2. Who are we?
We are Sublime Skinz. Our registered office address is 21, rue Pierre Picard, 75018 Paris, France. Our company number is SIRET : 803 054 048 00035 and our VAT number is FR25803054048.
Sublime is a leading ad tech company specializing in high impact digital advertising. We are the first platform of our kind to provide wallpaper-based advertising (called skins), working with advertisers, publishers, media agencies, trading desks and ad networks to drive efficient campaigns at scale. Sublime also provides actionable statistics and transparent insights in real time, allowing brands to capitalise on the most impactful formats.
We can be contacted at [email protected].
3. Data collection
Sublime is a global High Impact advertising marketplace that creates and delivers brand multi devices ad experiences that captivate, inspire and activate audiences at scale. We collect some data about you in order to build custom segments against which we will be able to serve high impact campaigns. By collecting those data, we make advertising more relevant, therefore more efficient for our clients and more interesting for Internet users such as yourself.
3.1 End-user data
When we process your data, you will have consented to data collection and processing from one or several publishers whose sites you have visited. Without that consent, we would not collect or process your data. The data we would collect about you would primarily be user IDs, IP addresses, device IDs, time and day the ad is served, publisher site the ad has been served to, country, the browser you have been using, URL referrers which allow to identify the precise page the user was on...
Thanks to that information, we will enhance the targeting in response to the engagement we see with those ads. We will also prioritise users who seem to engage better with them. This is both in the interest of our clients and of the users we serve ads to: the more relevant the ads, the more users will feel it is talking to them, the more it will lead to engagement with the products and services of our clients, and then more they will run successful campaigns.
You can change preferences at any time and you can also exercise your rights by writing to [email protected].
Sublime relies upon consent as a legal base.
Still, we believe we have a legitimate interest to collect and process personal data for the following objectives and purposes:
- Frequency measurement (counting the number of times ads have been seen): this is necessary if we want to make sure ads are not shown too often to the same user; this is one of the ways we make ads more relevant
- Frequency capping; this is how we will ensure ads are shown a maximum number of times to the same user
- Viewability measurement (understanding if ads are seen by users, often related to their placement on a publisher page); this allows us to guarantee to our clients that the high impact formats they run are properly seen by users we have chosen to serve those ads to
- Click count (counting the number of times ads seen have been clicked on); high impact formats such as skins are at the same time not intrusive and prone to engagement; counting clicks is a fundamental metric to ensure the campaign is well run
- Understanding browsing behaviours of aggregated users
- Testing ads
- Conversion tracking (counting the number of times users who have seen ads have proceeded to buy a product or service); this is necessary to understand the overall return on investment of that ad
- View-through measurement; understanding whether users who have seen those ads have ended up buying the products or using the services promoted by those ads
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us improve our site and to deliver a better and more personalised service. Some of the cookies we use are essential for the site to operate.
The data points received by our platform Ayads are similar end user data:
3.2 End user data through proprietary platform Ayads
Ayads.co is Sublime’s advertising platform for activity monitoring and configurations. This is user both by our publishers and employees. It is the platform which allows Sublime to monetise publishers’ inventory. Ayads.co plays the role of a meta-SSP and is interconnected with a direct ad server, ie Smart adserver. When the ad is called, that it is when a user visits a page of a site on which ads are displayed, publishers call on the Ayads platform. It will then interface with the SSP partners and with our ad server.
The data we would collect about you through a tag called SJS would be similar: user IDs, IP addresses, device IDs, time and day the ad is served, publisher site the ad has been served to, country, the browser you have been using, URL referrers which allow to identify the precise page the user was on...
3.3. Business contacts data
We will hold some personal data if we have been having a business relationship with you. You may be a client, a supplier, a publisher, an agency, a partner, a direct client, and we might have obtained some personal data about you such as business cards, names, email addresses, phone numbers, titles, business addresses etc. We use that personal data in order to communicate and exchange, frequently or not.
Or you could be a professional or business acquaintance with whom we hope to start a business relationship. We would have obtained that information from exchanging emails or business cards, meeting at industry events or at client meetings etc. Current law would not require us to obtain new consent in order to hold and continue processing this data. Still, you can always exercise your rights and ask for removal or erasure or portability etc. of your personal data by writing to us at [email protected]
We regularly review our data base of clients and prospects and apply the following retention policy with regards to business contacts, ie we will delete your data:
- Two years after the last contact
- Four years after the end of the contractual relationship
3.4. Employee data
If you are an employee at Sublime, we suggest you refer to our HR policy and the clauses regarding data protection on your employment contract. It is available with our HR department. We will only keep employee data which we deem necessary to fulfill certain tasks such as paying salaries, taxes etc.
4. Types of data collected and processed
Sublime collects three types of data:
- Data collected by Sublime, for Sublime’s purposes, from a publisher page; this is what the industry calls 1st party data
- Client data which is collected by Sublime if a client onboards from their client database (CRM system), this is what the industry calls 2nd party data
- Data supplied by data providers to Sublime, this is what the industry calls 3rd party data
For example, from each individual publisher, Sublime receives:
- User IDs (commonly called cookie data)
- IP Address;
- Time and day ad is served;
- Publisher site;
- List of IP addresses from source to destination including the proxy;
- Browser, user agent;
- Ad engagement metrics: clicks, impressions, viewability;
- Campaign data;
- Some location data, no more granular than the user's city;
- URL referrer.
We do not collect nor hold any information such as email, address, phone number, credit card information etc, considered high risk data under the GDPR. The cookie data we hold about you is not data which allows us to know who you are.
We do not process any data which could be used, with help of a third party, to determine the identity of users. We do not know who you are and we do not wish to know. We do not need to know who you are in order to run our business effectively.
We use the information we collect about web users in order to provide our advertising service, to improve it and for fraud detection.
Below are the specific purposes (or objectives of the processing of your data) for which we use the information we collect about web users:
- We use the data for insights and analytics: for example, we aggregate the number of impressions per country or city, or the number of impressions per type of browser.
- We use data to personalize your web experience: we use IP address to estimate geolocation and propose targeted content. For example, for local stores campaigns, we may have been asked to target people in the same city or region of this store to increase conversion.
- We also use data for research and development: We are always looking for ways to make our Services smarter, faster, secure, integrated and useful. We use data to identify trends, usage, activity patterns and areas for integration and improvement of the Services.
- We use the data for safety and security: we use information about web users to monitor suspicious or fraudulent activity and to identify violations of Service policies. Fraudulent activity costs billions of euros to the industry each year; it is essential to prevent this; it protects publishers and the quality of the content they provide, it protects you from malicious individuals or organisations, it protects advertisers who run campaigns on digital channels.
- We also need to protect our business interests and legal rights: when required by law or when we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about web users in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
Sublime believes consent should be the main legal base for collecting and processing your data. This means the personal data Sublime collects and processes should only be data that you are happy to share with Sublime.
6.1. First and third party cookies
“First party cookies” are cookies that belong to Sublime, while “third-party cookies” are cookies that another party places on a browsing device through our website. Both first party and third party cookies can be analytics, functionality and advertising cookies. Social media cookies will usually be set by a third party.
6.2. Types of cookies
|Analytics Cookies||These cookies collect information about how people are using our website, for example which pages are visited the most often, how people are moving from one link to another and if they get error messages from certain pages.|
|Functionality Cookies||These cookies allow us to remember choices and tailor our website to provide enhanced features and content. For example, these cookies can be used to remember user name, language choice or country selection, they can also be used to remember changes made to text size, font and other parts of pages that are customisable.|
|Advertising Cookies||These cookies are used to deliver our advertisements. They are used to limit the number of times users see an advertisement as well as help measure the effectiveness of the advertising campaign. They remember that users have visited a website and this information may be shared with other organisations such as advertisers. They are also used to deliver ads that are more relevant to you and your interests.|
|Referral Cookies||These cookies are placed on the device when users use one of our special referral pages to create a link to refer our service to their friends.|
6.3. How to manage cookies from this website
Our Cookies (first party cookies)
You can use the browser that you are viewing this website with to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note that if you set your browser to disable cookies, you may not be able to access secure areas of the website and other parts of the website may also not work properly.
Third Party Cookies
Cookies that are placed on your browsing device by a third party can be managed through your browser (as described above) or by checking the third party’s website for more information about cookie management and how to “opt-out” of receiving cookies from them. We are trying to give you direct link for third party opt-out in our cookie table when available.
Cookie table and Opt out
You can find our complete cookie table here with optout links.
7. Industry involvement
Sublime is involved with the following organisations:
- It is a member of IAB France, IAB UK and IAB Europe
- It is part of the IAB Europe global vendor list
- It is a signatory to the IAB Europe transparency and consent framework
- It is a member of the Coalition for Better Ads
8. Data retention
We hold your personal data according to the highest security and encryption standards, and we only do so for a minimal period of time, the time adequate to the needs of our business.
We delete cookie data after 13 months.
9. Data transfers
Like all companies operating in the complex field of advertising technology, we work with several partners. To drive our business, we need to transfer data to our key partners, some of which have servers hosted in the United States.
Our data transfers to the US, although limited, are governed by data processing agreements, which incorporate the standard contractual clauses adopted by the European Commission as well as additional measures to ensure a level of protection that is substantially equivalent to that provided in the European Economic Area.
Our partners guarantee the respect of your personal data and do not disclose any content, except where required by law or to comply with an enforceable legal order from a government agency. Also, our partners are committed to reviewing the merits of all binding orders and challenge those that are too broad or inappropriate in scope.
10. Personal sensitive data
Under the GDPR, personal sensitive data is any personal data revealing racial or ethnic origin, political opinions, religious and philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation.
Sublime does not collect any personal sensitive data.
11. Children’s data
Sublime Technology does not collect any children’s data. It does not want to collect any and applies all precautions and filters not to collect any. If you are a parent/guardian and you believe that Sublime may be processing data from someone that you have parental responsibility for, then contact us at [email protected]
12. Data subjects’s rights
The GDPR lists the following rights:
- The right to be informed
- The right of access
- The right of rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- The right not to be subject to automated decision-making
Sublime has a process to deal with users wishing to exercise their rights by writing at [email protected]
On the right to erasure: as we do not know your name, email address, address, postcode, we don’t know who you are, where you live, what you do, it might be hard to identify your personal data, or we might not be in a position where we can technically locate it. As we apply techniques such as data minimisation (not processing more data than what is needed), we consider it would be against the spirit of the law to hold data allowing us to identify you in case you want to exercise your right to erasure. Where we do not have the ability to identify individuals, we will be unable to address individual requests for erasure. Under GDPR we would not be obligated to collect more data about the data subject for the sole purpose of responding to a request for erasure in order to comply with the law.
13. List of our key data partners
- Xandr (AppNexus Inc.): 28W 23rd street, 4th floor, New York, NY, 10010, USA
- Improve Digital: Danzigerkade 215, 1013 AP Amsterdam, Netherlands
- Smart adserver: 66 Rue de la Chaussée d'Antin, 75009 Paris, France
- Freewheel: 123 Avenue Charles de Gaulle, 92200 Neuilly-sur-Seine, France
- Nielsen Inc.: 85 Broad St, New York, NY 10004, USA
- Celtra: 545, Boylston street, 11th floor, Boston MA02116, USA
- Moat Inc: 28 E 28th St, New York, NY 10016, USA
- IAS: 95 Morton Street, 8th floor. New York, NY 10014
- DBM: 36 East 20th Street, 3rd Floor. New York, NY 10003
- MediaMath: 4 World Trade Center, 150 Greenwich street, 45th floor, New York, NY 10007
- Sizmek: 2500 Bee Caves Road, Building 1, Suite 150, Austin, TX 78746
- The Trade Desk: 42 N. Chestnut St Ventura, CA 93001 USA
- Sirdata: 20 rue St fiacre, 75002 Paris, France
- Dynata: Devon House, 58 St Katharine's Way, London E1W 1LB, UK
- Mediametrie (Nielsen FR), 70 rue Rivay, 92532 Levallois Cedex, France
14. Data Protection Officer
You can contact our data protection officer(s) at [email protected].
Maître Pierre-Louis ROUYER, Avocat à la Cour, 38 avenue Hoche 75008 PARIS
Date of issue of this data privacy statement
We reserve the right to make amendments at any time to this data privacy statement for future effect.