such data directly via our SDK, or we may also receive such data directly from our trusted partners for the purpose of reselling it to third party companies, unless you have opted-out to such.

 

A list of such third parties is provided at Appendix 1 for your information.

 

  1. PERSONAL DATA WE COLLECT ABOUT YOU

 

Personal data”, or personal information, means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household”.

Data which has been anonymized or aggregated is not personal data.

 

In the course of providing its services, Predicio may collect personal data about you. Such information can be grouped together as follows:

 

Information related to website users and Predicio’s clients:

 

 

 

Information related to End Users of Partners Apps:

 

If you use a Partner App, we are likely to collect the information listed below about your device. Alternatively, we may also receive such information directly via our trusted partners, unless you have opted-out to such.

 

 

 

 

Aggregated Data

 

We also collect, use, or sell Aggregated Data such as statistical data to create statistics about the general use of mobile applications, which helps Predicio to improve existing services or develop new services.

Aggregated Data (also known as “deidentified” information) could be derived from your personal data but is not considered personal data in law as this data cannot reasonably identify or be linked, directly or indirectly, to a particular End User. For example, we may aggregate your Usage Data to calculate the percentage of End Users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

 

A quick word about children

 

We will never knowingly collect or sell information from any unsupervised child under the age of 16.

If you are under the age of 16, you may not use our Partner App and Predicio declines any liability for unsupervised children doing so.

 

Personal Data collected in the last 12 months

 

The categories of Personal Data which may have been collected by Predicio within the last 12 months are identical to those mentioned above.

 

  1. HOW WE MAY USE YOUR INFORMATION

 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

 

Information related to website users and Predicio’s clients:

 

 

Purpose/Activity

 

Type of data

 

To register you as a new customer/ provide our services

 

(a) Identity

(b) Contact

 

To process and deliver our services, including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

To manage our relationship with you which will include notifying you about changes to our terms or Privacy Policy

 

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

(a) Identity

(b) Contact

(c) Technical

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

 

(a) Technical

(b) Usage

 

To make suggestions and recommendations to you about goods or services that may be of interest to you

 

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

 

To comply with laws or to allow us to enforce the terms of these Principles.

 To respond to lawful requests and legal processes.

 To protect the rights and property of Predicio, our agents, customers, and others.

 To protect the safety of our employees and agents, our Partners or any other person.

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

 

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

 

 

 

Information related to End Users of Partners Apps:

 

Purpose/Activity

 

Type of data

 

To provide our services to publishers, advertisers or other selected third parties to help them get an understanding of how End Users are using Partners Apps.

(a)   Profile

(b)   Technical

(c)   Marketing and Communications

 

To allow selected third parties to provide you with tailored services and the display of customized content and targeted advertising, both on the Partner App and on other third-party apps.

 

(a)   Profile

(b)   Technical

(c)   Marketing and Communications

 

 

 

  1. OPT-OUT RIGHT FOR PERSONAL INFORMATION SALES

 

You have the right to opt-out from Predicio selling your personal data to third parties directly by clicking on the “Do not sell my Personal Information” link available on the Homepage of our website or at the following URL: http://www.predic.io/opt-out, or by clicking on such similar link provided to you on the Partner Apps.

You can also opt-out of information collected for online/interest-based activities from companies participating in Network Advertising Initiative or the Digital Advertising Alliance, directly by visiting the NAI’s opt-out page (https://optout.networkadvertising.org/?c=1) or the DAA’s Consumer Choice Page (https://optout.aboutads.info/?c=2&lang=EN).

 

Please contact the Partner App directly in case you are unable to find the mechanism for opting out.

 

We require that our business partners send us up to date data. Therefore, if you have opted out from selling your personal data to or by our partners at any time, we will be informed of such within a reasonable time.

Subject to the reception of an opt-out request on your part, Predicio undertakes not to not request reauthorization to sell your personal information for at least 12 months after your opt-out request.

 

Opting out will not stop advertising from the Partner App integrating our SDK being sent to you by third parties, but Predicio will no longer be able to collect data from your mobile.

 

  1. DISCLOSURE OF YOUR PERSONAL DATA

 

We may share your personal data with third parties as set out in Appendix 1 for the purposes set out in the table at section 5 above.

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

 

 

  1. DATA SECURITY

 

We have put in place appropriate security measures (such as data transfer encryption over HTTPS, account authentication and data rest encryption for our computer and databases storing Personal Information) to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

 

Unfortunately, no data transmission or storage system over the internet can ever be guaranteed 100 % secure. If you have any reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately by e-mail to the following address: legal@predic.io  

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

  1. DATA RETENTION

 

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

 

Details of retention periods for different aspects of your personal data are set out below:

 

In some circumstances you can ask us to delete your data: please see clause 10 “Your legal rights” below for further information.

 

In other circumstances, when we have anonymised your personal data (so that it can no longer be associated with you) for research or statistical purposes, we may use this information indefinitely without further notice to you.

 

  1. YOUR LEGAL RIGHTS

 

You have the following rights under data protection laws in relation to your personal data:

 

 

 

 

 

 

If you wish to exercise your rights, please contact Predicio by any of the following means:

 

 

Fee

 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

 

What we may need from you 

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

Time limit to respond 

 

We will use our best endeavour to respond to all legitimate requests within one month from their reception. Occasionally, this timeframe may be extended for an additional 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

APPENDIX 1: THIRD PARTIES

 

 

In the course of proving our Services, we may share your personal data or Aggregated Data with the following selected third parties:

 

INTERNAL THIRD PARTIES OR PUBLIC BODIES

 

 

 

 

 

SELECTED EXTERNAL THIRD PARTIES

 

 

 

We do not disclose information about identifiable individuals to our partners, but we provide them with Aggregated Data about End Users (for example, we may inform them that 500 mobile devices visited a specific retail location after being exposed to an advertisement on any given day). We may also use such Aggregated Data to help advertisers reach specific audiences (for example, mobile devices in a given geographical location). We may use the personal data we have collected from your mobile device to provide our partners with the data they need to perform their activity (analysis, measurement and advertising use-cases). This may involve our partners sending you behavioral and location-based advertising.

 

 

 

Predicio thrives at being completely transparent with you. To this effect, please see our list of the selected external third parties we may share your data with for the purposes indicated in this Privacy Policy.