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Charter for Interactive Advertising and Protection of Privacy



This 1000mercis Group Information and Commitment Charter (hereinafter the "Charter") for interactive advertising and protection of privacy allows You to find out more about:

We know this Charter is important to You, in order to have a positive and confident experience of interactive advertising. It is also important for us, so that We can answer Your questions in a precise and customized manner, and taking into account Your expectations whilst respecting Your choices and rights.



1. LEGAL INFORMATION



1000mercis / numberly is a French limited company with capital of 285,865.60 euros, headquartered at 28 rue de Châteaudun 75009 Paris, France, registered in Paris under the registration number B 429 621 311, represented by Mrs Yseulys Costes, President.

1000mercis can be contacted for any questions relating to this Charter by writing to dpo@numberly.com or by calling +33 (0) 1 49 49 06 60 between 9 am and 7 pm (CET) on working days (excluding weekends and French Bank Holidays).

The website www.1000mercis.com is hosted by Interxion France SAS - 129 boulevard Malesherbes - 75017 Paris.



2. DEFINITIONS AND GOVERNING LAW TO THE CHARTER


2.1 Definitions

"IP Address(es)" means the identification number assigned by Your internal access provider to Your Devices when connected to the Internet via the Internet Protocol (TCP / IP: Transfer Control Protocol / Internet Protocol) and We may have to deal with Your visit of the Site, one of Our Services, or an electronic communication service of one of Our Partners.

"Charter" means this document accessible on the website: https://1000mercis.com/ (hereinafter "the Site"), at the following address: http://ads.1000mercis.com/en.html

"Cookie(s)" means a text file that may be registered, subject to Your agreement in accordance with applicable French and European regulations (article 5.3 of the "ePrivacy" Directive 2008/58 / EC modified by the 2009 Directive / 136 / UE, or any subsequent text that succeeds them), in a space dedicated to Your browser in the hard drive of Your Device, during the consultation of one of Our Services or an electronic communication service of one of Our Partners or the installation of a browser or a mobile application. A Cookie file allows its issuer to identify the Device in which it is registered, during the validity period or registration of the Cookie. The validity period of a Cookie does not exceed thirteen (13) months, in accordance with the current regulations.

"Device(s)" means the equipment (computer, smartphone, telephone, etc.) that You use to access the Site, to use one of Our Services, to receive offers from Our Services or to consult electronic communication services of one of Our Partners.

"Navigation Data" means data relating to the connection of a Device to the Internet or an electronic communication service at a given time. We may process Navigation Data under the terms of this Charter, even though We do not necessarily know which Device You are using, or who You are at any time.

"Personal Data" means the data referred to in Article 4.1 of the EU General Data Protection Regulation 2016/679 of 27 April 2016, and allowing You to identify yourself, directly or indirectly at a given time, regardless of which Device You are using.

"Partner(s)" means any company other than those that make up the 1000mercis Group, their Service Providers, or Third Parties, related to 1000mercis by a contract of Services 1000mercis.

"Service Provider(s)", "Subcontractor(s)" means any company that may be required to process Data for Our Account, in accordance with Our instructions.

"Third Party" means any company(s) or public entity(s) (judicial or administrative authority) other than Us, Our Service Providers and Our Partners.

"You", "Your", "Member(s)", "User(s)" means any natural person who accesses, uses or is registered with one of Our Services governed by this Charter, or who consults or is a Member of a service of one of Our Partners and which We may have to treat, in compliance with this Charter and the applicable law, the Personal Data and / or Navigation Data related to this access, consultation, use or registration.

"We", "Our", "Site(s)", "Service(s)", "1000mercis Group", "Group", means 1000mercis Group companies and their Service Providers who may under certain conditions described below collect, use, store or share Navigation Data and Personal Data created or modified on the occasion of Your access or Your use of the Site or Our Services, the receipt of an offer or an interactive advertisement from one of Our Services or the visit of an electronic communication service of one of Our Partners.



2.2 Governing law and control Devices

The rights of Users and Members governed by Our Charter are related to the processing of Personal Data and Navigation Data by the 1000mercis Group, whose principal place of business is located in France. They are governed by the French law and by the international texts and treaties applicable in France, and in particular the EU Regulation
n°2016/679 of 27 April 2016.

1000mercis protects the Personal Data and privacy of Users in accordance with strict European and French rules applicable in this area. The processing of Personal Data and Navigation Data carried out within the framework of Our Services are the subject of a permanent and independent internal control placed under the authority of Our Data Protection Officer (DPO) designated to the CNIL (Commission Nationale Informatique et Libertés). You can, at any time, contact Our Data Protection Officer for any further information, by writing to dpo@numberly.com.

This Charter does not apply to the services and data processing services implemented by Our Partners, nor to Third Parties practices to the 1000mercis Group, over which the 1000mercis Group has no control.



3. NAVIGATION DATA PROCESSED BY 1000MERCIS

Since its creation, 1000mercis Group has always sought to anticipate the expectations of consumers and Internet Users, both in terms of protection of their private life and commercial aspects. Our ultimate ambition is to provide Our Members with offers that may be of interest to them, more relevant and less frequently than those offered by Our competitors.

Thus, in order to adapt the frequency of sending and the type of offers sent by 1000mercis to its Members, We process Navigation Data attached to their Devices) and browser used by their Device(s).



3.1 What is Navigation Data?

It involves traffic data, as defined in paragraphs b) and c) of Article 2 of the “ePrivacy” Directive 2002/58/EC as amended by Directive 2009/136/EC, and in particular:

3.2 What do We use for it?


Certain Navigation Data must be legally retained to enable us to ensure the security of Our Electronic Communications Services and to detect, avoid or find malicious or intrusive attempts or breaches of the terms of use of Our Services. Such is the case of the IP Address, dates and times of connection of a Device to one of Our Services.



We may be required to process Navigation Data when we receive or consult an electronic survey that We have sent to a Member. This Navigation Data may, in particular, result from Cookies that We operate within emails that We disseminate, subject to the choices expressed by the Member concerned in his/her browser and from Us.

This Navigation Data allows us to:



We may have to process Navigation Data about a User's reaction to an e-mail (e-mail, SMS, MMS) that We sent to him: has this mail been received and has the Member reacted or not to the content of this letter, has he/her visited the online Service promoted by this mail, has the Member subscribed to the promoted offer, etc?

Other Navigation Data may also relate to a User’s visit to a Service of one of Our Partners, to his journey on such a Service or to his/her reaction to the display of an Interactive Advertisement that We have posted or disseminated on behalf of one of Our Partners on one of its Services or on the Service of a Third Party.

This Navigation Data associated with a Cookie issued by 1000mercis also relates to the consultation of the electronic communication Services of Our Partners by the Device of a Member. Where applicable, these Navigation Data may allow Us, subject to Your consent and, at a later date, unless You object to Us, to determine which interactive advertisements or electronic surveys (by e-mail, SMS or MMS) are likely to interest a User, according to the electronic communication Services of Our Partners previously consulted by his/her Device and noted by the Cookies that We operate in relation to Our Partners.

However, when the Device of a Member is used by more than one person and when the same Device has several browsers, We can not ensure that interactive advertising or electronic surveys addressed to a User or his/her Device correspond to his/her own use of his/her Device and not to that of other Users of his/her Device.

If applicable, sharing the use of the Device with others is the free choice and responsibility of the Member. In addition, the Member's management of the privacy protection parameters offered by the browser(s) of his/her Device is his/her free choice and his/her sole responsibility.



The Navigation Data allows us to adapt the content or display of an interactive advertisement to a Member’s Device that We intend for his/her Device, by determining:



4. YOUR RIGHTS ON THE USE OF YOUR NAVIGATION DATA

The registration of a Cookie in a Device is subject to the will of the User of the Device, that can express and modify at any time through the choices offered by his/her browser, in accordance with the current regulations.

To find out about the options offered by Your browser and how to delete cookie files stored in Your Device, depending on the browser(s) installed on Your Device, We invite You to consult the "Your tracks" section of the website CNIL:

http://www.cnil.fr/vos-libertes/vos-traces/les-cookies/

The prior consent of the User

In accordance with the applicable regulations and the recommendations of the CNIL, 1000mercis informs Users, within an information banner, at the time of the first visit to the Site, that by continuing his/her Navigation on the website, the User accepts the use of Cookies to have Services and offers adapted to his/her interests.

Users may be informed about the use of Cookies and refuse this use by clicking on the link proposed or by consulting this Charter.

The validity of the User's consent is 13 months. At the end of this period, the information banner will be displayed again to collect the consent of the User.

The deposit and reading of Cookies will not be carried out if the User goes to the Site and does not continue browsing, this lack of action will be considered as an implicit refusal to use Cookies.

Similarly, if the User clicks on the link present in the information banner allowing him/her to set Cookies and if necessary, refuse the storing of Cookies.

If You have accepted the registration of Cookies in Your Device within Your browser, the Cookies that We issue may be stored temporarily in a dedicated area of Your Device. In these cases, We will be able to perform the processing of Your Navigation Data described above.

If You have refused in Your browser, prior to Your visit to the Site, the storing of Cookies on Your Device, the 1000mercis Cookies will not be triggered at the time of Your visit to the Site.



In accordance with the governing regulations, You benefit from Your data rights of access, rectification, deletion, portability, limitation to processing and profiling, and opposition for legitimate reason to the processing of Your Personal Data and of Navigation.

You can exercise Your rights at any time with 1000mercis and the Data Protection Officer at the following address: dpo@numberly.com

We will respond to Your requests within one (1) month of receiving Your request.

Any request will be admissible provided it is accompanied by a valid identity document.

You have the right to lodge a claim to the CNIL.



If You have refused the registration of Cookies in Your Device within Your browser or if You erase Cookies that We have registered there, We will not (or no longer) perform the processing of Your Browsing Data described above and the Navigation Data about You will no longer be recorded by Our Services.



You can refuse the use of Cookies at any time by 1000mercis, declaring Your refusal via the following opposition tool: mmtro.com/privacy/en/

Or, by setting up Your browser:

To know the options offered by the browser and the acceptance, refusal, reading or deletion of the cookie files of the Organizer or its Service Providers, the participant is invited to consult the following pages depending on the software Navigation used by this one:

https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies#ie=ie-11

https://support.google.com/chrome/answer/95647?hl=

https://support.apple.com/safari

https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored

http://www.opera.com/help



5. INTELLECTUAL PROPERTY

This presentation and each of its elements, the Site, including its trademarks, logos and photographs, domain names and graphic elements belong exclusively to 1000mercis and are protected by the laws on intellectual property.

The provisions of this Charter are protected by copyright and are the exclusive property of the 1000mercis Group. They may not be reproduced or exploited, in whole or in part, for the purposes of a commercial activity other than journalism, without the prior written permission of 1000mercis.