Kwanko has made its compliance with regulations and laws on the protection of privacy and personal data a priority.
The KWANKO Terms and Conditions of Sale (for advertisers) and Terms and Conditions of Use (for affiliates) contain the main rules that are applicable to the data collected and processed through our services and our platforms. We impose these rules on all partners that we work with and we ask them to comply with the laws and regulations in force for all services they provide to us.
As part of its business activities, Kwanko collects and processes personal data (1) on behalf of itself, but also (2) in the name and on behalf of its partners, be they advertisers or affiliates. In the first case, Kwanko acts as a data controller, while in the second case, it is a subcontractor within the meaning of the provisions of the GDPR.
Processing that is subcontracted by Kwanko is strictly governed by agreements concluded with its partners, in accordance with the requirements of the regulations in force.
2. COLLECTED DATA
“Data” as a general term may include all kinds of personal information, such as your name, address, or information about your device (for example, your operating system or browser).
2.1. Data collected via our website www.kwanko.com
When you browse on our website www.kwanko.com, we may collect information about you.
You can visit our website without any obligation to provide information about yourself. However, please note that our web servers temporarily record traffic data provided by the device you use to enter our website (including host name (IP address)), and the date, time and duration of your visit, your browser data and operating system, as well as the name of your service provider, and the website from which you have been redirected to our website (the so-called reference URL). This information is stored in a log file until it is automatically deleted.
The collection and processing of this data is done in order to facilitate the use of our website (implementing the login) and to ensure the security and stability of our systems as well as the technical administration of the network infrastructure.
We do not record any Personal Data (your name, address, telephone number or email address) other than those that you voluntarily provided, for example, as part of an enquiry or during an attempt to establish a contractual relationship.
2.2. Contact data when creating user accounts on the Kwanko platform
As part of our services, we collect Contact Data in order to be able to proceed with the creation of one or more user accounts that enable our partners to log into the Kwanko platform and to benefit from its services. To this end, we collect and process the following data:
– Surname and first name of the contact(s) at our partners,
– Postal, telephone and electronic contact information
– Language of use on the platform,
– Login username and password for the platform.
We may also collect, as appropriate, invoicing information, such as name and invoicing address, as well as banking details (“Relevé d’Identité Bancaire” or RIB in France).
2.3. Data collected via Kwanko tracking technology
We collect users’ technical identifiers from our partners in order to converge the browsers and mobile application environments that are used, and to present relevant advertisements based on user activity on different browsers and the environments.
For these purposes, we process and store:
- the CRM ID of our advertising partners and/or the email addresses in hashed form. (For example, the hashed form of email@example.com would be 95ad3e9a65078288849e0ce56cf032c4)
- the mobile advertising identifiers (such as IDFA for iOS-enabled mobile devices or GAID for Android-based mobile devices), which are technical identifiers created by mobile phone manufacturers for the purposes of customisation and analysis in a secure and non-identifying way for users.
We may also collect technical identifiers from trusted partners in order to improve our multichannel convergence technology (cross-device) and thus offer our partners a harmonised experience when browsing on a website or mobile application that is part of the KWANKO network.
Our partners may use deterministic or non-deterministic technologies but, in any case, we require that our partners share with us only the convergence data to the exclusion of any other data (whether personal or not) that may be collected by these partners as part of their services, and that they offer users a simple way to oppose the collection and processing of their data.
2.4. Data collected via our PartnerTag
KWANKO does not undertake behavioural advertising nor use tracking services, nor does the “PartnerTag” management tool supplied by KWANKO to its advertisers collect data for these purposes.
For this reason, we would like to draw your attention to the option of opposing the collection of data for the purpose of targeted advertising on the following websites: http://www.aboutads.info/choices/ and http://www.youronlinechoices.com/en/ (for the European zone).
2.5. Data collected via cookies
Cookies are small files that are installed on your device, which perform a variety of functions, including enabling you to navigate between pages efficiently, remembering your preferences, and generally improving your experience.
Kwanko stores cookies on the devices of users who visit the websites and who use the online services of our advertisers, in order to obtain convergence data and to record events such as sales and leads (for example, the sale a product on an e-store, or the completion of a form for being contacted back).
The sole purpose of our cookies is to link the dissemination of an advertisement on the website of an affiliate (a content publisher) to a commercial transaction performed on the website of the advertiser of said advertising, and to perform the corresponding invoicing services. Personally identifiable information about the user is neither collected nor processed nor used in tracking. Tracking cookies only store information about when and on which device a dissemination or a click on an advertisement occurred. We only store an individual sequence of numbers that cannot be attributed to an individual user and which contains only information about the advertiser’s advertising programme, the affiliate, and/or the dates and times on which the user saw or clicked on the advertisement.
Tracking operations also allow us to collect information on the type of electronic device that was used by the user to complete the commercial transaction. This, for example, consists of information about the operating system or the Internet browser used. These data are only collected for statistical purposes and for the optimisation of the services provided by Kwanko.
We only collect data related to users’ browsing through cookies or equivalent identifiers that record:
- events related to the user’s activity on our partners’ websites (for example: the number of pages viewed, the products viewed, and the searches made on our partners’ websites);
- information related to the user’s computer, tablet or smartphone (type of device, operating system, version) and events related to the dissemination of advertising via the KWANKO platform, such as the number of advertisements that have been displayed.
The cookies used are listed below:
A more complete version of this table is accessible from the page www.kwanko.com/en/gdpr.
2.6. Data via our lead generation services
As part of our “lead generation” services, we collect or receive through our affiliates, Data about you, such as your surname and first name, and your electronic, telephone and postal contact details.
This collection of data is performed on behalf of our advertiser partners, and only for the purpose of enabling them to identify potential prospects in order to grow their business activities.
2.7. IP address
In line with industry best practices, we use IP addresses for fraud detection purposes and not for targeting purposes. The objective is to identify situations that cannot be associated with human behaviour, such as a massive volume of clicks in a limited time, or to extract geographic information.
3. USE OF DATA
We collect and process solely Personal Data about you for which we have legal bases. The legal bases include your consent (when you have given your consent), the contract (where the data processing is necessary for the performance of a contract between you and Kwanko, or between our partners and you, for example, to provide you with the services you have requested), and “legitimate interests”.
We use the personal data provided by our affiliates and advertiser partners solely to administer and to provide our technologies and services, to respond to requests from partners and, where applicable, to execute the contract between a partner and Kwanko, or between a partner and yourself. We retain your personal data in strict accordance with applicable data protection and privacy laws and with our contractual obligations, and we will prevent any unauthorised access to the data to the best of our ability.
Finally, we may use the Data when it is necessary for complying with a legal or regulatory obligation.
4. RETENTION OF DATA
Kwanko will retain the Data in accordance with the general terms and conditions of sale and/or use signed with its partners, that is to say, for the time that is strictly necessary to enable Kwanko to fulfil its contractual obligations vis-à-vis its partners.
In the event that you are registered as an advertiser or disseminator on our platform, Kwanko retains your Data as long as your account exists or as long as necessary to provide its services. This includes the Data that you or third parties have provided to us and the Data generated or deduced based on your use of the services.
Kwanko may also retain some of your Data for a longer period of time, solely for the purpose of complying with any legal obligation or responding to any questions or complaints that may be submitted to it following the termination of the contractual relationship with its partners or yourself.
5. SHARING AND DISCLOSURE OF DATA
We only share the Data with our partners, which in any case only receive the personal information necessary to perform and provide our services, and which are not authorised to use this personal data in any other capacity other than for the service in question.
We may, however, transmit your data to our subcontracted service providers, but only if we have contractually mandated them to process the data on our behalf, and if we and the subcontracted service providers meet all the requirements of the data protection regulation. The data are stored in the European Union and the European Economic Area.
We may communicate personal data in order to comply with applicable legislation and to respond to requests from public or governmental authorities. We undertake, however, to notify you under the conditions provided for by the legislation in force.
6. TRANSFERS OF DATA ABROAD
We process data both inside and outside the European Union, and we rely on binding contractual mechanisms and legal processes to legally transfer data across the borders of the European Union and to secure these flows of data.
7. DATA SECURITY
Kwanko takes data security very seriously and strives to protect all Data collected in order to prevent it from being lost, distorted, damaged or accessed by unauthorised third parties.
For example, we have implemented safeguards to ensure the confidentiality, security and integrity of your Data. As such, we try to restrict access to the Data to only some of our employees and only to the employees of our service providers who need to know them and who have been trained on how to comply with privacy rules.
These measures take into account the sensitivity of the Data we collect, process and store, as well as the current state of technology. Our data are hosted by the company Claranet (ex-Oxalide), which has obtained ISO 27001 security certifications that are internationally recognised.
To learn more about current security and data privacy practices and policies, please see our Security Policy available on www.Kwanko.com/en/gdpr.
8. RIGHTS OF ACCESS AND CONTROL OF YOUR DATA
In the event that you are registered as an advertiser or disseminator on our platform, you can access your customer account and delete or correct some of your data yourself.
In accordance with the legislation in force, and in particular Act no. 78/17 of 06 January 1978 in relation to Data Protection (“Informatique et Libertés”) and the GDPR, you have a right of access, rectification and erasure of your Data, as well as a right to limit its processing, and to the portability of your Data.
You also have the right to oppose the processing of your Data by Kwanko for legitimate reasons, as well as the right to file a complaint with the CNIL (French data protection enforcement agency).
You can exercise your legal rights at any time by contacting us by email at firstname.lastname@example.org, or by post at KWANKO SA, 60 boulevard Maréchal Joffre 92340 Bourg-la-Reine, France.
In observation of the applicable privacy legislation, we will delete your data without any action on your part if the retention of your data is no longer necessary for the purposes pursued, or if the retention no longer has any legal basis. We may restrict the processing of your data instead of deleting it when we are bound by legal obligations to retain your personal data.
10. CONTACT KWANKO