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Data Protection and Privacy Charter

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This information charter sets out the 1000mercis Group's commitments (hereinafter the "Charter") with regard to interactive advertising and the protection of privacy, and provides you with information on:

This Charter is important for you, providing you with the means to have a positive, trustful experience of interactive advertising. It is equally important for us as it enables us to answer your questions in a precise and appropriate way, take your expectations into account and respect your choices and rights.


  1. LEGAL INFORMATION
  2. DEFINITIONS AND APPLICABLE LAW
    1. Definitions
    2. Applicable Law and Control Mechanisms

  3. BROWSING DATA PROCESSED BY 1000MERCIS
    1. What is Browsing Data?
    2. What do We use them for?
      1. To secure Our Services
      2. To measure the receipt and reading of Our e-mails
      3. To adapt interactive advertisements to a User
      4. To adapt interactive advertisements to a Terminal

  4. YOUR RIGHTS REGARDING THE USE OF YOUR BROWSING DATA
    1. Information from the User through this Charter and via Our Services and those of Our Partners
    2. To exercise all Your rights
    3. Prior consent from the User
    4. Accept or refuse the use of Cookies at any time

  5. How long Your Personal Data will be kept
  6. Sharing Your Personal Data
  7. Security
  8. INTELLECTUAL PROPERTY
  9. CHANGES TO THE CHARTER


1. LEGAL INFORMATION

1000mercis - Numberly is a French société anonyme with a capital of €285,865.60, located at 28 rue de Châteaudun 75009 Paris, France, registered with the Paris Trade and Commerce Register under number B 429 621 311, represented by Ms Yseulys Costes, the CEO. 1000mercis may act, depending on the situation, as:

- the person responsible for processing Your Personal Data in the context of the continuous improvement of the Services that we provide to Our Partners and the operation of our Websites, based on our legitimate interest, or

- the Processor for Our Partners who entrust us, under their responsibility, with the mission of processing Your Data on their behalf and under their instructions, as part of the Services that we provide to them. In the latter case, the legal basis on which 1000mercis processes Your Personal Data is the one under which Our Partner is likely to Process Your Personal Data.

1000mercis can be contacted for any questions relating to this Charter by emailing our Data Protection Officer at dpo@numberly.com or by calling +33 (0)1 49 49 06 60 between 9:00 am and 7:00 pm (Paris time) on working days (excluding weekends and French public holidays). The website www.1000mercis.com is hosted by Interxion France SAS - 129 boulevard Malesherbes - 75017 Paris.

2. DEFINITIONS AND APPLICABLE LAW

2.1. Definitions

"IP Address" means the identification number assigned by your Internet Service Provider to Your Terminal when connecting to the internet via the Interpret protocol (TCP/IP: Transfer Control Protocol/Internet Protocol) and which We may be required to process when You access our Website, consult one of Our Services or an electronic communication service from one of Our Partners.

"Charter" means this document, which can be accessed via the Website: https://www.1000mercis.com (hereinafter the "Website"), at the following address: http://ads.1000mercis.com/

"Cookie(s)" means a text file that may be saved, subject to your agreement expressed in accordance with applicable French and European regulations (art. 5.3 of the "ePrivacy" Directive 2008/58/EC, modified by Directive 2009/136/EU, or any subsequent text that may succeed them), in an area dedicated to the browsing software on your Terminal's hard drive, when consulting one of Our Services or an electronic communication service of one of Our Partners or when installing software or a mobile application. A Cookie allows its issuer to identify the Terminal on which it is registered for the Cookie's validity or registration period. The validity period of Our Cookies does not exceed thirteen (13) months, in accordance with the regulations in force.

"Browsing data", "Browsing" mean the data relating to the connection of a Terminal to the Internet or to an electronic communication service (for example, a website) at a given time. We may process Browsing Data under the conditions set out in this Charter, even if We do not necessarily know which Terminal You are using or who You are at any given time. Some Browsing Data may constitute Personal Data, as defined below.

"Personal Data": means the data referred to in Article 4.1 of the EU General Data Protection Regulation No. 2016/679 of 27 April 2016 (hereinafter, "GDPR"), which allows You to be identified, directly or indirectly at a given time, independently of the Terminal You are using.

"We", "Our", "Us", "Website(s)", "Service(s)", "Publisher", "1000mercis", "Numberly", "1000mercis group", "Group" mean the companies within the 1000mercis Group and their Service Providers, who may, under certain conditions described below, be required to collect, use, store or share Browsing Data and Personal Data created or modified when You access or use the Website or Our Services, receive electronic prospecting or interactive advertising from one of Our Services or visit an electronic communication service from one of Our Partners within which We provide Our Services to the latter or to Third Parties designated thereby.

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

"Service Provider(s)", "Subcontractor(s)" mean any person or company that may be required to process Data on Our behalf, in accordance with Our instructions and Article 4.8 of the GDPR, as well as, in general, any person acting on behalf of and under the instructions of a Data Controller.

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

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

"You", "Your", "Member(s)", "User(s)" mean any natural person who accesses, uses or is registered to one of Our Services governed by this Charter, or who consults or is a member of a service of one of Our Partners and whose Personal Data and/or Browsing Data related to such access, consultation, use or registration may be processed by Us, in compliance with this Charter and applicable law.

2.2. Applicable Law and Control Mechanisms

The rights of Users and Members governed by Our Charter relate to the processing of personal data and browsing data by the 1000mercis Group, whose principal place of business is located in France. They are governed by Act No. 78-17 of 6 January 1978 as amended, known as the "Loi Informatique et Libertés" (Data Protection Act) and by the international texts and treaties applicable in France, and in particular the GDPR.

1000mercis protects the personal data and privacy of Users in accordance with the strictest European and French regulations applicable in this matter. The processing of personal data and browsing carried out as part of Our Services is subject to permanent and independent internal control placed under the authority of Our "Data Protection Officer" (DPO) appointed by the French data protection supervisory authority, the Commission Nationale de l'Informatique et des Libertés (hereinafter, "CNIL"). You may, at any time, contact our DPO for any additional information, by writing to dpo@numberly.com.

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

3. BROWSING DATA PROCESSED BY 1000MERCIS

Since its creation, the 1000mercis Group has always sought to anticipate the expectations of consumers and Internet users, both in terms of protecting their privacy and in commercial matters. Our ultimate ambition is to send Our Members offers that may indeed interest them, which are more relevant and less frequent than those disseminated by Our competitors.

Therefore, in order to adapt the frequency of sending and the type of offers sent by 1000mercis to its Members, We process the Browsing Data attached to their Terminal(s) and to the browsing software(s) used by their Terminal(s).

3.1. What is Browsing Data?

This is data relating to Traffic, as defined in paragraphs b) and c) of Article 2 of the "ePrivacy" Directive 2002/58/EC amended by Directive 2009/136/EC, and, in particular:

3.2. What do We use them for?

- To secure Our Services

Some Browsing Data must be retained in accordance with the law. This is to enable Us to ensure the security of Our electronic communication Services and to detect, prevent or recover malicious attempts or computer intrusion or breaches of the terms of use of Our Services. Such is the case of the IP address and the dates and times of connection of a Terminal to one of Our Services.

- To measure the receipt and reading of Our e-mails

We may process Browsing Data when We receive or consult an electronic survey that We have sent to a Member. This Browsing Data may result, in particular, from the storage and/or reading of Cookies that We operate within emails distributed by Us, subject to the choices expressed by the Member concerned in their browser software and with Us (see Article 4 below).

This Browsing Data allows Us:

- To adapt interactive advertisements to a User

We may have to process Browsing Data relating to a User's reaction to an email (or SMS, MMS, etc.) that We sent them: has this email been received and consulted? Has the Member reacted or not to the content of this email? Have they visited the online service promoted by this email? Has the Member subscribed to the offer promoted, etc.?

Other Browsing Data may also relate to a User's visit to one of Our Partners' services, and said visit to such service or reaction to the display of an interactive Advertisement that We have displayed or broadcast on behalf of one of Our Partners on one of Our Partners' or a Third Party's services.

This Browsing Data associated with a Cookie issued by 1000mercis also relates to the consultation of Our Partners' electronic communication services by a Member's Terminal. Where applicable, this Browsing Data allows Us, subject to Your agreement and subsequently, unless You object thereto, to determine which interactive advertisements or electronic prospecting (by email, SMS or MMS) are likely to interest a User, according to the electronic communication services of Our Partners previously consulted by their Terminal as noted by reading the Cookies that We operate in relation to our Partners and that are stored on Your Terminal. This Data also enables Us to constantly improve the relevance of interactive advertising and electronic prospecting (by email, SMS or MMS) likely to interest a User.

However, when a Member's Terminal is used by several people and when the same Terminal has several browsers, We cannot ensure that interactive advertising or electronic prospecting addressed to a User or to their Terminal corresponds to their own use of the Terminal and not to that of other users of the same Terminal.

Management by the Member of privacy protection parameters offered by the browsing software(s) of their Terminal, is their own free choice and sole responsibility. Where applicable, sharing the use of the Terminal with other persons is the Member's free choice and responsibility.

- To adapt interactive advertisements to a Terminal

Browsing Data allows us to adapt the content or display of an interactive advertisement intended for a Member's Terminal, by determining:


4. YOUR RIGHTS REGARDING THE USE OF YOUR BROWSING DATA

- Information from the User through this Charter and via Our Services and those of Our Partners

The registration of a Cookie in a Terminal is subject to the will of the Terminal's User, which they may express and modify at any time through the choices offered thereto by their browser software or through the opposition tool made available by 1000mercis, in accordance with applicable regulations. To discover the options offered by Your browser software and the methods for deleting Cookie files stored in Your Terminal, depending on the browser(s) installed on Your Terminal, We invite You to consult the "Your traces" section of the CNIL website: http://www.cnil.fr/vos-libertes/vos-traces/les-cookies/

- To exercise all Your rights

In accordance with applicable regulations, You have the right of portability and the right to access, rectify, delete, limit and oppose the Processing by 1000mercis of Your Personal Data and Browsing Data and profiling of Your data.

You may exercise these rights at any time by contacting 1000mercis and the Data Protection Officer at the following address: dpo@numberly.com.

We will respond to Your requests within a maximum of one (1) month from receipt of Your request. All requests will be admissible if they are accompanied by proof of identity or a copy of a valid identity document.

You also have the right to file a complaint with the CNIL, either online at www.cnil.fr or via post at CNIL - 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.

- Prior consent from the User

In accordance with the applicable regulations and the recommendations of the Commission Nationale Informatiques et Libertés (CNIL), 1000mercis informs Users, by means of an information banner that will appear when they first visit the Website, that by continuing to browse the Website, Users accept the use of Cookies to provide adapted services and offers in line with their areas of interest.

Users may be informed about the Use of Cookies and refuse such use by clicking the link provided or by consulting this Charter.

The User's consent is valid for 13 months. At the end of this period, the information banner relating to Cookies will be displayed again to reobtain the User's consent.

Cookies will not be stored or read if the User goes to the Website and does not continue browsing, this lack of action constitutes implicit refusal to use Cookies.

The same applies if the User clicks the link in the information banner to set Cookies and if necessary, refuses the storage of Cookies.

If You have accepted the registration of Cookies in Your Terminal within Your browser, the Cookies that We issue may be temporarily stored in a dedicated area of Your Terminal. In these cases, We may process Your Browsing Data as described above.

If, prior to Your visit to the Website, You used Your browser software to refuse the storage of Cookies in Your Terminal, 1000mercis Cookies will not be activated when You visit the Website.

- Accept or refuse the use of Cookies at any time

If You used Your browser software to refuse the storage of Cookies in Your Terminal, or if You delete the Cookies that We have registered on Your Terminal, We will not be able (or will no longer be able) to process the Browsing Data described above and Your Browsing Data will no longer be registered by Our Services.

You may accept or decline the 1000mercis Group's use of cookies at any time, by stating or changing your preferences here: mmtro.com/privacy/fr/,

Or, by configuring Your browsing software: to find the options offered by your browsing software and the methods of accepting, refusing, reading or deleting 1000mercis Cookie files or those of their Providers, We invite you to read the following pages depending on the browsing software that You use:

5. How long Your Personal Data will be kept

We shall keep Your Personal Data only for the time required for the purposes for which they were collected or processed and in accordance with Our legal and regulatory obligations or those of Our Partners, when we act as Processor for the latter. We shall archive or delete Your Personal Data as soon as it is no longer necessary for the purposes for which they were collected and processed and, in any event, as soon as the justified or legal period of storage expires.

The table below summarises the maximum storage periods implemented by 1000mercis, according to the purposes for which 1000mercis may be required to process the Personal Data concerning You in their capacity as Data Controller, or according to the legal and regulatory obligations applicable thereto.

These maximum periods apply, unless You request deletion or oppose the use of Your Personal Data before the expiry of these periods, without prejudice to the legal or regulatory obligations that would apply to 1000mercis.

Purpose Retention periods
Audience measurement and personalisation of electronic prospecting, cookie management 13 months
Promotional and loyalty operations, commercial prospecting 3 years from the last interaction initiated by the client or prospect
Management of requests for objection to promotional and loyalty operations or to commercial prospecting 3 years from the date on which the right to object is taken into account

6. Sharing Your Personal Data

Your Personal Data is treated confidentially within the companies of the 1000mercis/Numberly Group, as well as with Partners and Service Providers located in and outside the European Union. In any case, any transfer of Personal Data outside of the European Union is governed by one of the mechanisms or one of the appropriate guarantees provided by applicable laws on Personal Data protection, including the GDPR.

Data might, as the case may be, be shared with Our Partners, in particular in the context of joint offers for products or services proposed by one or more Partners, for whom 1000mercis is one of the Processors, and in order to enable Us to provide Our Services to Our Partners when We act on their behalf, under their instructions and under their responsibility.

We will not share, sell, rent or disclose Your Personal Data to anyone other than those specified above without Your prior consent when required by applicable regulations, nor without instructions from our Partners, when We act on their behalf as Processor.

We might, however, disclose certain Personal Data about You at the request of a competent administrative or judicial authority, in order to comply with Our legal and regulatory obligations or those of the Data Processors on whose behalf We act, where applicable, or to protect and defend Our rights and interests and/or prevent any abuse, abusive use or unauthorised use of Our Services.

7. Security

We do our utmost to ensure that Your Personal Data is processed in complete security and confidentiality. 1000mercis has implemented appropriate technical and organisational measures to prevent the loss, misuse, alteration or deletion of or unauthorised access to Your Personal Data.

Only Our staff and those of Our Service Providers who must have access to Your Personal Data in order to perform a specific task or function for the purposes set out in this Charter are authorised to access this information. In addition, all 1000mercis Group personnel are bound by strict confidentiality obligations and are regularly trained in security.

8. INTELLECTUAL PROPERTY

The layout and all elements of the Website, including trademarks, logos and photographs, domain names and graphic elements, belong exclusively to 1000mercis and are protected by intellectual property laws.

The provisions of this Charter are also protected by copyright and are the exclusive property of the 1000mercis Group. They may not be reproduced or used, in whole or in part, for the purposes of any professional activity other than journalism or legitimate public information, without 1000mercis's prior written permission.

9. CHANGES TO THE CHARTER

We may amend this Charter at any time, in particular to comply with changes in Our legal and regulatory obligations or to incorporate changes to Our Services.

We will notify You in advance of any modification to this Privacy Policy by means of a notice visibly published on the Website, by sending you a notice directly or at the time of Your use of our Website or one of Our Services, so that You are always informed of the conditions of use of the Data We collect and that You may, where applicable, cease Your use of the Website or Services if You so wish or exercise Your Rights with Us. We encourage you to review this Policy every time that you use our Website or Services.