Personal Data Protection Policy
Kontiki Media ltd is an international company operating in the field of digital marketing and specialized in audience monetization. Its main activity is the generation of qualified leads and the marketing to Advertisers of the right to use databases for commercial prospecting purposes.
By accessing one of the sites published by the company Kontiki Media ltd and using the services offered, the User acknowledges having read and understood this General Policy on the protection of personal data, as well as the practices of collection of consent, collection and processing of the information described in this document.
Kontiki Media ltd undertakes to comply with all legal obligations regarding the protection of personal data, in particular by publicly committing itself to comply with the General Data Protection Regulations and the Data Protection Act Regulation (EU) 2016/679, known as the General Data Protection Regulation ("GDPR") and the Law No. 78-17 of 6 January 1978 relating to data, files and freedoms, as amended by law 2018-493 of June 20, 2018 ("Data Protection Act and Freedoms").
In accordance with the Data Protection Act, and the General Data Protection Regulation, Kontiki Media ltd undertakes to:
- treat only fair and lawfully collected data;
- treat the collected data only for specified, explicit and legitimate purposes;
- treat only relevant and relevant data that are not excessive in relation to the purpose of the processing;
- take all necessary precautions to preserve the security of the data, in particular to prevent them from being deformed, altered, damaged;
- not to communicate this data to third parties outside the company without informing the persons.
2. Intellectual property of our site
Our site content, the general structure, the tree structure, the textual contents, the images and the logos of which the site is composed are the exclusive property of the company Kontiki Media ltd. Any representation, total or partial, of this site or its content, on any medium, for a collective or professional use, even internally in the company, by any process whatsoever, without the express prior written permission Kontiki Media ltd is prohibited and constitutes an infringement punishable by articles L.335-2 and following of the Code of the Intellectual Property, likewise the violation of these provisions submits the offender and all persons responsible to the penal and civil penalties envisaged by French law.
Contact information for the person in charge of treatments
Treatment Manager: Mrs. Stéphanie Boehm
Contact email: email@example.com
Subcontractor hosting the site and data
Registered Office: 14455 North Hayden Rd., Suite 219, Scottsdale, AZ, 85260, U.S.A.
3. Designation of a DPO-DPO at the CNIL
Kontiki Media ltd has appointed a Data Protection Officer.
Its mission is to ensure rigorously independent compliance with the law regulating the protection of personal data for our employees, our customers, our candidates as well as for all our suppliers and partners.
It ensures on an ongoing basis that every precaution has been taken to preserve the physical and logical security of the data of the people in order to prevent such things as being compromised, distorted or damaged.
Data Protection Officer
Designated legal person:
Cabinet Dézavelle-Livowsky and Associates
11 rue Théodule Ribot ~ 75017 Paris
The correspondent of the CNIL in charge of our compliance:
Mr Jean-Michel Livowsky
Data Protection Officer
4. Collection and Use of Collected Data
Personal data may be collected and / or processed by Kontiki Media ltd when you register for a contest or subscribe to an offer via one of the sites we publish or via the site of one of our partners .
5. Legal basis of our data processing
We are entitled to process your data only from the moment:
- where you explicitly give us permission by validating the box "I accept ..." (or any other similar mention) present on the form of collection of consent.Then, if we have a contractual relation, the processing will be legitimate and necessary in the follow-up of the latter, insofar as you are party to or associated with the execution of pre-contractual or contractual measures undertaken with us.
6. Purpose of the collection
The company Kontiki Media ltd uses the personal data entrusted to it directly by Users or indirectly by its partners exclusively:
- For the processing of requests for information sent via the website;
- To make contact by telephone or electronically (email) with the people who contacted him;
- To send you personalized offers according to your interests, directly or via our selected partners;
- To update our databases;
- For Kontiki Media ltd and / or its partners to send you newsletters to which you have subscribed;
- To meet our obligations arising from the GDPR and relating to the storage and deletion of data collected and processed.
7. Categories of data collected
We will never affect your privacy or your reputation regarding the personal information that you entrust us with any misuse, and more generally, from any act likely. Kontiki Media ltd may nevertheless indirectly collect information from you via its partners. In this case, the Kontiki Media ltd company makes sure with its partners that you have consented to such a collection being made.
Kontiki Media ltd is also careful to collect only data strictly necessary for the stated purpose of the various treatments implemented by the company.
As part of its commercial activities, the following data are collected from Users:
- Name; First name; Civility
- Birth date ;
- Email Address ;
- Postal code ;
- IP address, which is an identification number of a connected device to a network using the Internet protocol;
- TimeStamp, which allows to associate a date/ ime to a data/action on the connected device;
- Collection URL, which is the address of a site or an Internet page.
- The postal address.
8. Information about children
The Sites published by Kontiki Media ltd are intended for a major audience. Also, the company Kontiki Media ltd is not intended to collect data of children of 15 years. In the event that a 15-year-old child sends personal data to Kontiki Media ltd via the sites it publishes, Kontiki Media ltd will make every effort to ensure the deletion and / or destruction of the transmitted data.
9. Recipients of your data
Your personal data will not be transmitted to third parties, except for the sole purpose that you have accepted when collecting your consent.
(i) Internal to the company
The persons in charge of the processing of personal information are:
- the executive staff of Kontiki Media ltd;
- employees in charge of deliverability and database processing
(ii) External to the company
- Authorized third parties;
- Subcontractors for hosting data
- Subcontractors for the routing of newsletters
- In the context of its commercial relations with its partners.
Kontiki Media ltd may also disclose or transfer your personal data to third parties in the following particular circumstances:
- by law, in the context of legal proceedings, litigation and / or a request from public authorities in your country of residence or otherwise;
- disclosure is necessary for national security, law enforcement or other public purpose purposes;
- in the event of a restructuring, assignment, merger or sale, to the relevant third party.
10. Transfer of personal data outside the European Union
In the event that your Data is transferred outside the European Union, we make sure that:
- Personal data is transferred to countries recognized as offering an equivalent level of protection.
- Personal data is transferred to entities certified under the Privacy Shield
- For personal data transferred outside the countries recognized by the ICO as having a sufficient level of protection, we will use mechanisms ensuring appropriate safeguards as provided by the applicable regulations, and in particular the adoption standard contractual clauses.
11. Shelf life of your information
Kontiki Media ltd, in compliance with current legislation, will only retain the Personal Data of candidates and prospects for the duration necessary for the processing of projects, and a year at most.
The personal data of the customers will be kept in active base five years at the most, after the end of the contractual relation.
The data collected from the data subjects via the entries to the contests and / or the offers of the partners of the collection will be kept for 3 years in active base from the last recorded activity.
The data collected from the data subjects via their subscriptions to the newsletters to Kontiki Media ltd will be kept until the request for unsubscription of the persons concerned.
For employees, the texts have variable durations for the preservation of certain data. (Employment contracts, invoices, tax declarations, URSSAF, pension funds, etc.) without prejudice to the legal obligations of conservation or limitation periods.
12. Reminder of your rights defined by the GDPR
Under the provisions of Article 12 of the GDPR you have the right to obtain clear, concise and transparent information from our company. The purpose of this document is primarily to fulfill the obligations referred to in Article 13.
12.1 Right to be confirmed a treatment You have the right to obtain from the controller the confirmation that your personal data are or are not processed. (article 15-1 of the GDPR)
12.2 Access rights, purposes, categories, recipients, duration You have a right of access to the said personal data and the following information:
- the purposes of the treatment; (article 15-1a of the GDPR)
- the categories of personal data concerned; (article 15-1b of the GDPR)
- the recipients or categories of recipients to whom the personal data have been or will be communicated; (article 15-1c of the GDPR)
- when possible, the retention period of the personal data envisaged, or the criteria used to determine that duration; (article 15-1d of the GDPR)
- Correction, deletion-forgetting, limitation, opposition, portability
You are entitled to ask the controller:
- the correction of your personal data (article 16 of the GDPR)
- the whithdraw of your data or the "right to be forgotten" (article 17 of the GDPR)
- limitation of the processing of personal data (article 18 of the GDPR)
- the right to oppose the processing of your data; (article 21 of the GDPR)
- the right to recover your data in a format easily readable by a machine to ensure its portability; (article 20 of the GDPR)
12.3 ICO complaint, data origin, automated decision
You also have the right:
- to lodge a complaint with a supervisory authority; (article 15-1f of the GDPR)
- when personal data are not collected from you, any information available as to their source; (article 15-1g of the GDPR)
- to verify the existence of automated decision-making, including profiling, and in such cases, useful information regarding the underlying logic and the significance and expected consequences of such processing. (article 22 of the GDPR) (article 15-1h of the GDPR)
12.4 Right to know if your data is subject to cross-border flows
You have the right to be informed of the appropriate safeguards provided if your data is transferred to a third country outside the European Union. (article 15-2 of the GDPR)
12.5 Right to obtain a copy of your data
You have the right, by justifying your identity, to obtain from the data controller an electronic or paper copy of the personal data concerning you, being processed in our company or at any of our subcontractors. (provided that this request does not affect the rights and freedoms of others.) You can send any request to this effect to the Data Protection Officer referred to above. (article 15-3 & 4 of the GDPR)
12.6 Right to give instructions in case of death
You also have the right to give us instructions on the fate of your data after your death (Law No. 2016-1321 of October 7, 2016 for a Digital Republic)
12.7 Right to revoke a collection authorization previously given
You have the right to withdraw your consent at any time. The withdrawal of this consent does not compromise the lawfulness of consent-based treatment prior to such withdrawal.
You must be informed of this right before giving your consent. It must be as simple for you to withdraw your consent as it is to give it to us. (article 7-3 of the GDPR)
12.8 Right to lodge a complaint with a supervisory authority
You have the right to lodge a complaint with a supervisory authority in case you find a violation of your data or if you consider that the processing of your personal data constitutes any violation of the rules.
However, we suggest that you first contact the DPO designated above to request clarification.
12.9 Right to know the consequences of a refusal to provide information
You are informed that in accordance with Article 32 of the Data Protection Act, the information you provide us through the forms on the site are necessary to answer your request. You have the right to refuse to send us this information, but you are informed that in this case, the company Kontiki Media ltd may in turn refuse to respond to an incomplete request from you.
12.10 Right not to be the subject of an automated decision
You have the right not to be the subject of a decision based exclusively on automated processing, including profiling, producing legal effects concerning you. (art 22-1) Kontiki Media ltd does not carry out such data processing.
12.11 Right to require that your data be kept safe
Kontiki Media ltd ensures the security and durability of your Personal Data by implementing a series of physical and logical protections in the preservation and safeguarding of your data, to prevent them from being destroyed, corrupted modified, diverted, or altered.
13. Exercise of rights
You have the right to access and rectify or delete information about you. You may also, for legitimate reasons, oppose the processing of this data or request portability.
To exercise your different rights defined in § 12 hereof, you will have to prove your identity and optionally:
- tell us why you want to exercise them
- precisely define the perimeter of the data you want to copy
- specify the data format you want back
You will contact for this purpose the DPO responsible for monitoring our compliance. The partial opposition (or simple request for unsubscription) is a right that you can exercise through a link on each email you receive from us.
14. Cookies policy on the website
You are informed that during your visits to our site, a cookie may be installed automatically on your browser.
Our cookies are sets of data that will not identify you, but are intended primarily to record information about your browsing. The configuration of the settings of your browser software allows you to be informed of the presence of our cookie and you are entitled to refuse it.
15. Measures taken for the protection of personal data
Kontiki Media ltd has taken measures to prevent any personal data breach, including:
- Appointment of Data Protection Officer at Kontiki Media ltd
- Sensitization of the teams to the protection of personal data
- Security audit of the information system
- Implementation of a general data protection policy
16. Applicable law and jurisdiction
Our website and our activities are governed by French law. In case of dispute arising from the use of our websites or its activity, the French courts will be exclusively competent.
17. Amendment of this Data Protection Policy
Kontiki Media ltd reserves the right to modify at any time this Data Protection policy, for example to take into account new data collected, changes to our treatments or our purposes, but also to bring us into compliance. cases of changes to certain legislative and regulatory provisions, particularly with regard to the Data Protection Act, or the GDPR.