TABMO Data Protection Policy

This Data Protection Policy provides information about our company, our data platform (HAWK), our way to process personal data (how we collect, share, store and use information), about your privacy rights and how you can exercise them. This Data Protection Policy only applies to information that we collect through our website at www.tabmo.io (“Website”), or otherwise process in the course of providing our services through the HAWK Platform.

About TABMO and HAWK

TABMO is a French corporation organized under the laws of France with its principal place of business located at Paris, 2 avenue de Clichy 75009 Paris and three subsidiaries respectively in the UK, the US and in Germany.

In 2013, TABMO has launched in France its website and a DSP Platform called HAWK.

Renaud Biet is in charge of the website Data processing and of the HAWK platform data processing.

Recently, we appointed a Data Protection Officer (DPO) who can be reached at the following address: dpo@tabmo.io

The website and the HAWK platform were built in France. Therefore, they comply with European Data Protection Regulations (General Data Protection Regulation – GDPR) and with applicable national data protection laws.

The following information is available to you in compliance with the provisions of article 13 and 14 of the GDPR.

About the aim of our data processing

Our website provides you an invitation to leave a message and personal data in order to contact you for a platform demo.

We do not use advertising cookies on our website.

Our data processing on the HAWK Platform is aimed to predict users’ interests and preferences for interest-based advertising

The HAWK Platform provides to its clients (media agency and advertisers), such as to data providers and media publishers, the technology and the tools for facilitating and improving their digital marketing campaign. The HAWK Platform helps our Clients to better target their digital mobile advertising and make mobile advertising on their products and services more relevant for consumers like you.

More precisely, we buy advertising spaces on mobile applications or websites and similar digital properties for our Clients. The HAWK Platform collects information sent by the mobile apps and sites you visit to better target the ads we display.

In other words, the HAWK Platform:
enables advertisers to deliver ads to a particular location and users’ location behavior,
determines how mobile users respond to certain ads,
create audience segments based on how mobile user respond to an ad,
reports aggregated statistics regarding, for example, the effectiveness of digital advertising campaigns,
detects and prevents fraud.

When personal data are processed, it is always on the basis of one of the following grounds:
we received your consent (for example when you leave your personal data on our website)
we need the information to provide our contractual obligation to you (we are in contractual relationships),
we have a legitimate interest to process your personal data (for direct marketing purposes, for fraud prevention and detection),
provided these interests do not violate your data protection interests or fundamental rights and freedoms.

About the personal data processed

The data collected on the website, only if you decide to provide them to us, are:

your name
your first name
your email address

The personal data processed on the HAWK Platform are:

The information collected and stored on your mobile Advertising ID.
The Location data (your GPS position only if you have decided to activate it on your mobile).

The HAWK Platform does not collect nor process any identifying information such as the name, surname, address, telephone number etc.

The HAWK Platform only permit the match of different data received from our partners and our clients but we never use them for ourselves.

We collect from our partners your Advertising ID and your location (if activated) at the moment of exposure. We do not store nor have access to any of your past or future navigation information.

The HAWK Platform also receives data posted by our Clients, whatever the source is.

The HAWK Platform matches these data received in order to help clients to improve their advertising campaigns and adapt consumer solicitations. Such “Client Data” is used subject to the privacy policies of our Clients. None of this information may be used by nor enable TABMO to personally identify you.

As we fully respect your rights, we require our Clients and partners to satisfy all transparency disclosure and consent requirements to enable TABMO to process personal data. The collection and use of that consumer information is governed by the privacy policy and legal terms of the data collector and the website using the data it is not governed by TABMO.

Data being submitted to TABMO from our partners uses identifiers associated with your mobile device. TABMO utilizes hashing, encryption and pseudonymisation techniques to help ensure your personal data are securely safeguarded at all times when data are shared with third parties. TABMO enforces generally accepted industry security standards on the HAWK Platform to protect the information both during transmission and once it is received.

About the recipients of the Personal data

Website Data: we do not share information received. Only our marketing staff, our CEO, our ISD and our DPO may access such information

HAWK Platform data: we may share your data with:
our Clients when we serve ads on their behalf, when you click on their ad and/or download their application,
our partners (Advertising ID only),
third parties such as advertising exchanges in order to bid on and purchase advertising inventory in mobile apps on behalf of TABMO Clients,
an authority legally entitled to know about the data, such as the Commission Nationale de l’Informatique et des Libertés, a court, a government agency provided that such disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights,
our affiliates in UK and Germany,
a potential buyer (its counsels, advisors or agents) if we plan a sale of our business or part of it, a merger or any other corporate deal provided that such partner agrees with our policies

However we remind you that such data are not identifying and that we share only aggregate data

About the transfer of personal data outside the European Union

Our servers are located in the European Union (France, Ireland) and in the US. However, your information may be transferred to and processed in countries outside the EU. These countries may have data protection laws that are different from the laws of your country and, in some cases, may not be as protective as the RGPD.

In particular, some of our clients and partners we share your information with may operate their business outside the EEA (e.g. United States of America). When we transfer your personal data to these clients or partners, your information will be processed outside the EEA. If you are located in the EEA, we have taken appropriate measures to comply with the RGPD. For example, transfer of your personal data to partner located in the United States shall occur only if such partner is a member of the Privacy Shield and abide by its provisions and undertakings or if we have concluded and implemented the European Commission’s Standard Contractual Clauses (“SCC”) with such partner or client in order to protect personal data they process from the EEA in accordance with European Union data protection law. You can obtain a copy of the SCC by contacting our DPO.

About the duration retention period of personal data:

We retain personal data we process and collect from you only if our clients are asking to or as long as we have an ongoing legitimate business need to do so (for example, to provide you with a newsletter or a service you have requested on the website or on the HAWK Platform or to comply with applicable legal, tax or accounting requirements).

Any personal data collected or stored on the HAWK Platform will be deleted after a period of 12 months following the digital campaign or earlier if our clients and partners select to delete and update these data more often.

About your data protection rights

Your data protection rights are as follows:
the right to oppose the process, withdraw your consent to the process of your personal data, access, correct, update or request deletion or portability of your personal data. You can exercise these rights at any time by contacting the DPO at dpo@tabmo.io.
Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
the right to opt-out from our marketing communications at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of mobile marketing campaigns, you can click on the icon on the corner of the ads. You will be able to opt-out from our lists and the ads you will be seeing will not be targeted anymore.
the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

About changes in our data protection policy

From time to time we may update this Data Protection Policy. We encourage you to visit regularly this policy to be informed. However, for material changes we will send you a notice provided that we possess an address to send it to you.