This privacy policy (the “policy“) informs you about the processing of your personal data collected during your visit on our website https://www.data-circle.eu (hereinafter the “Site“), as well as when you use our Medias Attribution Platform accessible at https://dashboard.data-circle.eu (hereinafter the “Platform”), as well as the Medias Attribution (https://edi5on.com) tag website (hereinafter the “Tag Website”). The Site and Tag Website are collectively referred as the "Sites"

The policy addresses the following topics:

1. Data Controller
2. Data Subjects
3. Personnal Data Collected
4. Purpose and Legal Basis for the Processing of Your Personal Data
5. Retention of Your Personal Data
6. Transfert of Personal Data to Countries Outside the European Union
7. Your Rights
8. Changes to this policy

1. Data Controller

Data Circle SAS (“Data Circle”), whose registered office is located at 9, rue des Colonnes, 75002 Paris, France, is the data controller for the processing of your personal data described in this policy.

Data Circle has appointed a data protection officer (DPO), whose contact details are set out in Section 8 “Your Rights” below.

Personal data means any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number or any element specifically relating to that person.

2. Data Subjects

Data Circle processes your personal data as described in this policy if you are a visitor of our Sites and / or a user of our Platform.

3. Personal Data Collected

We collect and process the personal data you provide to us when you contact us from the Sites as well as when you create and manage your account on the Platform.

The categories of personal data we collect and process include:

• Information about your identify, including for example: name, surname, contact information and the name of the company you work for
• Login information necessary for accessing the Platform, i.e. your password.

When you fill out a form on the Sites or the Platform, the required information is marked with an asterisk. This information is necessary for us to process your request and identify you. If you choose not to provide it, we will not be able to process your request.

You may also decide to include personal data within the free text areas that you fill in. We collect and process this data only to the extent necessary to process your request. You should not include personal data of third parties unless you have their prior consent.

4. Purpose and Legal Basis for the Processing of Your Personal Data

We collect your personal data for the following purposes, and we rely of the following legal basis:

5. Retention Periods of Your Personal Data

Data Circle retains your personal data for a limited period of time and in a secure manner. The period for which your personal data are retained by us depends on the purposes for which they were collected, as well as the legal and regulatory requirements with which we must comply.

Your personal data will be kept in our active database for no longer than the following periods:

The deletion of your personal data from our active database will be followed by an intermediate archiving period in order to meet our legal, accounting and fiscal obligations, and also to be able to manage any claims, within the limits of the applicable prescription periods.

The above retention periods do not prevent you from exercising your rights as detailed in Section 8 of the policy.

6. Recipients of Your Personal Data

Some of your personal data may be communicated, only to the extent necessary and permitted by the applicable regulations, to the following recipients:

• Authorized staff members of Data Circle who need access to it in the course of their work.
• Authorized staff member of Data Circle’s affiliates who need access to it in the course of their work, if you have a contractual relationship with one of our affiliates of if you submit a request from our Sites which concerns one of the solutions offered by one of our affiliates.
• Data Circle's processors acting on our behalf and in accordance with our instructions: these processors include the hosting services providers for the Sites and the Platform.
• In the cases provided for by law: the judicial authorities.
• The legal court officers (e.g., bailiffs) as well as our attorneys in case of litigation.

Finally, we inform you that mergers, demergers or sale of our assets may involve the sharing of documents containing personal data to certain third parties, as well as their review, for example in the context of due diligence operations. In the event of such an operation, we will put in place appropriate guarantees and security measures to ensure the confidentiality of your personal data.

7. Transfers of Personal Data to Countries Outside the European Union

If necessary, your personal data may be transferred to the United States by our service provider in charge of hosting the Site. These transfers are governed by the conclusion of transfer agreements, including the standard contractual transfer clauses published by the European Commission. A copy of these contracts can be obtained by sending an email to dpo@data-circle.eu

8. Your Rights

In accordance with the laws and regulations pertaining to the protection of personal data, you have the following rights:

• Access and rectification: you have the right to access your personal data free of charge and, if necessary, to request its rectification.
• Erasure: you may request the erasure of all or part of your personal data in the following cases:
  • When their processing is no longer necessary to the purposes for which they were collected or otherwise processed
  • When you exercise your right to object to the processing under the conditions indicated below;
  • Where the data has been unlawfully processed; or
  • When their erasure is required to comply with a legal obligation to which we are subject.
• Withdrawal of your consent: Where we process your personal data based on your prior consent, you have the right to withdraw it at any time and for the future.
• Objection: You may object, on grounds relating to your particular situation that you must communicate to us, to those processing of your personal data which rely on our legitimate interests. If you exercise this right, we will cease to carry out the concerned processing, unless (i) there are compelling legitimate grounds for the processing which override your interests and rights and freedoms, or (ii) for the establishment, exercise or defense of legal claims. You also have the right to object to the processing of your personal data for direct marketing purposes.
• Restriction: you may request the restriction of the processing of your personal data in the following cases:
  • When you contest the accuracy of your personal data – for a period of time that enable us to make the necessary verification;
  • When the processing is unlawful but you oppose the erasure of the data and request instead the restriction of their use;
  • When the processing is no longer necessary for us but you wish us to keep the data for the establishment, exercise or defense of legal claims;
  • When you exercise your right to object – for the period of time necessary to verify whether we have compelling legitimate grounds for continuing the processing.
• Portability: You may request portability of personal data processed on the basis of your prior consent or the performance of your contract.

You may exercise these rights at any time, or ask any other questions regarding Data Circle’s processing of your personal data, by contacting Data Circle’s Data Protection Officer at dpo@data-circle.eu.

You also have the right to file a complaint with the competent supervisory authority.

9. Changes to this policy

Data Circle may change this policy from time to time. We will ensure that you are informed of these changes. In any cases, we invite you to consult our Policy regularly.