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Política de Privacidade

PREAMBLE

This Privacy Policy is intended to provide you with comprehensive information about how Kwanko SA (hereinafter “Kwanko”) collects, uses and discloses personal data that it may collect and process within the scope of its commercial activities, as well as the rights that you have over the data concerning you. It enters into force on 25 May, 2018.

Updates to this version of the Privacy Policy reflect the changes made by the General Data Protection Regulation (EU) 2016/679 of the European Parliament and the Council dated 27 April 2016 (hereinafter the “GDPR”).

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.

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.

1. COLLECTED DATA

The way that you communicate with us or with our technologies and services determines the purpose of the collection and the processing of the information. Through this Privacy Policy, we want to inform you about the types of personal data that we may access.

1.1. 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.

1.2. 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).

1.3. Data collected via Kwanko tracking technology

We may collect users’ technical identifiers from our partners that do not directly identify you in order to serve relevant advertisements, to know on which sites you have seen or viewed one or more advertisements and to link to a possible purchase.

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 name@email.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. Kwanko stores this parameter as a "match" identifier in order to link a sale to an advertisement (the data being encrypted and/or cut to allow no other use).

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.

1.4. 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.

However, the tracking codes used by “PartnerTag” through our publishers may use cookies for behavioural advertising purposes. For this reason, we would like to draw your attention to the option of the possibility offered to you to control your cookies on the following websites: http://www.aboutads.info/choices/ and https://www.youronlinechoices.com/pt (for the European zone).

1.5. Data collected via cookies

Kwanko uses cookies for its tracking services in order to follow the navigation of the Internet user beyond the display of a visual or a click on an advertising link in order to know on which sites the Internet user has seen or consulted one or more advertisements and thus link a possible purchase to it.

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 have followed a Kwanko advertising link with the sole purpose of linking the delivery of an advertisement on the website that is affiliated to the Kwanko platform to a sale or action (e.g. filling in a form or downloading a mobile application) carried out on the website of an advertiser (e.g. e-merchant). Personally identifiable information about the user is not collected, processed or used in the tracking. This data is only collected for statistical purposes of navigation and to measure the performance of the advertising of sites affiliated to the Kwanko platform.

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:

GDPR - KWANKO’S COOKIE INVENTORY
Name company that places the Cookie Technical Cookie Name Cookie name description Cookie third party? Purpose of the Cookie Category Session Cookie / Persistent Cookie Lifetime of the Cookie When is cookie deleted? Cookie is placed on: All visitors / Segments
Kwanko SA neta Alternative name for secured version with Samesite=none
option (for Chrome browsers) is "neta_ssc"
First and third party Default persistent cookie for post-view and post-click conversion tracking advertising cookie persistent 2 months cookie lifetime all visitors
Kwanko SA netases Alternative name for secured version with Samesite=none
option (for Chrome browsers) is "netases_ssc"
First and third party Default session cookie for post-view and post-click conversion tracking advertising cookie session session browser close all visitors
Kwanko SA ctxxx xxx will contain an identifier
Alternative name for secured version with Samesite=none
option (for Chrome browsers) is "ctxxx_ssc"
First and third party ClicTime cookie for conversion tracking advertising cookie session session browser close all visitors
Kwanko SA convbwrxxx xxx will contain an identifier
Alternative name for secured version with Samesite=none
option (for Chrome browsers) is "convbwrxxx_ssc"
First and third party Conversion tracking for some compatible publishers
Used to prevent them in real time about potential conversion attribution
advertising cookie persistent 1 month cookie lifetime all visitors
Kwanko SA kwkcd Alternative name for secured version with Samesite=none
option (for Chrome browsers) is "kwkcd_ssc"
First and third party Cross device persistent cookie for conversion tracking advertising cookie persistent 15 days cookie lifetime all visitors
Kwanko SA kwkcdses Alternative name for secured version with Samesite=none
option (for Chrome browsers) is "kwkcdses_ssc"
First and third party Cross device session cookie for conversion tracking advertising cookie session session browser close all visitors
Kwanko SA kwku The kwku cookie, it is used by uniJS to store a click ID on the advertiser’s domain (in firstparty) re-sent during a conversion (again via uniJS). first party uniJS conversion tracking advertising cookie persistent 2 months cookie lifetime all visitors
Kwanko SA netaoptout Alternative name for secured version with Samesite=none
option (for Chrome browsers) is "netaoptout_ssc"
first party Advertisement and tracking opt-out cookie advertising cookie persistent 1 year cookie lifetime By clicking on opt-out link
available in our Privacy Policy
Kwanko SA kwknc Alternative name for secured version with Samesite=none
option (for Chrome browsers) is "kwknc_ssc"
First and third party No consent persistent tracking cookie with no personnal data identifier technical persistent 2 months cookie lifetime all visitors
Kwanko SA kwkncses Alternative name for secured version with Samesite=none
option (for Chrome browsers) is "kwkncses_ssc"
First and third party No consent session tracking cookie with no personnal data identifier technical session session browser close all visitors
Kwanko SA netattagXXX xxx will contain an identifier
Alternative name for secured version with Samesite=none
option (for Chrome browsers) is "netattagXXX_ssc"
First and third party Used for 3 tag conversion tracking method (when conversion is fired in S2S context by the advertiser) advertising cookie session session browser close all visitors

A more complete version of this table is accessible from the page www.kwanko.com/pt/gdpr.

You can control cookies via your browser preferences and other tools. To disable these cookies, we invite you to visit our dedicated Opt-out Page.

1.6. Data via our lead generation services

In the context of our lead generation services, the collection of data useful for filling in a form is carried out on behalf of our advertising partners, and its sole purpose is to enable them to identify potential prospects to develop their activities.

1.7. 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.

2. 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”.

When the processing of your Personal Data is subject to your consent, you have the right not to consent or to withdraw your consent at any time; when the processing of your personal data relates to legitimate interests, you have the right to oppose them. If you have any questions regarding the legal bases on which we rely for the collection and use of your personal data, please contact our Data Protection Officer, whose contact details are listed at the end of this Privacy Policy.

Finally, we may use the Data when it is necessary for complying with a legal or regulatory obligation.

3. 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 publisher 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.

4. 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 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.

In order to fulfil our contractual obligations, we may transmit your data to companies that we control and to subsidiaries thereof, provided that such companies are subject to this Privacy Policy or to confidentiality rules that guarantee a level of protection for your data which is at least equal to that of the Policy.

Finally, we may share your Personal Information within the context of a sale, merger or takeover, or in preparation for such events. Any third-party entity wholly or partly purchasing our business will be authorised to use your data, but only in accordance with this Privacy Policy and after having duly informed you of this transfer of activity. You may, of course, object to this by exercising your legal rights as described in Article 7 of this Privacy Policy.

5. 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.

6. 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, 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/pt/gdpr.

7. RIGHTS OF ACCESS AND CONTROL OF YOUR DATA

7.1.

In the event that you are registered as an advertiser or publisher on our platform, you can access your customer account and delete or correct some of your data yourself. Also, you can manage all your preferences for receiving communications from our platform on your "Profile" page.

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).

7.2.

In the event that you have followed a Kwanko advertising link in order to register with one of the merchant sites (ADVERTISER) you can change your choice:
- By deleting the Kwanko cookies listed in paragraph 1.5
- By managing your global opt-out on our tracking directly on the page http://pt.netaffiliation.com/opto

7.3.

When you use the www.kwanko.com Websites, an informative banner appears on your first visit asking for your consent and indicating that you have the option to accept or decline cookies. This banner uses OneTrust software technology.

You can exercise your legal rights at any time by contacting us by email at gdpr@kwanko.com, 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 of the said data is no longer required by legislation (laws and/or other regulations). We may restrict the processing of your data instead of deleting it when we are bound by legal obligations to retain your personal data.

8. AMENDMENTS TO THIS PRIVACY POLICY

Kwanko reserves the right to modify this Privacy Policy at any time. The amendments will come into effect twenty-four (24) hours after they have been posted online.
In continuing to use Kwanko’s services and platforms after the publication of the amendments to our Privacy Policy, you acknowledge that it means that the collection, use and sharing of your Data will be subject to the updated version of the Privacy Policy.

9. CONTACT KWANKO

If you have any questions or complaints in relation to this Privacy Policy, you can contact us online or send us a letter to the following address: KWANKO SA, 60 boulevard du Maréchal Joffre 92340 Bourg-la-Reine, France. You can also contact our Data Protection Officer (DPO) at the following address gdpr@kwanko.com.