KAIROS PRIVACY POLICY


Last update: 14th january 2021

 

 

Kairos Fire puts the utmost care in user privacy and in the confidentiality of the data collected by its solution.
Below is our Privacy Policy with all necessary information about data collection by Kairos.

 

 

1. IDENTITY OF THE DATA CONTROLLER


The data controller is KAIROS, a simplified joint-stock company with a capital of 68 345,00 Euros, registered in the Paris Trade and Companies Registry under number 513 652 438 Kairos' registered office is located at 128 rue La Boétie 75008 Paris, France.

 

 

2. HOW DOES OUR SOLUTION WORK?


Kairos collects data from in-store visits. To do so, Kairos installs beacons, compatible with Kairos' partner mobile applications, in points of sale. If the User has given his consent (opt-in) to the said application, the application sends us the in-store visit data.

The data is then processed and aggregated to measure the impact generated by advertising campaigns on in-store traffic.

Kairos provides its customers with a statistically extrapolated report of the uplift in traffic generated by a media campaign.
The final output is an uplift percentage (e.g. +12%).

We are a measurement and statistical analysis solution with a focus on in-store traffic .

We do not operate advertising campaigns.

 

 

3. WHAT CATEGORIES OF PERSONAL DATA DOES KAIROS COLLECT?


Kairos collects the following data from its mobile application partners who have integrated its SDK and with the consent of the Users:

• The identification number of the detected beacon
• The phone's advertising ID: IDFA (for IOS devices) and GAID (for Android devices)
• The timestamp (date and time of collection)

Nous collectons également la langue du téléphone et son système
d’exploitation (versions iOS ou Android.).

We also collect the language setup of the phone and its operating system (iOS or Android versions).

The advertising ID we collect is a unique identifier attached to a mobile phone, and can be reset at any time by the User by following the procedure below:

• For iOS: go to "Settings", then "Privacy", then "Advertising" and then "Reset Ad-ID" ;
• For Android: go to "Google Settings" (or "Settings" then "Google"), then "Ads".

Kairos does not collect any data that directly identifies Users (such as last name, first name, email address, phone number, etc.)

 

 

4. WHAT ARE THE PURPOSES OF KAIROS' PROCESSING OF PERSONAL DATA?


The purpose of the data processing by Kairos is to provide to its customers a measurement of the impact of their advertising on the traffic in their the point(s) of sale.

The final measure is therefore not traceable to a specific User.

Kairos undertakes to process personal data only for the purposes for which Users have given their consent.

 

 

5. WHAT IS THE LEGAL BASIS FOR PROCESSING PERSONAL DATA?


Kairos only collects and processes the User's data once the User has expressly consented to it through two opt-in windows on Kairos' partner mobile applications. The collection is only possible after the concerned Users have given their consent.

Our publishing partners contractually guarantee that they have informed the Users of their mobile applications of the purposes of the data processing before collecting their consent, purposes which are outlined in their Terms of Use.

We also insist on the fact that without opt-in, it is technically not possible for Kairos Fire to collect any data.

 

 

6. WHO ARE THE RECIPIENTS OF THE DATA COLLECTED?


We provide our clients (mainly Advertisers and their Agencies) with studies that contain only anonymized statistical data with the purpose to evaluate the impact of advertisements that have been marketed to them by media companies.

No data collected by the Kairos Fire solution is shared with third parties.

 

 

7. HOW LONG IS THE DATA STORED?


The data collected is kept for no longer than thirteen (13) months from the date of collection. This timeframe is in adequation with the purpose of the processing made by Kairos.

 

 

8. WHAT ARE THE RIGHTS OF THE MOBILE APPS' USERS?


You have the following rights:

• The right to access your personal data,
• The right to request the rectification of your data if they are incorrect,
• The right to request the deletion of your data,
• The right to limit the processing of your data,
• The right to object to their processing by withdrawing your consent,
• The right to benefit from the portability of your data,
• The right to lodge a complaint with the CNIL

You can address all questions about your rights to our data protection officer whose contact details are given below.

In order for requests from mobile apps' Users to be processed by Kairos, we would need you to provide us with your advertising ID.
The process to obtain your phone's Ad ID is the following:
• For iOS devices: you must download an application to retrieve your IDFA (e.g. the Identifiers) which will give you access to your identifier by following the link below:
https://itunes.apple.com/us/app/the-identifiers/id564618183?mt=8 ;
• For Android devices: you can directly access your ID in your phone's settings, by going to the "Ads" section.

You have the right to withdraw your consent at any time.
Such withdrawal does not affect the lawfulness of the processing based on the consent made prior to the withdrawal of consent.

 

 

9. DATA SECURITY


Kairos is committed to providing a level of security appropriate to the risk associated with the processing of your personal data.

In particular, Kairos has implemented the following principles to ensure the protection of its databases:
• Limited access by IPs
• Access by complex passwords
• Secure access to servers (ssh keys with passphrases)

The data collected by Kairos is stored on servers in France (Datacenters Iliad and OVH).

The Kairos solution does not transfer the data collected to third parties. We do not aggregate the data collected with other data in our possession.

The Kairos solution uses a pseudo-anonymization process for the collected data via sha256.

 

 

10. CONTACT INFO OF THE DATA PROTECTION OFFICER


In accordance with the applicable regulations, Kairos has appointed a Data Protection Officer (DPO).

You can contact him/her for any question related to our privacy policy:
• by email: dpo@kairosfire.com ;
• by mail: DPO - KAIROS - 128 rue La Boétie 75008 Paris

 

 

11. UNSUBSCRIBING (OPT-OUT)


A User may at any time unsubscribe from the Kairos service on his/her cell phone or via the partner mobile application (and without affecting its operation):

• Case 1: the User does not want the ads he receives to be measured by any party whatsoever
He just needs to deactivate in his phone settings the use of the advertising identifier.

• Case 2: More specifically, the User no longer wishes to benefit from Kairos services
We appear in the General Terms of Use (GTU) of our partner mobile applications, in which the user can find the means to contact us so that we can process his data according to his wishes.