Privacy Policy

Free access to many websites on the Internet is made possible by the distribution of advertisements by advertisers. These advertisements can be targeting the needs and expectations of the Internet users concerned or non-targeted, which are less likely to interest them. In all cases, Internet users are exposed to advertisements.

Advertisers, for their part, are also interested in displaying their offers to users they know are interested in them.

When Clipr (platform by Capteev), (or “We“, “Us“, “Our“) is used by an advertiser, Our mission is to accommodate the interests of Internet users and advertisers. To that end, We strive to preserve the confidentiality and security of the personal data that we process in the context of the campaigns delivered by our advertising clients, i.e. any information that makes it possible to analyze statistics indirectly (user agent, ISO country code or referrer, etc.) of a natural person (the “Personal Data“). 

To this end, we have put in place strict procedures and made strong commitments which are described in this document (the “Privacy Policy“).

1. Who we are ?

Clipr is a rich media vendor, providing technologies to create, serve and analyze statistics of dynamic rich media ad formats.

Clipr is a product of Capteev SAS, incorporated in France, with its headquarters in Paris.

2. What are our commitments ?

Clipr has made protection of Personal Data and privacy one of its priorities. We have thus chosen to work towards greater transparency and to offer a real visibility to users regarding the collection and processing of their Personal Data on the Internet, including the use of cookies.

Clipr is committed to process your Personal Data in the strict respect of the Regulation (as defined below), the lawful instructions of our clients – and this Privacy Policy.

Thus, and pursuant to the principle of data minimisation, Clipr ensures to process only Personal Data strictly necessary with regard to the specified, explicit and legitimate purposes for which they are processed. The processing will only be carried out for the time necessary to achieve the purposes concerned and within the framework of strict security and confidentiality measures.

These purposes have, moreover, been brought to the attention of Our Data Protection Officer (DPO) during the prior formalities carried out with the latter.

3. Which regulations apply to the use of your Personal Data ?

The regulations applicable to the processing of Personal Data cover all national and European laws and regulations in force and in particular (i) the European Data Protection Regulation 2016/679 of 27 April 2016 (the “GDPR“), (ii) the French provisions of Law No. 78-17 of January 6, 1978 as amended, (iii) the European Directive 2002/58/EC of July 12, 2002, (iv) the California Consumer Privacy Act of 2018 (hereinafter "CCPA") and (v) guidelines, opinions, recommendations, advice of the supervisory authorities, certifications, approvals and final court decisions (altogether, the “Regulations“).

4. How we collect data

4.1 - Regarding Clipr’s customers or prospects, Clipr collects information about you from:

- your use of the website as a site visitor

- emails you send to Clipr

- your subscription to the platform via registration form as an advertiser

- demo product request via contact form

4.2 - Regarding end-users, Clipr collects information about you from:

- indirectly from your use of the Services when you visit an advertiser’s sponsored asset delivered on a media website.

5. Categories of data we collect

5.1 - Regarding Clipr’s customers or prospects, the categories of data that Clipr collects from you include:

- identification information (e.g. name, surname, email address, title, company);

- data relating to the management of our business relationship and invoices; and

- connection data (e.g. login credentials access to the Clipr platform)

- our website navigation data via third party google analytics tag (User agent data, pages visited, time of visit)

5.2 - Regarding end-users, the categories of data that Clipr collects from you include:

- navigation data when accessing an ads (User agent, Country ISO code provided by CDN, referrer)

- behavior data (events) related to the accessed ad (clics, and events timestamps)

Clipr does not collect data that directly identify you (such as your surname, first name, email, telephone number, etc.), nor data that is sensitive or that We consider to be sensitive (e.g. health data, your precise geolocation data, data that reveals your ethnic origin, your political opinions, your religious or philosophical beliefs or your trade union membership, as well as genetic data, biometric data for the purpose of uniquely identifying a natural person, or data concerning your sex life or your sexual orientation).

6. What exactly is a cookie? How do We use them? How can you manage them?

“Cookies” are small data files placed on your device when you browse web pages subject to the choices you have made, in order to store and receive identifiers and other browsing information.

Cookies are used by Clipr to (i) facilitate your browsing, (ii) compile visit statistics.

  • Statistical cookies: they enable us to establish statistics on Website traffic and to detect browsing problems in order to monitor and improve the quality of Our services.

You may at any time set your browser to express and modify your wishes regarding cookies, in particular by refusing certain cookies.

You can also use the interface that we make available to you via the cookie banner that appears when you first connect to the Website or after any deletion of your cookies.

We remind you that by disabling targeted advertising cookies and/or statistic cookies:

  • you will continue to be exposed to advertising but it will no longer be targeted according to your preferences identified on the basis of your browsing profile. The deactivation of targeted advertising does not affect the volume of advertisements to which you are exposed but impacts their relevance; and/or
  • your visit to the Website will no longer be counted in our traffic measurement tools.

7. Duration of storage of collected data

The personal data that we collect via our website, in particular via the contact form, are kept for the time strictly necessary for the management of the commercial relationship. The collected browsing data is kept for a maximum of thirteen months (13 months) after the date of collection. Our cookies expire two months after their last update.

8. Rights of the user relating to his personal data

In accordance with the Data Protection Act, GDPR and CCPA, you have a right to access, rectify and delete personal data about you, as well as a right to portability of your data. You have a right to limit treatment, a right to oppose the treatment and a right to set guidelines on the fate of your personal data after your death. You can exercise these rights by writing to rgpd@clipr.co or to the address CAPTEEV SERVICE RGPD 10 RUE DE PENTHIEVRE 75008 PARIS. In accordance with the law, you have the legal right to lodge any claim with a supervisory authority https://www.cnil.fr/en/home.

9. Consent of the user & opt out

When consulting the Clipr website or the websites of its media & advertising partners, an information banner on these sites informs you of the deposit of  cookies and asks you to consent to them. However, if you want Clipr to no longer drop a statistical cookie on the browser you are currently using, you can disable them here. This will prevent Clipr from collecting anonymous data but will not interrupt the ad serving.

You can opt out from our cookies on your desktop and mobile web here.

10. What are Our requirements with respect to third party recipients?

We ask the recipients of your Personal Data to act in compliance with the Regulations and, in particular, to pay close attention to the confidentiality of your Personal Data.

11. Do We Transfer Your Personal Data outside the European Union?

The Personal Data collected may be processed outside the European Union.

In this case, Clipr takes the necessary steps with its processors and partners in order to ensure an adequate level of protection to your Personal Data, in accordance with the Regulation. To do so, We ensure that Our processors and partners (i) have adhered to the Privacy Shield (in case of transfer to the United States), or (ii) are located in a country ensuring an adequate level of protection or (iii) have signed a contract with Us that includes the “standard data protection clauses” adopted by the European Commission, or (iv) are subject to binding corporate rules approved by the competent supervisory authority.

12. What security measures does Clipr put in place to protect your Personal Data?

In order to provide the highest level of security for your Personal Data, Clipr implements the following security measures:

  • appropriate physical, technical and organizational measures to prevent any alteration or loss of your Personal Data or any unauthorized access to it;
  • access to Personal Data is strictly reserved to employees and service providers who need to know it. These persons are subject to strict confidentiality obligations and may be subject to disciplinary sanctions, if necessary, in the event of a breach;
  • regular audits of data collection, storage and processing;
  • communication of security instructions to employees who have access to Personal Data;
  • hosting of Personal Data in secure data centres;
  • encryption of access to our services using SSL technology.

13. Do you have a question?

If you have any questions about Clipr’s commitment to privacy and the protection of Personal Data, please contact Our Data Protection Officer at the following address: privacy@clipr.co.

14. Modification of the Privacy Policy 

Clipr reserves the right to modify the Privacy Policy, at any time, according in particular to the legal and regulatory context and the recommendations, opinions and decisions of the CNIL, the European Committee for Data Protection and the French and European jurisdictions.

Last update : June 17, 2020.