Privacy Policy (EU)

We, Adyoulike (“we”, “our” or “us”) are dedicated to protecting your privacy rights and attach particular importance to compliance with Regulation (EU) 2016/679 (GDPR) and French law no. 78-17 of January 6, 1978 on information technology, files, and civil liberties (“the French Data Protection Act”), which govern all data processing carried out by the company.

This privacy Policy (the “Policy” or the “Privacy Policy”) describes how we collect, store, use and disclose Personal Data regarding individuals who use, interact with, exposed to, and/or sign up to our Services, including visitors to our Websites and to our business partners, as applicable (“End User(s)” or “you”).

This Policy applies to all our websites (including without limitation https://www.adyoulike.com, or any other domain or subdomain owned and operated by us; collectively, the “Websites”), as well as to all Services provided by Adyoulike

This Policy also refers to any processing of Personal Data by us in the context of advertisements we serve on behalf of third-party companies (“Advertiser(s)”), through publishers’ assets or email providers (“Publisher(s)”), on such Publishers’ properties (“Properties”) via any of the abovementioned Adyoulike Services.

The Websites and any other features or Services described hereunder are collectively referred to as the “Services”.

Please read this Privacy Policy carefully and make sure that you fully understand it. By using any of the Services, you agree to the collection, use, storing and disclosure of your Personal Data as described in this Privacy Policy. You are not legally required to provide us with any Personal Data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your Personal Data, or to have it processed by us or any of our Service Providers (defined below), please avoid any interaction with us or use of our Services.

1. Types of Personal Data Collected, Legal Bases, Purposes, and Methods

Depending on your interaction with us, we may collect two types of data from you:

“Personal Data” or “Personal Information” (as defined under applicable US Privacy Laws) meaning individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual.

“Non-Personal Data” means aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Service. We are not aware of the identity of the End-User from which the Non-Personal Data is collected. Such Non-Personal Data may include aggregated usage information and technical information transmitted by your device, such as browser version, operating system type and version, mobile network information, device settings, and software data. We reserve the right to use, disclose, or transfer (for commercial or other purposes) aggregated Non-Personal Data to third parties for various purposes, including commercial use.

For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

Below are the details of the categories of Personal Data we collect, the methods and the purposes of such collection:

Account Information

If you choose to register an account with our Services, we collect your name, email address, company name and your phone number.

Contact Information

When you reach us through the “Contact Us” ou “Demo Request” forms on the Website, we collect the Personal Data you provide us. This includes your title (e.g., Mr/Ms/Mrs), full name, email address, company name, phone number and country of origin.

Technical Information

When you use our Services, we collect technical information about your interaction with our Services. Such information includes IP addresses, unique device identifiers as well as information regarding your interaction with our Services (collected through the use of cookies or other Tracking Technologies – please see Section 4 below).

We do not process Special Categories of Data as defined under the GDPR, or any other type of Personal Data of a sensitive nature as defined under any applicable law (e.g., Sensitive Personal Information under US Privacy Laws).

Why do we process your Personal Data?

This section explains for what purposes we use your Personal Data and outlines the legal bases that underlie our usage.

2. Categories of Recipients We Disclose Personal Data To; Purposes Disclosure

Adyoulike may disclose your Personal Data with third parties that help us maintain and provide our Services. More information about the categories of such third-party recipients is described below:

• Internal services of Adyoulike: We may share your Personal Data internally within the different services of Adyoulike , as necessary for administrative, management, legal or other business-relates purposes, as necessary to operate our Services, to communicate with you, to offer and provide our Services to you, etc.
• Service Providers: We disclose Personal Data to third parties that perform services on our behalf, such as hosting, storage, analytics, advertising and marketing, cyber and data security (collectively, “Service Providers”). We may also share such data with our business, legal and financial advisors.
• Business Partners: We may disclose Personal Data to Advertisers. We disclose Personal Data to Advertisers to either display advertisements on or through our Services or to manage our advertising on other websites or apps. Where applicable, we will only do so on the basis of End Users’ explicit consent which is obtained by our Publishers in the normal course of providing our Services to them. More information and options can be found on each of our Publishers’ respective Properties.
• Legal and Regulatory Entities: We may disclose your Personal Data when requested by legal or regulatory authorities in response to a verified request relating to terror acts, criminal investigations or similar illegal activity, or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose.
• Mergers and Acquisitions: We may use and disclose any of the Personal Data in connection with any merger, sale, transfer of any of our assets, investment, acquisition, bankruptcy, or similar event or any corporate transaction.

We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non-Personal Data to third parties for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.

When disclosing Personal Data to third parties, they are required to secure the Personal Data they receive and to use that Personal Data only in compliance with all applicable data protection regulations.

3. Cross Border Transfers of Personal Data

Adyoulike places the utmost importance on ensuring that your Personal Data is processed and stored within the EEA.

However, in the event of a transfer of Personal Data outside the EEA, this will only take place to countries which were recognized by the EU Commission as “Adequate Countries” or by using legally approved personal data transfer mechanisms, namely the Standard Contractual Clauses as approved by the European Commission.

4. Data Security

We work hard to protect the Personal Data we process from unauthorized access, alteration, disclosure, or destruction. We are using industry-standard physical, administrative and technical security measures to protect your Personal Data held with us, including by vendor security assessments, penetration testing, minimizing the amount of data that we store on our servers, restricting access to Personal Data by Adyoulike employees, contractors, agents, and encryption as appropriate.

5. Data Retention

In accordance with Article 5(1)(e) of the GDPR, your Personal Data will only be retained for a period not exceeding that necessary for the purposes set out in this Privacy Policy, including to provide you with our Services.

With regard more specifically to Personal Data processed in connection with our Advertising Services:

• We store your cookie ID (collected via the cookie we place on Publishers' websites) for a maximum of 30 days;
• Your IP address transmitted by Publishers is not stored by our Services

Personal Data linked to your account will be retained for up to 3 years from your last contact with us, then archived for the applicable legal limitation period or for the period necessary to comply with our legal obligations.

We may also retain and use Personal Data about you to the extent necessary to comply with our legal obligations, resolve disputes and enforce our terms and conditions, other applicable terms of Service, and our policies. If you stop using our Services, we may store your data in an aggregated and anonymized format, in which case, we may use this data for a longer period without further notice to you.

Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you. If you have any questions about our Data Retention Policy, please contact us by sending an email to rgpd@adyoulike.com.

6. Tracking Technologies

Our Services utilize “cookies”, anonymous identifiers, pixels and other technologies (collectively, “Tracking Technologies”). A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing it. You can find more information about cookies at https://www.allaboutcookies.org. Cookies and other Tracking Technologies help us provide our Services, secure and improve them, personalize your experience and monitor the performance of our activities and campaigns. We recommend the use of Tracking Technologies, but if you choose to remove or block them, we will respect your choice.

A list of the Tracking Technologies we use, information concerning our Advertisers, their policies as well as additional information about cookies, including our support of transparency and control initiatives and your opt-out options, can be found here. Additionally, you can use our cookie preferences tool at any time to adjust your cookie related choices. You may also object to their use by contacting us at the following address: rgpd@adyoulike.com.

7. Data Subject Rights

You have the following rights regarding your Personal Data that we process:

Right of access:

You have the right to receive confirmation as to whether or not Personal Data concerning you is being processed by us, and to access your Personal Data where applicable, in accordance with Article 15 of the GDPR.

Right of portability:

You have the right to request us to provide you with a copy of your Personal Data, where technically feasible, in order to dispose of it, in accordance with Article 20 of the GDPR. This right remains limited in that it applies only:

• to Personal Data that you have provided to us directly,
• whose processing is automated,
• whose processing is based on your consent or on a contract.

Right of rectification:

You have the right to request rectification of your Personal Data in our control in the event that your believe the Personal Data held by us is inaccurate, incomplete or outdated, in accordance with Article 16 of the GDPR;

Right of erasure:

You have the right to request that we erase or delete your Personal Data at any time; under the conditions set out in the texts in accordance with Article 17 of the GDPR.

However, we may refuse your request for erasure, in particular if:

• your Personal Data is necessary for exercising the right of freedom of expression and information,
• your Personal Data is necessary for archiving purposes in the public interest, for scientific or historical research purposes, or for statistical purposes,
• we are required by law to process your Personal Data,
• your Personal Data is necessary for the establishment, exercise, or defense of legal claims.

Right to restriction or objection to processing:

You have the right to request that we restrict or cease the processing of your Personal Data at any time in accordance with Article 18 of the GDPR;

Right to withdraw your consent:

To the extent we process Personal Data on the basis of your consent, you have the right to withdraw your consent at any time in accordance with Article 7 of the GDPR;

Right to define guidelines regarding the retention, deletion and communication of his or her personal data after his or her death.

You have the right to define guidelines regarding the storage, erasure, and communication of your Personal Data after your death, under the conditions provided for in Article 85 of the French Data Protection Act.

Exercising your rights:

• To exercise any of the rights listed above, you can contact us at the following email address: rgpd@adyoulike.com. • Please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your or your authorized agent’s identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with this Policy.
• If you think we have infringed data protection laws, you can file a complaint or claim with the French data protection authority (the Commission Nationale de l’Informatique et des Libertés (CNIL)) via the link https://www.cnil.fr/fr/plaintes or by post by writing to: CNIL Service des plaintes - 3 Place de Fontenoy, TSA 80715 - 75334 Paris Cedex 07, France

8. Indirect data collection - Sources of Information

In providing our Services, we collect Personal Data from the following categories of sources:

• Directly, through your activity on our Services: For example, from forms you complete on our Website.
• Indirectly, from third-parties sources: For example, from Publisher partners when we provide our Services to them and you interact with their Properties, and Service Providers who assist us in providing the Services to our customers, such as data analytics providers and fraud detection and prevention services.

9. Communications

We may contact you with important information regarding our Services. For example, we may notify you, through any of the means available to us, of changes or updates to our Services, password reset requests, security alerts, or any other messages necessary for the proper functioning of your account.

Subject to your prior consent, we may also send you “non-essential” communications relating to other updates about new features, offering, events and special opportunities, as well as information which relate to your interaction with the Service (likes, comments, etc.). If you do not wish to receive such “non-essential” communications, you may notify Adyoulike at any time:

• by changing your communications preferences in your account,
• by following the unsubscribe instructions (“unsubscribe”, “stop”, “opt-out” ou “change e-mail preferences”) contained in the “non-essential” communications you receive, or
• by sending an email to the following address: rgpd@adyoulike.com.

10. Additional Notes

Updates and Amendments: We may modify this Privacy Policy from time to time, in which case we will update the “Last updated” date at the top of this Privacy Policy, as well as notify you or take other steps as required by applicable law. The updated Privacy Policy will be effective as of the time of posting, or such later date as may be specified in the updated Privacy Policy.

Third Party Websites and Services: While our Services may contain links to other websites or Services, or may be offered via Properties, we are not responsible for their privacy practices, and encourage you to pay attention when you interact with any such website, Service or application of such third parties, and to read the privacy policies of each and every website, Service and application you interact with. This Privacy Policy applies only to our Services.

Please be advised that when you post links to/from YouTube, we make use of the YouTube API in order to support the preview of such content. Such activity is governed by YouTube TOS and Google Privacy Policy. We encourage you to review their practices carefully.

Children’s Privacy: Our Services are not intended for use by minors under the age of 16 (“Minors”). We do not knowingly collect Personal Data from Minors and do not wish to do so. If we learn that a Minor is using the Services, we will take the necessary steps to prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such Minor. If you believe that we might have any such data, please contact us by email at: rgpd@adyoulike.com.

11. Contact Us

Data Protection Officer (DPO): Adyoulike has appointed a Data Protection Officer for monitoring and advising on our ongoing privacy compliance, as well as serving as a point of contact on privacy matters for data subjects and supervisory authorities. Our DPO may be reached by email at rgpd@adyoulike.com, or by mail at: AdYoulike SASU (Attn: DPO), 145 avenue Charles de Gaulle (Bâtiment DESKEO), 92200 Neuilly-sur-Seine, France.

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