Personal Data Protection Policy
Policy Version: 14.03.2020
This document constitutes the Personal Data Protection Policy (the “Policy”) of Adrenalead. As part of a requirement for transparency, this Policy has been drafted to be understandable and easily accessible in order to reflect our commitments under the European Regulation (EU) 2016/679 on the protection of personal data (hereafter “GDPR”) and the French Data Protection Act as amended.
The data protection policy is intended for all natural persons who are in contact with our company, on the occasion of any collection of personal data, as well as for any person wishing to find out more about the services and professions exercised by our company, Adrenalead being a data-driven Marketing Solutions agency operating an advertising platform intended for e-commerce sites and advertisers.
Adrenalead’s business activities lead it to provide data processing services in partnership with third parties operating e-commerce activities (Publisher Sites) or wishing to broadcast online advertising (Advertisers). We therefore invite you to contact these third parties directly to find out about their data protection policies or to submit any request relating to the processing of data concerning you.
The first part of this document presents, for general information purposes, the principles and requirements of the GDPR that Adrenalead is committed to respecting in all data collection and processing. In the second and third parts, details are provided respectively of the processing carried out by Adrenalead in clearly identified situations as well as the rights of individuals that our company undertakes to respect. The last part specifies the means made available to individuals to answer any questions about the Personal Data Protection Policy.
As the policy is subject to change, we invite you to refer to it regularly.
Personal data is collected and processed by Adrenalead in accordance with the principles and requirements of the GDPR.
1. Treatments related to the management of the commercial relationship with customers and prospects
Adrenalead collects data in the context of establishing contact with clients and prospects interested in its activities. This is a corporate purpose to maintain and manage contractual relationships and to maintain contact with people interested in the company’s services.
As part of the implementation of the company’s showcase website accessible at https://adrenalead.com, Adrenalead is likely to deploy data collection forms within the contact sections as well as cookie technologies whose purpose is to understand the expectations of the website visitors and to improve the content offered to them. To learn more about cookie technology, please refer to the details provided in section 3 below.
2. Processing related to the activity of a data-driven Marketing Solutions agency
As part of its activity as a data-driven Marketing Solutions agency, Adrenalead operates an advertising platform for e-commerce sites and advertisers called Notifadz Delivery Platform (NDP) based on Web Push Notification (WPN) technology. The WPN technology equipping Internet browsers and the operating systems of Internet users’ fixed and mobile equipment allows, without the constraint of surfing the web, to relay information or advertisements in the form of Notifications to Internet users who have expressly agreed to receive notifications on the basis of consent (optin).
The WPN platform is based on the processing of non-nominative data using advertising cookies accepted by Internet users and the management of message flows in WPN mode. Details are given below on the notion of cookie and WPN. Adrenalead’s know-how produces information strictly for the purpose of personalizing, selecting, and distributing information and advertising campaigns in WPN mode intended to respond strictly to the interests of Internet users in line with the prospecting objectives of Publishers and Advertisers. Adrenalead uses non-nominative profiling methods that allow to adapt the nature of the WPN information messages transmitted to Internet Users. Profiling is a data processing method that is allowed by the WPN. It is defined by the GDPR as a form of automated processing of personal data consisting in using such data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict elements concerning the personal preferences, interests, behaviour, location or movements of that person. Profiling makes it possible to select and disseminate appropriate information messages, and then to evaluate their dissemination and their effectiveness with respect to the non-nominative knowledge of the reaction of individuals to the messages transmitted.
3. Processing related to advertising cookies and WPN
- Adrenalead uses advertising cookies containing a non-nominative identifier that enables the tracking of the browsing path of an Internet User for the sole purpose of providing the Internet User with the WPN service to send information that may be of interest to him/her. The use of these cookies is carried out in compliance with the applicable legal rules as well as within the framework of the recommendations and standards (framework) developed by the advertising industry in coordination with the authorities in charge of personal data protection. Your web browser will keep the Adrenalead cookie for a certain period of time, and will send it back to the relevant web server each time you connect to the site again.
- WPN (Web Push Notification) is a standard technology that is provided by all the Internet browser software publishers you use. It is a standardized technology. The Internet browser creates a non-personal identifier associated with your browser to allow you to receive notification messages only from websites that you have approved. You retain control over the receipt of WPN messages. This allows you to allow websites to ask if they can send push notifications. When you visit a website that can send you notifications, a dialog box appears asking if you want to receive them. Similarly, browsers offer a feature that allows you to access the full list of sites that send you notifications at a later time and change your choices. To learn more about setting up your own, the easiest way is to consult the help section of your web browser.
4. Processing of online applications
Adrenalead’s website allows job seekers to respond to an offer posted in the “Join us” section or to submit a spontaneous application. The information received in this context is subject to processing of personal data by Adrenalead in its capacity as data controller for the purposes of managing applications. The information is intended solely for the internal or external contacts in charge of recruitment. »
The information communicated by candidates will be kept for the duration of the examination of applications and subsequently, in the event of non-recruitment, for several months pending the finding of a suitable post with the possibility for the candidate to assert the rights granted to him/her by the GDPR and, in particular, to oppose the processing of data concerning him/her.
Adrenalead acknowledges the application of the rights resulting from the GDPR and undertakes to take into account any request as soon as possible.
As such, individuals have a set of rights that apply on a case-by-case basis taking into account the circumstances of the treatment and their relationship with Adrenalead. These rights are as follows:
- Right to information where personal data are collected directly or indirectly ;
- Right of access, making it possible to obtain confirmation from the controller whether or not personal data relating to them are being processed and, if so, access to such personal data ;
- The right of rectification and erasure, making it possible to rectify inaccurate personal data as soon as possible and, having regard to the purposes of the processing operation, the right to have the data supplemented, including by providing an additional declaration, and the right to erasure, making it possible to erase personal data as soon as possible where certain grounds are met ;
- The right to limit processing for a certain period of time where certain factors apply, such as the possible contestation of the accuracy of personal data, the existence of unlawful processing to which an individual is opposed, or where processing of the data of the data subject is necessary for the establishment, exercise or defence of legal claims, or where it is ascertained whether the legitimate grounds pursued by the controller outweigh those of the data subject ;
- Right to data portability where a processing operation is based, inter alia, on the consent of a person or a contract ;
- Right of opposition, to a certain extent with regard to the applicable texts, in the event of possible automated individual decision making based on a person’s particular situation ;
- Right not to be processed for the purpose of canvassing.
As part of the WPN service, Adrenalead relies on the following technical measures that allow you to directly exercise your rights within the framework of Web push notification (WPN) technologies:
- The Adrenalead cookie is under your control on two levels. Adrenalead relies on industry standards as well as on the recommendations of regulatory authorities to inform Internet users and enable them to exercise their rights in terms of cookie banners (CMP) and through Internet browsing software. The existence of Adrenalead cookies is first brought to your attention in the context of the Consent Management Platform or CMP or Tag Manager (Banners and cookie interfaces appearing when the Internet user connects to a Publisher’s website). Adreanalead cannot use a cookie concerning you if this step placed under your control is not respected. The CMP devices are obligatorily offered to you by websites offering Adrenalead cookies. In constant improvement, these devices aim to be economical and fair. They offer dialogue zones or interfaces that allow you to refuse or accept cookies and to subsequently modify your preferences according to the type of cookies you wish to use. Cookies are in all cases placed under your control thanks to the internal functionalities integrated into your Internet browser software. This allows you to manage your preferences to accept or reject them on a case-by-case basis or to reject them completely. Please note that the cookies you have accepted will in any case have a maximum operating time. Beyond a period of 13 months, Adrenalead can no longer use a cookie that you previously accepted. For more information, we invite you to consult the website of the data protection control authority, the CNIL, at the following link: https: //www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser. Sites such devices at your disposal.
- The WPN technology used by Adrenalead is under your control. Adrenalead relies on the Web Push Notification consent management standards that are integrated into Internet browsing software. You can authorise Adrenalead to send WPN messages to you for a website or partners, just as you can refuse and continue to browse the e-commerce site you have just visited. When you visit a website that can send you WPNs, a dialog box appears asking for your consent. In the same way, your browser software offers you a feature that allows you to access the full list of sites that send you notifications and to modify your choices at a later date. You can therefore freely change your mind if the notifications you receive do not match your interests. To learn more about configuring your own browser software, the easiest way is to consult the browser’s help section.
Adrenalead undertakes to examine any request in order to facilitate the exercise of the rights recognized by the GDPR. Responses will be provided to you in a concise, transparent, understandable and easily accessible manner, in clear and simple language.
In addition, the information may be provided to you in writing or by other means, including electronically if appropriate or if your request is made in that form.
At your request, the information may be provided orally, provided that your identity is demonstrated by other means.
Requests relating to your rights and/or the processing that we carry out, the application of the GDPR, the amended Data Protection Act or the application of this Policy, as well as any question relating to personal data may be addressed, according to your choice, in writing or orally, using the following contact details so that we can answer them as soon as possible:
By mail to :
Service Protection des Données personnelles
16 Rue Masaryk
69009 Lyon, France
Or by email at: firstname.lastname@example.org
In order to ensure your identity, you may be asked to provide supporting information or documents.
As Adrenalead has appointed a Data Protection Officer (DPO/DPO), you may contact him/her on all matters relating to the processing of their personal data and the exercise of your rights under the GDPR. You can request the contact details of our DPO by contacting Adrenalead by post or email.