Since ADTHINK’s businesses may lead the company to carry out data processing in partnership with third parties without a direct relationship to the natural persons concerned with our company, we invite you to approach them directly to find out about their policies or to present them with any request relating to the processing of data that affects you.
Part I of this document presents, as general information, the principles and requirements of the GDPR that ADTHINK agrees to respect upon any data collection and processing. Parts II and III specify, respectively, the processing strictly performed by ADTHINK in clearly identified situations as well as individuals’ rights that our company agrees to respect. Part IV specifies the means available to individuals for answers to any questions about the Policy on the protection of data of a personal nature.
As the policy is subject to change, we invite you to refer to it regularly.
1 - Data of a personal nature is collected and processed by ADTHINK in accordance with the principles and requirements of the GDPR
For the purposes of the GDPR, data of a personal nature is defined as any information relating to an identified or directly or indirectly identifiable natural person. Processing is the operations applied to data that fit into the situations and purposes specified within Part II of this policy. ADTHINK processes data in order to fulfill lawful, explicit, and legitimate objectives and purposes, according to fair processes for the purpose of providing services for its own account or those of its solutions and services client partners.
Taking into account the general requirements of the GDPR, in the case of data processing:
- We strive to collect and process data within the strict scope of the provision of the services and benefits concerned, for lawful, explicit, and legitimate objectives and purposes, according to fair processes, to provide services and benefits;
- temporary or permanent failure of computer or telephone networks,When we carry out the direct collection of data of a personal nature, we specify whether its provision is of a regulatory or contractual nature or whether it affects the benefit of a service or the outcome of a contract and whether the affected person is obliged to provide the data of a personal nature, and we also specify the possible consequences of non-provision of data;
- When the case arises, we indicate the existence of automated decision-making, including profiling, with the indication of useful information regarding the underlying logic, as well as the importance and expected consequences of such possible processing for the affected person;
- In the event of any intention to carry out a possible later processing of data of a personal nature for a purpose other than that for which the data was collected, we provide information to the individuals in advance about this other purpose and any other information necessary for it to be understood in a transparent way;
- We communicate restricted data to authorized recipients, including our company’s authorized services as well as the partners involved in the provision of services;
- We agree to ensure processing transparency with appropriate information from individuals in all cases of collection, when the data is received from the individuals themselves or possibly originating from third parties or technologies;
- We agree
- to minimize processing,
- to ensure the regular update of the data,
- to carry out commensurate preservation of the data according to criteria determined in particular with regard to the purpose of the processing, contractual or operational requirements, or to meet our regulatory obligations, all in compliance with applicable law,
- to manage relations with the recipients of data and subcontractors by all proper means to ensure the respect of our legal obligations,
- in the case of a possible transfer of data to a country located outside the European Union, to take all possible measures, in accordance with the requirements of the GDPR, guaranteeing compliance with the regulations applicable in Europe,
- to make colleagues aware of the requirement for the protection of data of a personal nature and its confidentiality,
- to ensure the security of the processing and of the data,
- to take into account all the rights granted to natural persons under applicable regulations.
Within ADTHINK, awareness of the principles and requirements of the law regarding protection of data of a personal nature is accompanied by organizational and technical measures, particularly starting with the design (privacy by design) and by default (Privacy by default) in order to apply the provisions of the GDPR in an effective manner, in accordance with the commitments and to provide operational guarantees.
2- The processing of data of a personal nature carried out by ADTHINK is part of clearly identified situations
A- Within the scope of the management of the commercial relationship with customers and prospects
ADTHINK carries out data collection as a part of entering into a relationship with clients and prospects interested in its activities. It is a corporate purpose allowing us to maintain and manage contractual relationships and maintain contact with interested individuals.
As part of the implementation of various Internet websites presenting various activities, ADTHINK may deploy data collection forms within the contact sections as well as cookies or tracer technologies whose purpose is to understand the expectations of visitors to the sites and to improve the content that is offered to them.
Cookies are likely to be set up automatically within the user’s Internet browser software and to be stored in the device used. The cookies used within the showcase websites fall into the category of browsing cookies, which allow statistical consultation studies to be performed. In order to understand the possibilities of parameterization, the User is invited to consult the educational explanations proposed by the French supervisory authority, the National Data Protection Commission (la Commission Nationale de l’Informatique et des Libertés): http://www.cnil.fr.
B- Within the scope of digital advertising activity
ADTHINK carries out data processing within the scope of the operation of digital advertising services for its own account as well as within the scope of services provided to advertisers and Internet website publishers.
In this context, ADTHINK carries out data processing for the purpose of personalization, selection, dissemination of editorial content aiming to respond to the interests of Internet users consistent with the objectives pursued by advertisers and Internet website operators. The collections of information on the interests are in this context associated with those possibly collected previously, in order to select and disseminate adapted advertisements, then to evaluate their dissemination as well as their effectiveness. The data processing indicates the displayed advertisements and their frequency in order to know individuals’ reactions to the displayed advertisements.
C- Within the scope of client acquisition
ADTHINK carries out data processing in the context of the operation of the deployment of promotional programs based on the organization of contests as well as in the context of setting up products and services comparison websites.
D- Within the scope of the service of sending campaigns by email and newsletters
In terms of sending advertising campaigns by email and mailing list management, ADTHINK offers a specialized outsourcing service offering consisting of the provision of technical means allowing customers, under their own control, to manage databases of email addresses, conducting the sending of advertising campaigns, and exploitation of the results of the survey campaigns that have been carried out.
3- ADTHINK recognizes the application of individuals’ rights resulting from the GDPR according to the requests they wish to assert and agrees to take into account any request as soon as possible
In this respect, natural persons have available a set of rights that apply on a case by case basis taking into account the circumstances of the processing and their relationship with ADTHINK. These rights are as follows:
- Right to the provision of information when data of a personal nature is collected in a direct or indirect manner;
- Right of access, allowing individuals to obtain from the controller confirmation that data of a personal nature concerning them is or is not processed and, when it is, access to such data of a personal nature;
- Right of correction and erasure allowing individuals to obtain, as soon as possible, the correction of data of a personal nature that is inaccurate and, taking into account the purposes of the processing, the right to have the data completed, including providing a supplementary declaration, as well as the right to deletion, allowing for the deletion, as soon as possible, of data of a personal nature when certain grounds are met;
- Right to the limitation of processing for a certain period of time when certain elements apply, such as a possible challenge to the accuracy of data of a personal nature, unlawful processing to which a person objects, or in the case of a need to process the affected person’s data for the establishment, exercise, or defense of rights in court, or in the case of verification of the possible prevalence of legitimate grounds pursued by the controller over those of the affected person;
- Right of objection, to a certain extent in accordance with applicable laws, in case of possible automated individual decision-making based on a person’s particular situation;
- Right not to be the object of processing for prospecting purposes.
4- How to exercise your rights with ADTHINK? How to contact us about our Policy regarding the protection of data of a personal nature?
ADTHINK agrees to examine any request to facilitate the exercise of the rights recognized by the GDPR. Answers will be provided to you in a concise, transparent, understandable, and easily accessible way, in clear and simple terms.
In addition, information may be provided to you in writing or by other means including electronically if appropriate or if your request is submitted in this form.
At your request, information may be provided orally, provided that your identity is demonstrated by other means.
Requests concerning your rights and/or the processing that we perform, the application of the GDPR, the Data Protection Act, as amended, or the application of this Policy, as well as any question relating to the data of a personal nature can be addressed, at your choice in writing or orally, using the following contact information so that we can respond as soon as possible:
By mail at :
SA Service Protection des Données personnelles
79 Rue François Mermet, 69160 Tassin-la-Demi-Lune, France
To ensure your identity, you may be required to provide information or supporting documents.