In the context of its PoP service, and solely within this service context, and only for the purposes of the PoP service, Swaven is collecting data during the brand’s website user visits or ad display. Swaven is collecting Data only for security and analytical purposes.
Swaven does not collect any personal data that could directly identify a natural person. Swaven has no intention and is not running any process to combine the collected data with any other first or third-party data sources in order to identify a natural person.
Swaven does not share, rent or sell the collected data with third parties, only anonymous and /or aggregated statistics are communicated with Swaven’s customers only.
Swaven will use two types of cookies for its data collection: Security Cookie (CloudFlare, see subprocessors list), and Performance & Analytical Cookie.
– The Security Cookie (CloudFlare): __cfduid
This is a strictly necessary cookie which protects Swaven from malicious practices. This cookie does not allow for cross-site tracking. It also does not allow for Swaven to follow users from site to site by merging various identifiers into a profile.
The _cfduid cookie collects and anonymizes End User IP addresses using a one-way hash of certain values so they cannot be personally identified. Generally, Cloudflare keeps user-level data (including the IP address of a requester) for less than 24 hours.
This cookie is a session cookie that expires after 30 days.
Considering that it has a legitimate interest to collect this data Swaven is not requesting any consent from the user. The legal basis is: GDPR – Article 6 (1) -F and Recital 47.
– The Performance and Analytical Cookie: __swntid
This performance and analytical cookie helps Swaven to measure and optimize the navigation and the performance of our PoP exclusively for the website or the ad currently visited by the user.
We use a visitor id in order to produce audience measures based on unique visitor measures. This cookie does not allow for cross-site tracking. It also does not allow for Swaven to follow users from site to site by merging various identifiers into a profile.
The End User IP address is pseudonymized immediately using a one-way hash when the log files are collected and destroyed 7 days after its collection.
The life duration of this cookie is 12 Months.
Swaven is not requesting any consent from the user for this data. The legal basis is: GDPR – Article 6 (1) F, CNIL and G29 recommendation.
Brand, publisher or advertiser for whom the service is released, acts as Controller and Swaven acts as Processor (having the meaning set forth under article 4 of GDPR).
For a better user experience and show local stores, Swaven can use the geolocation of the visitor to personalize the service. We operate a city scale geolocation “on-fly” thanks to the partial analysis of the IP address.
On POP on site only, not in display or video ad, Swaven can use a more precise geolocation by requesting the user consentment through his browser. This geolocation is used only during the session.
List of the committed subprocessors
|Subprocessor / PROCESSOR|
(Name, legal status, place of business)
|Location of the processing||Type of service||Description of safeguards in place for transfers to a Third Country (Art. 44)|
|Cloudflare, Inc.||USA/EU||Security and DNS services for web traffic transmitted to and from the POP.||https://www.cloudflare.com/privacyshield/|
|GoogleMap (For media only)||USA||Map||https://cloud.google.com/maps-platform/terms/maps-controller-terms/|
|Mapbox Inc. (for site only)||USA||Map||https://www.mapbox.co|
|Amazon Web Services EMEA SARL (CloudFront)||EU||Content distribution||https://aws.amazon.com/privacy/|
Activating or deactivating cookies
Cookies can be activated, deactivated or deleted in the settings of your internet browser. To find out more about the necessary procedure, please refer to your browser’s help window.
Personal Data: your rights
Regarding our usage of your Personal Data, you can ask, at any time, for an access, a rectification, an erasure, a data portability or a right to object.
To do so please send an email to [email protected]