Dolead is a service provider company specialising in digital marketing brokerage. Its services consist of putting users (hereinafter the 'User' or 'Users', as appropriate) in search of goods and/or services in contact, at their request, with one or more professionals (hereinafter the 'Partner(s)', as appropriate) likely to meet their needs. Dolead invites Users to consult the General Terms and Conditions of Use in order to find out more about this.
This Privacy Policy details Dolead's policy on the protection of Users’ personal data (hereinafter 'personal data') when they browse the website, www.dolead.com (hereinafter the 'Site') and/or use the services offered by Dolead from the contact interface pages (hereinafter the 'Interface(s)', as appropriate). It supplements the Site's Cookies Charter
What is personal data? This is all information relating to a natural person, allowing said person to be directly or indirectly identified, either by reference to information which is specific to him/her (for example, surname or first name etc.) or by cross referencing a set of data (for example, contact details, loyalty card number or IP address etc.).
What is personal data processing? This refers to all operations, whether or not automated, relating to personal data (for example, collection, recording, organisation, conservation, modification, use, dissemination or deletion etc.).
To find out more about your rights and the protection of personal data in general, you can consult the website of the ‘ICO’ (Information Commisioner's Office) (ico.org.uk/).
Dolead may modify this Policy at any time to adapt it to changes in legislation and its own activities. Such changes will take effect as and when published. We therefore invite you to consult this Policy frequently.
Dolead strives to ensure a high level of protection of Users' personal data, in accordance with Regulation No 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data (hereinafter 'GDPR'), and Law No 78-17 of 6 January 1978 relating to data processing, files, and liberties (hereinafter 'LIL').
The company, Dolead SAS, 3 Rue de Gramont 75002 Paris, France is the data controller. The company has appointed a Data Protection Officer (DPO), who can be contacted via:
You can contact the DPO to exercise one of the rights granted to you by the GDPR and/or the LIL, as well as to obtain additional information relating to the processing of your personal data by Dolead.
When Users access the Interfaces, a questionnaire, which varies depending on the search, must be completed in order to enable one or more Partner(s) to be contacted, according to their needs.
At this point, Dolead collects the personal data that you provide by filling in the fields of the Interfaces questionnaire. The nature and extent of the personal data collected thus depend on:
Dolead may collect, depending on the situation, the following personal data:
| CLASSIFICATION | PERSONAL DATA COLLECTED |
|---|---|
| Data for identification | We may collect your surname, first name and title. |
| Contact details | We may collect your e-mail address, telephone number and postal address. |
| Personal life | We may collect information relating to your lifestyle, your family situation, the existence of pets or your consumption habits, the occurrence or absence of a claim etc. |
| Professional life | We may collect information on your role, your profession, your professional address, telephone number, and e-mail address etc. |
| Economic and financial data | We may collect your income level by range, an estimate of your wealth by range, whether you own or rent your home etc. |
Personal data that must be entered in order to be put you in contact with one of our Partners is systematically indicated by an asterisk.
Dolead may also collect additional personal data about you. It is up to you whether to fill in the optional Interface fields or not. If you do not wish to provide this optional information, your decision will in no way affect your contact request.
All of this personal data is collected when you confirm your request to connect with one or more of our Partners.
Please be aware that, when you confirm your request for a contact, Dolead may send an SMS to the mobile phone number which you have provided in order to confirm the contact details indicated.
Dolead obtains information from its Partners on the follow-up by Users to the offers that have been made to them at the end of the contact with the latter.
The information obtained is limited to what is strictly necessary to enable the implementation of the contract which binds Dolead, as an intermediary, to the Partners.
When Users access the Interfaces, Dolead collects the Users’ IP address. This personal data is not transferred to our Partners, subject to the information in Article 4.1 'Transfer of personal data to Partners'.
As this is a contact service initiated by Users, their personal data, obtained in accordance with the terms of Article 3.1 'When you request a contact', is collected with the aim of being transferred to one or more Partners who are likely to meet the Users’ needs based on their search.
Once the contact is established, the Partner(s) concerned will be responsible for processing the Users’ personal data thus transferred, for example, if they decide to contact you or arrange a meeting with you. The Partner(s) concerned may not use Users' personal data for purposes other than contacting them in order to meet their needs and, where applicable, follow up on offers for which Users have expressed an interest. Consequently, if the Partner(s) concerned wish to send you additional advertisements once they have presented their offer(s) corresponding to your needs, they must obtain your consent, unless it is not required under a legislative or regulatory provision.
In certain cases, if your contact request is addressed to a single Partner, Dolead may ask for your consent to receive advertising solicitations from this Partner. Under such circumstances, Dolead will simply collect your consent and transmit proof of your agreement to the Partner. The subsequent uses of your personal data for this purpose will be carried out by the Partner alone, under its sole responsibility. Under no circumstances will Dolead send you advertising solicitations.
Dolead may also be required to transfer your IP address to Partners if the latter use it to ensure that Dolead fulfils the contact request correctly. In this case, the Partners cannot use your IP address for any other purposes.
Please note that Dolead will not transfer your personal data to Partners if they are not likely to meet the needs expressed with regard to your initial search.
Dolead may also transfer Users' personal data in an encrypted manner to other digital advertising providers.
To protect this data, Dolead uses a single channel encryption algorithm (SHA 256) during the transfer to ensure its integrity. This algorithm creates a unique fingerprint of the encrypted data. If the service provider to whom this data is transferred:
In the latter case, the recipient service provider is therefore unable to identify you because they do not have any knowledge concerning you.
Dolead may transfer Users' personal data to some of its service providers for the provision of their services (for example, advertising agencies, management tool or hosting providers etc.).
Where applicable, only the personal data necessary for the recipients concerned to carry out their services will be transferred to them. The transfer of this personal data is always governed by the clauses of the contracts entered into with them, adapted according to their characteristics.
Your personal data is hosted on servers located within the European Economic Area by the company Amazon Web Services Emea SARL, whose registered office is located at 38 avenue John F. Kennedy, L 1855, Luxembourg (Luxembourg). For any questions relating to the processing of your personal data, you can consult the Notice concerning data protection accessible from the following link: https://d1.awsstatic.com/legal/privacypolicy/AWS_Privacy_Notice_French_2020-08-15.pdf.
Dolead limits the use of service providers located outside of the European Union or the European Economic Area as much as possible. However, the geographic location of some of them, necessary for Dolead’s operations and the provision of the services offered, may result in such a transfer. In this case, Dolead will safeguard the transfer of your personal data by way of the Standard Contractual Clauses of the European Commission or any other appropriate guarantee.
Please note that some of our service providers may transfer your personal data outside of the European Union or the European Economic Area to carry out their services. In this case, Dolead will require that such transfers be carried out in accordance with the legislation applicable to the protection of personal data.
The processing of Users' personal data carried out by Dolead pursues the following purposes, the legal bases associated with this processing being indicated for each of them:
| PROCESSING | Purpose(s) | LEGAL BASIS(ES) |
|---|---|---|
| Collection and transfer of the Users' personal data obligatorily filled in during the contact request | To put the Users in touch with the Partner(s) likely to meet their needs. | Implementation of the contract entered into between the Users and Dolead (Article 6, Paragraph 1, b) of the GDPR). |
| Sending of a confirmation code | To confirm the Users' contact details. | Dolead's legitimate interest (Article 6, Paragraph 1, f) of the GDPR), the legitimacy residing in the need to verify that the contact details provided by the Users are correct. |
| Collection and transfer of the Users' personal data optionally filled in during the contact request | To allow Dolead and/or our Partners to get to know the Users better. | The Users’ consent (Article 6, Paragraph 1, a) of the GDPR). |
| Obtaining your consent to receive advertising solicitations from a Partner | To authorise a Partner to send you advertising solicitations. | The Users’ consent (Article 6, Paragraph 1, a) of GDPR). |
| Obtaining information on the follow-up by the Users to the offers proposed by the Partners | To implement the contract between Dolead and the Partner(s) to whom the Users' personal data has been transmitted. | Dolead's legitimate interest (Article 6, Paragraph 1, f) of the GDPR), the legitimacy residing in the need for Dolead to prove that it has fulfilled its obligations towards its Partners. |
| Collecting the User's IP address | To assess and strengthen the security of the Site and/or Interfaces; To produce statistics relating to visits to the Site and Interfaces. | Dolead's legitimate interest (Article 6, Paragraph 1, f) of the GDPR), the legitimacy residing in the need (i) to ensure the security of our services, (ii) to know the frequentation of the Site and the Interfaces. |
| Transferring Users' IP address to Partners | To allow Partners to ensure correct implementation of the contact request by Dolead. | Dolead's legitimate interest (Article 6, Paragraph 1, f) of the GDPR), the legitimacy residing in the need to carry out its contractual obligations.. |
| Transferring Users' personal data to the digital advertising providers | To search new audiences likely to be interested in the brokerage services offered by Dolead. | Dolead's legitimate interest (Article 6, Paragraph 1, f) of the GDPR), the legitimacy residing in the need to conduct its activity as a brokerage agency in digital marketing. |
| Transferring Users' personal data to service providers | To use the tools and services necessary for Dolead’s operations. | Dolead's legitimate interest (Article 6, Paragraph 1, f) of the GDPR), the legitimacy residing in the need to conduct its activity as a brokerage agency in digital marketing. |
Dolead retains Users' personal data for as long necessary for the purposes of the processing, namely:
| PERSONAL DATA CONCERNED | PRINCIPLE DURATION | EXCEPTIONS/RESERVATIONS |
|---|---|---|
| Personal data that is required to be given to contact our Partners & Personal data that is obtained following contact with the Partners | In principal, your personal data is kept for a period of 2 years on an active basis from the last active contact with you. At the end of this period, this data is kept in our archives for a period of 3 additional years in case a complaint or dispute is formulated by Users and/or our Partners relating to the execution of the contracts which bind Dolead to them. | If you make a request for modification and/or deletion of your personal data, this is modified and/or deleted. In the month following the receipt of this request, according to the procedures set out in Article 8 - ‘Users’ rights’. In the event of a complaint or claim, Dolead has a legitimate interest in keeping your personal data until its term, for the only purpose of being able to defend itself. |
| Personal data that is optionally given to contact our Partners | In principal, your personal data is kept insofar as you do not withdraw your consent. | As soon as you withdraw your consent, your personal data is deleted in the month following receipt of this request. If you do not withdraw your consent, your personal data will be deleted within a period of 5 years at most. In the event of a complaint or claim, Dolead has a legitimate interest in keeping your personal data until its term, for the sole purpose of being able to defend itself. |
| IP Address | Your IP address is kept for a period of 1 year. | If you make a request for modification and/or deletion of your personal data, it is modified and/or deleted in the month following the receipt of this request, in accordance with the terms set out in Article 8 'Users’ rights'. In the event of a complaint or claim, Dolead has a legitimate interest in keeping your personal data until its term, for the sole purpose of being able to defend itself. |
Dolead implements the necessary precautions to preserve the integrity, confidentiality, and security of Users' personal data collected and processed in order to prevent its alteration, loss, destruction, or otherwise unauthorised access by third parties, whether accidentally or unlawfully.
Dolead has put in place technical and organisational security measures corresponding to the current state of the art. In particular, please be aware that:
However, please be aware that Dolead cannot control all the risks associated with the functioning of the Internet. Dolead wishes to draw your attention to the existence of risks inherent in the use and functioning of the Internet, and recommends that you take measures to protect your privacy.
| PURPOSE | |
|---|---|
| Right to object | In accordance with the terms of Article 21, Paragraph 1 of the GDPR, you have the right at any time to object to the processing of your personal data when such processing is carried out on the legal basis of the legitimate interest. If you object to the processing of your personal data by us: for advertising purposes, you can oppose it without giving us any reason justifying your request; for all other purposes, you must indicate to us the imperative reason(s) for your request to exercise the right to object. Your objection to the processing of your personal data will apply in the future. |
| Right to withdraw your consent | In accordance with the terms of Article 7, Paragraph 3 of the GDPR, you have the right at any time to withdraw your consent to the processing of your personal data when such processing is carried out on the legal basis of this consent. You can withdraw your consent without giving us any reason justifying your request. The withdrawal of your consent to the processing of your personal data will apply in the future. |
| Right of access | In accordance with Article 15 of the GDPR, you have the right to: ask us about the nature and methods of the processing of your personal data that we carry out; obtain a copy of your personal data. |
| Right to rectification | In accordance with Article 16 of the GDPR, you have the right to ask us to correct your personal data which is incorrect, or to complete it. |
| Right to erasure | In accordance with Article 17 of the GDPR, you have the right to ask us to erase your personal data. In this context, we will delete the personal data concerned as much as possible. However, please be aware that such a request cannot affect our right to the personal data needed to meet our legal obligations. |
| Right to restriction | In accordance with Article 18 of the GDPR, you have the right to ask us to restrict the processing of your personal data, in any of the following cases: if you dispute the accuracy of this personal data, or if you consider that we have processed it contrary to our obligations, but you do not want it to be deleted immediately; in either case, we must suspend the processing of your personal data for the time needed to carry out the necessary checks; if we no longer need this data, but you need it to claim, exercise and/or defend your rights; in this case, we must keep the personal data which you need. |
| Right to portability | In accordance with Article 20 of the GDPR, you have the right to ask us to transmit your personal data to you and/or to the third party of your choice, in a format technically exploitable by you or by said third party. |
| Right to appeal to a supervisory authority | In accordance with Article 85 I. of the LIL, you have the right to give us instructions regarding the fate of your personal data after your death. |
| Le droit de saisir une autorité de contrôle | You have the right to lodge a complaint with the ICO (https://ico.org.uk) or any other competent supervisory authority. |
If you wish to exercise any of these rights, you can send your request:
No payment will be required for the exercise of your rights, other than the possible costs of sending your requests, except in the event of repetitive and clearly unfounded requests.
Please be aware that Dolead may ask you for additional information to confirm your identity.
Once your request to exercise your right(s) has been received, Dolead will inform the Partner(s) to whom your personal data has been transmitted, where applicable, so that they can process your request. Effectively, once the personal data required to contact our Partners has been transferred to them, Dolead will not contact you directly. In particular, Dolead will never send you prospecting e-mails. As a result, it is possible that a certain delay may occur between the moment that Dolead confirms having processed your request, and the time that the same request is then processed by the Partner(s) concerned.
Dolead will keep the personal data transmitted at the time you exercise your rights, as well as our subsequent correspondence. The legal basis for the processing of this personal data is Article 6 Paragraph 1 f) of the GDPR, that is, our legitimate interest. The legitimacy of this processing is based on being able to prove that we have processed your request to exercise your right(s), within the allotted time. This personal data will be kept in the form of archives for a period of 5 years from the final processing of your request, with the exception of the copy of your identity card, which will be deleted as soon as your identity is confirmed. Only an adviser and the DPO have access to this database archive.
In the event that you wish to withdraw your consent to receive advertising offers from one of our Partners, Dolead invites you to make your request directly to the latter. Under no circumstances will Dolead send you advertising offers.
Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of Business Partners' personal information with third parties. These businesses are required to accept requests for disclosures of these policies from Business Partners but are only required to honor one request per calendar year. Businesses have thirty (30) days to respond to each inquiry to the designated address. Each inquiring Business Partner will receive an explanation of the categories of Business Partner information shared and the names and addresses of any third-party businesses. In limited circumstances, Business Partners' failure to submit requests in the manner specified will not require a response from the business.
If you are a California resident, you may request such information from us by sending a letter to the address listed below. In your letter, please provide your name, address and email address, as well as a request that we provide such information to you, by using the following or similar language, “I request that Dolead provide its third-party information sharing disclosures required by section 1798.83 of the California Civil Code.”
Dolead, Incorporated 50 Milk Street, 16th floor Boston, Massachusetts 02109 United States
If you have any questions, complaints or disputes regarding the manner in which we use or protect your information, please contact us using the contact information provided below. We will investigate and attempt to resolve any complaints and disputes in a reasonable time and in a manner that complies with the principles described in this Privacy Policy.
You agree to try to resolve the dispute informally first by contacting us in accordance with this Privacy Policy. We’ll try to resolve the dispute informally by contacting you via email. If a dispute is not resolved within ninety (90) days of submission, either you or Dolead may begin formal legal action, subject to the terms of this Privacy Policy. The validity, performance, construction, regulation and interpretation of this Privacy Policy shall be governed under the laws of Delaware using English language. Any dispute, controversy or claim arising out of or in connection with this Privacy Policy, or regarding any legal relations arising out of or in connection therewith, and/or the breach, termination or invalidity thereof, shall be finally settled by arbitration in accordance with the arbitration rules and procedures of Judicial Arbitration and Mediate Services. Inc. (“JAMS”) then in effect. The place of arbitration shall be Santa Clara County, California where the award shall be rendered. The arbitration proceedings shall be conducted in the English language.
Notwithstanding the foregoing, both you and the Company shall have the right to institute an action in a court of competent jurisdiction for injunction or other equitable relief. Except for the fees of the legal advisors, which shall be borne by each respective party, all other expenses and costs of arbitration shall be borne by either or both parties as the arbitration tribunal may award.
This Privacy Policy was last updated as of the date indicated above. We reserve the right to amend and revise our Privacy Policy at any time, with or without notice. For example, we may amend or revise our Privacy Policy to comply with local, state, or federal laws or to accommodate changes in technology or the needs of our users. This Privacy Policy may therefore be amended from time to time, consistent with applicable data protection and privacy laws and principles. If we make any material changes to this Privacy Policy, we will post an updated policy here.
If you have any questions or complaints about these Terms of Use or of our Website, please email us at sales.nam@dolead.com or write to us at Dolead Incorporated, 50 Milk Street, 16th floor, Boston, Massachusetts 02109, United States.
Date updated: 29 June 2022