COOKIES POLICY

Trace Website Privacy Policy

The Trace Internet Site (hereafter “the Site“) is a showcase for all of the Trace group’s offers: television channels, radios, events, applications, mobile. Any person who accesses the Site (hereinafter “the User”) who wishes to benefit from the specific offers “Trace Play”, “Trace Mobile”, “Youtrace” and “Chat”, “Trace Content Distribution” is referred to dedicated sites. The Site also offers various articles focused on Afro-Urban culture. In addition, the Trace Website offers the User the opportunity to contact the professionals of the Trace group directly via the Site to submit one or more music videos, to make any request regarding the available advertising space of the Trace group and to respond to job offers or to make an unsolicited application. Finally, the Site offers the User to subscribe to the Trace group Newsletter in order to follow all the People, Music and Lifestyle news as well as new clips relating to Afro-Urban culture directly to the e-mail address he or she has provided. The Site is accessible through the following reception terminals: television, smartphone, digital tablet etc. In this respect, the Site is required to process information concerning the User. Indeed, by filling in his information to contact the professionals of the Trace group or to subscribe to the Newsletter, the User transmits information, some of which is of a nature to identify the User (“personal data“).

This Privacy Policy informs the User of the manner in which Trace Global collects and processes his personal data. We invite the User to read it carefully.

Data controller

The person responsible for the processing mentioned in this document is TRACE GLOBAL, a simplified joint stock company with a share capital of €1,204,000.00, registered with the Nanterre Trade and Companies Register under number 411 205 628, whose registered office is located at 73, rue Henri Barbusse 92110 Clichy, represented by Mr. Xavier SPENDER, its Managing Director, with power of attorney,

TRACE GLOBAL’s Data Protection Officer is Mr. Sven BALISSON.

Purpose of data processing

Trace Global uses the data it collects for :

– Fulfill its obligations towards the User when the User wishes to contact Trace Global,

– Send the Trace Group Newsletter when the User has subscribed to it or when the User has ticked the box “I wish to receive the Trace Newsletter”,

– Communicate with the User in order to help him/her in the event of a technical problem,

– Determine the general geographic location of the User, where the User has consented to this and thereby provide a service that is localized and tailored to the User’s needs,

– Communicate with the User (by e-mail, push notifications or instant messages) if the User has checked the box “I wish to receive commercial offers from Trace” in order to send him/her any special offers, promotional announcements, contests from the Trace group,

– Prevent, detect and investigate potentially prohibited or illegal activities, such as fraud, and enforce its terms and conditions of use.

– Analyze, improve and personalize its services and marketing activities in order to enable the User to benefit from the best possible customer experience in the event that the User has accepted all or part of the cookies.

Legal basis for the processing of your data

Trace Global collects and processes the User’s personal data only in the cases provided for by the regulations in force:

– The existence of a legitimate interest in using the User’s personal data. The legitimate interest is a set of commercial or business reasons that justifies the use of the User’s data by Trace Global (article 6.1, f) of the General Data Protection Regulations of April 27, 2016).

– The execution of the contract concluded between Trace Global and the User (article 6.1, b) of the General Data Protection Regulations of 27 April 2016),

– The consent given by the User to the use of his/her personal data (article 6.1, a) of the General Data Protection Regulations of 27 April 2016),

Data processed :

First of all, Trace Global processes the personal data that the User communicates to it such as:

– Last name, first name, title,

– E-mail address, postal address, telephone number,

– Portrait

– Geolocation

Secondly, Trace Global processes data that it collects automatically when the User visits the Site, such as:

– IP address,

– Computer connection identifier,

– Activity on the Site, in particular the research that the User has carried out,

– Details about the User’s interactions with the Trace group such as the date, time and content of e-mails,

– ID or unique identifier of the User’s device, its characteristics and those of the software with which it is equipped (such as type and configuration),

– Connection data,

– Statistics on the pages displayed,

– Forwarding URL,

– Standard information on Internet connection logs 

In a third step, Trace Global processes data collected through cookies and other tracers:

What are cookies and other trackers?

Cookies or other similar trackers are files that are deposited when visiting a website, mobile application or online advertisement and stored in a specific space on the hard drive of the computer or mobile device.

Cookies are used to send status information when a User visits a site. Status information can be, for example, a session ID, language, expiration date, response domain, etc. Cookies are managed by the User’s web browser, and only the sender of a cookie can decide whether to read or modify the information contained therein.

Cookies have several functions, such as allowing the User to navigate efficiently on the Site to optimise its operation, to remember the User’s choices, to propose relevant advertising content according to the User’s centres of interest expressed during his navigation.

There are different types of cookies:

– Functioning cookies,

– Cookies related to targeted advertising operations,

– Some audience measurement cookies,

The installation of cookies is subject to the User’s consent. During his first visit to the Site, an information banner will be displayed indicating that by continuing his navigation on the Site, the User will be able to choose which cookies will be installed on his equipment. The User must necessarily consent to the installation of certain cookies in order to continue browsing the Site or the Application; these are known as operating cookies. If the User consents in accordance with the terms and conditions brought to his knowledge, he may however at any time reconsider his choice in accordance with the terms and conditions described in the paragraph below “How to deactivate cookies”.

SDKs (Software Development Kit) are programming tools offered to publishers and developers of mobile applications. SDKs may have various functionalities. Some SDKs allow you to debug or debug mobile applications. Others, to detect and analyze application crashes. Finally, some are used to analyze the audience and user behavior on applications to measure the popularity of the application or to broadcast advertisements.

What are the cookies and tracers present on the Site?

_ga (Google)

Analytics(Google)

_gat (Google)

_gid (Google)

G_ENABLED_IDPS (Google)

Geolocation (123 Multimedia)

cookieconsent_status (123 Multimedia)

LoginFailed (123 Multimedia)

infoAlreadyDisplayed (123 Multimedia)

Ltime (123 Multimedia)

VIPLoginInfo (123 Multimedia)

chatterInfos (123 Multimedia)

Chat (123 Multimedia)

Tk (123 Multimedia)

51D_Bandwidth

Test_cookie

-gat_property2

_smVID

_gid

GIF_1x1

Beacon_API

Cookies may be managed by our advertising partners for their own purposes.

Why are cookies and other tracking devices present on the Site?

Trace Global and its Service Providers use, if the User has consented, cookies and other technologies for various reasons. Among other things, cookies and other technologies make it easier for the User to access the Trace Website, to measure the frequency of the Website (number of page views, number and frequency of visits), to more accurately identify users, to better understand their interests, and to target advertising and marketing campaigns.

These cookies also enable Trace Global to enforce its Terms of Use, prevent fraud and ensure the security of the Site.

How to disable cookies?

The User has several options for deleting cookies and other trackers:

Setting up his browser:

The recording of a cookie in the User’s terminal is subject to his will, which he can express and modify at any time and free of charge through the choices offered by his browser software.

The User has the possibility to choose to accept all cookies or to reject them systematically or to choose which ones he wishes to accept depending on their originators. The User may also set his browser to accept or reject cookies on a case-by-case basis prior to their installation. The User can also regularly delete cookies from his terminal via his browser. The User must not forget to set up all the browsers of his various terminals (tablets, smartphones, computers, etc.). The configuration of each browser is different for the management of cookies and his choices. It is described in the help menu of his browser, which will allow him to know how to modify his wishes in terms of cookies.

Cookies or tracers allow you to take full advantage of the functionalities of the Site and the Application. If the User’s browser is configured to refuse all cookies or tracers, this may prevent the use of some of Trace Global’s services, for which Trace Global cannot be held responsible.

In order to manage cookies and tracers as closely as possible to the User’s expectations, the User is invited to configure his browser taking into account their purpose.

Deactivate cookies and other tracers deposited by third party publishers:

The User may choose to disable cookies and other trackers deposited by third party publishers by going directly to their sites, using the link indicated in the table above.

Cookies or trackers deposited by social networking sites are their sole responsibility.

How long do cookies last?

The lifetime of cookies is a maximum of 13 months. At the end of this period, the Site must again obtain the User’s consent.

Persons concerned

Data processing only concerns persons who wish to contact Trace teams and/or subscribe to the Trace Newsletter and/or receive commercial offers from the Trace Group.

Recipients of the data

Recipient categories

Trace Global shares User data for various purposes with third parties as described below:

– To the ecosystem of Trace Group companies in order to process and store the User’s data and to provide personal tracking of the User’s requests.

– To Trace Global’s service providers: Trace Global uses other companies, agents or subcontractors (“Service Providers”) who perform certain services on our behalf or assist us in providing our services to you. For example, Trace Global works with Service Providers in the area of IT services. These Service Providers may have access to the User’s personal data. Trace Global does not allow them to use or disclose the User’s personal data, except when such use is in connection with the provision of their services,

– As part of the protection of Trace Global and its Service Providers : Trace Global and its Service Providers reserve the right to disclose and otherwise use User’s personal and other data when they believe in good faith that such disclosure and use is necessary to (a) comply with any law, regulation, legal process or government request, (b) enforce applicable terms of use, including for the purpose of determining possible violations of these Terms, (c) to detect, prevent or address illegal or suspected illegal activities (including payment fraud), security breaches or any technical problems, or (d) to guard against any infringement of the rights, property or safety of Trace Global, its users or the public, where required or permitted by law,

– As part of a business transfer: whether as part of a reorganization, restructuring, merger, sale or any other type of asset transfer, Trace Global will transfer data, including the User’s personal data, provided that the receiving party agrees to respect such personal data in accordance with Trace Global’s Privacy Policy,

– In the context of information sharing, when Trace Global transfers personal data to countries outside the European Economic Area and other regions that have data protection legislation, it ensures that such transfers are carried out in accordance with this Privacy Policy and in compliance with applicable data protection legislation.

Transfer of data outside the European Union

Your data may be transferred to our partners (subcontractors, business partners) outside the European Union who can provide sufficient and appropriate guarantees regarding the protection of your data.

Data retention period :

Trace Global may retain the User’s personal data for a period of three years from the last interaction between the User and Trace Global’s teams.

If the User has subscribed to the “Trace Newsletter” or has consented to receive “Trace newsletters”, his data will be retained until the User decides to unsubscribe (via the unsubscribe link included in the newsletters).

If the User has also consented to receive “commercial offers from the Trace Group”, his data will be kept for a period of three years after the last commercial solicitation sent by Trace Global and remained unanswered by the User.

Security :

Site and Application belonging to Trace Global

In order to guarantee the security of the User’s personal data, Trace Global has notably adopted the following measures to prevent its data from being distorted, damaged or accessed by unauthorized third parties:

– Protection of physical access to the premises in which the User’s data are stored (secure building);

– Implementation of a user authentication process using individual passwords;

– Carrying out processing on a dedicated internal network not connected to the Internet.

Sites belonging to third parties

Links present on the Site may refer the User to external sites.

The personal data protection policies of these sites may differ from this policy.

Consequently, it is recommended that the User read the personal data protection policy of each of the sites concerned.

In any case, Trace Global cannot be held liable in the event that the content of one of the sites concerned contravenes the legal and regulatory provisions in force.

Changes to this Privacy Policy :

This Privacy Policy is subject to change or modification at any time.

You are invited to consult it regularly.

User’s Choice :

If the User no longer wishes to receive certain types of messages and communications (commercial offers, newsletters) from Trace Group, simply click on the “Unsubscribe” link in the e-mail.

Rights of the User :

The User may request access to his personal data, modify, update or delete erroneous or obsolete data that Trace Global keeps if they are no longer necessary for the relationship between Trace Global and the User or for any other legitimate purpose. To do so or for any other question concerning our privacy practices, the User may contact Trace Global by writing to the following e-mail address: dpo-trace@trace.tv or to the following postal address: TRACE GLOBAL, -DPO-, 73 Rue Henri Barbusse, 92110 Clichy.

If the User considers, after contacting Trace Global that his rights on his data are not respected, the User may address a complaint to the CNIL on the CNIL website or by postal mail by writing to : CNIL – 3, place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07.

Last modification :15/05/2020.

In case of translation, the French version prevails.

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