Personal Data Privacy Policy

This policy is intended to inform you, in a transparent manner, the processing of different  personal data used in connection with the use of the services provided by ADVALO.

1. WHO ARE WE?

As part of its activities, ADVALO provides its professional customers with an online PULSE  platform enabling them to follow the online and offline journey of their customers.

ADVALO is committed to respecting the privacy of individuals, so it is committed to ensuring the highest level of protection of their personal data.

ADVALO, acts as a subcontractor, and undertakes to comply with the provisions of Law No. 78-17 of 6 January 1978, as amended, relating to data, files and freedoms with regard to the automated processing of personal data of personal data as well as the regulation (UE) n ° 2016/679 of April 27, 2016 from its application on May 25, 2018.

2. WHAT ARE THE PERSONAL DATA COLLECTED?

What is personal data?

The term “personal data” is defined as any information that directly or indirectly identifies a natural person, in particular by reference to an identification number, location data, an online identifier (IP address, cookie) …

As part of the provision of the PULSE platform by ADVALO, the customer can collect:

Personal data identifying persons (Surname, first name, address)

  • Personal data relating to your personal life (number of children, name of spouse)
  • Personal data related to transactions of purchased goods and services
  • Personal data related to navigation
  • Location-related personal data

3. WHO COLLECTS PERSONAL DATA?

The personal data processed by ADVALO is collected by its professional customers as part of the provision of the PULSE software and the tag inserted on the site is made available by ADVALO.

ADVALO acts as a subcontractor within the provision of the regulations. In this context, ADVALO acts in accordance with the lawful instructions of its customers and in compliance with the obligations imposed by the law n ° 78-17 of 6 January 1978 modified relating to data processing, files and freedoms with regard to the automated processing of personal data and Regulation (EU) No 2016/679 of 27 April 2016 from its application on 25 May 2018.

4. WHAT ARE THE PURPOSES OF COLLECTING PERSONAL DATA?

When personal data is collected and stored in the PULSE platform; ADVALO can process them for the following purposes:

  • Measure the attendance of the site
  • Follow-up with customer behavior for online and offline reconciliation
  • Host customer data using the PULSE platform
  • Commercial prospecting operations

ADVALO ensures that all quantities of data collected within its platform is processed with strict compliance to their stated purposes.

5. WHO IS THE DATA TRANSMITTED TO?

When the data is collected by the customer in the platform, it sends them to ADVALO for the fulfillment of the aforementioned purposes. ADVALO does not transmit any of this data to a third party entity without the prior consent of the customer.

As part of the services offered by ADVALO, the customer can use connectors (Ex: Mailchimp, Digitaleo …) developed by third parties. These entities may be recipients of personal data when the ADVALO customer uses it.

The different connectors and potential recipients of the data are:

  • AppNexus
  • Google Adwords
  • Splio
  • SMART FOCUS
  • MailChimp
  • Facebook
  • Salesforce
  • Digitaleo

6. WHAT ARE YOUR RIGHTS AND HOW TO EXERCISE THEM?

The law of 6 January 1978 gives the right to any natural person whose personal data is processed within the framework of an information society to exercise their rights of access, rectification and opposition. And the right to clearly define advance directives on the fate of its data after death in accordance with Articles 38 to 40. Pursuant to Regulation 2016/679 of 27 April 2016, the natural person may also exercise a right to limit treatment, to the portability and erasure from May 25, 2018.

These rights can be exercised directly with the companies that collect the data of the natural person by following the procedure issued by them. These rights can be exercised by writing to the company which also has a period of two months to respond. However, in the absence of a satisfactory answer, the natural person has the right to lodge a claim with the National Commission on Informatics and Liberty.

7. IS THE PERSONAL DATA SENT OUTSIDE THE EUROPEAN UNION?

The personal data that is processed on the PULSE platform may be transmitted solely for the purposes previously defined earlier by the companies located in countries outside the European Union and which do not have an adequate level of protection with regards to the protection of personal data (USA).

Thus,prior to the transfer outside the European Union, and in accordance with the regulations in force, ADVALO implements all the procedures required to obtain the guarantees necessary to secure such transfers and warns its client of the need to regulate data transfers.

8. HOW LONG IS THE PERSONAL DATA PRESERVED?

Each client determines, within the framework of its internal policy, the adequate retention period of its data. In compliance with this policy, ADVALO updates the data transmitted to it.

Internally, ADVALO has defined its own policy in accordance with the instructions of the client and the law n ° 78-17 of 6 January 1978 modified relating to data processing, files and freedoms with regard to the automated processing of data. personal nature achieved as well as Regulation (EU) No 2016/679 of 27 April 2016 from its application on 25 May 2018.

This retention period is applied when the customer does not define any data retention period and does not send any instructions to ADVALO. This retention period is set at 5 years from the last contact of the individual with the customer.

9.WHAT SECURITY MEASURES ARE ADOPTED TO PROTECT THE DATA?

General rules

As a subcontractor, ADVALO, takes all the necessary measures to preserve the security and the confidentiality of the data in respect with the regulation of (article 35 of the law 78-17 of January 6th, 1978) and those instructions to its customers in order to ensure safety.
ADVALO has put in place adequate measures in accordance with the state of the art in this area.

Without these measures being exhaustive, ADVALO has placed in existence:

  • Permanent monitoring of his tools and procedures by appointing a Data Protection Representative who accompanies him on these subjects,
  • A secure data transmission device
  • Secure data consultation through the implementation of a complex structure password policy

10. DOES ADVALO USE COOKIES, TAGS AND TRACERS?

WHAT IS A COOKIE?

The term “cookie” encompasses several technologies that make it possible to perform navigation tracking or behavioral analysis of the user. These technologies are numerous and are constantly evolving. For example there are specific types of cookies, tags, pixels, Javascript code. The HTTP cookie, which is currently the most widely used technology. It is a small text file saved by the browser of your computer, tablet or smartphone that allows to keep user data to facilitate navigation which permits the onset of certain features.

Therefore,when a customer implements on its website the services offered by ADVALO, this will result in the generation of a cookie that is deposited on the terminal of its own customer or visitors of its website, subject to the choices that the user would have made concerning Cookies and it can change at any time.

WHAT ARE THE REASONS FOR COOKIES, TAGS AND TRACERS ?

Cookies that the customer sends on the site allow him:

  • To establish statistics and volumes of use when applied to various sections of the site. eg..(audience measurement cookies)
  • Allow to reconcile the online and offline behavior of consumers

HOW TO SET THE COOKIES, TAGS AND TRACERS DEPOSIT?

In accordance with Article 32II of Law 78-17, each client of ADVALO must obtain the prior consent to the deposit of advertising cookies, audience measurement and sharing to social networks.

 

The user can make the choice at the entrance to the customer’s website using the cookie banners provided for this purpose or by setting his browser. In addition, the cookies offered by ADVALO can be set in the Tag Manager (Ghostery, Commanders Act …).

 

In compliance with the regulations, ADVALO advises each customer to insert an information banner at the entrance of their sites in order to collect the prior consent of Internet users before the deposit of cookies and to disseminate a cookie policy on their websites. .

Setting up your browser software

The user can configure his browser so that cookies are stored in his terminal or, retroactively, they are rejected, either systematically or specifically according to their issuers. He can also configure his browser so that the acceptance or the refusal of cookies are proposed to you punctually, before a cookie is likely to be registered in your terminal.

How to exercise your choice, depending on the browser used?

For the management of cookies and your choices, the configuration of each browser is different. It is described in the help menu of your browser, which will allow you to know how to change your wishes for cookies.

For Internet Explorer™ : http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies ,
For Safari™ : http://docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html ,
For Chrome™ : http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647 ,
For Firefox™ : http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies ,
For Opera™ : http://help.opera.com/Windows/10.20/fr/cookies.html

Setting up the operating system of your smartphone

You have the capacity to control the deposit of Cookies on your Smartphone in the rules of the operating system.

For iOS : https://support.apple.com/fr-fr/HT201265
For Android : https://support.google.com/chrome/topic/3434352

To better know your rights, visit the CNIL website : www.cnil.fr/fr/comprendre-vos-droits

Last Update: 01/17/2018