Privacy Policy for data of a personal nature  

This document constitutes ADTHINK’s Privacy Policy for data of a personal nature (hereinafter, the “Policy”). As part of the framework of a transparency requirement, this policy has been drafted to be understandable and easily accessible in order to convey our commitments under the European General Data Protection Regulation (EU) 2016/679 (hereinafter, the “GDPR”) as well as the Data Protection Act, as amended. The data protection policy is intended for all natural persons who are in contact with our company, upon any collection of data of a personal nature, as well as for anyone wishing to know more with respect to the services and businesses that our company performs as a controller or outsourcer in the fields of digital advertising performance, online services, customer acquisition, and email solutions. As a variation of this policy, ADTHINK’s various businesses are likely to bring a personal data privacy policy to the attention of their customers when they enter into direct contact with them. The Policies are accessible through various means that are accessible to natural persons (websites, applications, or mobile phone services...).

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:

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):

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:

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
[email protected]

To ensure your identity, you may be required to provide information or supporting documents.

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