Privacy Policy

This Privacy Policy details the conditions under which ADCLEEK collects and/or processes the personal data of (i) Visitors to the ADCLEEK Website, (ii) Populations Targeted by the ADCLEEK platform for the purchase of advertising space during an advertising campaign, and (iii) Users of the Local Media Platform Software called LMP and associated services (the "Service").

In this policy the ADCLEEK Website, the ADCLEEK platform, the LMP Software and the Service are referred to collectively or individually as the "ADCLEEK Offering".

The User acknowledges and accepts that any browsing of the Website, any downloading of an application, as well as in general any use of the ADCLEEK Offer, implies the express and prior acceptance of this Privacy Policy.

ADCLEEK reserves the right to modify this Privacy Policy. Visitors and Users are therefore invited to check regularly whether any changes have been made to the Privacy Policy.

DATE OF LAST UPDATE OF THIS PRIVACY POLICY: NOVEMBER 2020

DEFINITIONS

In this document, words and expressions identified by a capital letter have the meanings set out below, whether used in the singular or plural, except where it is clear from the context or a specific provision that this meaning is not applicable to the provision in question.

"ADCLEEK": ADCLEEK, a SAS with a capital of 262,330 euros, whose registered office is located at 96 rue Aristide Briand 92300 Levallois, registered with the Nanterre Trade and Companies Registry under number 53244752100032. ADCLEEK is referred to as "ADCLEEK" or the "Company" throughout this document.

"Cookie": refers to a text file placed in the browser's memory by the Site's server or by a third party authorised by the Site. It is used to collect and store data on browsing behaviour from the connected computer. The Cookie is used by the server to memorise information relating to the use of each browser.
"Data": refers to documents, information, data and various elements integrated by the Client or by a User for processing via the Services.
"Offer": means all the products and services offered by ADCLEEK
"Platform": means all the technical and human resources of ADCLEEK allowing the purchase of advertising space
"Targeted population": means all the Internet users to whom an advertising campaign is addressed
"Privacy Policy": means the privacy policy concerning the processing of personal data by ADCLEEK.
"Service(s)": refers to access to the Local Media Platform Software, more simply called LMP, operated by ADCLEEK allowing to exploit the functionalities of this Software, including all the means used to provide this service and in particular the platform. It operates via a dedicated web application and allows:
- to visualise the catchment areas of a point of sale
- to choose local media and communication supports
- to carry out media planning
- to optimise a space purchase budget
"Site": refers to the ADCLEEK website accessible at www.adcleek.com
"User": refers to the natural person authorised by the Customer to access the Service, under the Customer's control and responsibility. The User is an employee of the Customer.
"Visitor": refers to an Internet user browsing the ADCLEEK website.

I - Personal data concerned

The data concerned by this privacy policy are the data that the Visitor or the User provides to ADCLEEK:
- when the Visitor fills in the contact form on the Website
- when the User creates an account within the framework of the Services,
- when the User uses the Services, and in particular when he/she uses ADCLEEK's assistance.

The data concerned are also the following data that ADCLEEK collects in the context of the use of the Services
- information on the use of the Services (functionalities used, size and names of downloaded files, types of content consulted, etc.);
- connection information (IP address, type of browser, language, etc.); - information on the hardware (PC or tablet (display related to the use of a different mouse or touch), operating system, device settings, etc.); - information on the use of the Services (functionalities used, size and names of the downloaded files, types of content consulted, etc.).);
- hardware information (PC or tablet (display related to the use of a different mouse or touch), operating system, device settings, etc.);
- billing information (contact details of the invoice recipient)

The data concerned may also be transmitted to ADCLEEK by the company employing the User or the group to which the company employing the User is affiliated

II - Data controller and recipients

The data collected is processed by the company ADCLEEK.

The data collected within the framework of the operation of the ADCLEEK Services are exclusively intended for the administrative and technical services of ADCLEEK, with the exception of:
- companies to which ADCLEEK has entrusted the provision of technical services linked to the ADCLEEK Services such as server hosting or the processing of bank cards, it being understood that these companies are contractually bound to protect all personal data transmitted to them in this context;

Some data may be transmitted to a third country in the context of support for ADCLEEK's customers. All the necessary guarantees to ensure the security of this data have been put in place.

III - Purposes of processing and legal bases

The data collected by ADCLEEK is used for the following purposes:

- as part of the operation of the ADCLEEK Services:
o contacting the Website Visitor who has filled in the contact form
o creating and managing the User's account;
o invoicing;
o operation of the ADCLEEK Offer and in particular the possibility given to Users to consult their browsing history, depending on the Services used;
o improving ADCLEEK services and developing new products;
o detecting fraudulent activities or breaches of security of the ADCLEEK Services, and prosecuting related cases;
o answering a request for legal communication;

- in the context of the promotion of offers from third-party partners;

The processing is carried out on the following legal bases:
- legitimate interests of ADCLEEK aiming at:
o providing the Services to the ADCLEEK customer through whom the User is authorized to access the Services, and
o improving the Services offered.

IV - Visitors' and Users' Rights

In accordance with the applicable regulations, the Visitor and the User may exercise the following rights on their personal data, under the conditions and within the limits provided for in Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data:
- right of access, rectification, opposition and erasure;
- right to limitation of processing;
- right to data portability;
- right for the Visitor and the User to define their directives regarding the retention, erasure and communication of their personal data after their death.

These rights can be exercised by sending an e-mail to the following address: support@adcleek.com

The User may in any case:
- modify his data by logging into his User account;
- request the deletion of his account on the Site by sending an email to support@adcleek.com

Finally, the Visitor and the User are informed that they may lodge a complaint with the competent supervisory authority (the Commission Nationale de l'Informatique et des Libertés (CNIL) in France).

V - Shelf life

The Visitor's data is kept for a period of 3 years

The Targeted Populations' data is kept for the duration of the advertising campaign concerned

The User's data is kept for the duration of the provision of the Service as well as for a period of three years from the end of the commercial relationship, in order to be able to continue to solicit the User during this period

The data necessary to comply with a legal obligation or necessary for the defence of the company in the event of litigation is kept in accordance with the provisions in force (in particular those provided for by the Commercial Code, the Civil Code and the Consumer Code).

VI - Cookies

Information relating to your navigation on the Site and the Service may be recorded in files known as "cookies" or similar tools ("Cookies"). This information from Cookies does not allow you to be identified directly or indirectly.
Cookies allow the Site and the Service to function efficiently and to remember the preferences of the Visitor or the User, to provide information for statistical purposes.

ADCLEEK only uses statistical Cookies for audience measurement: these Cookies help to establish statistics and volumes of frequentation and use of the various elements composing the Site (sections and contents visited, path), allowing ADCLEEK in particular to improve the interest and the ergonomics of the Services.

VII - Security

ADCLEEK has security procedures in place to protect the personal information stored on its systems. For example, ADCLEEK limits access to personal information to those employees who, in its reasonable judgment, need to know that information.

The attention of the Users is however drawn to the fact that, although ADCLEEK implements appropriate technical and organisational measures to protect against unauthorised or unlawful processing of personal information and against any loss, damage or accidental destruction of such information, it has no means of guaranteeing the absolute security of personal data.