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Privacy Policy

Effective date: October 16, 2018

The QMJ Group Ltd ("us", "we", or "our") operates the website (hereinafter referred to as the "Service").

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from http:/



Service is the website operated by The QMJ Group Ltd

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).


Cookies are small files stored on your device (computer or mobile device).

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.

Usage Data

We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.
  • Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Use of Data

The QMJ Group Ltd uses the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), The QMJ Group Ltd legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

The QMJ Group Ltd may process your Personal Data because:

  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it is not overridden by your rights
  • To comply with the law

Retention of Data

The QMJ Group Ltd will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

The QMJ Group Ltd will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The QMJ Group Ltd will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Business Transaction

If The QMJ Group Ltd is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, The QMJ Group Ltd may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

The QMJ Group Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of The QMJ Group Ltd
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Our Policy on "Do Not Track" Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. The QMJ Group Ltd aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where The QMJ Group Ltd relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.


We may use third-party Service Providers to monitor and analyse the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:


We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.

Smart AdServer

Smart (“Smart”, “our”, “us”, “we”) is a fully transparent ad monetization platform, Supply Side Platform (“Platform”) providing programmatic buyers with exclusive access to high quality premium publisher (“Clients”) inventory. As an independent, publisher-focused platform, Smart help Smart Clients monetize their websites (“Services”) so that they can continue offering users (“Users”, “you”, “your”) free content.

Smart technology gathers User information to optimize the delivery of digital advertising to you. Smart use this information to tailor advertising to you effectively and for statistical reporting and analytics purposes, as explained below.

Smart AdServer is located at 66 rue de la Chaussée d’Antin, 75009 Paris, France. If you have any questions regarding privacy, you can contact Smart at [email protected].

The purpose of this Privacy Policy is to explain what information Smart gather, for which purposes, how Smart use it, what Smart do to protect it, and inform you about your choices regarding how Smart gather and use information about you (“Personal Data”).

How do Smart collect data?

Smart uses technologies like cookies, tags, and mobile SDKs to collect the data and store it on a user’s device. Cookies are small text files that contain a string of characters, stored in the user’s device, allowing Smart to recognize and remember the browser, user preferences and other information. The Smart tag is a small piece of code that is inserted into our Client’s website source code, for them to have access and manage our services. SDK means Software Development Kit. It is the software used by our Clients to integrate Smart to their mobile application (iOS and Android). Web beacons are used to help our Clients understand how visitors interact with their websites. Pixel tags are transparent images, iFrames, or JavaScript that are placed on a site. The use of a pixel tag allows a website to measure the actions of the visitor opening the page that contains the tag.

What data do Smart process?

  • IP address;
  • cookie information, for example your unique browser ID;
  • technical information about the device: browser, operating system, screen size;
  • information about the geographic location of the device when it accesses a website;
  • pseudonymous ID of audience segmentation (if the website uses this type of system);
  • information about other identifiers assigned to the device (IDFA, AAID);
  • information about the user’s activity on the device, including web pages and mobile apps visited or used.

Please note that, as part of our Services, Smart do not collect any information that could directly identify you. This means Smart do not know who you are. Smart do not know your address, your place of work, your date of birth, your email address, your phone number. Smart do not collect sensitive information (such as 2 religion, political opinion, health…). Smart do not create segments to specifically target children under 16 years old.


For which purposes and on which grounds will Personal Data be processed?

  1. Purposes

Smart does not collect nor process information that are not strictly necessary in relation to the purposes for which they are processed. The information Smart collect and receive will be used for the following purposes:

  • to perform our Services to our Clients, including providing, operating, managing, maintaining and enhancing our Platform;
  • to improve our performance;
  • to perform interest-based advertising and increase the relevancy of the ads being displayed to you;
  • to perform optimization in respect to a campaign, including to limit the number of times you see a particular ad;
  • to custom ads to a particular location;
  • to show ads related to the content of the concerned web page;
  • to report aggregated statistics regarding the effectiveness of an online advertising campaign for example;
  • to secure, amend and improve our Services;

In some cases, and provided that you gave your explicit consent, in the course of our Services, if activated by our Client, Smart will analyze your information to build individual profiles. These profiles will be used to predict future interests and display targeted advertisement. The aim is to provide you with relevant and interesting offers for you. The profiling is based on your behavior on our Client’s website. As Smart do not collect information to directly identify you (your name for example), Smart expect that our Services will have no further impact, other than providing you with a good user experience when visiting our Clients’ websites.

  1. Legal grounds

When Smart are operating as a data controller, meaning that Smart determine the purposes and the means of the processing, Smart rely on i) our legitimate interests to process personal data on our Platform for security purposes, for the detection and prevention of fraud and invalid inventory, to decide which buyer and creative wins an auction to purchase advertising inventory, and to optimize the real-time purchase and sale of advertising inventory or on ii) user consent if required.

When Smart are operating as a data processor, Smart are processing the data on behalf of our Clients based on their instructions. Therefore, they are accountable for the establishment of an appropriate legal basis for the processing of the data that you can find in their own Privacy Policy available on their website.

To whom do Smart provide your Personal Data? Who can have access to your Personal Data?

Smart may share information, including Personal Data, with trusted third parties that provide services for Smart, such as hosting and internet connectivity. Smart may also share data with business partners in order to perform or enhance our products and services. These third parties are prohibited from using the information Smart provide for purposes other than performing the services Smart prescribe.

Smart may also disclose information if Smart are required to do so on account of national or international law or legislation and/or to comply with an authorized request or demand, or if necessary in order to defend our own rights or interests.

Finally, Smart may transfer your data to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.



How long do Smart store the data?

The data Smart use to provide our Services is being kept between two days and thirteen months, depending on the cookie or tag storing it. For more details about the storage duration, please see the table below. The data is then no longer active and stored in a compressed form, in our archive databases for a maximum of 36 months, for security and regulatory purposes.

Pid (Smart
13 monthsAdvertising displaying, cappingUnique ID associated with an end-user
(according to a domain and a browser)
Pdomid13 monthsTechnical cookie used to distribute
the traffic between Smart’s servers
Server SQL ID associated with an end-user
Pbw2 daysAllows to display ads in the right
format according to the browser, the
screen size, the OS and to make
Browser ID, OS ID et screen size (cache)
Sasd1 daygeolocationISP ID, postal code, phone prefix, country,
region, city, DMA (designated market area)
zone ID
Sasd21 daygeolocationTimestamp, longitude, latitude, connection
Comp13 monthsLabelling end-users with key-words
defined by a Client
Key-words associated with an end-user
vsSession cookie
when closing
the browser)
Counting new visitsTimestamp of the last time an end-user
visited a website
csync13 monthsAllowing the synchronization
between the end-user Smart ID and
the Demand-Side Platform’s ID
Smart ID and DSP ID associated with an
partner-xxxx 13 monthsLabelling end-users with key-words
defined by a Partner
Key-words associated with an end-user
csfq360 minutesTechnical cookie used to trigger the
injection of monitoring scripts
Technical data
gid13 monthsEquivalent to the pid cookie for
Clients using a custom CNAME.
Used to harmonize unique IDs across
Global unique ID cross domains associated
with an end-user
dyncdn1 dayTechnical cookie used to trigger the
injection of a pixel monitoring the
performance of an end-point and its
End-point and traffic data
Trk<x>30 daysTracking cookie – to be read by
tracking pixel if any
Client (Publisher) page ID
trkC<x>30 daysTracking cookie – to be read by click
tracking pixel if any
Client page ID
TestifCookieSession cookieTechnical cookie used to test if
session cookies are accepted
Technical data
TestifCookieP13 monthsTechnical cookie used to test if
persistent cookies are accepted
Technical data
x-smrt-dSession cookieTechnical cookie used to debug by
Smart AdServer service and support
Technical data
Smart’s tag< 1 daygeolocation, fraud detection,
advertising displaying, platform
IP address


Your privacy rights

You can exercise your rights directly to Smart for the Personal Data Smart are controller of. Please note that Smart do process Personal Data on behalf of Publishers. In some cases, it may be appropriate for you to exercise your rights directly on the website of the Publisher of your choice.

You may ask Smart at any time:

  • to confirm your Personal Data is being processed and/or to provide you a copy of your Personal Data;
  • to rectify your Personal Data if it is inaccurate or incomplete;
  • to withdraw your consent;
  • to erase your Personal Data, for instance if it is unlawfully processed or if you withdraw your consent;
  • to opt out the process of any data;
  • to restrict the processing of your Personal Data, (i) if the information is inaccurate, (ii) the processing is unlawful, (iii) you need us to retain the information after the retention for a legal claim, or (iv) you have objected to the processing and a verification of our legitimate interests is pending;
  • to provide you with an electronic file of your Personal Data, or to transfer your Personal Data to a third party if technically feasible (portability).

Before you send Smart any request, please note and consider that it is not feasible for Smart to provide Personal Data that is tied to your identity. Instead, you can provide Smart with your Smart AdServer ID and Smart shall be able connect this information with the Personal Data tied to this ID (see section: How to find your Smart AdServer ID below).

Your request should be addressed to [email protected]. Smart will respond within one month. If permitted under applicable legislation, Smart may extend the response period with two further months if such is necessary due to the complexity and number of requests. Smart will notify and explain the reasons of any extension to you. If Smart deny your request, Smart will inform you of the reasons of such denial.

If you consider your rights have been infringed according to the current privacy regulation, or regarding the denial of a request you may lodge a complaint towards your local competent supervisory authority.

How to find your Smart AdServer ID?

You have the possibility to oppose the deposit of cookies and to have access to a list of your cookies by configuring your browser.

  • Chrome: Follow the primary instructions under “Delete cookies from a site” section. Search for Click on it and search for the cookie named “pid”. You can find your ID number under “Content”.
  • Mozilla: Follow the primary instructions under “Delete cookies for a single site”. Search for Search and click on the “pid” cookie. You can find your ID number under “Content”.
  • Opera: Follow the instructions under Configuring cookie settings and “Manage cookies”.Search for Search and click on the “pid” cookie. You can find your ID number under “Content
  • Safari: Follow the primary instruction under “Remove stored cookies and data”. Search for Search and click on the “pid” cookie. You can find your ID number under “Content” in the pid.

Transfer of Personal Data

Personal Data may be transferred to partner located in a third country not providing adequate protection regarding data protection, Smart sign with such partner standard contractual clauses adopted by the European Commission to ensure an adequate level of protection.

Personal Data may be transferred in the United States of America, Smart ensure that the other party is complying with the Privacy Shield Framework, regarding the collection, use and retention of personal information transferred from the European Union to the United States, respectively.

Opt-out and withdrawing of consent

For the sake of transparency, Smart has adopted a cookie opt-out policy, allowing each Internet user to opt out from our advertising network. This ensures that your browser will no longer be identified by our system. Please note that for Smart to acknowledge your desire to opt-out, one cookie will be placed on your device in order to ensure the performance of your opt-out. Moreover, this opt-out will only be available for the device on which it was created.

If you wish to opt-out, click here. A blank page will open, confirming the opt-out process has been completed and Smart will no longer place cookies on your computer.

You can withdraw your consent, as the case may be, at any time directly on the website,

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email: [email protected]