Effective as of 1 December 2019
86-90 rue du Dôme, 92100 Boulogne Billancourt, France
Information we collect about you
We may collect and process the following information about you:
- Your name, your email address and other business contact details;
- Your training profile, including details of courses you’ve attended and courses that you’re due to complete;
- Information that you provide by filling in forms on www.mediaocean.com (our website) or on Mediaocean Support; when you contact us, or when we contact you;
- If you contact us, we keep a record of that correspondence;
- Records of pages and features you’ve used within our Web applications (but not of the data you’ve entered into those applications);
- Results from surveys that you complete for research purposes; and
- Details of your visits to our website including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access. We may collect information about your computer, including your IP address, operating system and browser type, for system administration.
We do not collect Sensitive Information about you.
We use your Personal Information to provide the services that we’ve contracted to provide to our clients in the following ways:
- To enhance or improve your experience on our website and/or with our products & services generally;
- To respond promptly and effectively to your support requests;
- To contact you where necessary or appropriate, for example if you have a query;
- To provide you with information, products, or services that you request from us and notify you of any changes to these;
- To help us keep the information that we hold about you up-to-date;
- To carry out obligations arising from contracts entered into between the client company and us;
- To keep your information secure. To minimize the risk of unauthorized access to your information, we may use some of your information to authenticate you when using our website or when you contact us by telephone.
- To perform or administer our obligations under a contract or in connection with our obligations to our employees and contractors.
For this reason, we don’t ask you to consent to us retaining this information. You won’t be able to use our support services if you are not willing to provide this information. We will, however, normally obtain your consent before using your Personal Information for a purpose that is incompatible with the purpose(s) for which it was originally collected, except where use or disclosure is required or permitted by law.
How we store and share your information
Personal Information collected from European users will be transferred from time to time to the USA and the UK, and may be transferred to any other countries where Mediaocean group companies have offices (Australia, Canada, France, Germany, India). Data transfer agreements (including the EU model clauses) have been put in place with other Mediaocean entities within the group to ensure protection of Personal Information in line with European data protection requirements.
Mediaocean uses cloud-based software solutions for customer relationship management, support and incident management, and marketing communications. These run at Tier III, SOC1, SOC2, or ISO 27001 compliant data centres located in the USA. Further details can be provided on request. Mediaocean shares your name and business contact details with these providers for the purpose of operating the websites, and the information is used strictly for the purposes described above. All Personal Information transferred by Mediaocean to the providers is covered by contractual clauses which govern the transfer, processing and use of the data and prohibit any further unauthorised onward transfer of the data, unless the provider is a member of the US-EU Privacy Shield scheme. Mediaocean uses additional hosted or cloud-based software solutions in the USA to facilitate internal processes. Where this is the case, Mediaocean will only transfer your Personal Information under similar data transfer agreements.
We retain your Personal Information in accordance with Mediaocean’s Data and Document Retention Policies. These policies define retention rules based on the nature of the information and the purpose for which it is required. We destroy or dispose of all Personal Information securely when it is no longer needed.
How we keep your information secure
All information you provide to us is either stored on our secure servers at our data centre, or else in secure cloud solutions as described above. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or to use Mediaocean applications, you’re responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we’ll do our best to protect your Personal Information, we can’t guarantee the security of your Personal Information transmitted to our website; any transmission is at your own risk. Once we have received your information, we’ll use strict procedures and security features to try to prevent unauthorised access.
Logical access tools have been put in place to ensure that access to Personal Information is appropriately restricted. Administrative access to the information is restricted to authorized personnel. Physical and network security measures are in place to restrict access to the computing equipment. The security measures that we have in place to protect Personal Information are certified annually. We also obtain security reports from our cloud service providers to ensure that they are adhering to the required standards.
Your rights under this Policy
- You have the right to ask us for confirmation of whether or not we hold any Personal Information about you. You may ask us about the purpose for which we hold the information, whom we share it with and the criteria we use to determine how long to retain it. If your Personal Information is being held abroad, you can ask us how we’ve made sure that it will safeguarded. You may also ask us to provide you with a copy of your Personal Information that we hold, subject to confirmation of your identity (as long as this does not adversely affect the rights & freedoms of any other individuals). We will not charge you for providing this information, though we reserve the right to charge a reasonable fee based on administrative costs if the request is excessive, unfounded or repetitive.
- If you determine that the Personal Information we hold about you is incorrect, you have the right to ask us to correct the data we hold.
- You have the right to opt-out of any use of your Personal Information for marketing purposes by contacting us or by unsubscribing using the link provided at the bottom of our emails.
- You have a right, on certain grounds, to object to the processing of your Personal Information; you may also, on certain grounds, request erasure or restrictions on processing of Personal Information. For more information about how to do this, please see the section on Enquiries and complaints below.
- If you are not happy with the way that we have responded to a complaint, or with the way we are processing your Personal Information, you have a right to lodge a complaint with the Information Commissioner’s Office.
Children under the Age of 13
Our websites and services are not intended for children under 13 years of age. No one under age 13 may provide any Personal Information to or on the website. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provide any information on this website or on or through any of its features. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at Infosec&Compliance@mediaocean.com.
Enquiries and complaints
We will cooperate with the relevant local Supervisory Authority, for example the Commission Nationale de l' Informatique et des Libertés, and any other relevant government agencies, and law enforcement and judicial authorities in investigating any privacy complaints or suspected violations of privacy laws or Mediaocean’s privacy commitments, as well as in rectifying any noncompliant practices. Employees or contractors who violate the terms of these principles may be subject to disciplinary consequences up to and including termination of employment or termination or non-renewal of contract, in addition to any other legal measures that may be taken by Mediaocean, its clients, or the affected individuals and their representatives.
- Personal Information is any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier, regardless of the medium or format in which the information is stored.
- A Third Party is an entity or person other than you, Mediaocean or its clients. This includes providers of cloud-based software solutions and sub-processors.
- Sensitive Information consists of Special Categories of Personal Data as defined by the EU General Data Protection Regulation, that is, information about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric data, health information, or sex life/orientation.
- A Supervisory Authority is an independent public authority which is established by an EU Member State in order to monitor the application of EU Data Protection law.