Data Protection Policy 

1. Purpose of the Data Protection Policy 

1. Addict Mobile Technology has defined its policy regarding the protection of personal data in compliance with data protection regulations, particularly the European Union’s General Data Protection Regulation (GDPR) [1]. 

2. Through this data protection policy, Addict Mobile Technology commits to protecting the privacy of its prospects and clients (referred to as « data subjects ») by ensuring the protection, confidentiality, and security of the collected personal data, in line with the applicable regulations. 

3. Addict Mobile Technology is dedicated to allocating financial, human, and technical resources to safeguard human dignity, the legitimate interests, and fundamental rights of data subjects. 

4. The primary objective of this data protection policy is to consolidate clear, simple, and precise information about data processing carried out by Addict Mobile Technology in a single document. This aims to help data subjects understand the personal data collected, how it is used, and their rights concerning this data. 

5. Addict Mobile Technology reserves the right to modify this data protection policy at any time, subject to compliance with applicable data protection regulations. 

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

2. Personal Data Governance 

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

7. This policy encompasses all guidelines, rules, procedures, and practices established by Addict Mobile Technology to meet the requirements of data protection regulations, as presented in this policy. 

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

9. The mission of the DPO is to ensure compliance with data protection regulations and act as a liaison between Addict Mobile Technology, the CNIL (Commission Nationale de l’Informatique et des Libertés), and all parties involved in the collection or processing of personal data. 

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

3. Definitions 

– « Anonymization » refers to « the result of processing personal data to prevent, irreversibly, any identification » ; 

– « Collect » refers to the act of gathering personal data. This collection can take place through questionnaires or online forms, among other means ; 

– « Consent » means any freely given, specific, informed, and unambiguous indication by which the data subject agrees to the processing of personal data related to them ; 

– « Service providers » broadly refers to subcontractors and other service providers working in relation to Addict Mobile Technology ; 

– « Products or services » refers to all products and services, including technological ones (websites, applications, and associated services), offered or to be offered by Addict Mobile Technology and its subsidiaries ; 

– « Prospect » refers to any person who contacts Addict Mobile Technology to obtain information about a product or service offered by Addict Mobile Technology ; 

– « Data controller » refers to the person or entity who, alone or jointly with others, determines the purposes and means of processing personal data ; 

– « Processing of personal data » refers to any operation or set of operations applied to data, regardless of the method used. 

4. Context of Personal Data Collection 

11. Personal data may be collected primarily in the following contexts : 

  • Management of applications addressed to Addict Mobile Technology and/or its subsidiaries ; 
  • Establishment of a relationship with Addict Mobile Technology ; 
  • Use of Addict Mobile Technology’s products and services, including technological services (websites, applications, and associated services) ; 
  • Relationship between Addict Mobile Technology, its prospects, and its clients ; 
  • Execution of contracts. 

5. Categories of Data Processed by Addict Mobile Technology 

12. Personal data refers to any information relating to an identified or identifiable natural person. 

13. The main categories of data collected by Addict Mobile Technology include contact details, identification data, photographs, data related to service usage, and data related to job applications. 

14. Personal data may include but is not limited to: name, surname, telephone number, photograph, video recording, exchanged messages, postal address, email address, IP address of an individual’s computer, and type of terminal used. 

5.1 Declarative Personal Data 

15. Declarative personal data is provided by the data subjects and collected by Addict Mobile Technology in the context of commercial or contractual relationships, or during job applications addressed to Addict Mobile Technology and/or its subsidiaries. 

16. The data primarily comes from the data subjects themselves or from individuals authorized by the data subjects to transmit the data to Addict Mobile Technology. 

17. For example, data subjects may provide personal data related to their company, names, surnames, contact information, professional training, professional experience, and photographs. Such data may be collected through forms, whether digital on websites or mobile applications, paper-based, or in response to questions asked by an Addict Mobile Technology employee. 

5.2 Personal Data from Third Parties 

18. The processed personal data may also come from : 

  • Service providers ;  
  • Public or supervisory authorities ; 
  • Subcontractors, service providers of Addict Mobile Technology, or third parties to Addict Mobile Technology if their data protection policies allow it ; 
  • Other products or services provided by third parties to which the data subjects have subscribed and/or authorized the sharing with Addict Mobile Technology. 

6. Personal Data Processed by Addict Mobile Technology 

19. The following are the main types of personal data processed by Addict Mobile Technology : 

  • Name, surname ;  
  • Country of origin of the request ; 
  • Email address ; 
  • Postal address ; 
  • Phone number ;  
  • Curriculum vitae ; 
  • Connection and browsing data on Addict Mobile Technology’s websites (IP, device, logs, trackers) ; 
  • Photographs ; 
  • Messages exchanged with Addict Mobile Technology’s employees. 

7. Recipients of Data Collected by Addict Mobile Technology 

20. The personal data collected, as well as any data collected subsequently, are intended for Addict Mobile Technology as the data controller. 

21. Addict Mobile Technology ensures that only authorized individuals can access the personal data of data subjects when necessary to perform their duties. 

22. Certain personal data may be shared with third parties to comply with legal, regulatory, or contractual obligations or with legally authorized authorities. 

23. Categories of recipients of the data include but are not limited to : Addict Mobile Technology companies, the human resources department, the legal department, the sales department, customer relations services, technical service providers, and any other relevant department or subsidiaries of Addict Mobile Technology involved in processing requests. 

Each subsidiary of Addict Mobile Technology processes data in accordance with the provisions of the GDPR, governed by a privacy policy available from the relevant subsidiary. 

8. Retention of Personal Data 

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

25. As a principle, Addict Mobile Technology is committed to choosing subcontractors and service providers that meet the best criteria of quality and security and provide sufficient guarantees in terms of reliability, security, and resources for the implementation of technical and organizational measures. 

26. Addict Mobile Technology continuously determines the location of its data hosting to be able to justify it to the relevant supervisory authorities. 

27. The GDPR has strengthened the duty of information for data subjects in the context of personal data collection. 

9. Guiding Principles for Personal Data Protection 

9.1 Lawfulness, Fairness, and Transparency 

9.1.1 Lawfulness 

28. Addict Mobile Technology refrains from processing data that would be unlawful, considering that lawfulness is assessed based on the conditions described below. 

29. Consent of the data subject. Addict Mobile Technology may process data when the data subject has consented to the processing of their personal data for one or more specific purposes. 

30. This consent can be given through a written statement, including electronically, or through an oral statement or when using the services. 

31. Legitimate interests of Addict Mobile Technology. Addict Mobile Technology’s legitimate interests or those of a third party may justify the processing of personal data concerning data subjects. 

32. Addict Mobile Technology’s legitimate interests may vary but may include : 

  • Improving marketing knowledge of data subjects ;  
  • Enhancing products and services ;  
  • Marketing prospecting. 

33. These processes are implemented, taking into account the interests and fundamental rights of data subjects. Consequently, they are accompanied by measures and guarantees to protect the interests and rights of data subjects, thus striking a balance with Addict Mobile Technology’s legitimate interests. 

9.1.2 Fairness and Transparency 

34. Addict Mobile Technology commits to providing loyal, clear, and transparent information. 

35. As such, Addict Mobile Technology undertakes to inform data subjects of each data processing operation it carries out through information notices. 

9.2 Specific, Explicit, and Legitimate Purposes 

36. Personal data is collected and continuously processed by Addict Mobile Technology for specific, explicit, and legitimate purposes. 

37. Addict Mobile Technology uses personal data in accordance with the conditions of this data protection policy and with a constant focus on the ethics and security of its clients’ personal data. 

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

  • Application management ; 
  • Reception of inquiries through the contact form addressed to editorial and webmaster teams ; 
  • Management of follow-ups to received requests ; 
  • Communication regarding events or news ; 
  • Management of exchanges with partners of Addict Mobile Technology concerning claims or requests addressed to it ; 
  • Management, protection, and security of tools, websites, and applications ; 
  • Measurement of quality and satisfaction ; 
  • Improvement of provided services ; 
  • Service innovation ; 
  • Conducting solicitation operations ; 
  • Compilation of visit and navigation statistics on the website ; 
  • Handling requests related to data subjects’ rights ; 
  • Management of feedback from data subjects regarding products, services, or content. 

9.3 Adequacy, Relevance, and Limitation 

39. For each processing operation, Addict Mobile Technology commits to ensuring that the processing is adequate and that only strictly necessary data is collected and processed for the intended purpose. 

9.4 Accuracy of Data 

40. Addict Mobile Technology is committed to collecting complete and up-to-date data, as far as circumstances permit. 

41. Data subjects have the right to exercise their right to rectification, as described above, if they discover the existence of inaccurate data. 

9.5 Data Retention and Limitation 

42. Addict Mobile Technology commits not to retain personal data longer than necessary to achieve the purposes for which they are processed or longer than the duration prescribed by regulations regarding the protection of personal data. 

No. Categories of Personal Data Active Retention Rules 
1. Information requests 1 year 
2. Applications Retention of up to 2 years from the last contact with the candidate. In case of dispute/complaint from the candidate regarding the rejection of their application during this period, the data will be retained for a total duration of 5 years from the date of sending the rejection letter to the candidate. 
3. Audience measurement statistics 26 months 
4. Newsletter management Until unsubscribed 
5. Photographs (excluding job applications) 5 years 
6. Messages 1 year 

43. After the retention period has elapsed, the data is deleted from Addict Mobile Technology’s information system. 

9.6 Security and Confidentiality Commitment 

44. Addict Mobile Technology commits to implementing security measures appropriate to the sensitivity of personal data to protect it from any malicious intrusion, loss, alteration, or unauthorized disclosure to third parties. 

45. All premises of Addict Mobile Technology where personal data is processed are electronically and/or manually protected against unauthorized third-party intrusion. 

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

47. For example, Addict Mobile Technology may pseudonymize personal data whenever possible and necessary. 

9.7 Rights of Data Subjects 

48. Data subjects whose data is being processed benefit from the following rights, unless otherwise required by law : 

The right to information ; 
The right of access ; 
The right to rectification ;  
The right to erasure or the right to be forgotten ;  
The right to data portability ;  
The right to object ;  
The right to restrict processing ;  
The right to define directives regarding the retention, erasure, and communication of their personal data after their death. 

9.7.1 Exercise of These Rights 

For questions or requests related to the processing of personal data carried out by Addict Mobile Technology, data subjects are invited to contact: dpo@addict-mobile.com. 

9.7.2 Right to Lodge a Complaint 

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

51. Data subjects may lodge this complaint with the French supervisory authority, the CNIL. 

9.8 Supervision of Transfers Outside the European Union 

52. Personal data that European nationals have transmitted to Addict Mobile Technology in accordance with the agreed-upon purposes is subject to transfer within the European Union or outside the European Union. 

53. For transfers to a country outside the European Union, rules ensuring the protection and security of this information have been implemented. 

54. Addict Mobile Technology takes all necessary and appropriate measures to ensure the security of personal data in all cases. 

55. This personal data may be communicated, at the request of data subjects, to official organizations, administrative or judicial authorities, or third parties. 

10. Specific Processing Operations 

10.1 Cookies and Other Trackers 

56. Cookies or other trackers refer to trackers deposited and read, for example, when visiting a website, reading an email, installing or using software or a mobile application, regardless of the type of device used. 

57. To improve the use and functionality of its websites, Addict Mobile Technology uses different types of « cookies » or other indicators, 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 implemented a cookies policy on its websites. For more information, please refer to the Cookies Policy available on the site during your visit.