GAMNED! DATA PROTECTION CHARTER

Free access to many sites on the Internet is made possible by the dissemination, by advertisers, of advertisements. These advertisements can be targeted on the basis of the needs and expectations of the Internet users concerned or untargeted, which are less likely to interest them. In all cases, Internet users are exposed to advertising.

Advertisers, for their part, are also interested in displaying their offers to users whom they know to be interested in them.

When Gamned! (Where " We "," Our "," ») Is mandated by an advertiser, our main mission is to reconcile the interests of Internet users and advertisers. To do this, we strive to preserve the confidentiality and security of the personal data that we process in the context of the campaigns entrusted to us by our advertiser clients, namely all information allowing direct identification (name, first name, profile picture, etc.) or indirectly (client or advertising ID, IP address, etc.) a natural person (the " Personal data ").

To this end, we have put in place strict procedures and made strong commitments which are described in this document (the “ Protection Charter ").

1. When does the Protection Charter apply?

The Protection Charter applies as soon as you communicate voluntarily (having given your authorization for an advertiser to send you targeted advertising, etc.) or that Gamned! collects your Personal Data (by subscribing to Our newsletter, by creating a customer account with Our sales department).

2. Who are we?

Gamned! is a trading desk and a publisher of programmatic solutions. Information about Gamned !, is available on our Legal notice.

Gamned! is referenced as vendor Transparency and Consent Framework of the Interactive Advertising Bureau (IAB) Europe - association of web advertising producers. Such referencing allows Internet users to choose, on any site equipped with a Consent Management Platform, which data it authorizes which entities to collect.

Likewise, Gamned! follows the recommendations of the platform of choice YOC "Youronlinechoices" which allows Internet users to deactivate all the cookies that Gamned! and other member companies would have placed on their computers.
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3. What are Our commitments?

Gamned! has made the protection of Personal Data and respect for privacy one of its priorities. We have thus chosen to work towards greater transparency and to offer real visibility to users regarding the collection and processing of their Personal Data on the Internet, including the use of cookies.

Gamned! undertakes to process your Personal Data in strict compliance with the Regulations (defined below), the lawful instructions of our customers, data controllers and this Protection Charter.

Thus, and by virtue of the principle of data minimization, Gamned! ensures that it only processes Personal Data that is strictly necessary with regard to the explicit, legitimate and determined purposes for which they are processed. The processing operations will only be carried out for the duration necessary for the accomplishment of the purposes concerned and within the framework of strict security and confidentiality measures.

These purposes have also been brought to the attention of Our Data Protection Officer (DPO) during the prior formalities carried out with the latter.

4. What regulations are applicable to the use of your Personal Data?

The regulations applicable to the processing of Personal Data cover all the laws and regulations, national and European, in force and in particular (i) the European Regulation 2016/679 on data protection of April 27, 2016 (the " GDPR "), (Ii) the French provisions of law n ° 78-17 of January 6, 1978 as amended by law n ° 2018-493 of June 20, 2018, (iii) European directive 2002/58 / EC of 12 July 2002 and (iv) the guidelines, opinions, recommendations, opinions of the supervisory authorities and the certifications, approvals or final court decisions (together, the " Regulation ").

5. What are the processing of Personal Data operated by Gamned!

Gamned! operates two types of Personal Data processing:

• in quality of data controller (in particular with regard to the processing of Personal Data of Our employees, customers, partners, etc.),
• in quality of subcontracting by processing the Personal Data of Internet users on the sole instructions of an advertiser client acting as data controller.
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5.1. When Gamned! acts as data controller:

5.1.1. When you (or your employer) are a client or partner of Gamned! or if, in general, you have a commercial relationship with Us (as a supplier, agency, etc.), we collect and process your Personal Contact Data (your name, first name (s), professional email address , telephone number, function within your company, etc.) for the purposes of managing the commercial relationship, providing Our services and building loyalty (management of the contract, invoices, accounting, support requests, provision of services , subscription to the newsletter, invitation to Our events, etc.).

The processing thus implemented is based on (i) the legitimate interest of Gamned !, insofar as this is necessary for the proper performance of the services offered by Gamned !, (ii) the performance of the contract concluded between Gamned! and you, (iii) compliance with Gamned's legal obligations! and, where applicable (iv) your express consent.

Your Personal Data is only kept by Our services for the period strictly necessary, namely three (3) years from the end of the commercial relationship between Gamned! and you or, with regard to the data strictly necessary for compliance by Gamned! of its legal obligations, during the applicable limitation period.

Gamned! communicates your Personal Data only to recipients who need to have access to it: the sales, accounting and marketing departments of Gamned! and the subcontractors of Gamned !, and this only to the extent necessary for the accomplishment of the tasks entrusted to them.

5.1.2. When you (or your employer) are Gamned! and / or that you visit Our Site, vou may need to (i) give us your last name, first name (s), email address, etc. in order to subscribe to Our newsletter or (ii) authorize Gamned! to place cookies on your terminal.

Your Personal Data is processed mainly for the following purposes:

• subscription to our newsletter,
• carrying out statistical analyzes of visits,
• provision of targeted advertising tailored to your interests, on behalf of Gamned.

These treatments are operated by Gamned! on the legal basis of (i) the pursuit of legitimate interests relating to the improvement of the quality of Our services and (ii) your express consent.

The Personal Data processed for the purposes of (i) carrying out statistical analyzes are kept for a maximum period of three (3) years, (ii) receipt of Our newsletter as long as you have not unsubscribed via the link unsubscription integrated into each newsletter and (iii) provision of targeted advertising for thirteen (13) months.

Gamned! communicates your Personal Data only to recipients who need to have access to it: the sales, accounting and marketing departments of Gamned! and the subcontractors of Gamned !, and this only to the extent necessary for the accomplishment of the tasks entrusted to them.

5.1.3. When you apply to join the Gamned! Teams, We process the Personal Data that you communicate to Us as part of your application and your possible interview. The purpose of this processing is to process your application and ensure the management and follow-up of Our recruitments; it is based on the legitimate interest of Gamned! to respond to your application requests and to find profiles suited to the positions available within Gamned !.

If you have applied following an advertisement published on Our “Jobs” page or spontaneously applying, We are likely to keep your Personal Data in our files for two (2) years following your last contact with Us, and to call you if a there is another opportunity that may match your qualifications, even if your application was not initially selected.

Gamned! communicates your Personal Data only to recipients who need to have access to it: the human resources, sales and marketing departments of Gamned !, the management teams of Gamned! and the subcontractors of Gamned !, and this only to the extent necessary for the accomplishment of the tasks entrusted to them.

5.2. When Gamned! acts as a subcontractor:

As part of Our trading desk activity, We are required to process Personal Data concerning you (navigation data, IP address, type of connection used (wifi, 4G), type of terminal used (tablet, mobile, computer), brand and model of the terminal, internet access provider) in order to allow our customers, advertisers, to effectively operate targeted advertising campaigns.

Gamned! thus acts as a subcontractor, acting on behalf and on the instructions of its customers / advertisers / data controllers

You are therefore invited to consult the information notice / personal data protection charter of each advertiser whose website you will visit in order to obtain information relating to the methods of processing your Personal Data defined by it. .

6. What exactly is a cookie? How do we use them? How can you manage them?

"Cookies" are small data files placed on your terminal when you browse internet pages, subject to the choices you have made, in order to store and receive identifiers and other browsing information.

Cookies are used on the Site to (i) facilitate your navigation, (ii) offer you personalized advertising and (iii) compile visit statistics.

• Targeted advertising cookies: they make it possible to optimize the advertisements offered to you on the Site in order in particular to offer you advertisements likely to interest you and to limit the repetitions of the same advertisement;
• Statistical cookies: they make it possible to establish statistics of visits to the Site and to detect navigation problems in order to monitor and improve the quality of Our services.

You can configure your browser at any time to express and modify your wishes in terms of cookies, in particular by refusing certain cookies.

You can also use the interface that we make available to you via the cookies banner that appears when you first connect to the Site or after deleting your cookies.

We remind you that by disabling targeted advertising and / or statistical cookies:

• you will continue to be exposed to advertising but it will no longer be targeted according to your preferences identified on the basis of your browsing profile. Disabling targeted advertising has no impact on the volume of advertisements to which you are exposed but on their relevance; and or
• your visit to the Site will no longer be counted in our traffic measurement tools.

Personal Data collected via Our cookies is kept for thirteen (13) months.

7. What are Our requirements with third party recipients?

We ask the recipients of your Personal Data to act in accordance with the Regulations and in particular to pay particular attention to the confidentiality of this Personal Data.

8. Do We transfer your Personal Data outside the European Union?

The Personal Data collected may be processed outside the European Union.

In this case, Gamned! takes the necessary steps with its subcontractors and partners to guarantee an adequate level of protection in accordance with the Regulations for your Personal Data. To do this, We ensure that Our subcontractors and partners (i) are located in a country with legislation considered to offer adequate protection or (ii) have signed a contract with Us containing the "standard contractual clauses" of the European Commission, or (iii) are subject to binding internal rules approved by the authorities.

9. What are the security measures implemented by Gamned! to protect your Personal Data?

In order to bring the highest level of security to your Personal Data, Gamned! puts the following security measures in place:

• appropriate physical, technical and organizational measures to prevent any alteration or loss of your Personal Data or any unauthorized access to them;
• access to Personal Data strictly reserved for employees and service providers who need to know about it. These people are subject to strict confidentiality obligations and are liable to be subject to disciplinary sanctions, if applicable, in the event of a breach;
• regular audits on the collection, storage and processing of data;
• the communication of instructions relating to security to employees having access to Personal Data;
• hosting of Personal Data in secure hosting centers.
• encryption of access to our services using SSL technology
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10. What are your rights and how can you exercise them?

In application of the Regulations, you have the following rights, concerning the processing, by Gamned !, of your Personal Data as data controller:

To. Access and be informed : you have the right to be informed in a concise, transparent, understandable and easily accessible way of how your Personal Data is processed. You also have the right to obtain (i) confirmation whether or not Personal Data concerning you is processed by Gamned! and, where applicable, (ii) access all of your Personal Data and obtain a copy thereof.

b. Rectify : at any time you can ask Gamned! to rectify and / or complete any Personal Data concerning you which is incomplete or incorrect, which Gamned! will do as soon as possible.

vs. To erase :, in certain cases, you can request, from Gamned !, the erasure of your Personal Data (“right to be forgotten”); however, this is not an absolute right, Gamned! may have, in certain cases, legal or legitimate reasons to keep your Personal Data.

d. Limit : in some cases listed in article 18 of the GDPR, you can ask Gamned! to limit the processing of your Personal Data.

e. To transfer : you have the right to the portability of your Personal Data, in a structured, commonly used and machine-readable form. You are, therefore, free to transmit your Personal Data to a recipient of your choice without Gamned! cannot oppose it. However, this right only applies if the processing of your Personal Data is based on your consent or on the performance of a contract, and the processing is carried out using automated processes.

f. Oppose you : when the processing of your Personal Data is based on the legitimate interest of Gamned !, you have the possibility to object to this processing. Gamned! will then terminate the processing of your Personal Data, unless there is a legitimate reason for the processing. You also have the right to object at any time to the processing of your Personal Data for commercial prospecting purposes. Finally, you have the right to unsubscribe from Our newsletter by simply clicking on the “Unsubscribe” link at the bottom of each newsletter.

g. Set guidelines after your death : these directives, revocable at any time, may relate to the storage, erasure and communication of your Personal Data by designating a person responsible for their execution:

• when it comes to general guidelines, you can send them to a trusted digital third party certified by the CNIL,
• when it comes to specific instructions, you can send them directly to Gamned !.
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h. Submit a complaint : you always have the right to lodge a complaint with the National Commission for Informatics and Freedoms (CNIL).

If you wish to exercise all or part of the aforementioned rights or benefit from additional information, you can send a request to the Data Protection Officer (DPO) of Gamned !, accompanied by a copy of a signed proof of your identity and any other information necessary to confirm your identity and allow us to process your request (your postal address for example):

• via our online form, accessible here:

• by mail to: Gamned !, DPO, 125 rue de Saussure, 75017 PARIS

A response will be sent to you within one (1) month of receipt of your request.

11. Do you have a question?

For any questions about Gamned's commitment! regarding the protection of privacy and Personal Data, please contact Our Data Protection Officer at the following address: privacy@gamned.com.

12. Modification of the Protection Charter

Gamned! reserves the right to modify the Protection Charter at any time, depending in particular on the legal and regulatory context and the recommendations, opinions and decisions of the CNIL, the European Data Protection Committee and French and European courts.

Last updated January 22, 2020