Data Protection Policy

1. What is the purpose of the data protection policy?

1. Addict Mobile Technology has wished to set out its personal data protection policy with regard to data protection regulations by taking into account the European Union standards in this matter and more particularly the General Data Protection Regulation (“GDPR”) [1].

2. With this data protection policy, Addict Mobile Technology undertakes, within the framework of its activities and in accordance with the regulations in force, to protect the privacy of its prospects and customers (the “data subjects”) by ensuring the protection, confidentiality and security of the personal data collected.

3. Addict Mobile Technology further undertakes to have suitable financial, human and technical means to safeguard the data subjects human dignity, legitimate interests and fundamental rights.

4. The main objective of this data protection policy is to concentrate in a single document clear, simple and precise information concerning the data processing operations carried out by Addict Mobile Technology, in order to enable the data subjects to understand what information and personal data (hereinafter referred to as the “personal data”) are collected, how they are used and what their rights are with regard to these personal data.

5. Addict Mobile Technology reserves the right to amend this data protection policy at its sole discretion and at any time, in accordance with applicable data protection regulations

[1] Reg. (EU) 2016/679 of 27 April 2016

2. Governance of personal data

6. Addict Mobile Technology has developed a personal data governance policy.

7. This policy includes all the guidelines, rules, procedures, and practices implemented by Addict Mobile Technology to take into account the requirements of regulations relating to the use and protection of personal data, whose guiding principles are presented in this policy.

8. In this context, Addict Mobile Technology has designated a Data Protection Officer (DPO).

9. The task of the DPO is to ensure compliance with data protection regulations and to liaise with the Data Protection Authorities and all data subjects in relation to the collection or processing of personal data.

10. The DPO can be contacted by any interested person at the following postal address: «Service RGPD – 350 rue Denis Papin CS 90554 13594 Aix en Provence Cedex 3 France » or at the following email address “dpo@addict-mobile.com”.

3. Definitions

– “anonymisation” means “the result from processing personal data in order to irreversibly prevent identification”[2];

‐ “collect” means to obtain personal data. Data may be collected in particular by means of questionnaires or replies to messages;

‐ “consent” means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

– “providers” should be construed in the broadest sense and means in particular service providers, subcontractors working with Addict Mobile Technology;

– “prospect” means any person who has contacted Addict Mobile Technology to obtain information about a product or service offered by Addict Mobile Technology.

– “controller” means the person or body which, alone or jointly with others, determines the purposes and means of the processing of your personal data;

– “processing of personal data”: means any operation or set of operations in relation to such data, whatever the mechanism used.

4. When does Addict Mobile Technology collect personal data?

11. Personal data may be collected primarily in the context of:

the management of applications addressed to Addict Mobile Technology and/or its subsidiaries;
the entry into contact with Addict Mobile Technology;
the customer’s use of any Addict Mobile’s products and services, including technological services (website, application, and associated services);
the relationship between Addict Mobile Technology, its prospects, and its customers;
the performance of contracts;

5. What are the categories of data processed by Addict Mobile Technology?

12. Personal data means any information relating to a natural person which permits to identify him or her, directly or indirectly.

13. The data collected by Addict Mobile Technology may be filed under the following main categories: contact data, identification data, photos, data linked to the use of the services, payment data, data related to applications for job offers.

14. Personal data may include an individual’s first and last name, telephone number, photograph, video recording, messages exchanged, postal address, email address, computer’s IP address, type of device used.

5.1 Declarative personal data

15. Declarative personal data is any data provided by the data subjects and collected by Addict Mobile Technology in the context of commercial or contractual relationships or when applying to Addict Mobile Technology and/or its subsidiaries.

16. The data come mainly from the data subjects and the persons authorised by the data subjects to transmit them to Addict Mobile Technology.

17. For example, the data subject may be asked to provide personal data about his company, his name, first name, contact information, his professional training, his professional experience, his photograph. This data can be collected through electronic forms (on website or mobile applications), paper forms or verbally through answers to questions asked for example by an employee of Addict Mobile Technology.

5.2 Personal data from third parties

18. The personal data processed may also come from:

service providers;
public or supervisory authorities;
subcontractors, providers of the Addict Mobile Technology or third parties if their personal data protection policies allow it;
other products or services provided by third parties to which the data subjects have subscribed and/or for which they have authorised sharing with Addict Mobile Technology.

6. What are the personal data processed by Addict Mobile Technology?

19. Addict Mobile Technology processes the following main personal data in relation to user:

last name, first name
country of origin of the applicant
email address
mailing address
telephone number
curriculum vitae
connection and consultation data of electronic applications (IP, device, logs, tracers)
photographs
messages exchanged with employees of Addict Mobile Technology

7. Who are the recipients of the data collected by Addict Mobile Technology?

20. The personal data collected, as well as those that will be obtained later, are intended for Addict Mobile Technology in its capacity as the data controller.

21. Addict Mobile Technology ensures that the personal data of the data subjects are only accessed by authorised persons and only when necessary for the performance of their tasks.

22. Some personal data may be sent to third parties to comply with legal, regulatory or contractual obligations or to legally authorised authorities.

23. The categories of recipients of the data include: customers, Addict Mobile Technology companies, the human resources department, legal department, sales department, internal customer relations, technical providers, and any other competent services of the Addict Mobile Technology subsidiaries concerned by the requests.

Each subsidiary of Addict Mobile Technology processes the data in accordance with the provisions of the RGPD, which are governed by a confidentiality policy, accessible from the subsidiary concerned.

8. How long does Addict Mobile Technology keep the personal data?

24. Personal data is stored in Addict Mobile Technology’s information systems or those of its subcontractors or providers. Subject to transmission to third parties, personal data is stored in a data centre and processed in Europe.

25. As a matter of principle, Addict Mobile Technology undertakes to choose subcontractors and providers who meet the best quality and security criteria and provide sufficient guarantees in terms of reliability, security and resources to implement technical and organisational measures.

26. Lastly, Addict Mobile Technology knows at all times the place where its data are hosted in order to be able to demonstrate compliance to the competent supervisory authorities.

27. The GDPR has strengthened the duty to provide information to data subjects whose personal data are collected.

9. Guiding principles for the protection of personal data

9.1 Lawfulness, fairness and transparency

9.1.1 Lawfulness

28. Addict Mobile Technology will not process data unlawfully, with the understanding that lawfulness is assessed in the light of one of the conditions described below.

29. Consent of data subject. Addict Mobile Technology may carry out processing where the data subject has given consent to the processing of his or her personal data for one or more specific purposes.

30. Such consent may be given by a written statement, including by electronic means, or an oral statement, or when using the services.

31. The legitimate interests of Addict Mobile Technology or a third party may be such as to warrant Addict Mobile Technology’s processing of the data of the data subject.

32. The legitimate interests pursued by Addict Mobile Technology are diverse but may consist in particular of:

the improvement of the marketing knowledge of the data subjects;
the improvement of products and services;
marketing prospects.

33. Such processing operations are carried out taking into account the interests and fundamental rights of the data subjects. As such, they are accompanied by measures and guarantees to ensure the protection of the interests and rights of the data subjects and allow a balance with the legitimate interests pursued by Addict Mobile Technology.

9.1.2 Fairness and transparency

34. Addict Mobile Technology undertakes to provide fair, clear and transparent information.

35. Addict Mobile Technology undertakes to inform the data subjects of each processing operation it carries out by means of information notices.

9.2 Specified, explicit and legitimate purposes

36. Personal data are collected and processed by Addict Mobile Technology for specified, explicit and legitimate purposes at all times.

37. Committed to guaranteeing the ethics and security of the personal data of its customers, Addict Mobile Technology uses personal data in accordance with the terms of this data protection policy.

38. Addict Mobile Technology uses all or part of the personal data for the following main purposes:

the management of the applications;
the reception of the requests in the form of contact addressed to the publisher and the webmaster;
the management of the follow-up given to the requests received;
communication about events or news;
managing exchanges with Addict Mobile’s partners in the context of complaints or requests sent to it;
managing, protecting and securing tools, websites and applications;
measuring quality and satisfaction;
improving the services provided;
developing service innovation;
executing solicitation operations;
developing trade statistics;
managing data subject’s requests in relation to their rights;
managing people’s opinions on products, services or content;

9.3 Adequacy, relevance and restriction

39. For each processing operation, Addict Mobile Technology undertakes to ensure that the processing operations are adequate and to collect and process only data that are strictly necessary for the purpose pursued.

9.4 Data accuracy

40. Addict Mobile Technology is committed to ensuring that the data collected are complete and as up-to-date as circumstances permit.

41. Data subjects have the right to exercise their right to rectification, under the conditions given below, if they become aware of the existence of inaccurate data.

9.5 Storage period and restriction

42. Addict Mobile Technology undertakes that it will not keep personal data longer than is necessary to fulfil the purposes for which they are stored or no longer than the period provided for by the regulations relating to the protection of personal data.

N°	Categories of personal data	Rules of active conservation
1.	Requests for information	1 year
2.	Applications	Retention of 2 years maximum starting from the time of last contact with the applicant. In case of complaints of the applicant on the refusal of his application within this period: conservation for a total duration of 5 years starting from the sending of the refusal letter to the applicant
3.	Analytics statistics	26 months
4.	Newsletter management	Until unsubscription
5.	Photographs (excluding applications)	5 years
6.	Messages	1 year

43. After the end of the retention period, the data will be deleted from Addict Mobile Technology’s information system.

9.6 Commitment to security and confidentiality

44. Addict Mobile Technology undertakes to implement security measures appropriate to the degree of sensitivity of the personal data to protect them against any malicious intrusion, loss, alteration or disclosure to unauthorised third parties.

45. All Addict Mobile Technology’s premises in which personal data are processed are protected electronically and/or manually against intrusion by unauthorized third parties.

46. Addict Mobile Technology has adopted internal policies and processes implementing measures that comply with the principles of personal data protection by design and by default.

47. For example, it may apply pseudonymisation of personal data as soon as this is possible or necessary.

9.7 Rights of data subjects

48. The individuals whose data are processed are granted the following rights, unless otherwise legally required from Addict Mobile Technology:

the right of information;
the right of access;
the right to rectification;
the right to erasure or the right to be forgotten;
the right to portability;
the right to object;
the right to restriction of processing;
the right to give guidelines for the storage, erasure and communication of personal data after their death.

9.7.1 Procedures for exercising these rights

49. If you have any questions or requests regarding the processing of personal data by Addict Mobile Technology, please contact: dpo@addict-mobile.com

9.7.2 Right to lodge a complaint

50. The data subjects have the right to lodge a complaint with a supervisory authority, without prejudice to any other administrative or judicial remedy.

51. The data subjects may lodge this appeal with the Data Protection Authorities: Information Commissioner’s Office (ICO).

9.8 Framework for transfers outside the European Union

52. The personal data that European citizens have transmitted to Addict Mobile Technology in accordance with the agreed purposes are transferred to a country inside the European Union or outside the European Union.

53. In case of transfers to a country outside the European Union, rules have been put in place to ensure the protection and security of the data.

54. In all cases, Addict Mobile Technology undertakes to take all necessary and appropriate measures to ensure the security of personal data.

55. These personal data may be communicated, at the request of the data subjects, to official bodies and to authorized administrative or judicial authorities, or to third parties.

10. Special processing

10.1 Cookies and other tracking technology

56. When we talk about cookies or other tracking technology, we mean the technology placed and read for example when you consult a website, read an email, install or use software or a mobile application, whatever the type of device used.

57. In order to improve the use and functionalities of its websites, Addict Mobile Technology uses various types of cookies or other trackers such as pixel tags, some of which may automatically record and transmit personal data to Addict Mobile Technology’s websites.

58. Addict Mobile Technology has set up a cookies policy for its websites. For more information please refer to the Cookie Policy available on the site during your visit.