When using the Online Services, information relating to the navigation of the device (computer, tablet, smartphone, etc.), may be recorded in “cookies” files deposited on the device, subject to the choices expressed concerning cookies and which can be modified at any time.
Cookies are data used by a server to send status information to a user’s browser, and for that browser to send status information back to the originating server.
Examples of status information include a session ID, language, expiration date, response domain, etc. Cookies are used to store status information when a browser accesses different pages of a website or when the browser returns to that website later.
There are different types of cookies:
- session cookies that disappear as soon as you leave the site;
- permanent cookies that remain on your device until their lifetime expires or until you delete them using your browser’s features.
In addition, it should be noted that the Mobile App has access to identifiers that are stored on your device and allow it to be identified. Through these identifiers, the App tracking tools collect information to ensure that the App and all of its features are working and to customize advertising messages based on your habits.
2- Main purposes of the cookies and mobile identifiers installed
Some of the cookies that may be installed on your device have the exclusive purpose of allowing or facilitating communication by electronic means.
Others are strictly necessary for the provision of an online communication service at your request.
More precisely, the main purposes of the cookies installed by the Site Publisher are
- to adapt the presentation of the site to the characteristics of your device (language, resolution, operating system …);
- to memorize information that you have entered or requested or products that you have chosen;
- to allow you to access reserved areas (your account…);
- to implement security measures.
In addition, the cookies that may be installed are used to carry out statistics and traffic analyses.
Indeed, when a visitor uses the online Service, information relating to the connection and behavior of visitors for statistical purposes (number of visitors, pages visited) is collected. This information is collected to improve the content and functionality of the Site. This information does not allow a direct identification of the visitors and the Website Editor does not take any steps to identify the visitors. In particular, it does not establish any cross-referencing or reconciliation between the Personal Data that you are asked to provide, for example, in the site’s forms or when you log in, and the information necessary for statistics, in order to identify yourself.
3- List of Web Cookies and App Tracking Tools
All information about the cookies and tracking tools of the App and the Milinus website is detailed in the list below
We use the following cookies:
Company: Google Tag Manager
- Cookie name: _gat
- Purpose(s): MEASURE
- Retention period: 1 minute
Company: Google Analytics
- Cookie Name: _ga
- Purpose(s): MEASUREMENT
- Retention Period: 2 years
- Cookie Name: _gat_UA-46012774-2
- Purpose(s): MEASURE
- Retention period: 1 minute
- Cookie Name: _gid
- Purpose(s): MEASURE
- Retention period: 1 day
The Google Analytics cookies on our website use the IP address anonymization function. This means that IP addresses are only processed in a shortened form in order to exclude any connection with a specific person. The lifetime of these cookies is 1 month. In any case, you can go to http://tools.google.com/dlpage/gaoptout at any time to prevent Google Analytics cookies from being installed on your computer.
Google will use this information on our behalf to evaluate the use of our online products and services by users, to compile reports on activities within these online products and services, and to provide us with other services associated with the use of these online products and services and the Internet. Pseudonymous user profiles may be created from the processed data. We only use Google Analytics with the IP address anonymization feature enabled. This means that Google will truncate the IP address of users located in the member states of the European Union or in other countries that are party to the agreement on the European Economic Area.
Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and then truncated. The IP address transmitted by the user’s browser will not be merged with other Google data. Users can prevent the storage of cookies by changing the settings of their browser software accordingly.
The legal basis underlying the use of this service is Art. 6, para. 1, sentence 1, letter f of the GDPR. Users can prevent the collection of data generated by cookies by downloading and installing the available browser add-on. Google is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation.
If you do not wish to have your activity tracked by Google Analytics in the future, you can opt out at any time by sending an e-mail to: firstname.lastname@example.org
Google Marketing Services
In our App, we use the marketing and remarketing services of Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) which allow us to display more targeted ads that may be of interest to users. Through (re)marketing, ads and products are served to users based on an interest identified through their activity within other apps in the Google network. To do this, when a user accesses our App, Google uses a code and (re)marketing tags are embedded in the app. With these beacons, an individual cookie (i.e., a small file) is stored on the user’s device (similar technologies can also be used instead of cookies). Cookies can be set by various domains. This file records which apps users have visited, what content they are interested in and which offers have been used. In addition, it records technical information about the browser and operating system, referring apps, duration of visits and additional data about the use of online products and services. The IP address of users is also recorded. However, we would like to inform you that within the framework of Google Analytics, IP addresses from EU member states or other countries that are part of the Agreement on the European Economic Area are truncated.
All users’ data will only be processed via pseudonyms. Google does not store names or email addresses. As a result, all ads that are displayed on the screen are not specific to a person, but to the owner of the cookies. This information is collected by Google and transmitted to and stored on servers in the United States.
One of the Google marketing services we use is the Google AdWords online advertising program. With this program, each AdWords customer receives a different conversion cookie. Thus, these cookies cannot be tracked through the app of the AdWords clients. The information collected by the cookie is used to generate conversion statistics for AdWords customers who have opted-in to conversion tracking. AdWords customers can see the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they will not receive any personally identifiable information.
The underlying legal basis for the use of this service is Art. 6, para. 1, sentence 1, letter f of the GDPR. If you wish to opt out of interest-based advertising offered by Google’s marketing services, you can do so through the opt-out settings and options provided by Google. Google is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation.
Facebook Marketing Services
We use “visitor action tracking pixels” from Facebook Inc. (Menlo Park, California, USA) on our website so that we can track the behavior of users after they click on an advertisement within Facebook that directs them to our website. This allows us to measure the effectiveness of our Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, which means that we do not have access to the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you of this based on our current knowledge of the situation. Facebook may link this information to your Facebook account and use it for its own promotional purposes in accordance with Facebook’s data use policy. You may give Facebook and its partners permission to display advertisements on and off Facebook. For these purposes, cookies may also be stored on your computer. You may object to the collection of your data by the Facebook pixel or to the use of your data for the publication of advertisements by Facebook.
We also use Facebook’s Software Development Kit (SDK) in our apps to link various Facebook services to our apps. For example, this allows users to share content from our apps on their Facebook feed or to send messages to other Facebook users. More information about the Facebook SDK for iOS is available here. For Android, please visit: https://developers.facebook.com/docs/android
We use Facebook’s Events app via the Facebook SDK to observe both the reach of our advertising campaigns and the use of the Facebook SDK. Facebook simply provides us with a general analysis of user behavior with respect to our app. We have no further influence on the information that will be processed by Facebook through the Events app. In the settings of our app, you can opt out of the use of the Events app for these purposes.
Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation. The legal basis for this data processing is Article 6, paragraph 1, sentence 1, letter f of the GDPR. If you do not wish to have your activity tracked by Facebook in the future, you can opt out at any time by sending an e-mail to email@example.com
Facebook Custom Audiences
As part of online advertising based on user behavior, Facebook’s Custom Audience service (Facebook Custom Audience 1601 S. California Avenue, Palo Alto, CA, 94304) is also used on our website. As a rule, your usage data generates a non-reversible, non-personal checksum (digital footprint) that can be transmitted to Facebook for analysis and marketing purposes. This is done either by placing a Facebook pixel code on our website or by recording your browsing behavior in our app via the Facebook SDK (for a detailed description of these two Facebook services, see the section above). We may also provide Facebook with a customer list that includes the email address you provided to us when you signed up. This allows us to collect information about your activity on the site (such as browsing behavior, subpages visited, etc.). This allows Facebook to create a profile on our app and website about your browsing habits. Your IP address is recorded and used to send you geographically targeted advertising.
The legal basis for this data processing is Article 6, paragraph 1, sentence 1, letter f of the GDPR.
For registrations from June 2020: The underlying legal basis for this data processing is Art. 6, para. 1, sentence 1, letter a of the GDPR. We will only actively provide Facebook with customer lists containing your email address or other personal data with your consent. You can of course withdraw your future declarations of consent at any time.
If you no longer wish us to share your data with Facebook, you can object to this in the settings of our apps. In this context, please note that Facebook may also use the data we provide about your browsing behavior and e-mail address for its own purposes. You have the possibility to object to the targeting by Facebook here. You can also contact us directly by e-mail at firstname.lastname@example.org.
For more information about the purpose and scope of data collection, further processing and use, and privacy settings, please see Facebook’s data protection guidelines.
The underlying legal basis for the use of this service is Art. 6, para 1, sentence 1, letter f of the GDPR. If you wish to opt out of interest-based advertising offered by Remerge, you can do so through the opt-out settings and options provided by Remerge.
In the context of online advertising based on user behavior, the personalized audience service of Snapchat (Snap Group Limited, 7-11 Lexington Street, London W1F9AF, Great Britain) is also used on our website. As a rule, your data usage generates a non-reversible, non-personal checksum (digital fingerprint) that can be transmitted to Snapchat for analysis and marketing purposes. In doing so, a Snapchat tracking pixel is placed on our website. This collects information about your activity on the site (such as browsing behavior, subpages visited, etc.). Your IP address is recorded and used to send you geo-targeted advertising.
You have the ability to opt out of this targeting by Snapchat. You can also contact us directly by email at: email@example.com
We use the Firebase service from Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) to obtain behavioral analysis data. This information allows us to see how users interact with our website and app.
Firebase is part of the Google Cloud Platform and offers many services to developers. Some Firebase services process personal data. In most cases, this data is limited to what is known as the “instance ID”, which is provided with the date and time stamp. These “instance identifiers” assigned by Firebase are unique and thus make it possible to link different events and processes together. We do not consider this data to be personally identifiable information, nor do we seek to associate it with anyone in the future. We process this aggregated data in order to analyze and optimize usage behavior, for example by studying error reports.
Currently, we use the following services from Firebase:
Google Analytics for Firebase: Google Analytics uses the data to provide analytics and attribution information. The exact information collected may vary depending on the device and environment. Google Analytics retains data associated with an ID for 60 days, and retains consolidated reports and campaign data with no automatic expiration time, unless the Firebase customer changes their data retention preferences in the Google Analytics settings, or deletes their project.
With Analytics for Firebase, Google uses not only the “instance ID” described above, but also the advertising ID of the user’s device. You can restrict the use of the ad ID in your mobile device settings. For Android: Settings > Google > Ads > Reset Ad ID For iOS: Settings > Privacy > Advertising > No Ad Tracking
Firebase Remote Config: Remote Config uses instance credentials to select configuration values to send back to end-user devices. Firebase retains the instance IDs until its client makes an API (App Programming Interface) request to remove them. Following this request, the data will be deleted from active and backup systems within 180 days.
Firebase Dynamic Links: Dynamic Links uses the features of a device on iOS to open recently installed apps on a specific page or in a specific context. Dynamic Links only temporarily retains the device’s features in order to provide the service.
Firebase Cloud Messaging: Firebase Cloud Messaging is used to deliver in-app notifications or messages (messages that are only displayed within the app). A pseudonymous notification reference is associated with the mobile device that is targeted by the in-app notifications and messages. Notifications can be turned off and on at any time in the mobile device settings. Firebase Cloud Messaging uses instance IDs to determine which devices to send messages to. Firebase retains the instance IDs until its client makes an API (App Programming Interface) request to remove them. Following this request, the data will be deleted from active and backup systems within 180 days.
Firebase will use this information on behalf of Milinus for the purposes stated above.
The underlying legal basis for the use of this service is Art. 6, para. 1, sentence 1, letter f of the GDPR. Google is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation.
3.2 App Tracking Tools
We use the following tracking tools:
- Apple connect
- Facebook connect
4- cookies settings
You have several options to manage cookies and oppose them if you wish. Indeed, if most browsers are set by default and accept the installation of Cookies. You have the possibility, if you wish, to choose to accept all the cookies, or to reject them systematically or to choose the ones you accept according to the sender.
You can also set your browser to accept or reject cookies on a case-by-case basis prior to their installation. You can also regularly delete cookies from your device via your browser. Do not forget to configure all the browsers of your different devices (tablets, smartphones, computers).
The configuration of each software is different. It is generally described in the help menu of your browser. We invite you to read it. You will then be able to know how to modify your wishes regarding cookies.
In any case, you can go to the help section of your browser to find out how your browser allows you to choose the cookies you accept or refuse.
Several advertising industry platforms also offer you the option to refuse or accept cookies used by their member companies. These centralized mechanisms do not block the display of advertisements but only prevent the installation of cookies allowing the adaptation of advertisements to your centers of interest. You can, for example, go to the site www.youronlinechoices.com to prevent the installation of these cookies on your device.
5- Setting up Mobile IDs
Mobile credentials are collected and used as long as the App is installed on your device. If you do not want us to collect and use your Mobile IDs, you should not install the App on your device.
With the exception of tracking tools used for advertising purposes, all of the tracking tools in the App listed above are necessary for the stable operation and use of the Online Services to which you have subscribed.
For tracking tools for advertising purposes, you can set your device to refuse personalized advertising:
For Apple / IOS:
Go to Settings > Privacy > Advertising
Activate “Limited ad tracking”.
(In case of changes, please visit: https://support.apple.com/en-us/HT205223)
For Android / Google Play Store:
Go to Settings > Account or Sync or Google (depending on your device) > Privacy or Advertising or Ads (depending on your device)
Enable “Disable ad personalization”.
You are informed that turning off ad personalization will not disable advertising on the App, you will only see non-personalized ads.
Alternatively, you can download the AppChoice: https://youradchoices.com/appchoices which allows you to select which advertisers are allowed to collect your advertising preferences.
At any time, you can prevent the App’s tracking tools from using your mobile credentials by uninstalling/deleting the App from your device.
If you have any questions about this cookies policy or any requests regarding cookies and mobile IDs, you can contact us at firstname.lastname@example.org