Privacy Policy

1. Who are we?

GINGERAD is a simplified joint-stock company (SAS) with a share capital of €7,500, headquartered at 62 rue Rodier, 75009 Paris, registered with the Paris Trade and Companies Register under number 883 594 095.

When GINGERAD determines the purposes and means of processing personal data, it acts as the data controller.

Data protection contact: dpo@ginger.ad.

2. Browsing the ginger.ad website

The ginger.ad website has been designed to minimise the collection of data about its visitors.

• no cookie is placed on the visitor's device;
• no audience measurement tool such as Google Analytics is used;
• no advertising or social network pixel is used;
• no programmatic advertising is displayed;
• no third-party content liable to track navigation is embedded;
• fonts are hosted directly by GingerAd.

Simply browsing ginger.ad therefore does not result in any advertising profiling by GingerAd.

As with any website, certain technical data necessary for establishing the connection, operating the service and ensuring its security — notably the IP address and information contained in the server's technical logs — may nonetheless be processed by the hosting infrastructure. The website is hosted in Switzerland by Infomaniak Network SA. Technical data processed by the host is retained in accordance with the durations applicable to the relevant services and its privacy policy.

3. Data communicated directly to GingerAd

When you contact GingerAd, we may process the information you choose to communicate to us, for example: first and last name, company, job title, professional email address, phone number and the content of your request.

This data is used to respond to your request and, where applicable, to manage the commercial or professional relationship that results from it.

Depending on the nature of the request, processing is based on the performance of pre-contractual measures, the performance of a contract, or GingerAd's legitimate interest in managing its professional relationships.

The data is retained for the period necessary to process the request and the relevant professional relationship, and then, where necessary, for the periods required by our legal obligations or necessary for the defence of our rights.

4. Absence of cookies and trackers on ginger.ad

In its current configuration, ginger.ad does not place any cookie and does not use any tracking device requiring the visitor's consent. No cookie consent banner is therefore presented when browsing the website.

This situation is distinct from the advertising sales activity carried out by GingerAd on the websites and applications of its partner publishers, described below.

5. GingerAd's advertising activity

GingerAd provides website and application publishers with services enabling them to access programmatic advertising demand.

GingerAd does not operate its own ad-serving infrastructure ("ad server") and does not build, on its own servers, a database of internet user profiles derived from advertising auctions.

For this activity, GingerAd uses in particular Microsoft Advertising/Xandr technologies, including Microsoft Monetize and Microsoft Curate.

6. The GingerAd bidder

On certain partner publisher websites and applications, GingerAd may be integrated as a bidder in a Prebid.js configuration.

The GingerAd bidder relies on Microsoft/Xandr technology. GingerAd does not operate an intermediary server designed to collect and store the personal data contained in these advertising requests.

Within the scope of Microsoft's services, certain personal data may however be processed directly or indirectly by Microsoft. Depending on the processing concerned, Microsoft may act as a data controller or as a processor.

7. Data that may be processed in an advertising context

Depending on the publisher's configuration, the technologies used, the nature of the auction and the choices expressed by the user, the relevant advertising platforms and partners may process in particular:

• the IP address;
• advertising or technical identifiers;
• information relating to the browser and device;
• information relating to the website or application from which the request originates;
• information concerning the delivery of or interaction with an advertisement;
• the user's consent choices and signals.

This does not mean that GingerAd directly receives or stores all of this data. The technical processing related to auctions carried out via the GingerAd bidder is performed using the infrastructures of the relevant advertising platforms.

8. Consent and user choice

Where regulations require consent for the use of cookies, local storage technologies, or for access to certain device information, the relevant processing may only take place after obtaining that consent.

On partner publisher websites and applications, the required consent is collected through the consent management platform (CMP) implemented by the publisher. GingerAd requires its partners to collect the necessary information, consents and choices in accordance with applicable regulations and to transmit them to the relevant advertising platforms using the applicable technical protocols, including IAB protocols where they are used.

9. Advertising partners

GingerAd primarily uses the Microsoft Advertising/Xandr platform for its programmatic activity. Depending on configurations and advertising opportunities, demand may also come from other authorised partners.

• Microsoft Advertising/Xandr – Privacy Statement
• ADYOULIKE – Privacy Policy
• OneTag – Privacy Platform
• Sovrn – Privacy Policy

These partners may process personal data depending on their role, the services used, the delivery context and the choices expressed by the user. They describe their processing and how to exercise your rights in their respective privacy policies.

This list is updated when the partners to whom GingerAd grants access as part of its services change.

10. Purposes of advertising processing

Depending on the technologies enabled, the delivery context and the user's choices, processing may in particular be carried out to enable the auctioning and sale of advertising space, select and deliver an advertisement, measure the delivery and performance of advertising, ensure the security of advertising transactions and combat fraud, manage consents and preferences and, where the legal conditions are met, implement certain advertising features based on identifiers or information from the device.

11. International transfers

Certain service providers or technology partners may process data outside the European Economic Area. Where regulations require it, international transfers must be based on a mechanism recognised by applicable regulations, in particular the European Commission's Standard Contractual Clauses where the corresponding conditions are met.

12. Your rights

In accordance with the GDPR and applicable legislation, you may, depending on the processing concerned, have in particular a right of access, rectification, erasure, restriction of processing, objection, portability where applicable, and the right to withdraw your consent at any time where processing is based on it.

For processing for which GingerAd is the controller, you may exercise your rights at: dpo@ginger.ad.

To protect the data concerned, GingerAd may request the information reasonably necessary to verify the identity of the requester where there is doubt as to that identity.

Where a request concerns processing for which a partner is itself the controller, GingerAd may direct the data subject to that partner or cooperate with that partner where necessary.

You also have the right to lodge a complaint with the Commission nationale de l'informatique et des libertés (CNIL), the French data protection authority.

13. Security

GingerAd implements technical and organisational measures appropriate to the nature of the data it processes and the associated risks. Service providers and partners operating within their own technical environments are responsible for the security measures applicable to the processing they carry out, in accordance with their respective obligations.

14. Changes to this policy

This policy may be amended to reflect changes in GingerAd's services, partners, technologies or regulations. The date of the last update is indicated at the top of this page.