DATA PROTECTION POLICY
Last update on 25th April 2019
- Definitions and parameter
- Identity and particulars of processing controller and data protection delegate
- How do we collect your Personal Data?
- What information do we collect?
- Why do we collect your Data?
- How long is your Personal Data kept?
- Who has access to your Personal Data?
- Your choices concerning the personalization of the contents, targeted advertising and prospecting by email
- Transfer of your Personal Data
- Your rights
The Data Protection Policy is designed to inform you about the policy of APPLEHEADLINES.COM in terms of the protection of personal data and all rights relative to personal data protection that are extended to you.
In using our Services, Websites and/or Apps, you confirm that you accept the terms of this Data Protection Policy. If you disagree with one of these terms, you are entitled to no longer use our Services, Websites and/or Apps.
1.Definitions and parameter
“Application”: refers to the public online communication service(s) produced by the companies of the APPLEHEADLINES Group, accessible to a User via the interface previously downloaded from the Android Play Store® and/or Apple App Store®. The App(s) provide access to the Service(s).
“User Account»: refers to a space reserved for the User which is accessible after enrollment to our Services using a login (email address) and a confidential password and allowing in particular (i) access to some of the Contents contained in the Services and/or (ii) participation in games and competitions and/or (iii) participation in an Expert’s Club test and/or (iv) taking advantage of other functionalities reserved for enrolled members.
“Cookie(s)” refers to all the non-executable text files, tracers, web tags and other technologies such as transparent GIFs, clear GIFs or web-bugs, stored on the device browser (computer, tablet, smartphone, etc.) by, Sub-Contractors or Partners, after consent has been given by the User, when browsing around the Services via the Websites and/or Apps. The information contained in this file can only be read and/or modified by its issuer.
“Browsing Data”: refers to any data concerning a device at a given time, even if we do not know directly what device you are using or who you are at a given moment. The following data can be collected as Browsing Data:
- The identification and content of a Cookie file stored by us or by Partners on your device;
- The IP address of device connected to the Service(s).
- The date, time and duration of the connection of a device to a Service component or components.
- The Internet address of the origin page of the device gaining access to the Service(s).
- The type of operating system used by the device (e.g.: Windows, MacOs, Linux, Unix, BeOS, etc.) ;
- The type and version of the browser software used by the device (Internet Explorer, Firefox, Safari, Chrome, Operator, etc.);
- Possible errors in downloading;
- The navigation software user language used by the device;
“Personal Data”: refers to any information concerning a physical person who is identified or identifiable, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, an online login etc. As far as our Services are concerned, “Personal Data” refers to all the data referring to you alone at a given moment, whatever device you may be using.
“APPLEHEADLINES Group”: refers to the APPLEHEADLINES company and all the countries under direct or indirect control of APPLEHEADLINES under the terms of article L233-3 of the Code of Commerce.
“Appleheadlines”: refers to the Appleheadlines.com company.
“Partner(s)”: refers to any company other than a Sub-Contractor selected by one of the companies in the Group with which it has drawn up a contract governing the provision and protection of Personal Data.
“Service(s)”: refers to any public online communication service and/or content made available by APPLEHEADLINES.COM.
“Website(s)”: refers to the public online communication service(s) produced by the APPLEHEADLINES.COM and accessible to a User via their connection device and located at the URL address(s) mentioned above and/or any other address which might be added to them or replace them. The Website(s) provide access to the Service(s).
“Sub-Contractor(s)”: refers to any company which might process Personal Data or Navigation Data for one of the companies in the APPLEHEADLINES.COM in compliance with the instructions given by it or them.
“User”: refers to any physical person aged sixteen (16) years or more, gaining access to the Services, Website and/or Apps, on a non-business and non-commercial basis.
The Data Protection Policy applies to any User of the following Services:
APPLEHEADLINES.COM, accessible at the following URL: https://www.appleheadlines.com/
The Data Protection Policy does not apply to the websites of our Partners, or to the methods used by third-party companies with respect to the APPLEHEADLINES.COM and for which the APPLEHEADLINES.COM has no controlling rights.
2.Identity and particulars of controller and data protection delegate
2.1 Identity and particulars of the controller
– Apple headlines, Ahmedabad- Gujarat
2.2 Particulars of data protection officer
The data protection officer for the company can be reached at appleheadlines.com.
3. How do we collect your Personal Data?
We collect and process your Personal Data, with your consent, to execute the contract drawn up with you (acceptance of the General Conditions of Use of our Services) and based on our legitimate interests.
When the User Account is created, or when you subscribe to some of the services available on our Website and/or the Apps (such as promotional games, enrollment for a newsletter etc.), you are informed by an information message that we will be gathering personal data and processing it.
In addition, you consent to as collecting and processing your Personal Data under the terms specified below when you accept this Data Protection Policy, accessible through the Personal Data collection form.
4. What information do we collect?
The Personal Data collected directly from you
Among the Personal Data collected directly from you when you enroll or use our Services, the following might be included:
Name, first name, sex, email address, postal code, age;
Username(s), pseudonym(s) and password(s);
Information concerning the means of payment (such as the number of your bank card) for the Services concerned;
Interests and preferences in terms of business prospecting;
Participation date(s) and response(s) given during participation in a promotional game;
Comments or opinions about our Services, Websites and/or Apps;
Personal Data gathered indirectly:
We can also gather Personal Data indirectly from third parties, in particular when a proposition is made for you to create a User Account, by linking to your Facebook account.
When you request connection, using third-party social network logins (Facebook), some of the Personal Data you have supplied to these social networks may be passed on by third-party service producers, under the general conditions of use of the social network concerned. This Personal Data can be, but not limited to, your name, first name, email address, postal address, your “Like” responses etc. When you connect to your User Account, you are free to refer to them and set up restrictions regarding the transmission of Personal Data concerning you.
We agree to comply with the confidentiality rules that you defined when you enrolled with third-party social networks and that you can change on them at any time.
The Personal Data you supply to us, through your third-party social network (Facebook) logins when you create a User Account is not passed on to the producers of these third-party services.
5.Why do we collect your Data?
The Personal Data we collect directly from you, especially when you create a User Account or use our Services, may be used for the following purposes:
Creating and managing your User Account, giving you access to the contents of the Websites and Apps, enabling you to benefit from our Services (enrollment for a newsletter, a promotional game etc.) to which you have subscribed;
Performing management operations concerning the order and delivery of contents, invoicing and following up this customer relation (for the Services concerned, that is: APPLEHEADLINES.COM);
Detecting any acts as part of our paid Services identified as possibly being fraudulent;
In accordance with the legal dispositions in force, with your consent and when required by the legislation, sending you:
- Marketing, advertising and promotional messages about our Services, Websites and/or Apps, or those of our Partners to which we may have forwarded Personal Data concerning you;
- Informing you about the use, current affairs, developments of our Services, Websites and/or Apps;
- Suggesting to you and advising you on contents, products or services that you might find interesting, using the data in your User Profiles.
The Browsing Data we collect during the use of our Services can be processed for the following purposes:
Generally speaking, permitting you to navigate and consult our Websites and/or Apps, adapting the content or display of our Services to your device to improve your navigation, and optimizing our Websites and/or Apps;
Memorizing information concerning a form you have already filled out (e.g.: your User Account) or concerning products, services or information from our Services (e.g.: consulted contents, etc.).
Personalizing our contents and advertising to suit your centers of interests;
Compiling statistics and make audience measurements on the attendance of our Websites and/or Apps;
Enabling you to share via the social networks;
Accessing the efficiency of the advertising messages we send you;
Ensuring the security of our Services, Websites and/or Apps by detecting/tracing back any attempt at a malicious act, IT intrusion or violation of the General Conditions of Use (GCU).
Fulfilling our legal obligations, responding to any requests made by third parties authorized by law, asking us to supply Browsing and/or Personal Data about the Users of our Services.
6. How long is your Personal Data kept?
6.1. Except for the Personal Data categories referred to in articles 6.2 to 6.4, your Personal Data will be preserved for the following times:
One (1) year after the closing of your User Account or the end of our business relations where applicable;
Three (3) years after the last time you use our Services, Websites and/or Apps, if you have not closed your User Account (inactive account);
6.2. Any identity documents you supply to us with respect to the exercising of your rights are kept for a period of one (1) year after your request.
6.4. Browsing Data is kept for thirteen (13) months starting from the date of collection.
7. Who has access to your Personal Data?
The following may have access to your Personal Data:
The Service producer, being in charge of processing for the Services; the other entities of the appleheadlines.com Group as third-party data recipients; appleheadlines.com as joint controller ;
Within the APPLEHEADLINES.COM AND Group companies, only some of our partners have access to your Personal Data, solely as required, and under a strict obligation of confidentiality.
The Sub-Contractors we use regarding technical services, payment, analytical solutions etc.
The Partners, that is advertisers, data brokers and any other recipients who have a contract with the APPLEHEADLINES Group entity concerned covering the provision of data or an agreement concerning data protection.
Third parties, in some cases regarding legal matters in particular by legal and/or administrative authorities, your Internet access provider.
8. Your choices concerning the personalization of the contents, targeted advertising and prospecting by email
8.1 Personalised User experience
We inform you that your Personal Data may be put through two types of processing operations:
combining with Browsing Data or other relevant information held by the APPLEHEADLINES.COM and Group, strictly necessary for completing the processing issues concerning you;
Profiling, for personalisation/recommendation of contents and targeted advertising. On this subject, we inform you that we analyse the data you supplied to us or that you generate in using our different Services, to construct profiles (segments) corresponding to your centres of interest.
As prerequisites for implementing the personalisation/recommendation of contents, all these operations are needed for executing the contract drawn up with you, aimed at giving you a personalised experience.
In addition, it is in our legitimate interests to perform these operations because they also enable us to send you advertising, as a function of your profile and your centers of interests that we have identified. Targeted advertising is a major source of financing for all our Services, such as APPLEHEADLINES.COM.
When an advertiser attempts to contact a specific public target, we can create audience segments (profiles), like groups of people in a particular age group (for instance, 16-34-year-olds) or a group of people having a particular interest (for instance, chocolate lovers). But these segments are not shared with the advertiser in any way allowing individuals to be identified directly. We also inform our advertisers how many people in a targeted public have seen their specific advertising and we may supply them with your IP address so that they can check that the number of hits is correct. This enables advertisers to see how efficient their advertising really is. After drawing up a contract relating to the provision of the data concerned, we can also share your Browsing Data and your “pseudonymised” Personal Data to help them better target their advertising on our services. “Pseudonymisation” means that the relevant Personal Data is converted into a coded version so that it can no longer be attributed to a specific person concerned, without recourse to additional information. For instance, we are liable to create logins to temporary advertisers for our users, that we share with the advertisers so that they can limit the number of times you see a specific advertisement. However, the advertisers have no way of identifying you directly from these logins (ID).
At any time, you can oppose the profiling of your Personal Data for targeted advertising by:
Going to your User Account (If Available), “My Account” section then “Authorisation” and checking the following box: “I no longer want my data to be collected and processed for the purpose of targeted advertising profiling”.
Sending your request to us by email to appleheadlines’s Contact form .
If you are opposed to the profiling all your Personal Data, we inform you that you will continue to receive advertising but it will no longer be tailored to your profile and your centers of interests.
8.2 Email prospecting
When your User Account is created and/or during the use of some of the Services available on our Websites and/or in our Apps, you can choose to give us your consent by filling in your preferences regarding the email we sent you relative to:
APPLEHEADLINES.COM targeted offers
APPLEHEADLINES.COM Partner targeted offers;
If you have stated that you wish to receive direct prospecting messages by email from the APPLEHEADLINES.COM or its Partners, you can withdraw your consent at any time:
by unchecking the corresponding box (boxes) in your User Account, “My Account” section then “Authorisations” or;
by clicking on the de-enrollment hypertext link supplied in each of our messages or;
by sending your request to us by Contact to appleheadlines.com
We inform you that it is in our legitimate interests, to send you our email in the following cases:
Information about and communication of substantial updates to the General Conditions of Use of our Services and/or the Data Protection Policy;
Transmission of newsletters to which you have subscribed or of other email concerning similar product and/or service to those we have supplied to you via our Services, Websites and/or Apps. In this case, you can state your opposition to receiving these solicitations:
- By checking the corresponding box (boxes) in your User Account, “My Account” section then “Authorisations” or;
- By clicking on the deenrollment hypertext link supplied in each of our messages or;
- By sending your request to us by appleheadlines.com
9.Transfer of your Personal Data
We inform you that your connection and localizing data might be forwarded to the United States to supply money-related and decision-making services related to video advertising. Our Sub-Contractor adheres to the “Privacy Shield” agreement between the United States and the European Union, covering transatlantic transfers of personal data, and complies with the standard contractual clauses of the European Commission.
You may apply your rights:
From your User Account(If you Have), in the “My Account” section then “Edit My Info” where applicable or,
By writing to the address: appleheadlines.com;
10.2. Justifying documents
Your request for exercising one of your rights must be accompanied by a copy of an identity document bearing the signature of the holder. Your request must also specify the address to which the response shall be sent.
To be able to identify your User Account, please indicate the email address you used to create your User Account.
We will then have a period of one (1) month after the reception of the request to answer you. This time may be extended by two (2) months, depending on the complexity and number of requests.
These rights are not absolute: you must use them within the framework of the law and within the limits of these rights. In some cases, we will be unable to give a favorable answer to your request (legal obligation, compliance with our commitments regarding new, etc.). If such is the case, we will inform you of the reason or reasons for this refusal.
10.3. Rights of access, correction or erasure
As the creator of a User Account, you may access the Personal Data that we have collected directly from you to correct, complete or erase any inaccurate information by:
Connecting directly to your User Account, “Edit my info” section: change the inaccurate/incomplete information then save the modifications;
Contacting us directly at the email and/or postal address (addresses) indicated above.
You may decide to close your User Account at any time, by connecting to it in the “Edit my info” section: “If you would like to close your account click here.”.
You have the right to erase your Personal Data when:
It is no longer necessary with respect to the purposes for which it was collected or processed; or
You have withdrawn your consent for this processing of your Personal Data and there is no other legal basis for processing; or
You are against this processing and there is no essential legitimate reason to justify such processing; or
The Personal Data must be erased to comply with a legal obligation, as stipulated by the legislation of the European Union or the Member States to which the APPLEHEADLINES Group adheres; or
The Personal Data has been collected as part of the supply of Services that you have subscribed to.
10.4. Right to limiting processing
You have the right to demand the limiting of processing when any of the following conditions applies:
You consider the Personal Data to be inexact; or
The processing is illegal and you are against the erasure of your Personal Data and request rather the limiting of its use; or
APPLEHEADLINES note longer needs the Personal Data for processing purposes but it is required by you to establish, exercise or defend your rights; or
You are opposed to the processing and to any checking needed to find out whether the legitimate reasons of the APPLEHEADLINES.COm override yours.
10.5. Right to withdraw consent at any time
You can withdraw your consent at any time, under the conditions described in article 8.2 concerning the processing of your Personal Data, for purposes of the direct prospecting of products and/or services not related to those that we supplied to you through our Services, Websites and/or Apps.
10.6. Right of opposing the processing of your Personal Data
At any time, you can oppose the profiling of your Personal Data for targeted advertising by:
sending your request to us by appleheadlines.com.
If you wish to oppose the profiling of your Personal Data, please bear in mind that you will continue to receive advertising but that it will no longer be adjusted to your profile and your centres of interest.
10.7. Right to portability of your Personal Data
You are entitled to require the portability of your Personal Data, that is, to receive the Personal Data that you supplied to us, in a structured format, frequently used and legible by a computer, and to forward it to another party responsible for its processing.
To exercise your right to the portability of your Personal Data, please send us your request
10.8. Directives concerning the use of your Personal Data after your death
You are entitled to define the directives concerning the use of your Personal Data after your death.
To exercise this right, please send us an message to appleheadlines.com :
Concerning “Directives concerning the use of my Personal Data after my death”;
indicating the email address you used to create your User Accounts;
indicating the person or persons who may act on your behalf in the eventuality of your death, and any instructions that you wish us to follow.
If a User should die without leaving directions relative to the use to which his or her Personal Data should be put after death, the inheritors may request the closing of the User Account of the deceased party, by sending us an email message to appleheadlines.com