Last updated March 29, 2019
We have prepared this Privacy Notice to explain how, why, and when we collect data from you on our website.
Please note that this Privacy Notice only applies to data that we collect when you visit a French Morning Media Group website, including frenchmorningmediagroup.com, www.frenchmorning.com, london.frenchmorning.com, www.mauditsfrancais.ca, www.frenchly.us. To learn what data we collect when you visit the websites of our advertiser clients, please visit the French Morning Service Privacy Notice.
1. About French Morning Media Group’s Services
French Morning Media Group provides targeted advertising and marketing services for our advertiser clients (“Advertisers”). The French Morning Media Group website(s) are a collection of sites that we use to share news with French or Francophiles all around the world. Those websites are displaying ads from advertiser clients.
We are using a technology that help to show our customers’ ads to the people that are most likely to find them interesting. We aim to make advertising more useful and relevant to consumers by showing ads that are best tied to their specific interests. And we show these ads on websites which rely on advertising revenue to support the content we all consume each day, often for free.
To do this, when you visit a website or a mobile application operated by us (collectively “Digital Properties”) or we serve you an ad on behalf of an Advertiser on a third party site, we may collect some or all of the data described in our Services Privacy Notice. Our platform uses that data, as well as other data described below, to help Advertisers provide ads to you that are more relevant to you.
2. What data we collect and how we use it
We may collect the following categories of information on our website and use them for the purposes explained below.
Contact Information: You may provide us with your name, address, phone number and email when you set up an account with us and you may provide your name, title, company, email, address and/or phone number when you sign up for an event with us online or download content from our site.
Account Information: If you open a account, we will collect your username and a password and other information necessary to open and access your account.
Customer Service Information: Information you may provide to customer service including your email address for purposes of responding to your inquiries and survey responses.
Financial Information: Credit card number or other payment account information. This information is collected directly by our payments processor and not stored at French Morning.
Activity on our Digital Properties: This is data about your browsing activity on our websites. For example, which pages you visited and when, what items were clicked on a page, how much time was spent on a page, or whether you downloaded a white paper.
Device and browser information: This is technical information about the device or browser you use to access our website. For example, your device’s IP address, cookie string data, operating system, and (in the case of mobile devices) your device type and mobile device’s unique identifier such as the Apple IDFA or Android Advertising ID.
Ad data: This is data about the online ads we have served (or attempted to serve) to you. It includes things like how many times an ad has been served to you, what page the ad appeared on, and whether you clicked on or otherwise interacted with the ad.
Data from Advertising Partners: This is data that we lawfully receive from other digital advertising companies that we work with (“Advertising Partners”) to help us deliver ads to you and recognize you across browsers and devices. This may include pseudonymous advertiser identifiers (meaning identifiers that help identify your browser or device, but do not directly identify you as a person) which some third party Advertising Platforms choose to share with us – for example, an identifier (such as a cookie) associated with a hashed version of your email address, or demographic data such as age range. We may work with our Advertising Partners to synchronize their unique, pseudonymous identifiers to our own to enable us to more accurately recognise a particular unique browser or device and the advertising interests associated with it.
Hashed email addresses: We collect hashed versions of the emails you enter on our site. Hashing is a “one-way function” that effectively pseudonymizes email addresses. For instance, when [email protected] is run through a typical hashing function, it becomes the following string of code: 0F0B7B1A1A7E8BDBBC6AA545F8CCD6F83671B32479271BFCB6CC8498912058D5. We take this step to de-identify data and protect email addresses, while being able to use an identifier to better connect devices and browsers. We describe how this helps us better provide our services in “How we use the data we collect” below.
Third party information: We may collect additional information about you from other third party sources where they have the rights to share such information and we have the rights to use it, for example, demographic data or title and employer data. We use this data to better understand our customers and to better market our services to you.
3. How we use the data we collect
We use this data to operate our business and provide services to you as well to personalize French Morning Media Group advertising and marketing materials we may serve to you:
Providing our French Morning Services and Customer Support: For example, to monitor usage of features, manage campaigns, and log data for audit purposes. We may contact you when you ask us for support or when it appears to us that you might need support, and to maintain records of our communications with you for future reference.
Invoice you and collect fees for services we have provided.
Troubleshoot Problems: To monitor and fix our website performance, for example if the site is slow, not loading properly, or to investigate aberrations in performance of our services.
Prevent potential fraud and enforce our Terms of Service. To prevent fraud on our site or through the use of our services; to enforce our Terms of Service or other policies or investigate any potential violation of those Terms and policies, any potential violation of the law; or to protect ourselves, our customers, or any third party from any potential harm (whether tangible or intangible).
Customize, measure and improve our website and services: To provide customized content and to measure which content is most helpful (or unhelpful) to our customers, which helps improve our website and our services. For example, if we notice higher visits to certain Help Center articles or receive higher Customer Support tickets for specific issues, we can improve our support materials or identify areas where we can make our product better for our customers.
Contact you about your account or our services, including to market our services to you: We may use your contact information to contact you about your account, for example, in relation to performance of your campaigns, to follow up on billing issues, or to tell you about new services we are offering. When we can legally do so, we may augment the information you give us in order to contact you by phone or even snail mail. You can opt out of receiving emails by unsubscribing through the link at the bottom of our emails or by updating your email preferences here. You can let us know if you don’t want to receive phone calls or other marketing materials from us by contacting [email protected].
Targeting: Selecting ads that are more likely to be relevant to you on other sites around the net based on the interests previously associated with your device and the time of day you may be most interested in viewing these specific ads. For example, we may show you ads for an French Morning Group product on another site related to a whitepaper you downloaded from one of our websites (or similar sites we think you may like) during lunch or commute hours.
Frequency capping: Making sure that you don’t see the same ad too many times.
Sequencing: If you are being served a sequence of ads, making sure we show you the right ad next in the sequence.
Cross-device matching: Identifying all devices that are likely to be associated with you so that ads can be targeted, capped and sequenced across those devices. For example, cross-device matching helps us NOT show you ads for the French Morning Media Group services you were looking at on your phone but that you already signed up for on your laptop. Instead we’ll try to show you ads for our newly launched feature or product that can help your business dare to grow even more. It also helps us match devices so we can honor your opt-out choices across all devices we know are connected to the opted-out cookie.
Attribution: Monitoring when, where, and at what price we served certain ads so that we can measure our influence on the marketing result of the Advertiser’s campaigns and overall marketing strategy. For example, being able to measure if a certain ad campaign (the ads shown and to whom they were shown) actually led to a potential customer becoming a paying customer.
Reporting: Analyze how our ads are performing and gain insights into our customers. Reporting may include ad metrics such as impressions, clicks, and conversions (for example, if you create an French Morning Media Group account or download a white paper from our site). This helps us identify ads that are useful to our customers and demonstrate French Morning Media Group’s value, and relatedly, helps us identify an ad that is not performing well (customers aren’t clicking on it), we will be able to see that data and update our ad or ad campaign strategy.
4. Our legal basis for processing personal data (European Territory Visitors only)
We provide the representations and information in this Section 4 in compliance with European privacy laws, in particular the European General Data Protection Regulation (GDPR). They are specific to persons located in EEA countries or Switzerland, so please don’t rely on the below, if you’re not in one of those countries.
If you are a visitor from the European Territories, our legal basis for collecting and using the personal data described above will depend on the personal information concerned and the specific context in which we collect it. “European Territories” mean the European Economic Area and Switzerland. For the purpose of this Privacy Notice, the term “European Territories” shall continue to include the United Kingdom, even after the United Kingdom leaves the European Economic Area following Brexit.
However, we will normally collect personal data from you where the processing is in our legitimate business interests to, for example, administer our platforms and services and fulfil our contractual obligations as a service provider.
In some cases we may collect and process personal data based on consent.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, including if you would like to better understand how our legitimate interests to process your data are balanced against your data protection rights and freedoms, then please contact us using the contact details provided under the “Contact us” heading below.
5. Data Sharing
We may disclose information about you:
With our service providers: We contract with companies who help with parts of our business operations (e.g., for example, website and data hosting, fraud prevention, viewability reporting, data hygiene, marketing, and email delivery), as well as billing, collections, tech, customer and operational support.
With our subsidiaries and related companies: But they will only process your data for the purposes already explained in this Privacy Notice.
With other advertising companies in the digital advertising ecosystem. We share hashed email addresses (or other pseudonymous identifiers associated with those hashes), technical data that we collect about your browsing habits and your device (such as data relating to our cookies, tracking pixels and similar technologies) with other advertising companies in the digital advertising ecosystem. This enables them and us to better target ads to you.
In connection with legal proceedings: When we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of French Morning Media Group, our Advertisers or any other third party.
To comply with legal process: To satisfy in good faith any applicable law, legal process, or proper governmental request, such as to respond to a subpoena (whether civil or criminal) or similar process.
To investigate wrongdoing and protect ourselves or third parties: To enforce our Terms of Service or other policies or investigate any potential violation of those Terms and policies, any potential violation of the law, or to protect ourselves, our customers, or any third party from any potential harm (whether tangible or intangible).
In connection with a sale of our business: If a third party acquires some or all of our business or assets, we may disclose your information in connection with the sale (including during due diligence in preparation for the sale).
Finally, we may disclose aggregated, anonymized information to third parties, for example, when we conduct industry wide surveys to publish benchmark reporks, or to include statistics when collaborating with researchers or other companies on industry white papers.
6. Cookies and related technologies
Cookies are small data files that are served by our platform and stored on your device. Tracking cookies enable us to identify your device when you move between different Digital Properties, so that we can better understand your interests and serve targeted advertising to you.
Specifically, the French Morning cookie we serve through the AdRoll platform for this purpose is named “__adroll”.
We may also drop cookies from our Advertising Partners for the purposes described above. For example, we drop cookies for the exchanges through which we buy ads, such as AppNexus and Rubicon and for analytics tools such as Pixalate which helps us measure viewabilty (meaning whether the ad was actually served and seen) and prevent fraud.
Additionally, we use non-tracking cookies (not unique) to store user decisions in terms of your ad and opt-out choices:
We may drop an __adroll cookie with value opt-out if you opt-out as described below and an AdRoll consent cookie to track your consent choices.
We may drop a __consent cookie that stores the choices you have made regarding data processing and advertising by AdRoll.
To get more information about the individual cookies dropped by our website, please see the Adjust Ad Preferences link on the footer of our website or in our cookie consent banner.
7. Your choices and opting-out
We recognize how important your online privacy is to you, so we offer the following options for controlling the targeted ads you receive and how we use your data:
You can opt-out of receiving targeted ads served by us: You can opt out of receiving targeted ads served by us or on our behalf by clicking on the blue icon in the corner of the ads we serve or by clicking here. Please note that, if you delete your cookies or upgrade your browser after having opted out, you will need to opt out again. Further, if you use multiple browsers or devices you will need to execute this opt out on each browser or device. If you opt-out we may collect some data about your online activity for operational purposes (such as fraud prevention) but it won’t be used by us for the purpose of targeting ads to you.
You can opt-out of receiving targeted ads served by us or other advertising companies: AdRoll is also a member of the Network Advertising Initiative (NAI) and adheres to the NAI Codes of Conduct. You may use the NAI opt out tool here, which will allow you to opt out of seeing targeted ads from us and from other NAI approved member companies.
We also comply with the Self-Regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA). You may opt out of receiving targeted ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAA website here.
We also comply with the Canadian Self-regulatory Principles for Online Behavioral Advertising as managed by the Digital Advertising Alliance of Canada (DAAC). You may opt out of receiving targeted ads from other companies that perform ad targeting services, including some that we may work with as Advertising Partners via the DAAC website here.
We also adhere to the European Interactive Advertising Digital Alliance (EDAA) guidelines for online advertising and you may opt out via their Your Online Choices website.
Please note that when using the ad industry opt-out tools described above:
If you opt-out your browser may still send us data, for example your IP address. However, we isolate this data and do not use it other than for accounting and, in some cases, for fraud prevention. If you have opted-out on that browser, we do not use this data to personalize ads or to track you.
If you use multiple browsers or devices we will additionally opt out those we have linked to you.
Since we may not have all your browsers or devices connected back to your user, you may need to execute this opt out on each browser or device.
Other ad companies’ opt-outs may function differently than our opt-out.
To opt out of receiving targeted ads that are based on your behavior across different mobile applications follow the below instructions, for iOS and Android devices:
iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting
For Android devices with OS 2.2 or higher and Google Play Services version 4.0 or higher: Open your Google Settings app > Ads > Enable “Opt out of interest-based advertising”
Please note: Opting out will not prevent you from seeing ads, but those ads will likely be less relevant because they won’t be tailored to your interests. The ads might, for instance, be randomly generated or based on the web page you are visiting.
You can request that we stop email marketing to you. You can use the unsubscribe link in our marketing emails or contact [email protected].
Some internet browsers allow users to send a “Do Not Track” signal to websites they visit. We do not respond to this signal.
In addition, if you are located in a European Territory you will also have additional data protection rights. These are described under the heading “Additional data protection rights for European Territory residents” below.
8. Data retention
We retain data for as long as necessary to provide our services and for the purposes described in this Privacy Notice. For example, we may retain billing information as necessary to meet audit requirements. We may retain login information to confirm when Terms of Service were accepted. We retain cookie data such as device and browser information, ad data, and data collected on our Digital Properties associated with a cookie for up to 13 months and then delete it or anonymize it. We may also retain information as long as necessary to meet legal requirements, resolve disputes or enforce agreements.
We apply technical, administrative and organizational security measures to protect the data we collect against accidental or unlawful destruction and loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against other unlawful forms of processing.
10. International transfers
We may transfer the information we collect about you to countries (including the United States of America) other than the country where we originally collected it for the purposes of storage and processing of data and operating our services. In general, these countries will be the countries in which we, our Advertisers, or our or their service providers operate.
Those countries may not have the same data protection laws as your country. However, when we transfer your information to other countries, we will protect that information as described in this Privacy Notice and take steps, where necessary, to ensure that international transfers comply with applicable laws.
11. Additional data protection rights for European Territory residents
If you are a resident of a European Territory, you have the following enhanced rights under EU data protection law:
If you wish to access, correct, update or request deletion of your personal information, you can contact us using the contact details provided under the “Contact us about questions or concerns” heading below.
You can object to processing of your personal information, ask us to restrict processing of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contact us about questions or concerns” heading below.
Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. 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.
Specifically, you can withdraw consent for us or our partners to drop our __adroll cookie and our partners’ cookies by clicking here or by withdrawing consent for French Morning when you see a “consent banner” on a publisher or advertiser site which lists French Morning or French Morning Group as a vendor.
You have 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. (Contact details for data protection authorities in the European Territories are available here.) However, if you have any questions about our collection and use of your personal information, please contact us first at [email protected]. If you are unable to obtain the information or resolution that you seek, you may also contact our Data Protection Officer at [email protected].
12. Changes to this Privacy Notice
Changes to this Privacy Notice will be posted on this page. If we make a material change to our privacy practices, we will provide notice on the site or by other means as appropriate.
If we are required by applicable data protection laws to obtain your consent to any material changes before they come into effect, then we will do so in accordance with law.
13. Contact us about questions or concerns
If you have any questions about this Privacy Notice, our privacy practices, or with French Morning Media Group generally, you can contact [email protected].
If you wish to escalate your inquiry after contacting the support team, you are welcome to contact our Data Protection Officer at esaint[email protected] or by writing to the following address:
Attn: Emmanuel Saint-Martin
27 W 20th Street
New York, NY 10010