TVTY.TV PRIVACY NOTICE
Update May 25, 2021
This privacy policy (the “Policy“) informs you about the processing of your personal data collected during your visit on our website https://tvty.tv (hereinafter the “Site“), as well as when you use our Moment Marketing Platform accessible at https://activate.tvty.tv (hereinafter the “Activate Platform”) or our TV to Web Platform accessible at https://measure.tvty.tv (hereinafter the “Measure Platform”). The Activate Platform and the Measure Platform are collectively referred to as the “Platforms”.
The Policy addresses the following topics:
- Data Controller
- Data Subjects
- Personal Data Collected
- Purposes and Legal Basis for the Processing of Your Personal Data
- Retention of Your Personal Data
- Recipients of Your Personal Data
- Transfers of Personal Data to Counntries Outside the European Union
- Your Rights
- Changes to This Policy
1. Data Controller
TVTY SA (“TVTY”), whose registered office is located at 81, rue Réaumur, 75002 Paris, France, is the data controller for the processing of your personal data described in this Policy.
TVTY has appointed a data protection officer, 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
TVTY processes your personal data as described in this Policy if you are a visitor of the Site and/or when you use our Platforms.
3. Personal Data Collected
3.1. We collect and process the personal data you provide to us when you contact us from the Site as well as when you create and manage your account on the Platforms.
The categories of personal data we collect and process include:
- Information about your identity, including for example: Name, surname, contact information and the name of the company for which you work.
- Login information necessary for accessing the Platforms, i.e., your password.
When you fill out a form on the Site or the Platforms, 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.
3.2. You may also decide to include personal data within the free text areas that you fill in (e.g., in the textbox “Please specify how we can help you” of our contact form). 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. Purposes and Legal Basis for the Processing of Your Personal Data
We collect your personal data for the following purposes, and we rely on the following legal basis:
| Purposes | Legal basis |
|---|---|
|
Process your requests when you contact us from the Site. |
Your prior consent |
|
Send you commercial communications by emails about our company and the solutions we offer, if you choose to receive these communications from the contact form on our Site. |
|
|
Create and maintain your account on the Platforms. |
The performance of your contract with us or one of our affiliates. |
5. Retention Periods of Your Personal Data
5.1. TVTY 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:
| Purposes | Retention Periods |
|---|---|
|
Data processed for the purpose of processing your requests when you contact us from the Site. |
3 years from the date of collection or last contact from you. |
|
Data processed for the purpose of sending you commercial emails about our company and the solutions we offer. |
|
|
Data processed for the purpose of creating and maintaining your account on the Platforms. |
3 years from the end of your commercial relationship with us or one of our affiliates. |
5.2. 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.
5.3 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 TVTY who need access to it in the course of their work;
- Authorized staff member of TVTY’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 Site which concerns one of the solutions offered by one of our affiliates;
- TVTY’s processors acting on our behalf and in accordance with our instructions: these processors include the hosting services providers for the Site and the Platforms.
- 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@tvty.tv.
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 defence 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 verifications;
- 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 TVTY’s processing of your personal data, by contacting TVTY’s Data Protection Officer at dpo@tvty.tv. You can also send a letter to TVTY at the address mentioned in Article 1. In order to facilitate the processing of your request, we invite you to specify in the subject line of your message or letter “Exercise of my personal data rights”.
You also have the right to file a complaint with the competent supervisory authority.
9. Changes to This Policy
TVTY may change this Policy from time to time.
We will ensure that you are informed of these changes.
In any case, we invite you to consult our Policy regularly.