1.1. Who are we?
VERTIGO MEDIA, designs, markets and implements loyalty and customer relationship management services on its own behalf or that of its Partners. Its activity is the processing and marketing of data as well as the design of direct marketing campaigns.
VERTIGO MEDIA PERFORMANCE is also a service provider company specialized in digital marketing brokerage.
Vertigo Media Performance's services consist of:
to put users (hereinafter the User" or the "Users", in function), at their request, in search of goods and / or services, in contact with one or more professionals (hereinafter the "Partner(s)", according to) likely to meet their needs.
to solicit Users by sending communications on services and / or products of Partners for commercial prospecting purposes, on behalf of the latter.
1.2. Personal data, processing: what are we talking about?
What is personal data?
This is any information relating to a natural person, allowing directly or indirectly to identify him, either by reference to an element specific to him (e.g. surname, first name, etc.), or by cross-referencing a set of data (e.g. contact details, loyalty card number, IP address, etc.).
What is personal data processing?
This means all operations, automated or not, relating to personal data (e.g. collection, recording, organisation, storage, modification, use, dissemination, erasure, etc.).
To find out more about the protection of personal data and your rights, you can consult the website of the Commission Nationale de l'Informatique et des Libertés (www.cnil.fr).
1.3. Additional information
VERTIGO MEDIA PERFORMANCE may modify this Policy at any time to adapt it to legislative changes and those of its activities. These changes will take effect as soon as they are published on the Site. We therefore invite you to consult this Policy frequently.
VERTIGO MEDIA PERFORMANCE strives to ensure a high level of protection of Users' personal data, in accordance with Regulation No. 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data (hereinafter "GDPR") and Law No. 78-17 of 6 January 1978 on data processing, to the files and freedoms "hereinafter "LIL").
2. Identity of the controller
The company VERTIGO MEDIA PERFORMANCE SL, 75calle Ecquador 08029 BARCELONA, SPAIN is the data controller.
The company has appointed a DPO, whom you can contact by:
- email, at: email@example.com
- by post, for the attention of the DPO, to the aforementioned address of vertigo media's head office.
You can contact the DPO to exercise any of the rights granted to you by the GDPR and/or the LIL as well as to obtain additional information relating to the processing of your personal data by VERTIGO MEDIA.
3. Personal data collected
3.1. When you request a connection
When Users access the Interfaces, a questionnaire that varies according to the searches must be completed to allow the connection with one or more Partners, according to their needs.
On this occasion, VERTIGO MEDIA PERFORMANCE collects the personal data that you provide by completing the fields of the Interfaces questionnaire. The nature and extent of the personal data collected depends on:
on the one hand, the purpose of your request for connection;
on the other hand, products and/or services you are looking for.
VERTIGO MEDIA PERFORMANCE may collect, depending on the situation, the following personal data:
|TYPOLOGY||PERSONAL DATA COLLECTED|
|Identification data||We may collect your surname, first name and title.|
|Coordinates||We may collect your email address, telephone number, postal address.|
|Privacy||We may collect information relating to your lifestyle, your family situation, the existence of pets or your consumption habits, the occurrence or absence of a claim, etc.|
|Professional life||We may collect information about your functions, your business, your business address, your business phone number, your business email address, etc.|
|Financial economic data and||We can collect your income level by range, an estimate of your wealth by range, whether you own or rent your home, etc.|
The personal data must be filled in to be put in touch with one of our Partners asterisk.
VERTIGO MEDIA PERFORMANCE are systematically indicated by a is also likely to collect additional personal data about you. You are free to fill in or not the fields of the Interfaces that are not required.
If you do not wish to fill in this optional information, your decision will not affect your request for connection.
All this personal data is collected when you confirm your request to connect with one or more of our Partners.
Please note that when you confirm your request for contact, MEDIA PERFORMANCE VERTIGO may send you an SMS to the number indicated. mobile phone that you have entered in order to confirm the contact details
3.2 After your request to connect
VERTIGO MEDIA PERFORMANCE obtains information from its Partners on the follow-up(s) given by Users to the offers that have been proposed to them at the end of the connection with them.
The information obtained is limited to what is strictly necessary to allow the execution of the contract that binds Partners. VERTIGO MEDIA
3.3 When consulting the Interfaces
When Users access the Interfaces, as an intermediary, vertigo MEDIA PERFORMANCE collects the IP address of the Users.
This personal data is not transferred to our Partners, subject to the information in Article 4.1 "The transfer of personal data to The Residents".
4. Transfers of personal data
4.1. Transfer of personal data to Partners
As this is a linking service initiated by Users, their personal data obtained in accordance with the terms of Article 3.1 "When requesting a connection" are collected for the purpose of being transferred to one or more Partners, depending on the Users' research, likely to meet their need(s).
Once obtained, the Partner(s) concerned is/are responsible for processing the Personal Data of Users thus transferred, for example when they decide to contact you or make an appointment with you.
The Partner(s) concerned may not use the Users' personal data for purposes other than to contact them in order to meet their needs and, where appropriate, to follow up on offers for which Users express an interest.
Consequently, if the Partner(s) concerned wishes, once they have presented you with their offer(s) corresponding to your needs, to send you in addition to the advertisements, they must obtain your consent, unless it is not required under a legislative or regulatory provision.
In some cases, when your request to connect is addressed to a single Partner, VERTIGO MEDIA PERFORMANCE may offer you to consent to advertising from this Partner.
In this case, VERTIGO MEDIA PERFORMANCE merely collects your consent and transmits proof of your agreement to the Partner.
Subsequent uses of your personal data for this purpose are carried out by the Partner alone, under its sole responsibility. Under no circumstances does VERTIGO MEDIA PERFORMANCE send you advertising solicitations.
VERTIGO MEDIA PERFORMANCE may also transfer your IP address to Partners when they use it to ensure that VERTIGO MEFIA properly executes the connection request. In this case, The Partners may not use your IP address for any other purpose.
Please note that VERTIGO MEDIA PERFORMANCE does not transfer your personal data to Partners who are not likely to meet the needs expressed with regard to your initial research.
4.2. The transfer of digital personal data
VERTIGO MEDIA PERFORMANCE to advertising providers may also transfer Users' personal data in an encrypted manner to other digital advertising providers.
During this transfer, to protect this data, VERTIGO MEDIA PERFORMANCE uses a single-way encryption algorithm (SHA 256) to ensure its integrity. This algorithm creates a unique fingerprint of the encrypted data; if the service provider to whom this data is transferred:
holds the data relating to the User concerned, he can recognize it by comparing the fingerprint that VERTIGO MEDIA PERFORMANCE transferred using the fingerprint of the data he has;
does not even generate the data relating to the User concerned, he will not obtain access to the personal data transferred. In the latter case, the receiving service provider is therefore not able to identify you because it does not know you.
4.3. Transfer of personal data to our service providers
4.3.1. General information
VERTIGO MEDIA PERFORMANCE may transfer Users' personal data to some of its service providers for the performance of their services (e.g. advertising agencies, management tools, hosting providers, etc.).
If necessary, only your personal data necessary for the recipients concerned to perform their services are transferred to them. The transfer of this personal data is always governed by the clauses of the contracts concluded with them, adapted according to their quality.
Your personal data is hosted on servers located in France at OVH, 2 rue Kellermann 59100 Roubaix.
4.3.2. Specific information relating to transfers of your personal data outside the European Economic Area
VERTIGO MEDIA PERFORMANCE limits as much as possible the use of service providers located outside the European Union or the European Economic Area. Nevertheless, the geographical location of some of them, necessary for the operation of VERTIGO MEDIA PERFORMANCE and the provision of the services offered, may result in such a transfer. In this case, VERTIGO MEDIA PERFORMANCE accompanies the transfer of your personal data to the Standard Contractual Clauses of the European Commission, or any other appropriate guarantee.
Please note that some of our service providers may transfer your personal data outside the European Union or the European Economic Area to perform their services. In this case, VERTIGO MEDIA PERFORMANCE requires that such transfers be carried out in accordance with the applicable legislation on the protection of personal data.
5. The use of personal data collected without transfer in the context of vertigo media's commercial activity.
5.1. The processing of data in the context of the communication of commercial offers from Partners.
The personal data obtained in accordance with the terms of Article 3.1 "When requesting a connection" are also processed directly by VERTIGO MEDIA PERFORMANCE as part of their exploitation for commercial solicitations of the User, by Partners of VERTIGO MEDIA PERFORMANCE.
The purpose of this processing is to:
- To send communications about products and services, for commercial prospecting purposes. These communications may take the form of email or postal mail, SMS, phone call or targeted online advertising.
- Once the data have been collected in connection with the provision of a service or enquiries, information on similar or targeted services based on previous requests may be sent, unless the data subject requests to stop sending such commercial communications or chooses not to receive them.
In this context, VERTIGO MEDIA PERFORMANCE, supports its Partners, for the construction and optimization of their operations of marketing campaigns, loyalty, customer relations, communication and information, studies and surveys.
Whenever an electronic communication for commercial prospecting purposes is sent, the recipient has the possibility to choose not to receive it in the future through an unsubscribe link.
In addition, it is possible, at any time, to send an e-mail to the following e-mail address: "Sender's e-mail address", in order to request to stop sending these commercial communications.
5.2. No transfer of data in the context of commercial solicitation directly by VERTIGO MEDIA PERFORMANCE.
In this case, VERTIGO MEDIA PERFORMANCE is responsible for the processing of Users' personal data insofar as it alone defines the purposes and means of such processing.
VERTIGO MEDIA PERFORMANCE undertakes to collect and process only the personal data strictly necessary.
Personal data is not transferred to Partners. They are processed only by VERTIGO MEDIA PERFORMANCE, on behalf of its Partners, in compliance with the provisions of the legislation in force.
5. The purposes of the processing and the associated legal bases
The processing of Users' personal data carried out by VERTIGO MEDIA PERFORMANCE pursues the following purposes, the legal bases associated with these treatments being indicated for each of them
|The collection of your consent to receive advertising solicitations from a Partner.||Authorize directly (with data transfer) or indirectly through VERTIGO MEDIA PERFORMANCE (without data transfer) a Partner to send you advertising solicitations.||The consent of Users (Art. 6 para. 1 lit. a) GDPR).|
|Obtaining information on the follow-up given by Users to the offers offered by Partners||Execute the contract that binds VERTIGO MEDIA PERFORMANCE to the Partner(s) to whom the Users' personal data have been transmitted||The legitimate interest of VERTIGO MEDIA PERFORMANCE (Art. 6 para. 1 , f) GDPR), the legitimacy lies in the need to verify that the contact details provided by the Users are accurate.|
|Collection of Users' IP addresses||Evaluate and strengthen the security of the Site and/or interfaces; Compile statistics relating to visits to the Site and interfaces.||The legitimate interest of VERTIGO MEDIA PERFORMANCE (Art. 6 para. 1 , f) GDPR), the legitimacy lies in the need to verify that the contact details provided by the Users are accurate.|
|The transfer to the Partners of the IP address of the Users||To enable the Partners to ensure that VERTIGO MEDIA PERFORMANCE properly executes the connection request||The legitimate interest of VERTIGO MEDIA PERFORMANCE (Art. 6 para. 1 , f) GDPR), the legitimacy lies in the need to verify that the contact details provided by the Users are accurate.|
|The transfer of Users' personal data to digital advertising providers||Search for new audiences likely to be interested in the brokerage services offered by VERTIGO MEDIA.||The legitimate interest of VERTIGO MEDIA PERFORMANCE (Art. 6 para. 1 , f) GDPR), the legitimacy lies in the need to verify that the contact details provided by the Users are accurate.|
|The transfer of Users' personal data to service providers||Use the tools and services necessary for the operation of VERTIGO MEDIA.||The legitimate interest of VERTIGO MEDIA PERFORMANCE (Art. 6 para. 1 , f) GDPR), the legitimacy lies in the need to verify that the contact details provided by the Users are accurate.|
6. Retention periods for personal data
VERTIGO MEDIA PERFORMANCE keeps the personal data of Users for as long as necessary for the purposes of the processing pursued, namely:
|THE PERSONAL DATA CONCERNED||DURATION(S) OF PRINCIPLE||EXCEPTIONS/RESERVATIONS|
|Personal data that must be provided to be put in touch with our Partners and Personal data obtained as a result of being put in touch with the Partners||Your personal data is in principle kept for a period of 2 years on an active basis from the last active contact with you; At the end of this period, this data is kept as an archive for an additional period of 3 years, in the event that a claim or dispute is formed by the Users and/or our Partners relating to the execution of the contracts that bind VERTIGO MEDIA PERFORMANCE to them.||If you make a request to modify and/or delete your personal data, these are modified and/or deleted within one month of receipt of this request, in accordance with the procedures set out in Article 8 "Users' rights"; In the event of a claim or dispute, VERTIGO MEDIA PERFORMANCE has a legitimate interest in keeping your personal data until their end, for the sole purpose of being able to defend itself.|
|Personal data that may optionally be provided to be put in touch with our Partners||Your personal data is in principle kept as long as you do not withdraw your consent.||As soon as you withdraw your consent, your personal data will be deleted within one month of receipt of this request; If you do not withdraw your consent, your personal data will be deleted within a maximum of 5 years; In the event of a claim or dispute, VERTIGO MEDIA PERFORMANCE has a legitimate interest in keeping your personal data until their end, for the sole purpose of being able to defend itself.|
|Personal data communicated during the use of the Interface and collected and processed directly by VERTIGO MEDIA||Your personal data is in principle kept for a period of 3 years on an active basis from the last active contact with you.||If you make a request to modify and/or delete your personal data, these are modified and/or deleted within one month of receipt of this request, in accordance with the procedures set out in Article 8 "Users' rights"; In the event of a claim or dispute, VERTIGO MEDIA PERFORMANCE has a legitimate interest in keeping your personal data until their end, for the sole purpose of being able to defend itself.|
|Ip address||Your IP address is stored for a period of 1 year.||If you make a request to modify and/or delete your personal data, these are modified and/or deleted within one month of receipt of this request, in accordance with the procedures set out in Article 8 "Users' rights"; In the event of a claim or dispute, VERTIGO MEDIA PERFORMANCE has a legitimate interest in keeping your personal data until their end, for the sole purpose of being able to defend itself.|
7. Security measures for personal data
VERTIGO MEDIA PERFORMANCE implements the necessary precautions to preserve the integrity, confidentiality and security of Users' personal data collected and processed in order to prevent their alteration, loss, destruction or unauthorized access by third parties, accidentally or unlawfully.
VERTIGO MEDIA PERFORMANCE has implemented technical and organizational security measures in accordance with current rules of the art.
In particular, be aware that:
- your personal data is only accessible in plain text to our employees who have an effective need to access it to carry out their missions, according to a strictly regulated access protocol;
- your personal data are, for the various processing as far as possible anonymous; Made, made our networks and servers are secured to limit as much as possible any access by third parties;
- the security of our information systems is ensured by our own employees.
Nevertheless, bag hez that VERTIGO MEDIA PERFORMANCE the risks related to the operation of the internet. cannot control all VERTIGO MEDIA PERFORMANCE draws your attention to the existence of the risks inherent in the use and operation of the Internet, and recommends that you take measures to protect your privacy.
8. Users' rights
8.1. Enumeration of rights
|The right to object||In accordance with the terms of Article 21(1) of the GDPR, you have the right, at any time, to object to the processing of your personal data, where such processing is carried out on the legal basis of legitimate interest. When you object to the processing by us of your personal data :p for advertising purposes, you can object to this without giving us any reason(s) justifying your request; for all other purposes, you must then indicate to us the compelling reason(s) motivating your request to exercise the right of opposition. Your objection to the processing(s) of your personal data is valid for the future.|
|The right to withdraw your consent||In accordance with the terms of Article 7(3) of the GDPR, you have the right at any time to withdraw your consent to the processing of your personal data, where such processing is carried out on the legal basis of such consent. You can withdraw your consent without giving us a reason(s) justifying your request. The withdrawal of your consent to the processing(s) of your personal data is valid for the future.|
|The right of access||In accordance with Article 15 of the GDPR, you have the right to: ask us about the nature and methods of the processing of your personal data that we carry out ;d obtain a copy of your personal data.|
|The right to rectification||In accordance with Article 16 of the GDPR, you have the right to ask us to correct or complete your personal data that is incorrect.|
|The right to erasure||In accordance with Article 17 of the GDPR, you have the right to ask us to erase your personal data. In this context, we delete the personal data concerned as much as possible. Nevertheless, please be aware that such a request cannot affect our right to retain your personal data necessary to meet our legal obligations.|
|The right to limitation||In accordance with Article 18 of the GDPR, you have the right to ask us to restrict the processing of your personal data, in one of the following cases: when you dispute the accuracy of such personal data or you consider that we would be processing it in breach of our obligations, but you do not immediately wish to delete it; in either case, we must suspend the processing of your personal data while we carry out the necessary checks; when we no longer need this data but you need it to claim, exercise and/or defend your rights; in this case, we must keep your personal data that is necessary for you.|
|The right to portability||In accordance with Article 20 of the GDPR, you have the right to ask us to transmit your personal data to you and/or to the third party of your choice, in a format that is technically usable by you or by the said third party|
|The fate of personal data||In accordance with Article 85 I. of the LIL, you have the right to give us instructions regarding the fate of your personal data after your death.|
|The right to refer the matter to a supervisory authority||You have the right to lodge a complaint with the CNIL (https://www.cnil.fr/fr/plaintes) or any other competent supervisory authority.|
8.2. Modalities of exercise
If you wish to exercise any of these rights, at the address you can make your request by:
- email, at: firstname.lastname@example.org
- by post, for the attention of the DPO, to the above-mentioned address of the headquarters of MEDIA VERTIGO
No payment will be required for the exercise of your rights, other than the possible costs of sending your requests, except in the event of repetitive and manifestly unfounded requests.
Please note that VERTIGO MEIDA may ask you for additional information to confirm your identity.
8.3. Processing your request
8.3.1. As part of the transfer of data for matchmaking.
Once your request to exercise your right(s) has been received, if applicable, MEDIA PER FORMANCE rmations VERTIGO informs the Partner(s) to whom your personal data have been transmitted, so that they can process your request. Indeed, once your personal data is obtained for the purposes of being put in touch with our Partners transferred to them, do not contact directly. . VERTIGO MEDIA PERFORMANCE does not you Thus, it is possible that a certain delay occurs between the moment when VERTIGO MEDIA PERFORMANCE the moment when this confirms having processed your request, and last one is also processed by the Partner(s) concerned.
VERTIGO MEDIA PERFORMANCE on the occasion of your request keeps your personal data transmitted to exercise of rights as well as our subsequent correspondence. The legal basis for the processing of this personal data is Article 6 (1) (f) GDPR, namely our legitimate interest.
The legitimacy of this processing is to be able to prove that we have processed your request for the exercise of rights within the time limits set. These personal data are kept in the form of archives, for a period of 5 years from the final processing of your request, with the exception of the copy of your identity card which will be deleted as soon as your identity is confirmed Only a reference and the DPO have access to this database.
8.3.2. As part of the data processing directly by VERTIGO MEDIA.
VERTIGO MEDIA PERFORMANCE undertakes to provide the data subject with information on the measures taken, following a d of Articles 15 to 22 of the R GPD issued in application, as soon as possible and in any event within one month of receipt of the request.
If necessary, this period may be extended by two months, taking into account the complexity of the number of applications.
VERTIGO MEDIA PERFORMANCE will inform the member and person concerned of this extension and the reasons for the postponement within one month of receipt of the request.
Where the data subject submits his or her request in electronic form, the information shall be provided electronically where possible, unless the data subject requests otherwise.
If the controller does not comply with the data subject's request, it shall inform the data subject without delay and at the latest within one month of receipt of the request of the reasons for his or her inaction and of the possibility of lodging a complaint with a supervisory authority and of seeking a judicial remedy.
VERTIGO MEDIA PERFORMANCE keeps a register of requests for access, rectification, and opposition for legitimate reasons.
VERTIGO MEDIA PERFORMANCE personal character with: may be required to share certain personal data with:
- Subcontractors who process certain services in relation to personal data for the sole purpose of providing technical assistance to VERTIGO MEDIA PERFORMANCE such as hosting providers.
- Competent authorities to which VERTIGO MEDIA PERFORMANCE would be required to disclose information in the context of legal proceedings or to detect technical and/or security problems.
8.4. Advertising solicitations sent by our Partners
In the event that you wish to withdraw your consent to the receipt of advertising solicitations sent by one of our Partners, VERTIGO MEDIA PERFORMANCE invites you to exercise your request directly with the latter. Indeed, under no circumstances does VERTIGO MEDIA PERFORMANCE send you advertising solicitations.