Privacy Policy

As a leading actor in digital marketing, we consider protection of our partners’ personal data is crucial.

You will find hereunder TRACKAD FRANCE’s Privacy Policy, i.e. the explanation of our practices and commitments in terms of protection of personal data, in compliance with the General Data Protection Regulation.

As we think clear and transparent information is key, we have included several tables to help you better understand and exercise your rights.

This Privacy Policy was last updated on 17/11/2020.


1.  WHO IS THE DATA CONTROLLER OF YOUR DATA?

Activities of the TrackAd group in the European Union are managed by TRACKAD FRANCE, a French simplified joint-stock company with a capital of EUR 26,000.00, VAT number FR80 831322938, and its registered office at 3, rue du Colonel Moll – PARIS 17 (75017) (FRANCE) (hereinafter “TRACKAD” or “we”).

TRACKAD collects and processes a various range of personal data for its own purposes, as described below – for instance to measure the audience of its website trackad.ai, or to promote its marketing analysis services.

In those cases, TRACKAD is the data controller; this means that we are your contact for any question or concern relating to those various uses of your data. You may contact us in this respect by email at gdpr@trackad.ai.

Important: Those cases where we process your data for our own purposes are distinct from cases where we collect and process data on behalf of our clients, in the context of providing our services.

Indeed, services provided by TRACKAD involve the collection of a certain number of personal data relating to clients, leads and end users of our own clients. When processing this data, TRACKAD is not the data controller, but merely a commissioned processor of its clients.

Should you have any question or concern in relation to the processing of your data in the context of our services, we will get you in touch with the respective client (provided that we can identify the client on behalf of whom we have processed your data), so that they may answer your question/concern in accordance with GDPR rules.


2.  WHICH DATA DO WE COLLECT, AND WHY?

a.    Connecting to trackad.ai and our SaaS services

When you connect to trackad.ai or to one of our SaaS services, a certain number of data is automatically collected by the hosting service provider of that website/service. This data relates to your device (computer, smartphone, etc) and your web browser. This includes your IP address.

This data is collected to allow your device to connect to the respective web servers, and afterwards to detect bugs and cyberattacks. They are retained for 12 months after the date of the respective http query.

Collection and processing of this data is justified by TRACKAD’s legitimate interest in providing functioning, secure and accurate website and services that may work on the various types of existing devices and web browsers, in accordance with Article 6.1.f) GDPR.


b.    Web audience measuring

The trackad.ai website uses web audience measuring cookies. These cookies collect data relating to your browsing, such as visited web pages, consulted contents and duration of your session.

This data is used to generate web audience statistics for the trackad.ai website and to understand the preferences of our audience in order to improve the content and style of our website.

Processing of this data is justified by TRACKAD’s legitimate interest in improving its website and its content, in accordance with Article 6.1.f) GDPR.


c.    Chat module on trackad.ai

The trackad.ai website includes a chat module allowing you to speak to our team for any question you may have (especially technical and commercial questions).

Using this chat module involves collection of a certain number of personal data including connection identifiers (your IP address) and text messages exchanged through the module.

Processing of this data is justified by TRACKAD’s legitimate interest in talking with visitors of its website and promoting its services, in accordance with Article 6.1.f) GDPR.


d.    Demo requests

You may ask for a demo of our services through the trackad.ai website. For this you must enter all information marked as mandatory with an asterisk (*) in the respective form on our website (i.e. name, surname, email address, phone number, organization and position).

This data is used to contact you to organize the demo of our services, and to follow up on that demo as applicable (by providing you with a quote). The data is retained for 3 years following the last contact we receive from you.

We also use VoIP services to perform the demo; these services collect and process a certain number of personal data such as connection identifiers and text messages exchanged through the chat module of those services, as applicable.

These various uses of your data are justified by TRACKAD’s legitimate interest in promoting its services with a B2B audience, in accordance with Article 6.1.f) GDPR.


e.    Client relationship management

We collect a certain number of personal data relating to our business and technical contacts within our clients (i.e. employees and representatives of said clients) and to natural persons who use our services on behalf of said clients (end users). This is to manage the client relationship lato sensu (including billing and payment management).

This data primarily includes names, surnames, email addresses and phone number of our contacts and text messages exchanged with them, and data relating to the use of our services (connection logs, activations of the Google Data Studio plugin, etc).

This data is retained for the duration of our business relationship with the respective client.

Processing of this data is justified by TRACKAD’s legitimate interest in managing and following up on its client relationships, in accordance with Article 6.1.f) GDPR.

Some of this data may also be further processed and retained after the end of the relationship with the respective client, for evidential reasons as described below (retention of proof).


f.     Direct marketing

We may promote our services through emailing campaigns, for which we use professional email addresses we received or collected on public sources, as applicable.

This use of professional email addresses is justified by TRACKAD’s legitimate interest in promoting its services with a professional audience, in accordance with Article 6.1.f) GDPR.

We will cease to use your professional email address as soon as you oppose to it, and at most 3 years after the last contact we will receive from you.


g.    Targeted advertising

We also promote our services through targeted advertising campaigns on various social media.

For this we use services from 3rd-party service providers (FACEBOOK and LINKEDIN), which rely on trackers such as cookies of pixels and collect identifiers such as your IP address to display targeted advertising on the respective social media.

These identifiers are automatically deleted 180 days after your last visit on the trackad.ai website, which is the retention period the abovementioned 3rd-party service providers commit to.

Processing of this data for targeted advertising purposes is based on your consent, which you give us when you accept the use of the respective cookie/pixel on your device, in accordance with Article 6.1.a) GDPR.


h.    Recruitment

The “Careers & Culture” part of the trackad.ai website allows you to apply to different positions within TRACKAD or other companies of the TrackAd group, or to send a spontaneous application.

For this you must enter minimum mandatory information marked as such with an asterisk (*) on the application form; you may also complete your application by entering non mandatory information (no asterisk).

This data shall be collected and processed by TRACKAD to review your application and answer it as applicable. It will be retained for the duration of the whole recruitment process; we may also retain and process rejected applications afterwards to offer you other positions within TRACKAD or another company of the TrackAd group, for a maximum duration of 2 years.

Processing of the data during the recruitment process is justified by precontractual measures at your demand as per Article 6.1.b) GDPR; its further 2-year retention and processing is justified by TRACKAD’s legitimate interest in managing its own recruitment needs, in accordance with Article 6.1.f) GDPR.


i.     Proof retention

We may retain all or part of the data mentioned above as a matter of proof. We will use it, as applicable, to prevent, initiate or reply to any dispute in the context of which it may seem relevant, whether you are a party to this dispute or not.

This retention is justified by TRACKAD’s legitimate interest in protecting and defending its own rights and interests (before a court as applicable), in accordance with Article 6.1.f) GDPR.

We will retain all those data that seem relevant as a proof for the applicable statute of limitations, which in principle is 5 years (French statute of limitations for typical civil claims).

► Summary

Your rights What they allow you to obtain Which data/ processing they are applicable to Conditions, exceptions or limitations
Right of access A legible and understandable copy of all personal data we have that relates to you, and a copy of this Privacy Policy All personal data None
Right to rectification Rectification, update or completion of the personal data we have that relates to you All personal data Clearly identify data which needs rectification, update or completion and provide the appropriate additional/new data
Right to object To stop the processing of your personal data Processing based on TRACKAD’s legitimate interests (see above) Clearly state the grounds relating to your particular situation which justify the objection
Right to erasure Erasure or complete anonymization of your personal data All personal data See conditions above (d)
Right to limitation of processing Retention of your personal data by TRACKAD without using it All personal data See conditions above (e)
Right to data portability A reusable, machine-readable copy of your personal data Data collected through targeted advertising cookies/pixels As applicable, clearly state the identity and contact details of the person or organization to which you wish your data be transferred
Right to provide directives regarding your personal data after your death Respect of your “last wishes” regarding the retention, use, transfer or deletion of your personal data All personal data Clearly state the identity and contact details of the persons who will control the respect of your directives after your death

3.  WHO CAN ACCESS YOUR DATA? WHOM IS IT SHARED WITH?

a.    TRACKAD’s and other TrackAd companies’ teams and employees

TRACKAD’s teams and employees may access and use your data within the limits of their missions, for the purposes described above.

Your data may also be accessed and used by teams and employees of other companies within the TrackAd group, within the limits of their missions, where it is necessary that those other companies intervene for the purposes described above.


b.    Hosting service provider for trackad.ai and @trackad.ai inboxes

Data linked to the trackad.ai website is hosted by a professional secured hosting service provider, on servers located in the EU.

Also, data linked to email we exchange with you (such as messages received from the forms on trackad.ai) is hosted by a professional secured hosting service provider, on servers located in the EU.


c.    Other technical and legal service providers

Certain data may also be accessed or stored by the following persons and organizations, for the purposes of the services they provide to TRACKAD:

  • Technical service providers who assist TRACKAD in maintaining and modifying the trackad.ai website and its technical infrastructure;
  • Providers of the web audience measuring cookies;
  • Providers of the targeted advertising cookies/pixels (FACEBOOK and LINKEDIN);
  • VoIP service providers, as necessary to perform demos of our services;
  • Provider of the chat module on the website;
  • TRACKAD’s legal counsels.

d.    Authorities, jurisdictions and parties to a dispute

Occasionally, we may be required to share all or part of the data above with authorities and jurisdictions which are competent to require communication of this data, and with the authorities, jurisdictions and parties (and their counsels) to the disputes and proceedings we may intervene in for the defence of our rights and interests.


e.    Mergers and acquisitions

In case of a merger or acquisition of our company or any equivalent operation, we may need to transfer your data to the respective buyer or seller. In such a case we will inform you of the identity thereof and the reasons for the transfer.


4.  WHAT RIGHTS DO YOU HAVE TO CONTROL THE PROCESSING OF YOUR DATA?

As any person whose data we process as a data controller, you have a certain number of rights determined by applicable laws and regulations.

You will find details for each of those rights below. A summary table is provided at the end of this section.

You may exercise those rights by writing an email to TRACKAD at gdpr@trackad.ai. Please make sure you mention clearly the nature of the right you wish to exercise and the reasons which justify your request, as applicable.


a.    Right of access

You have the right to request a copy of all personal data we have that relates to you, in a legible, understandable format, and a copy of this Privacy Policy.


b.    Right to rectification

You have the right to ask us to rectify, complete or update personal data we have that relates to you, in case it appears inaccurate, incomplete or obsolete.

In such case, please make sure you provide us spontaneously, as possible, with all information necessary to proceed with the requested rectification, completion or update.


c.    Right to object

You have a right to object to those processing activities above that are based on TRACKAD’s legitimate interests (such as proof retention) on grounds relating to your particular situation.

In other words, you may ask TRACKAD to stop processing your personal for a given purpose that is based on a TRACKAD’s legitimate interest, by explaining the particular reasons that justify this objection.

It is possible however that we refuse to comply with your request if the processing of your data is still necessary, according to us, for compelling reasons that override the grounds relating to your particular situation (e.g. use of said data as proof in an actual dispute).

If it is grounded and no compelling reason goes against it, your objection will result in us ceasing the respective processing activities, but not necessarily deleting the data; to obtain deletion of your data, you must exercise your right to erasure (see below), which also comes with a series of conditions and limitations.


d.    Right to erasure

You may ask us to delete all or part of the data we have that relates to you, where one at least of the conditions below is met:

  • You objected to the processing of your data as explained above, and you wish that TRACKAD delete the respective data.
  • It is not necessary anymore for TRACKAD to retain the respective data for the purposes described in this Privacy Policy.
  • You consider that TRACKAD collected and/or processed the data in an unlawful manner.
  • Deletion of the data is imposed as a legal obligation.
  • The respective data was collected when you where less than 15 years old.

Please be aware that TRACKAD may refuse to delete certain data where it is required to retain it for important reasons such as defending TRACKAD’s interests before a court.

Also, please note that we may choose to anonymize the data instead of deleting it. In this case, we will be able to retain the data in a format that does not allow to identify you anymore (for instance for statistical purposes).


e.    Right to limitation of processing

You may ask us to limit the processing of your data, i.e. to retain it without using it (except for legal obligations). You may especially ask this instead of asking for deletion of the same data.

You may exercise this right where one at least of the following conditions is met:

  • The respective data appears inaccurate and you prefer that we stop using it for the time necessary to verify and rectify it as applicable.
  • You objected to the processing of your data as explained above, and you wish that we stop using it for the time necessary to verify the grounds for that objection.
  • You consider that TRACKAD collected and/or processed your data in an unlawful manner, but still you prefer that we retain that data instead of deleting it.
  • It is not necessary anymore for TRACKAD to retain the respective data for the purposes described in this Privacy Policy, but still you wish that we retain that data for you to be able to use it before a court.

In such a case, we will stop using the respective data and will retain it for the appropriate duration.


f.     Right to data portability

You may ask us to give you a machine-readable copy of personal data collected through the targeted advertising cookies/pixels on trackad.ai, so that you may reuse that data yourself or with another service provider.

This right to data portability is not the same as the right of access above, as it is about obtaining not a legible copy of the data, but a machine-readable copy that may be reused by you or another service provider.


g.    Right to provide directives regarding your personal data after your death

You may provide us with directives as to how you want TRACKAD to proceed with your data after your death.

For instance, you may ask that we delete all of your personal data (except as needed for TRACKAD to defend its rights before a court) or to transfer it to a recipient of your choice.

You may also designate any person of your choice to control our respect of those “last wishes”. That person does not need to be your heir or your testamentary executor.

► Summary

Your rights What they allow you to obtain Which data/ processing they are applicable to Conditions, exceptions or limitations
Right of access A legible and understandable copy of all personal data we have that relates to you, and a copy of this Privacy Policy All personal data None
Right to rectification Rectification, update or completion of the personal data we have that relates to you All personal data Clearly identify data which needs rectification, update or completion and provide the appropriate additional/new data
Right to object To stop the processing of your personal data Processing based on TRACKAD’s legitimate interests (see above) Clearly state the grounds relating to your particular situation which justify the objection
Right to erasure Erasure or complete anonymization of your personal data All personal data See conditions above (d)
Right to limitation of processing Retention of your personal data by TRACKAD without using it All personal data See conditions above (e)
Right to data portability A reusable, machine-readable copy of your personal data Data collected through targeted advertising cookies/pixels As applicable, clearly state the identity and contact details of the person or organization to which you wish your data be transferred
Right to provide directives regarding your personal data after your death Respect of your “last wishes” regarding the retention, use, transfer or deletion of your personal data All personal data Clearly state the identity and contact details of the persons who will control the respect of your directives after your death


You consider that we did not provide a satisfactory answer to your request or that we process your personal data in an unlawful manner?

We invite you to first contact us so that we discuss the issue together and try to find a way to solve it efficiently.

If you wish, you have the right to lodge a complaint with the competent data protection supervisory authority, such as the French Commission Nationale de l’Informatique et des Libertés (CNIL), through its website cnil.fr or by postal mail at CNIL – 3, place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07 (FRANCE).

This right to lodge a complaint may be exercised at any time and free of charge, except for (as applicable) postal fees and legal counsel fees (if you choose to get assistance from a legal counsel).

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