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PRIVACY POLICY

- PERSONAL DATA AND COOKIES

1. INTRODUCTION

In the course of its commercial activity as a publisher of daily newspapers and magazines on digital media, and its related commercial activities, the Mandatory.gg Publishing Company may process information about you. For example, by filling in a subscription form, by making a purchase on our online shop, by contacting our Customer Service, by registering for an event we are organising, by taking part in a competition, by browsing our websites or our mobile and digital applications, by clicking on an advertising link that we present to you, you are transmitting information to us, some of which is of a nature to identify you ("personal data").

This Privacy Policy informs you about how we collect and process your personal data. Please read it carefully.

 

Important

 

We only use your personal data in the cases provided for by the regulations in force:

  • the performance of a contract we have entered into with you, and/or
  •  Compliance with a legal obligation, and/or
  •  Your consent to the use of your data, and/or
  •  The existence of a legitimate interest to use your data. The legitimate interest is a set of commercial or business reasons that justifies the use of your data by the Mandatory.gg Publisher.

For the publisher of Mandatory.gg, this legitimate interest is mainly, in a context of change in the media offering in France and in mandatory.gg, to maintain the level of commercial revenue necessary to preserve its independence as a press organisation, to finance the production of quality editorial content offered to its readers, to maintain the free availability of certain content on its sites and applications or the existence of subscription offers at a preferential rate for certain categories of subscribers.

We believe that this legitimate commercial interest is part of a wider framework of maintaining a free and independent press, which is essential to freedom of expression and freedom of opinion in a democratic society.

By agreeing to receive marketing and advertising information from our publications and partners, you are helping to maintain the economic viability of our business as a newspaper publisher.

In any case, your individual rights will always take precedence over our legitimate interest, and we will never use your data for commercial purposes against your wishes.

If you have any questions about this document, you can contact the data protection officer at mandatory.gg.

2. WHO IS THE CONTROLLER OF THE PROCESSING OPERATIONS MENTIONED IN THIS DOCUMENT?

The person responsible for the processing mentioned in this document is the publishing company of Mandatory.gg named Z AGENCY, a company with a capital of 1000 €, whose registered office is located at 4 Rue Frédéric Passy 69100 VILLEURBANNE, registered in the Lyon Trade and Companies Register under number 834 475 808 and of which Mr Hugo Poiblanc, Chairman of the Management Board, is the legal representative.

The Data Protection Officer is Mr. Timothee Malossane.

3. WHAT DATA DO WE COLLECT ABOUT YOU AND UNDER WHAT CIRCUMSTANCES DO WE COLLECT IT?

3.1. Data that you transmit directly to us

 

During the various contacts we have with you, you may be asked to provide us with information about yourself. This information is collected in particular when you take out a subscription, create an account on our sites and applications, place an order on our online shops, or access any other offer or service.

 

These data include:

  • Name, first name, title, date of birth ;
  •  Postal address, e-mail address, telephone number ;
  •  Encrypted login and password used to identify you on our sites or applications;
  •  Encrypted information about your payment methods (in particular your credit card number);
  •  Choices in commercial prospecting ;
  •  Any other information you wish to share with us.

 

3.2. The data we collect during our commercial relationship

 

The data we collect in the course of our business relationship with you includes the following:

  • Information relating to the history of your commercial relationship with Mandatory.gg: subscriptions, orders for products and services, invoicing and payment where applicable;
  •  Your participation in promotional offers, competitions or events;
  •  Requests you have made to our customer service department or incidents you have reported to us, for example concerning the delivery of our products or the performance of our services;
  •  Information about your purchases of products and services from our partners.

 

3.3. The data we collect automatically

 

Each time you visit our websites and mobile applications, we collect information about your connection and navigation. Different technologies may be used to collect this data. We refer to them generically as "cookies".

 

- Data collected through cookies

 

A cookie is a text file deposited when you visit a website, mobile application or online advertisement and stored in a specific space on the hard drive of your computer or mobile device. Cookies are managed by your Internet browser or the mobile application you are using, and only the issuer of a cookie can decide whether to read or modify the information contained in it.

A cookie has a limited validity period. It is deposited and stored on your terminal in compliance with the applicable legislation and subject to the choices you have made and which you may modify at any time, under the conditions specified in article 9 below.

A cookie does not identify you personally. It allows its issuer to recognise your terminal and to collect a certain amount of information relating to the navigation carried out from this terminal.

Cookies have several functions, such as allowing you to navigate efficiently on a website or mobile application, remembering your choices, the goods and services you wish to purchase, and offering you relevant advertising content according to your interests expressed during your navigation. You can find more information about cookies on the following websites

The cookies deposited by the Mandatory.gg Publisher, subject to your choices, give us access to the following information:

  • Identifiers of the equipment you use (IP address of your computer, Android ID, Apple ID, etc.),
  •  Type of operating system used by your terminal (Microsoft Windows, Apple Os, Linux, Unix, BeOS, Android, iOS, etc.),
  •  Type and version of the browser software used by your terminal (Microsoft Internet Explorer, Apple Safari, Mozilla Firefox, Google Chrome, etc.),
  •  Dates and times of connection to our services,
  •  Address of the referring web page,
  •  Browsing data on our services, content viewed.

 

- Data collected through standard Internet technologies

 

We may also use standard Internet technologies such as scripts, pixels and redirects. Scripts (sometimes called tags), written in javascript, are programs that run in your browser or mobile application and perform various actions, such as sending information to our servers. Scripts are also capable of creating pixels. Pixels (sometimes called transparent GIFs, clear GIFs, or web bugs) are lines of code that display a graphic image (usually invisible) on a web page or in an email. Redirects make a web page available under multiple page addresses (URLs). When a browser opens a redirect URL, a page with a different URL is opened.

The purpose of these technologies is to enhance your experience on our sites and applications, including providing you with content tailored to your interests. For example, when a user clicks a share button on an article, a script creates a pixel that tracks the share. In this way, we are able to see the total number of shares of an article, and we can rank the most shared articles.

These technologies give us access to the following information, among others

  • Information about your use of our sites and applications;
  •  Information about the presence of cookies on your terminal, the time and date of a page view, and a description of the page where the web beacon is placed;
  •  Information on whether or not you read the e-mails we send you, on the clicks you make on the links contained in these e-mails.

Our websites and mobile applications may also include third-party scripts, pixels and redirects. These technologies allow third party service providers to collect certain information such as your browser type, and the web page that redirected you to our websites or mobile applications. These third party service providers process the information they collect for auditing, research, and reporting information about our sites and applications and the advertisements viewed on them. We do not share your personally identifiable information with these third parties in connection with their use of these technologies.

 

- Data from mobile devices

 

Some mobile devices, depending on the permissions you have granted to the mobile application and which you can change at any time (e.g. "notification" or "geolocation"), send information such as your phone model, operating system version, connectivity type, name and version of the application used.

This data, which is necessary for the proper functioning of the mobile applications we publish, is automatically processed by our servers and those of some of our partners (in particular AT Internet, SmartAdServer, HockeyApp, Google Analytics) in order to provide you with a service and advertisements adapted to the technical characteristics of your device and to measure the audience of our mobile applications.

In addition, if you have accepted this feature, we may identify the physical location of your device (geolocation), in particular to inform you about content or offers that we believe are relevant to your interests or to improve your experience on our mobile applications. In accordance with applicable law, geolocation features can be disabled at any time in the system settings of your device.

 

3.4. The data we assume

 

By combining the data we have about you with general, anonymous statistical information, we may be able to make assumptions about the content and services that might suit your tastes or uses.

Example: If, according to statistical data, a majority of people aged between 30 and 50, living in Paris and interested in Valorant news, are also interested in tierlists, and you are one of our Parisian subscribers, aged 42, who regularly consult the "Streams and videos" content on our site, we will assume that you are also interested in competitions and we will be able to show you an advertisement for a subscription video-on-demand service, specialised in e-sport competitions, when browsing through our site

 

3.5 Data on minors

 

In principle, our products and services are intended for people who have reached the age of majority and are capable of entering into contractual obligations.

Users who are minors must obtain the consent of their legal guardians prior to the communication of personal data concerning them.

For registration on our sites and for some of our online services (e.g. newsletter), the age of 16 is accepted.

An Internet user who is under 18 years of age at the time of publication or creation of an online account has a specific right to the deletion of data concerning him/her.

If you have any questions about this document, you can contact the data protection officer of mandatory.gg.

 

3.6. Third party data

 

Before you offer a subscription or any other product or service that we market to a third party, you must ensure that the person concerned agrees to their personal data, including postal details, being passed on to us.

 

3.7. Exclusion of any sensitive data

 

The mandatory.gg website does not collect any sensitive data about you. Sensitive data includes racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health data or sexual orientation. If such information is in any way communicated to mandatory.gg, it will be deleted.

 

4. FOR WHAT PURPOSES DO WE USE YOUR DATA?

This section tells you the main purposes for which we use the data mentioned in section 3.

 

4.1 Operations necessary for the provision of products or services

 

  • Consideration of your subscription to a contract for our publications and execution of this contract ;
  •  Acceptance and execution of your order for products or services;
  •  Management of subscriptions to our newsletters and/or e-mail alerts;
  •  Invoicing; collection of payments ;
  •  Delivery management and order tracking;
  •  Customer relations: a customer service department is available by post, telephone, e-mail or chat for any questions or complaints;
  •  Conducting satisfaction surveys;
  •  Sending information about changes or developments in our services;
  •  Management of unpaid bills and disputes ;
  •  Management of the exercise of your rights to your personal data, under the conditions set out in Article 9 ;
  •  Verification of compliance with applicable legislation, our contracts and general conditions of use.

 

4.2 Marketing and commercial prospecting operations relating to the publications, products and services of the mandatory.gg website

 

  • Postal standards, updating, enrichment and deduplication of your personal information in a dedicated database of the mandatory.gg website;
  •  Sending information about our press group, its publications and activities;
  •  Sending marketing, advertising and promotional offers relating to our products and services by post, mail, e-mail, mobile notifications, social networks or any other medium;
  •  Customised loyalty or business development actions;
  •  Setting up competitions or other promotional operations;
  •  Collection of customer reviews ;
  •  Development of business statistics.

 

4.3. Transactions related to commercial partnerships

 

  • Sharing, exchanging or renting files with commercial partners in compliance with the regulations in force and security requirements;
  •  Sending marketing, advertising and promotional messages about partners' products and services by post, mail, e-mail, mobile notifications, social networks or any other medium;
  •  Setting up competitions or other promotional or event-based operations with commercial partners.

 

4.4 Purposes associated with depositing cookies on your browser

 

- Operation and optimisation of navigation on our sites and applications

 

  • Adaptation of the presentation of our sites and applications to the display preferences of your terminal (language used, display resolution, operating system, etc.) during your visits, according to the hardware and software for viewing or reading that your terminal has;
  •  Storage of information relating to a form you have filled in on our site (registration or access to your account) or to products, services or information you have chosen on our site (service subscribed to, content consulted, purchase made, etc.);
  •  Automatic connection to reserved or personal areas of our site, such as your account, thanks to identifiers or data that you have previously entrusted to us;
  •  Provision of sharing tools on social networks;
  •  Management of our platforms and performance of internal technical operations in the context of problem solving, data analysis, testing, research, analysis, studies and surveys;
  •  Implementation of security measures ;
  •  Quality measures to ensure that our content is displayed on your device.

 

- Traffic and audience measurement

 

  • Establishment of statistics and volumes of frequentation and use of the various elements composing our site (sections and contents visited, path) in order to improve the interest and ergonomics of our services;
  •  Counting of the total number of advertisements displayed by us on our advertising spaces, classification and statistics;
  •  Audience analysis based on advertising campaign results;
  •  Determination of interests and behaviours ;
  •  Improved customer/user knowledge for personalisation purposes.

 

- Personalisation of advertisements on our sites and applications

 

  • To adapt the advertising spaces to the display preferences of your terminal (identification of advertisements, establishment of statistics and volumes of frequentation and use of the various elements making up our site: sections and contents visited, path) in order to improve the interest and ergonomics of our services;
  •  To adapt the advertisements displayed on your terminal while you are browsing our sites and applications to the technical characteristics of your terminal (1), to your web browsing and to the cookies you have previously accepted (2), to your centres of interest and uses (3), to the data you have previously communicated to us (4), and, where applicable, to the geographical location data of your terminal (5);
  •  Recognize you to display personalized ads on social networks;
  •  To measure the effectiveness of our advertising campaigns and service offerings.

 

- Personalisation of the reader's path

 

  • Customise some of the editorial content put forward to match the reader's supposed interests
  •  Personalise the products and services offered by mandatory.gg
  •  Measuring the effectiveness of our personalisation services
     

5. HOW LONG DO WE KEEP YOUR DATA?

Your personal data is retained for a period of time that is either legally required or proportionate to the purposes for which it was collected. Some retention periods are in the legitimate interest of mandatory.gg as specified in the introduction.

Retention periods vary depending on whether we have an ongoing contractual relationship with you (you are an active customer), whether we have had a contractual relationship with you in the past (you are an inactive customer) or whether we have never had such a relationship with you (you are a prospect). The data related to your navigation on our online services collected by the cookies that you have authorised has a specific retention period.

The table below shows the main periods of retention of your data.

In any event, we regularly review the information we hold. Where its retention is no longer justified by legal, commercial or customer account management requirements, or where you have exercised a right of amendment or deletion, we will securely delete it.

Data categoriesGoalsShelf life
Data on a prospect
Data setCreation and management of a file of prospects3 years from the date of collection of the data or the last contact from the prospect
Data on an active customer
Data setCustomer account managementThroughout the contractual relationship
Inactive customer data
Data relating to the execution of the contractManagement of customer account, orders, deliveries, invoicing, payments10 years after the end of the contract or the last contact from the inactive customer
Identification and contact data - Inactive customers Daily pressSending information on the evolution of our publication and our offers5 years after the end of the contract or the last contact from the inactive customer
Identification and contact data - Inactive customers Press

Magazines

Sending information on the evolution of our publications and offers5 years after the end of the contract or the last contact from the inactive customer

(10 years for surname, first name and postal address)

Identification data

- Digital subscribers

Sending information on the evolution of our publication and our offers5 years after the end of the contract or the last contact from the inactive customer
Identification and contact data - Newsletter subscribersSending information on the evolution of our publications and offers3 years from unsubscription or last contact by the customer
Identification and contact data - Web account registrantsSending information on the evolution of our publications and offers3 years from unsubscription or last contact by the customer
Identification and contact data - Mail order buyersSending information on the evolution of our publications and offers5 years after delivery of the product or the last contact from the inactive customer

(10 years for surname, first name and postal address)

Data generated by cookies
Data related to your navigation on our services

online

Operation and optimisation of services

Attendance measurements.

Personalization of content and advertising

13 months maximum
Assumed data
Data relating to your alleged uses and interestsSending information and offers that are supposed to match your interests and usesAnnual update

 

6. WHO MAY HAVE ACCESS TO THE DATA WE COLLECT?

6.1. Access to data within the mandatory.gg website

 

Some of your data may be accessed by

  • Employees in the subscription, customer relations, administration and accounting departments
    and controlling, IT and marketing & sales.
  •  Google Inc. is the advertising agency for the mandatory.gg website.

Access to your data is based on individual and limited access authorisations. Staff who have access to personal data are subject to a confidentiality obligation (by means of a nominal and personal confidentiality undertaking)

 

6.2. Data transmission

 

Some of your data may be accessed by

 

- Subcontractors

 

They provide services on our behalf, including

  • Managing your subscription
  •  Securing online payments and fighting fraud
  •  Carrying of publications
  •  Shipping of orders
  •  Handling telephone calls, sending postal or digital mail
  •  Customisation of content for websites and mobile applications
  •  Carrying out maintenance operations and technical developments
  •  Collection of customer reviews
  •  Provision of analytical solutions or audience measurement statistics

Access to your data by our subcontractors is based on signed contracts that specify their obligations to protect the security and confidentiality of the data.

 

- Social networking platforms

 

The use of social networks to interact with our sites and applications (in particular the "share" buttons on Facebook and Twitter) is likely to lead to exchanges of data between the mandatory.gg site and these social networks. For example, if you are connected to the Facebook social network and you visit a page on the site www.mandatory.ggFacebook may collect this information. Similarly, if you view an article on the www.mandatory.gg and you click on the "tweet" button, Twitter will collect this information. We therefore invite you to consult the personal data management policies of the various social networks to find out what they collect and process on your data.

 

- Our business partners

 

They promote products or services on their own behalf or on behalf of advertisers. Please note that if you choose to subscribe to our business partners' products or services and you allow them to access some of your information, including by logging into their sites or applications, their privacy policies and cookie deposits will be binding on you. We have no control over the collection or processing of your data by our business partners on their own platforms.

 

- Police, judicial or administrative authorities

 

Where we are legally obliged to do so or in order to safeguard the rights, property and safety of mandatory.gg.

7. IS YOUR DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION?

We store your personal data in the European Union. However, it is marginally possible that the data we collect when you use our platforms or services may be transferred to subcontractors or business partners located in other countries, some of which may have less protective data protection laws than those in the country where you reside. In the event of such a transfer, we will ensure that the processing is carried out in accordance with this privacy policy and is subject to the European Commission's standard contractual clauses which ensure an adequate level of protection for the privacy and fundamental rights of individuals.

8. HOW IS YOUR DATA PROTECTED?

As a data controller, we implement appropriate technical and organisational measures in accordance with applicable legal provisions to protect your personal data against alteration, accidental or unlawful loss, use, disclosure or unauthorised access, including

  • The appointment of a data protection officer ;
  •  The creation of a unit dedicated to the security of information systems;
  •  Raising awareness of the confidentiality requirements of our employees who have access to
    to your personal data;
  •  Securing access to our premises and IT platforms;
  •  The implementation of a general IT security policy for the company;
  •  Securing access, sharing and transfer of data;
  •  The high level of data protection requirements when selecting our subcontractors and partners.

9. WHAT ARE YOUR RIGHTS?

9.1. Your rights of access to your personal data

 

You have the right to access your personal data and to request that they be corrected, completed or updated. You may also request the deletion of your data or object to their processing, provided that you have a legitimate reason.

You may request to exercise your right to data portability, i.e. the right to receive the personal data you have provided to us in a structured, commonly used format and the right to transmit this data to another controller.

Finally, you can formulate directives concerning the conservation, deletion and communication of your personal data after your death.

You can exercise your rights by contacting the mandatory.gg site's personal data protection officer at the following address ZAGENCY Mandatory.gg, 26 rue Emile Decorps, 69100 Villeurbanne or by email: [email protected]

Before responding to your request, we may verify your identity and/or ask you to provide further information to respond to your request. We will endeavour to respond to your request within a reasonable time and in any event within the time limits set by law.

In the event of an unsatisfactory response, you may lodge a complaint with the Commission nationale de l'informatique et des libertés (CNIL): https://www.cnil.fr/fr/plaintes

 

9.2. Your rights to object to commercial solicitations

 

We may use your contact information for marketing purposes in accordance with applicable law and the terms of this Privacy Policy. You may object to such solicitations at any time, depending on the communication channel we use to send them to you.

 

- Commercial solicitations by electronic means (e-mail and SMS) :

 

We respect the rules of article L.34-5 of the French Post and Electronic Communications Code, which provides for the prior and express collection of your consent for the sending of commercial prospecting by electronic means (e-mail, push notifications or SMS).

Thus, on the forms you fill out when you subscribe to one of our products or services, when you create an account on our sites or applications, or on the occasion of any other contact with us, you are expressly asked for your consent:

  • to receive offers from mandatory.gg
  •  to receive offers from partners of the mandatory.gg website

Exception: Your express prior consent is not required if you are already a customer of mandatory.gg and the purpose of our solicitation is to offer you products or services similar to those we already provide.

In any case, you always have the possibility to object to the receipt of such solicitations by taking the following actions:

  • For e-mail, by clicking on the unsubscribe link provided in each e-mail, by going to your online account or by contacting our customer service.
  •  For the sms, by sending a STOP SMS to the number indicated in it or by contacting our customer service.

 

- Commercial solicitations on mobile applications

 

When you first open the mobile applications of the mandatory.gg website on your smartphone or tablet, you can give permission to receive mobile notifications or "push" notifications. These notifications allow us to communicate editorial content to you (news alerts, content highlighted by the editorial staff), and may, from time to time, be used for commercial offers. You can deactivate these notifications at any time in the settings of your smartphone.

 

- Commercial telephone solicitations

 

We may contact you by telephone to offer you products or services. If you do not wish to be contacted, you can register on the telephone marketing opposition list accessible on the website www.bloctel.gouv.fr

However, telephone canvassing, including of persons registered on the do not call list, is permitted by law when the purpose is to supply newspapers, periodicals or magazines.

 

- Solicitations by any other means

 

We invite you to contact our customer service department to inform them that you do not wish to be the subject of these solicitations.

 

9.3. Your rights to accept and manage cookies

 

The registration of a cookie on your navigation terminal is subject to your wishes. You can modify your choices regarding the acceptance or refusal of cookies placed on your terminal at any time, either on your browser or online with various operators.

In order to manage cookies in the way you want, we invite you to configure your browser according to the purpose of the cookies.

How to exercise your choices?

 

Make your choices on your browser

 

You can set your browser software either to offer you the option of accepting or refusing cookies from time to time, before a cookie is likely to be saved, or to systematically accept or refuse the saving of cookies in your terminal.

We would like to warn you that any setting on your browser software concerning the refusal of technical and functional cookies may alter your browsing comfort on our websites, or even prevent the use of some of our services requiring the use of these same cookies.

If necessary, we decline all responsibility for the consequences linked to the degraded functioning of our Internet sites and our services resulting from the impossibility for us to record or consult the cookies necessary for their functioning and which you would have refused or deleted.

Each browser has a different configuration for managing cookies and your choices. This is described in the help menu of your browser, which will tell you how to change your cookie preferences.

 

Adobe Flash Player Flash Cookies

 

Adobe Flash Player is a computer application that allows the rapid development of dynamic content using the Flash computer language. Flash (and applications of the same type) memorises the settings, preferences and use of this content using a technology similar to cookies. However, Adobe Flash Player manages this information and your choices through a different interface than that provided by your browser.

If your terminal is likely to view content developed with the Flash language, we invite you to access your Flash cookie management tools directly from the site http://www.adobe.com/fr

 

"Do not track

 

You can also set your browser to send a code telling websites that you do not want to be tracked ("Do not track" option).

 

Make your choice online

 

For audience measurement and analytical cookies

 

Analytical cookies allow us to obtain anonymous statistics on the number of visitors to our site in order to optimise it and detect any malfunctions. They are placed on our sites and applications by the companies Google Analytics, ATInternet (XiTi), Amplitude, Chartbeat, Weborama, ACPM.

If you do not want our sites and services to store cookies in your browser for audience measurement purposes, you can click on the following links for further information:

 

For "Social Network" cookies

 

We use several sharing buttons on our site.

Deactivating these cookies therefore prevents any interaction with social networks.

 

For advertising cookies

 

We use the Doubleclick platform to manage advertising displays on our websites.

- To manage Doubleclick's cookies https ://www.google.com/settings/u/0/ads/authenticated

We also use the Outbrain platform to offer articles based on popularity and your interests as well as sponsored articles.

- For more information on interest-based targeting

http://www.youronlinechoices.com/fr/a-propos-de-la-publicite-comportementale/

- To disable this Outbrain targeting technology https://www.outbrain.com/legal/privacy#privacy-policy

You can also connect to the website http://youronlinechoices.comThe European Digital Advertising Alliance (EDAA) is a European association of digital advertising professionals and is managed in France by the Interactive Advertising Bureau France.

This European platform is shared by hundreds of Internet advertising professionals and constitutes a centralised interface allowing you to express your refusal or acceptance of the cookies used by these companies to adapt the advertisements likely to be displayed on your terminal to your navigation information:

http://www.youronlinechoices.com/fr/controler-ses-cookies/

Finally, some cookies are placed by third-party service providers for the purpose of personalised advertising. You can also click on the following links to learn more about their practices and exercise your choices:

 

For cookies that personalise the reader's experience

 

These cookies are set by our service providers:

 

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