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I. THE PROCESSING OF PERSONAL DATA BY LIVE DATA SOLUTIONS

As part of its activity, LIVE DATA SOLUTIONS undertakes to comply with the provisions of Law No. 78-17 of 6 January 1978 as amended, relating to data processing, files and freedoms, as well as Regulation 679/2016 of 27 April 2016 on the protection of personal data.

LIVE DATA SOLUTIONS undertakes to take the necessary measures to ensure the security and confidentiality of the personal data entrusted to it.

LIVE DATA SOLUTIONS only processes personal data on instructions and on behalf of its partners and customers.

1. Activities of the use of the LIVE DATA SOLUTIONS website
1.1. Purposes of processing

Through the operation of its website www.livedata-solutions.com, LIVE DATA SOLUTIONS processes as Data Controller of personal data, on its own behalf, as part of the management of its customer and prospect file.

This data processing allows LIVE DATA SOLUTIONS TO:

  • to respond to your requests on our offers or services when you provide your data through our forms;
  • to contact you to offer you our offers or services and, if necessary, a demonstration,
  • to send you the information and/or documents you wish to obtain;
  • to communicate with you for marketing purposes and in particular by sending our newsletter;
  • understand your needs and preferences to better meet your request;
  • Facilitate your navigation and carry out audience measurements.

The purpose of collecting your data and to offer the user and/or visitor a personalized and optimal experience of our website.

1.2. Data collection via forms on the pages of the www.livedata-solutions.com site

Professional data relating to users and visitors of the LIVE DATA SOLUTIONS website are collected via the forms and pages of the website, in particular the subscription to the newsletter via your professional e-mail address and/or the contact form.

1.3. Nature of the data processed

Category of persons concerned:

  • Users and professional visitors of the LIVE DATA SOLUTIONS website
  • LIVE DATA SOLUTIONS Customers

Nature of the Data processed:

  • Civility
  • Name of your company
  • Name and surname
  • Email address
  • Phone Number
  • IP address of your browser
  • Duration of your visit
  • Pages visited
  • Your communication preferences.

1.4. Legal basis for processing

The legal basis for processing is the legitimate interest of the data subjects at the time of data collection.

1.5. No data transfer

LIVE DATA SOLUTIONS does not transfer your data to third parties. The data collected is intended exclusively for LIVE DATA SOLUTIONS and its subsidiaries.

Thus, data will not be disclosed to third parties or entities unless the law in force provides otherwise.

2. Activities of providing marketing campaigns on behalf of third parties
2.1. Purposes of processing

LIVE DATA SOLUTIONS makes personal data available for marketing campaigns for the benefit of these customers. This data is collected by partners (data controllers) for whom LIVE DATA SOLUTIONS acts as a subcontractor.

LIVE DATA SOLUTIONS offers marketing campaign delivery services for its clients through:

  • Routing (performed with the database transmitted by the LIVE DATA SOLUTIONS clients)
  • Data Rental
  • Campaign delivery via our affiliation network.

Thus, LIVE DATA SOLUTIONS helps its customers to build and optimize their marketing, loyalty, customer relations, communication, studies and surveys campaigns by means of processing and statistical analysis in order to:

  • Select prospects for a marketing and/or communication campaign;
  • Allow its customers to enrich their customer base with contact data
  • Allow its customers to better know and therefore retain its own customers;
  • Allow the realization of relevant surveys and studies;
  • Enable the optimization of marketing campaigns in real time.

Different channels can be used to contact people: by post, telephone, email, SMS and via media campaigns.

Operations allowing the personalization of the communication can be carried out in order to contact you only in the context of your interests.

To carry out these treatments, LIVE DATA SOLUTIONS acts exclusively at the request of its customers and on their behalf.

LIVE DATA SOLUTIONS never comes into contact with persons whose data is processed on its own behalf.

Once the selection has been carried out by LIVE DATA SOLUTIONS, the data is either processed by LIVE DATA SOLUTIONS on behalf of the client(campaign routing) or transferred to the client or the client's trusted third party.

2.2. Indirect collection of identifying data

LIVE DATA SOLUTIONS does not collect data directly from individuals.

It is LIVE DATA SOLUTIONS's partners, data owners, who collect data from individuals and who then transmit their database to LIVE DATA SOLUTIONS acting as a subcontractor for the constitution of a database for marketing.

As part of its partnerships, LIVE DATA SOLUTIONS only contracts with companies that undertake to comply with the legislation in force in the context of the processing of personal data.

The personal data that LIVE DATA SOLUTIONS processes comes from file owners from the following fields of activity:

  • E-merchants
  • Satisfaction surveys
  • Media sites
  • Competitions / Co-registration

2.3. Nature of the data processed

Category of persons concerned:

  • Users of partner sites
  • Consumers who are natural persons
  • Customers of LIVE DATA SOLUTIONS customers

Nature of the Data processed:

  • Civility
  • Postal address
  • Email address
  • Phone Number

Personal data collected in connection with these services is used for the purpose of providing services and marketing to our customers.

2.4. Legal basis for processing

The legal basis for the processing is the consent of the data subjects at the time of data collection.

LIVE DATA SOLUTIONS therefore only processes personal data for which you have previously consented to the purposes and transfer.

2.5. No transfer of data without your consent

LIVE DATA SOLUTIONS does not transfer the data processed as part of this service to third parties without the explicit consent of the person concerned.

3. Customer database enrichment activities
3.1. Purposes of processing

LIVE DATA SOLUTIONS processes personal behavioral data or advertising targeting to offer services to enrich pre-existing customer files belonging to its customers.

It is important to emphasize that the customer of LIVE DATA SOLUTIONS who processes his own database enriched with behavioral data remains responsible for the processing of this database and therefore determines alone the purposes.

LIVE DATA SOLUTIONS undertakes to use personal behavioral or advertising targeting data only as part of the services of enrichment of pre-existing customer files for its customers and not to use them for other purposes without the prior and specific consent of the person concerned.

3.2. Indirect collection of behavioral data.

LIVE DATA SOLUTIONS indirectly collects behavioral data:

  • which make it possible to determine the actions and behaviours of data subjects when theyare users of a partner website;
  • which make it possible to determine the best time to send a marketing campaign by the INSTANT MAIL offer.

LIVE DATA SOLUTIONS uses Internet user connection data collected by its partners when accepting the cookie banner on their website. LIVE DATA SOLUTIONS combines this connection data with the opt-in customer and prospect database of its advertising Clients, to send them personalized advertisements in real connection time. In accordance with applicable law, the person concerned by the processing may exercise their right of access, modification and deletion of the data concerning them and have a right to object to the processing of these personal data, by send an email to dpo@livedata-solutions.com or by post to Live Data Solutions SL, 75 calle Ecquador, 08029 Barcelona, Spain.

PURPOSES

COMMERCIAL PROSPECTING FOR ITS CUSTOMERS THROUGH BEHAVIOURAL PROFILING (DATA MATCHING)

DATA CATEGORIES

Tracking of connection data through the use of connection data collected by Partners through acceptance of the cookie banner of their site and information on data transmission and purposes

DATA DETAILS

Email, IP, date, timestamp

SOURCE

Data generated by user activity on Partner websites and transmitted to LIVE DATA SOLUTIONS with the consent of the Internet user

Protection of personal data in the context of indirect data collection.

LIVE DATA SOLUTIONS does not process any sensitive personal data, nor does it cross Data to create it. In addition, no categories or segments of Data are created to target minors under the age of 18.

LIVE DATA SOLUTIONS ensures that in the process of data collection by its Partners, for its benefit and that of its customers, the persons concerned have received the prior, clearly accessible and transparent information relating to:

  • the processing and use of data, and where applicable electronic tracers for the benefit of the Partners or Customers of the partners of the collecting entity;
  • the transmission of the information collected, and if necessary thanks to tracers, to LIVE DATA SOLUTIONS as a partner of the collecting entity;
  • for the purposes of use by LIVE DATA SOLUTIONS or by LIVE DATA SOLUTIONS' customers (advertisers, etc.) of the data collected, where applicable through tracers, in particular by inserting a link to the LIVE DATA SOLUTIONS Privacy Policy. The latter will be able to carry out personalized marketing operations in real time;
  • the terms of data transfer.

LIVE DATA SOLUTIONS also ensures that its Partners have enabled their Site users:

  • where necessary to express their choices regarding tracers and the processing of Personal Data and the transmission of this data;
  • to freely and informed express their consent for the processing of their data and the transmission of partners and customers of partners;
  • the possibility of opposing it at any time, in particular by referring to an unsubscribe link.

Finally, LIVE DATA SOLUTIONS ensures that its Partners implement all necessary confidentiality and security measures to protect its computer system against any unauthorized access, alteration, disclosure or destruction of the Data it has collected, at least, at the same level as LIVE DATA SOLUTIONS. As an indication, the measures put in place may be:

  • effective technologies such as encryption through SSL technology; hashing/encryption, of the firewall to prevent intrusion from malicious third parties;
  • regular audits on the collection, storage and processing of data in order to verify access to the Partner's databases and to prevent any unauthorized system from accessing the Partner's systems;
  • restrictions on access to Data collected in compliance with strict confidentiality obligations to which they are subject.

In general, LIVE DATA SOLUTIONS requires its Partners to strictly comply with Law No. 78-17 of 6 January 1978 as amended, relating to data processing, files and freedoms, the Post and Electronic Communications Code and Regulation 679/2016 of 27 April 2016 on the protection of personal data.

3.3. Nature of the data processed

The data processed may include, but is not limited to, information about the behavior of users of partner sites, such as pages visited, products purchased or viewed, searches performed, interactions with advertisements and marketing campaigns and in particular real-time login information (INSTANT MAIL), as well as targeting data, such as age, gender, geographic location, interests, and buying behaviors.

3.4. Legal basis

The legal basis for the processing of behavioral data is the consent of the persons concerned on the use of technological tracers (cookie banners and other tracers) for the benefit of LIVE DATA SOLUTIONS.

3.5. TRANSFER: CATEGORY OF RECIPIENTS OF THE DATA

The personal data collected with your consent on the purposes defined at the time of collection (consent of the cookie banner) will allow the enrichment of the customer databases of LIVE DATA SOLUTIONS operating in the following sectors of activity:

  1. Health and well-being
  2. Education and training
  3. Technology and IT
  4. Financial services
  5. Real estate
  6. Marketing and advertising
  7. Media and entertainment
  8. Retail and e-commerce
  9. Tourism and travel
  10. Transport and logistics
  11. Manufacturing
  12. Energy and environment
  13. Professional Services
  14. Public sector and not-for-profit organizations
  15. Agriculture and Agri-Food
  16. Construction and engineering
  17. Legal Services
  18. Sports and leisure
  19. Telecommunications

These data transfers are carried out in accordance with the provisions of the General Data Protection Regulation (GDPR) and applicable laws on the protection of personal data.

The recipients of the data undertake to use the personal data only for the purposes for which they were communicated and to comply with the provisions of the GDPR and applicable laws on the protection of personal data.

II. EXERCISE OF RIGHTS

In accordance with the legislation in force and more specifically Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR"), applicable from 25 May 2018, You have a right of access, rectification, deletion, instructions (portability or instructions after your death) on your data and opposition for legitimate reasons.

You can withdraw the consent granted at any time and request the deletion of your data. In any communication that reaches you after processing your personal data you are informed of your rights with the possibility either to unsubscribe in case of email and sms, or to contact the person in charge of the campaign in order to oppose the use of your data.

To exercise your rights you can send your request by post with a copy of identity document to the following address: LIVE DATA SOLUTIONS – DPO – Calle de l'Ecuador 75, 08029 Barcelona, Spain or by email to the following address: dpo@livedata-solutions.com or via the form at the top of the page.

As part of these requests, LIVE DATA SOLUTIONS will delete the data in the processed databases and will systematically forward this request to the Partner who provided it with this data for marketing.

The rights can also be exercised directly with the Partner who collected the personal data or with the customer who contacts the person. A response must be provided within 1 month.

In case of problem you can appeal to the competent authority.

III. DATA RETENTION PERIOD

In accordance with Article 5e of Regulation 2016/679 of 27 April 2016, personal data are only kept in a form allowing identification for a period that does not exceed the duration necessary for the purposes for which they are collected and processed.

For the processing of data on its own behalf in connection with the use of its website, LIVE DATA SOLUTIONS stores the data for the time necessary to achieve the intended purpose or until the exercise of the right of opposition.

As such, the data is kept by LIVE DATA SOLUTIONS for the duration indicated by its Partners.

In the absence of instructions received from the latter, LIVE DATA SOLUTIONS has established strict rules respecting the rights and freedoms of individuals and therefore, any individual whose last contact or transaction with a partner dates back more than 3 years will not be kept by LIVE DATA SOLUTIONS.

In the case of processing involving the provision of LIVE DATA SOLUTIONS of its Customers' data, the data is destroyed according to the customer's instructions.

IV. DATA PROTECTION MEASURE

To do this, LIVE DATA SOLUTIONS has defined a strict policy of security and confidentiality of personal data.

LIVE DATA SOLUTIONS staff with access to data are regularly made aware of the security of personal data and more generally of IT security.

Thus, user authentication, authorization management and workstation security follow strict rules.

An IT charter signed by all staff includes all these points.

The protection of the information system is our priority. The data is stored on our servers at OVH, 2 Rue Kellermann, 59100 Roubaix, France.

Our infrastructure is managed by our administrators who master all the security conditions ensuring total control of the data entrusted to us. Regular maintenance operations are carried out and we have a backup system.

The physical security of the premises is ensured by remote monitoring devices and the data is kept in a secure environment with restricted access.

All our data transfers are made via secure protocols such as HTTPS, SFTP or CFT. These protocols ensure data encryption and for CFT, additional compression.

In the event of a data breach, a procedure has been put in place to notify our Partners as soon as possible and to document the elements necessary to inform the supervisory authority if necessary.

In April 2019, LIVE DATA SOLUTIONS is one of the first companies to obtain the Privacy Protection Pact label, which confirms its commitment to the respect and security of personal data. Click here to learn more.

LIVE DATA SOLUTIONS also holds a CYBERVADIS certification in order to guarantee data privacy and integrity to it's clients.