1.3 On behalf of Client, ADALONG shall collect and process the following data from Creators:
(i) the username and identification number of the Creator;
(ii) the Uniform Resource Locator (URL) of the UGC
(iii) the date and location of the UGC.
1.5 By providing the Service, ADALONG acts as a “data processor” on behalf of the Client (section 4.8 GDPR) and processes the Creators Personal Data on behalf of Client and only on documented instructions from the Client (section 28 GDPR).
1.6 Both parties shall maintain a record of their respective data processing activities (section 30 GDPR).
1.7 The Client shall inform Creators (section 12 GDPR) that ADALONG processes, on its behalf, some Creators Personal Data which are collected through the subscription to the Service for marketing or communication campaigns purposes. By allowing the Client to process their UGC for Client’s marketing campaigns after replying to the Client through the Service and agreeing to the Client’s own specific terms and conditions, Creators give consent (section 6.1 (a) GDPR) for the processing by Client of their Personal Data relating to the UGC.
1.8 Personal Data collected from Creators are processed and stored until Creators withdraw consent. Consent can be withdrawn for free, at any time by Creators, by contacting the Client according to the Client’s terms of conditions under which the Creator has given consent. ADALONG shall delete personal data relating to any Creator on behalf of Client after instruction from the Client.
1.9 By giving consent to the processing of their data on behalf of Client, Creators have (i) a right to access (section 15 GDPR), (ii) a right to rectification (section 16 GDPR), (iii) a right to erasure (section 17 GDPR) and (iv) a right to object “including profiling” (section 18 GDPR). Creators wishing to assert any of their rights may send their request to the Client according to the Client’s own terms of conditions under which the Creator has given consent.
1.10 ADALONG, acting on behalf of Client, shall take all measures of security relating of its IT system and Service, including encryption of the transmission and storage of Creator personal data using industry-standard encryption technologies (section 32 GDPR).
1.11 Acting as “data processor” of the Client, ADALONG shall inform the Client without undue delay after becoming aware of any breach of Creators Personal Data (section 33.2 GDPR). The Client shall (i) notify the breach to the supervisory authority competent within seventy-two (72) hours (section 33.1 GDPR) and (ii) communicate the breach to Creator without undue delay when the breach is likely to result in high risk to their rights and freedoms (section 34.1 GDPR).
1.12 ADALONG guarantees that the Service is provided in France. ADALONG shall not make any transfer of Creators Personal Data outside the European Union.
1.13 If you have any questions regarding security you can contact us at firstname.lastname@example.org.
July 2018, Paris France