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- JCDecaux processes and analyzes data generated when technologies attached to JCDecaux assets collect data or interact with mobile devices to create information that is used to plan and manage advertising campaigns;
- JCDecaux does not collect Personally Identifiable Information (PII) of individuals (such as name, email address or telephone number) whose mobile devices interact with JCDecaux assets or who otherwise interact with JCDecaux assets without their consent;
- JCDecaux shares aggregated or statistical information with business partners, such as media buyers who use it to make decisions regarding their advertising campaigns and better adapt their campaign to the assumed interests of their target audience.
For ease of use of this document, certain terms have been associated with the specific meaning provided below.
“Ad Impression” means a single instance of the display of an advertisement to an individual.
“Aggregated Data” means the consolidation of information relating to multiple individuals or information that has been combined with other data and therefore cannot be traced back to a specific individual.
“Data” means anonymous, aggregated data about a person’s whereabouts, activities, or location relative to a JCDecaux Asset, or that is generated by, or results from, the interaction of a person with an Asset, such as for example, interaction with a QR Code affixed on a bus shelter owned or operated by JCDecaux. It can also be provided by Third Party Providers who have access to their own data sources and are able to correlate their information to JCD Assets.
“De-Identified Data” means data that has been rendered anonymous by removing any information that would allow someone to determine an individual’s identity.
“Device Advertising ID” means an identifier that is associated with a particular device, but will not be used to determine the identity of the owner or user of that device. The most common types of Device Advertising ID are IDFA (for iOS devices) and GAID/AAID (for Android devices)
“JCDecaux Asset” or “Asset” means an advertising display owned or operated by JCDecaux, and affixed on structures such as, but not limited to, buildings, walls, bus shelters, benches, newsstands, kiosks signage displays or other type of panel.
“JCDecaux Services” or “Services” means the services, proprietary platforms, tools, methodology and equipment developed by or for JCDecaux to collect or receive data about its Assets and to enable Media Buyers to plan for, measure, manage, and optimize their digital advertising campaigns.
“JCDecaux Technology” or “Technology” means any of the identifying technologies that are affixed on JCDecaux Assets and that are used or intended to be used to transmit or convey certain information. JCDecaux Technologies include, for example, beacons, NFC tags, cameras, sensors and QR Code tags (defined below in this document).
“MAC Address” (or Media Access Control Address) means the unique identifier assigned to network interfaces of a computer or device for communications with a network (ISP, cellular, etc.)
“Media Buyer” or “Customer” means a company that advertises its products or services, or those of its clients, on advertising signage displays, bus shelters, mobile phones or tablets or similar platforms. For example, a department store that advertises its shoes, or a university that advertises its courses could be a Media Buyer.
“Non-Personally Identifiable Information” (or “Non-PII”) means data that is linked to a particular computer or device, and may include without limitation, IP address, MAC address, Advertising ID (IDFA and/or GAID/AAID) and other unique identifiers associated with Devices where such identifiers or IP addresses are not linked to Personally Identifiable Information.
“Personally Identifiable Information” (or PII) means information that is used or intended to be used to identify a specific individual, including, for example, name, address, telephone number, email address, or payment card number or government-issued identifier.
What Services does JCDecaux Offer?
JCDecaux provides Media Buyers with the ability to advertise their products or services on the JCDecaux Assets. JCDecaux uses Technologies to identify each of its Assets. The Technologies are intended to provide JCDecaux and its service providers and business partners with information about the location of its Assets, and the ability to collect data about people who walk or stand by or near a JCDecaux Asset, or who interact with an Asset. We cannot associate such data with a particular individual without having access to confidential information held by telecommunications or internet service providers. JCDecaux does not have any direct or indirect means to determine a person’s actual identity (such as name), unless the person provides it to JCDecaux.
JCDecaux or its service providers or business partners compile this data to create just-in-time statistical information based on an environment, for example, a plaza, a train station corridor, or a bus shelter. This information is used by Media Buyers to manage and optimize their digital marketing campaigns.
For example, JCDecaux may provide a Media Buyer with information about the number of people standing in the vicinity of a particular JCDecaux Asset during particular time periods based on historical data, such as a bus shelter in New York. This is provided to help the Media Buyer understand the potential number of people or Ad Impressions to which their advertisement would be exposed. The Media Buyer may decide to display an advertisement for its product on that bus shelter based on that information.
What Data does JCDecaux Collect?
JCDecaux or its Third Party Providers may collect, use and share data it collects through your proximity to our Assets or through your interaction with Technologies associated with our Assets.
- Non PII Collected JCDecaux may collect non-PII from or through the JCDecaux Assets. When people use an NFC or QR Code tag from a JCDecaux Asset, this use may generate non-PII that JCDecaux may receive from its service providers or business partners.
- De-Identified Data Collected JCDecaux may, from time to time, collect De-identified data from or through the JCDecaux Assets. However, it is the policy of JCDecaux not to re-identify any data at any time.
What Technologies does JCDecaux Uses?
JCDecaux may affix Technologies on its Assets as allowed by its advertising agreements with various city authorities or agencies. JCDecaux has entered into contracts with service providers and business partners who are able to read data provided by the Technologies.
- Beacons Beacons do not capture information. Instead, they emit their identification number and information about their location over Bluetooth connections.
Only Devices that are equipped with Bluetooth technology and have this feature turned on by you may be able to recognize a signal emitted by a beacon installed on a JCDecaux Asset.
Only those Devices that are equipped with app(s) that are able to recognize these beacons may capture the signal emitted by such beacons.
For Android users, an app is able to detect a beacon signal only if it is in use and only if you have allowed the app to share your location.
For iOS users, an app is able to detect a beacon signal only if the person has allowed the app to share his/her location. For additional information, please reference
- Cameras Camera technology may be used when a device is attached to a JCDecaux Asset to capture and store images in order to count people or measure engagement with a JCDecaux Asset. Neither JCDecaux nor its Third-party providers will use facial recognition technology.
- NFC and QR Code Interactive Touchpoints NFC (or Near Field Communication) is initiated by tapping a device on an intelligent NFC interactive touchpoint. The tapping triggers the device’s capabilities to interpret the embedded URL being transmitted by the NFC tag, and opens the corresponding website or application provided by a Third Party within the device environment.
A QR Code is similar to a barcode. When a person scans a QR code using an app located on his/her device, the app interprets the QR Code and accesses the related website or application of the Third Party whose URL address is written into the QR Code.
- Sensors A Sensor is a device, embedded in a JCDecaux asset, that is used to count nearby devices that are broadcasting a Wi-Fi signal. All data is encrypted using the Advanced Encryption Standard (AES). Only devices within a particular proximity (approximately 80 meters/260 feet) to a Sensor can be detected by said sensor.
How Does the Data Collection Technology Work?
When a person passes or stands by a JCDecaux Asset, the person’s device may interact with a beacon and/or sensor located on or near the JCDecaux Asset. The receipt of the information by a device triggers the transmittal of the information that can be measured and analyzed to develop statistics concerning the environment in which the particular Asset is located. When a person taps on an NFC reader or scans a QR Code touchpoint, affixed on a JCDecaux Asset, the action triggers the transmittal of the information contained in the NFC or QR touchpoint to a third party, an entity that can measure and analyze the data to develop statistics concerning the environment in which the particular Asset is located. If a JCDecaux Asset leverages Camera technology for pedestrian/vehicle counting, then the camera technology will register a count if you are within the range of this specific technology Importantly, no images or videos are stored or recorded.
This data may be combined with other data collected by the measurement and analysis entity or a third party through other tools. JCDecaux does not have any control over the nature, type, or detail of the data that the person’s Device transmits to third parties. These settings are solely in the control of the publisher of the application that performs such transmittal or that of the person as explained in the section “What Rights do I have?” (located below).
What Information Does JCDecaux Receive from Third Parties?
JCDecaux receives non-PII, aggregated data, or Device Advertising ID. This information is derived from data that has been collected by (i) sensors and/or cameras installed by JCDecaux and/or (ii) measurement and analytics service providers and media buyers (with whom it has previously contracted) whose apps are able to recognize the signals sent by JCDecaux beacons or to interpret the signals generated by interaction with an NFC reader or QR codes affixed on the JCDecaux Assets when they interact with peoples’ devices. The combination of the information that is collected through the use of the JCDecaux Technologies by JCDecaux or its service providers or business partners may help the Media Buyer infer that a particular JCDecaux Asset is located in an area where at a certain time of the day or the week, a certain percentage of people walking in that area meet a certain profile, such as certain demographics, interest, lifestyle, median age, interest or socio professional background. For example, the aggregate information might indicate the number of adults, who are walking in a particular area, who appear to be interested in classical music but does not provide any information about a particular individual.
What is Required from Business Partners, Service Providers, Third Party Data Suppliers, and Media Buyers
JCDecaux requires its business partners, service providers, third party data suppliers, and Media Buyers that deal with Interest Based Advertising (IBA) to comply with the requirements of the DAA. For information about the DAA you should visit the following site: DAA: http://www.aboutads.info/
How Does JCDecaux Use and Share this Information?
JCDecaux does not use any PII of individuals when providing the JCDecaux Services without consent. We use information only in aggregated form (i.e. combined with that of hundreds or thousands of other individuals) to create statistics and analytics regarding the people that walk by or near our JCDecaux Assets.
- Service Providers and Business Partners
We allow our service providers and business partners to use in raw form the data that they receive and that is emitted when a sensor and/or beacon communicates with an individual’s device, or when a person activates an NFC or QR Code communication from one of our Assets.
These service providers and business partners may include, for example, Advertisers, Advertising Networks, Ad Exchanges, Ad Servers, Agency Trading Desks and Demand Side Platforms (DSP’s), who may use this information for analytics purposes (e.g. to create statistics about the pedestrian traffic near a JCDecaux Asset) or for retargeting purposes (e.g. to deliver an ad to a person who is assumed to have seen an advertisement on a JCDecaux Asset).
The information collected as indicated above, after it has been combined with third parties’ information, may be used to make decisions regarding where and when to display advertisements. For example, an advertiser or advertising agency may elect to purchase advertising space on that particular JCDecaux Asset after the advertiser or advertising agency has identified that a particular JCDecaux Asset meets their needs and requirements for advertising purposes.
- Third Party Mobile Advertising Suppliers JCDecaux may also partner with third party suppliers who provide mobile advertising programs. These third parties are able to deliver an advertisement to a person’s mobile device when they are in the vicinity of any JCDecaux Asset, or have interacted with an Asset in the past, through the use of anonymous mobile identifiers (IDFA, AAID, WindowsID).
- To Defend or Enforce our Rights. We may use or share data, if any, in our custody or control: (i) to protect ourselves, (ii) to protect the JCDecaux website, (iii) to establish or exercise our legal rights, (iv) to identify a breach of contract, (v) when we believe it is appropriate to protect the property and rights of JCDecaux or a third party, the safety of our company, our Media Buyers or others, or (vi) to investigate, prevent, take action against, or stop any fraudulent, illegal, unethical, or legally actionable activity.
- Business Transfers JCDecaux may share data with its affiliates and subsidiaries. Additionally, JCDecaux may engage in corporate restructuring, acquisitions or divestitures and we may disclose, share or transfer some or all of the data associated with our Assets, as part of the due diligence, or after the transaction has been consummated, to allow for continuation of Services or in connection with a bankruptcy proceeding.
- Compliance with Laws and Third-Party Requests JCDecaux cooperates with government and law enforcement officials or private parties to enforce and comply with the law, as required by applicable law. We may disclose data associated with JCDecaux Assets to government or law enforcement officials or private parties as we, in our reasonable discretion, believe necessary or appropriate to respond to legal process (including a facially valid subpoena, warrant, court order or other legal process), respond to and defend against legal claims, or otherwise as required by applicable law.
- After Aggregating Data JCDecaux may aggregate data about different Assets in order to obtain statistical information. We may create, publish, share or sell industry reports, analyses and similar materials that are used for industry analysis, demographic profiling, sales, marketing, and other business purposes. These reports provide data in aggregate form. No individual, company, or customer will be identified from these reports.
JCDecaux employs administrative, physical, network and electronic measures designed to protect data associated with our Assets from unauthorized access, loss, misuse, disclosure, alteration, and destruction, in
accordance with the sensitivity of such data. While we do our best to implement security measures, we do not guarantee that our safeguards will always work. JCDecaux is not liable for unauthorized disclosure of data that occurs through no fault of JCDecaux.
Data Retention JCDecaux retains data only as long as we have a business need for such data.
What Rights do I Have? We respect the privacy of individuals. To this end, we identify below the privacy choices that people may have.
• You can prevent the collection of data Information, if any, about a person’s presence near a JCDecaux Asset is collected by or through third party apps that the person has installed on his/her device, in addition to collection via Bluetooth and Wi-Fi. JCDecaux does not interact directly with people, and therefore, we are not able to offer people the ability or any technology that would provide the ability to block the collection of data associated with JCDecaux Assets. However, you may learn more about your choices by visiting our website at https://www.jcdecauxna.com/
To prevent the collection of information by third parties, in response to a signal from a beacon, people can do any of the following:
- Power off their phone
- Disable Bluetooth (which will prevent interaction with a beacon)
- Disable Wi-Fi (which will prevent interaction with a sensor)
- Prohibit the use of geolocation
- Remove or not use those applications that are able to interact with the JCDecaux Technologies To prevent the collection of information by third parties, in response to an NFC or QR Code signal, people should not use or interact with NFC or QR code touch points.
- You can limit the Collection of Data for Interest Based Advertising The advertising industry offers means for individuals who want to limit the collection of data about them for Interest Based Advertising (IBA). If you wish to prevent certain forms of tracking, you may wish to consider the use of the AppChoices App, offered by the Digital Advertising Alliance, which provides the ability to limit the collection of data for interest based advertising from all or a number of the companies that participate in the DAA program on a mobile device. We comply with the principles set forth by the Digital Advertising Alliance. For more information, please visit: http://www.aboutads.info/appchoices
- You can adjust the settings of your mobile Device You may also wish to adjust the setting on your mobile device. On these settings, you will be able to reset your device’s Advertising ID and/or limit ad tracking. Please note that by limiting ad tracking through the settings on your device, you will disable all ad tracking, not just those of a specific entity.
For iOS 6 users: Go to Settings / General / About / Advertising.
For iOS 7 and more recent users: Go to Settings/ Privacy / Advertising.
Go to Google Setting / Ads / Opt-out of Interest-Based ads.
Our Policy Towards Children
We do not knowingly collect PII from devices associated with users under age 13. If we become aware that we are inadvertently in possession of PII about a child under age 13, we will remove such data from our files.
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