As part of its "Trace Play" service consisting of the provision of videos on demand by subscription giving its users access to a selection of television channels, series, films, documentaries and afro-urban music ("Content"), and as part of its commercial activities and weekly press publisher on digital media, Trace UK is required to process information concerning the User. Indeed, by using the various services offered by the Trace Play service, the User transmits information, some of which is of a nature to identify the User ("personal data").
The person responsible for the processing mentioned in this document is Trace UK world limited, a limited liability company with a share capital of GBP 300,000, registered at Companies House in London under number 07589222, whose VAT number is 126886774, whose registered office is located at 36-38 Westbourne Grove, Newton Road, London, Greater London, W2 5 SH and of which Mr. Laurent Dumeau, Director, is the legal representative.
The Data Protection Officer is Mr. Sven Balisson.
Purpose of data processing
Trace UK uses the data it collects for :
- Fulfill its obligations to the User who has subscribed to the Trace Play subscription (processing your subscription, orders and payments),
- Communicate with the User about the service and its evolutions (new content available, new features, satisfaction survey...) or in order to help the User in case of a technical problem when the User subscribed to the subscription,
- Determine the general geographic location of the User, where the User has consented and thereby provide localized content to the User,
- Communicate with the User (by e-mail, push notifications or instant messages) in the event that the User has checked the box "I would like to receive Trace news",
- Communicate with the User (by e-mail, push notifications or instant messages) in the event that he has checked the box "I wish to receive commercial offers from Trace" in order to send him any special offers, promotional announcements, contests from the Trace group,
- Prevent, detect and investigate potentially prohibited or illegal activities, such as fraud, and enforce Trace Play's terms and conditions of use (e.g. to determine eligibility for free trials),
- Analyze, improve and personalize its services and marketing activities in order to allow 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 UK collects and processes the User's personal data only in the cases provided for by the regulations in force:
- The execution of the contract concluded between Trace UK 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 data (article 6.1, a) of the General Data Protection Regulations of 27 April 2016),
- The existence of a legitimate interest for Trace UK to use the User's data. The legitimate interest is a set of commercial or business reasons that justifies the use of the User's personal data by Trace UK (article 6,1, f) of the GDPR of April 27th 2016).
Data processed :
First of all, Trace UK processes personal data that the User communicates to it such as :
- Surname, first name, title,
- E-mail address, postal address, telephone number,
- Encrypted username and password used to identify you on our site or application,
- Encrypted information relating to your means of payment,
Secondly, Trace UK processes the User's personal data that it collects automatically when the User uses the service such as :
- Activity on the Trace Play service, including Content viewed, reading history and searches performed;
- Details about User's interactions with customer service, such as the date, time and content of your e-mails;
- The User's IP address
- The User's computer connection identifiers
- The iD or unique identifiers of the User's devices, their characteristics as well as those of the software they are equipped with (such as their type and configuration),
- The login data,
- Statistics on the pages displayed,
- The referring URLs,
- Standard Internet connection log information.
In a third step, Trace UK processes the data it collects via 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 disk of the User's 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 or the mobile application he or she is using and only the issuer of a cookie can decide whether to read or modify the information contained therein.
Cookies have several functions, such as enabling the User to navigate efficiently on a site or mobile application and/or to optimise its operation, to remember his choices, to offer him relevant advertising content according to his centres of interest expressed during 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 or application, an information banner is displayed indicating that by continuing his navigation on the site, he 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, these are called operating cookies. If the User consents in accordance with the terms and conditions brought to the attention of Trace UK, he may however at any time reconsider his choices according to the terms and conditions described in the paragraph below "How to disable 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.
Which cookies does Trace UK use?
Provided that the User is not opposed to it, the cookies and tracers used on the Site are :
- Google Analytics
- Google Firebase
- Youbora - Nice People at Work
Trace UK and its Service Providers use, if the User has consented, cookies and other technologies for various reasons. Cookies and other technologies allow Trace UK among other things to authenticate the User in particular when he is connected to the website and/or the application in order to provide the service to him, to facilitate his access to the services (Trace UK proposes to the User to remember him each time he connects), to measure the audience of these advertisements and the frequency of the Site or Application (number of pages viewed, number and frequency of visits), to enable Trace UK to provide and analyze its services, to identify its users more precisely, to better understand their interests, and to target its advertisements and marketing campaigns. This is for example the case with Google Analytics, Google Firebase, Youbora or Braze trackers. These cookies also enable Trace UK to enforce its terms and conditions of use, prevent fraud and ensure the security of its service.
How to disable cookies?
The User has several options to delete cookies and other trackers:
Set 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 the parameters of 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 regarding cookies.
Cookies or tracers allow you to take full advantage of the Site's functionalities. If the User's browser is configured to refuse all cookies or trackers, this may prevent the use of some of Trace Play's services, for which the Publisher cannot be held responsible.
In order to manage cookies and trackers as closely as possible to the User's expectations, the User is advised 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. Cookies or trackers deposited by social networking sites are their sole responsibility. The User can consult the privacy conditions of each of these sites on their own page.
What is the shelf life of cookies?
The lifetime of cookies is 13 months maximum. At the end of this period, Trace UK will have to collect the User's consent again.
The data processing only concerns persons who wish to subscribe to the Trace Play service and/or the commercial offers of the Trace group and/or the newsletters of the Trace group.
Trace UK shares User data for various purposes with third parties as described below:
- To the Trace Ecosystem: Trace UK shares User data with Trace Ecosystem companies for the purposes of processing and storing User data, providing access to services, providing customer support, making decisions regarding service improvements and content development, and for other purposes as described in the Use of Data section of this Privacy Statement,
- Trace Service Providers: Trace UK uses other companies, agents or subcontractors ("Service Providers") who perform certain services on behalf of Trace UK or who assist Trace UK in providing services to the User. For example, Trace UK works with Service Providers in the area of IT services, to personalize and improve the service, to process credit card and other payment transactions, and to process and administer consumer surveys. In the course of providing these services, these Service Providers may have access to the User's personal data or other data about the User. Trace UK will 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,
Other websites, platforms and applications
Data transfer outside the European Union
Personal data may be transferred to Trace partners outside the European Union who can provide sufficient and appropriate guarantees regarding the protection of the User's personal data.
Access to your account and profiles
In order to make it easier for the User to access his account and to simplify the management of the Trace Play service, we use technologies that allow the User to identify himself as the account holder and provide him with direct and simplified access to his account without having to enter a new password or other means of identification when he returns to the service. Whenever possible, users of public or shared devices are strongly encouraged to disconnect and deactivate their device systematically at the end of each visit. If the User sells or makes a computer or device compatible with the Trace Play service, it is imperative that the User disconnects and disables the device beforehand. Otherwise, if he does not keep his password or device secure, or if he does not disconnect and deactivate your device, other users will be able to access your account, including your personal data.
If the User shares his or her account or allows others to access his or her account, these individuals will be able to view your information, including in some cases the User's personal data, such as account information (your email address, among others).
Legal age to use the service
The User must be 18 years of age or older in order to subscribe to the Trace Play service.
Minors may use the service, but only with the consent and under the supervision of a parent or legal guardian.
Data retention period :
Trace UK retains your personal data for a period of three years from the end of our commercial relations relating to your Trace Play subscription.
If you have also consented to receive our commercial offers we retain your data for three years after the last commercial solicitation we sent you that remained unanswered by you.
If you have also consented to receive our newsletters, we keep your data until you unsubscribe (via the unsubscribe link in the newsletter).
Site belonging to Trace
In order to guarantee the security of the User's data, Trace UK has adopted the following measures to prevent personal data from being distorted, damaged or accessed by unauthorized third parties:
- The protection of physical access to the premises where the data is stored (secure building);
- The implementation of a user authentication process using individual passwords;
- Processing is carried out on a dedicated internal network not connected to the Internet.
Sites belonging to third parties
Links present on the Site or the Application may direct you to external sites.
The personal data protection policies of these sites may differ from this policy.
Consequently, it is recommended that you read the personal data protection policy of each of the sites concerned.
In any case, we cannot be held liable in the event that the content of one of the sites concerned contravenes the legal and regulatory provisions in force.
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, events) from Trace UK, simply click on the "Unsubscribe" link in the email or reply STOP (or the indication received in the message) to the SMS. Please note that you cannot unsubscribe from some of our communications, including messages about transactions related to your account.
You can opt to receive push notifications from Trace UK. If you later decide that you no longer wish to receive these notifications, you can disable this feature at any time through your mobile device settings.
To make your choices regarding the cookies used on our website and other types of tracking and online advertising, please see the section "Cookies and Online Advertising".
User Rights :
The User will also be able to request Trace UK to delete his personal data if it is no longer needed for the service, for billing records or for other legitimate reasons. To do so, or if the User has any other questions regarding Trace Play's privacy practices, the User may write to email@example.com.
If the User believes, after having contacted Trace UK, that the rights to his data are not respected, he 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 :24/03/2020.
In case of translation, the French version prevails.