Privacy Policy

PRIVACY POLICY

We process your data

Any reference to the term "data" in this Data Protection Policy means personal data, that is, any information relating to an identified or identifiable natural person.

that is, the company TPL Investment 1 (trading under the commercial name "GLOOH Media"), are the data controller for the data that

You

customer, website visitor or supplier, provide to us.

We scrupulously comply with the applicable legislation in this area, as in all others. This Data Protection Policy, which is intended to inform you, is one example of this.

We may make changes to this Data Protection Policy from time to time. In that case, we will make sure to identify the changes we have made on this page. If substantial changes were to be made to this Policy, you may be informed by email.

How do we collect your data?

In general, you provide us with your personal data yourself, by completing a form on our website, through the services we offer, or during an exchange with a member of our sales team or our customer service.

We may also collect your data through a third party, such as Facebook or Google for example, when you choose to register on the management platform using these third-party accounts.

Is your data transferred to third parties?

For certain processing operations, as specified below, your data may be transmitted to third parties (for example: in order to manage your order, manage our contractual relationship, etc.).

We sign confidentiality agreements as well as contracts relating to the processing of personal data with these third parties, to ensure that they comply with the legislation in this area. We review these documents whenever necessary.

Why do we process your data?

Provision of our services

*Purpose *

–

The data you provide to us is of course processed to enable you to benefit from our services (development of a solution, maintenance services, etc.) and in order to communicate with you on this subject.

*Legal basis –*

The personal data processed is essential for the performance of the contract.

*Categories of data –*

Identification data: last name, first name, username
Contact data: email address, telephone number, mobile phone number, postal address
Online account data: settings, usage data of your online account
Login data: username and password, IP address, operating system version, device type, device ID, MAC address, information about the system and its performance, your browser type and the universally unique identifier (UUID) when connecting via a mobile device, timestamp information

All of this data is therefore essential for the performance of the assignment you entrust to us. Without it, we cannot carry out our assignment successfully.

*Recipients of the data –*

Their disclosure to third-party providers such as content creators may be necessary for the performance of our assignment. The list of these third-party companies is available on request at docs@glooh.media. Your data may also be processed by the host of our website, by the host and provider of our IT services and by several payment service providers, for the purposes strictly necessary to comply with the instructions we give them. They act as processors in this regard.

*Duration –*

The data you entrust to us is kept for 10 years, in particular to comply with our tax and accounting obligations, as well as for reasons of contractual liability.

Management of our contractual relationship

*Purpose –*

Your contact and financial data is also used to invoice our services and recover payment for them, or to notify you of a change to the contract or to the Data Protection Policy (in particular new purposes). This data is therefore essential for the performance of our contract. Without it, we cannot carry out our assignment successfully.

*Legal basis –*

The personal data processed is essential for the performance of the contract.

*Categories of data –*

The following data may be processed:

Identification data: last name, first name, username
Contact data: email address, telephone number, mobile phone number, postal address
Economic and financial data: bank details (account number, account holder, etc.)

*Essential –*

All of this data is therefore essential for the performance of the assignment you entrust to us. Without it, we cannot carry out our assignment successfully.

*Recipients of the data –*

The data is also transmitted to the tax and social security authorities, to our payroll agency and to our accountant. It could be transmitted to our legal counsel or to a bailiff in the event of judicial debt recovery. Your data may also be processed by the host of our website, by the host and provider of our IT services and by several payment service providers, for the purposes strictly necessary to comply with the instructions we give them. They act as processors in this regard.

*Duration –*

We are required to keep this invoicing data until our tax and accounting obligations expire, that is, for 7 full tax years from 1 January of the financial year following the date of purchase of our products or delivery of our services.

Promotion of our services and personalized services

*Purpose (1) –*

Keeping you informed.

Your personal data is processed to promote our products and services by various means. In this way, we can keep you informed about our products and services.

*Legal basis*

* –*

If you have subscribed to our newsletter or if you have agreed to the placement of cookies, your consent justifies our carrying out information operations (about our news, our events, etc.) or operations promoting our services (sending personalized promotional offers, etc.). This consent can be withdrawn at any time. In the absence of consent, our legitimate interest in promoting our services could justify our sending you this type of communication, which you may object to at any time without justification.

*Categories of data –*

The following data may be processed:

Identification data: last name, first name, username
Contact data: email address, telephone number, mobile phone number, postal address
Internet tracking data: cookies, trackers, browsing data

*Recipients of the data – *

The data is transmitted to an email marketing service.

*Duration –*

We keep your data for this purpose until you ask us to stop, and for a maximum of 5 years after your last contact with us.

The retention period for each type of cookie is indicated in our cookie policy.

If you do not wish to receive personalized marketing content on the Web in connection with our service, you can delete cookies via your browser settings. See the article in our Help Center on this procedure.

*Purpose (2) –*

Informing certain third parties.

If you give us your consent, we may rely on our contractual relationship for up to 5 years after it ends in order to facilitate a sale, merger or transfer of all or part of our company or business, or the preparation of such events. In this case, we may indeed be required to disclose the names of some of our customers. The information disclosed does not, under any circumstances, relate to your private life.

Statistics on our services, improvements for our future services

*Purpose –*

Our legitimate interest justifies our processing some of your data in order to improve our products and services.

*Categories of data – *

The following data may be processed:

Internet tracking data: cookies, trackers, browsing data, log files

*Recipients of the data –*

We are the sole recipients of this data.

*Duration *

*–*

We keep your data for this purpose until you ask us to stop, and for a maximum of 5 years after your last contact with us.

The retention period for each type of cookie is indicated in our cookie policy.

Management of the solution we make available to you

*Purpose – *

We may process your personal data when we seek to detect, prevent or address fraudulent activities, security breaches or any technical issues.

We may also process your personal data when we conduct an audit to verify compliance with the terms of the license for the solution (and the software that comprises it).

*Legal basis –*

The personal data processed is essential for the performance of the contract.

*Categories of data –*

The following data may be processed:

Internet tracking data: cookies, trackers, browsing data, log files,
Online account data: settings and data relating to the use of your online account
Login data: username and password, IP address, operating system version, device type, device ID, MAC address, information about the system and its performance, your browser type and the universally unique identifier (UUID) when connecting via a mobile device, timestamp information

*Recipients of the data –*

Your data may also be processed by the host of our website, by the host and provider of our IT services and by several security service providers, for the purposes strictly necessary to comply with the instructions we give them. They act as processors in this regard.

*Duration –*

The data you entrust to us is kept for 10 years for reasons of contractual liability.

Social networks

*Purpose –*

The data you provide when visiting our pages on social networks is or could be processed jointly by the social network and the administrator of that page for the following purposes:

the collection of certain data by means of cookies;
the improvement by the social network of its advertising system;
obtaining audience statistics for the page.

This data will only be processed by the page administrator within the scope of its legitimate interest in obtaining statistics on the visitors to its page in order to promote its page appropriately. The audience statistics compiled by the social network are only transmitted to the page administrator in anonymized form.

*Categories of data – *

The data linked to your account on the social network in question and the data linked to the sharing of content or to the communications you have with other people may be processed.

*Duration – *

This data is or could be processed for as long as the page exists and you visit it.

The personal data use policies of each social network can be found by clicking on the following links:

[Facebook and Instagram](https://www.facebook.com/legal/terms/information_about_page_insights_data)

[Twitter](https://twitter.com/fr/privacy)

[Youtube](https://policies.google.com/privacy?hl=fr&gl=fr)

[Linkedin](https://www.linkedin.com/legal/privacy-policy?trk=hb_ft_priv)

Is your data transferred outside the European Union?

Your data is, in principle, exclusively stored on servers located within the European Union.

We may nevertheless use processors located outside the European Union, or using servers located outside the European Union. In that case, we naturally ensure that they comply with the same standards of personal data protection as in the European Union, by means of appropriate contractual clauses. You can obtain a copy of these safeguards upon simple request.

What are your rights as a data subject?

*Information –*

This right is exercised through this document. If the data processed includes data relating to your staff, you undertake to bring this document to their attention.

*Access and rectification –*

You have the right to access your data and to have it rectified where appropriate.

*Objection –*

You may object to the processing of your data that we carry out on the basis of our legitimate interest.

*Withdrawing your consent –*

Where data is processed on the basis of your consent, you may reverse that decision at any time, without calling into question past processing.

*Erasure –*

You may obtain the erasure of your data or the restriction of processing under the conditions provided for

[ in Articles 17 and 18 of the General Data Protection Regulation](http://eur-lex.europa.eu/legal-content/FR/TXT/?uri=CELEX%3A32016R0679)

*Portability –*

The data you have provided to us can be communicated to you in electronic format.

Who should you contact?

The controller of your data, TPL Investment 1, is at your disposal for any questions and, subject to proof of your identity, for any request relating to the rights set out above. For these matters, the following contact details should be used:

TPL Investment 1 SRL (Glooh Media)

Rue des Guillemins, 139

4000 Liège,

Belgium

Or by email at

[docs@glooh.media](mailto:docs@glooh.media)

If you would like further information, or if you wish to lodge a complaint, you can contact the Data Protection Authority (Rue de la Presse, 35 – 1000 Brussels, Tel. + 32 2 274 48 00 – https://www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte,

[contact@apd-gba.be](mailto:contact@apd-gba.be)

1. Definition of cookies

Cookies (or "trackers") are small pieces of data that we store on the device (computer, mobile phone, tablet or other mobile device) you use to access the Glooh Media websites (Sites) in order to recognize returning users. Each cookie expires after a certain period, depending on the use we make of it. Like many commercial websites, Glooh Media uses cookies on its web pages. We use cookies for various purposes. Below is the list and description of the different cookies we use on our site.

By using the Glooh Media websites, you expressly agree to the use of cookies as described on this page and in our Privacy Policy. You will find below details about the different cookies we use on our Sites.

2. Why do we use cookies?

We use the following categories of cookies on our sites:

Cookies essential to the proper functioning of the site;
Functional cookies; and
Analytics cookies

*Essential cookies*

To manage the proper functioning of our websites, we place

essential

cookies. Since these cookies are necessary for the proper technical functioning of the websites, you cannot refuse them.

*Functional cookies*

We also use so-called

functional

cookies. These cookies enable certain additional features on our websites, such as those that store your preferences (e.g., your username and selected language) and prevent users from responding to the same survey multiple times. This latter feature improves the user experience.

These cookies are therefore necessary for the proper functioning of this website. It is not possible to refuse these cookies if you want to visit our website, download our templates or consult us online.

*Analytics cookies*

In addition, cookies for

marketing and social media sharing

purposes are placed. The use of these third-party cookies is subject to your prior consent. You can therefore refuse to have these cookies installed on your device. You will not, however, be denied access to our site. Nevertheless, some features may not be available.

These are "third-party" cookies. We therefore do not control the information that is collected. Their use is subject to your prior consent and you can refuse to have these cookies installed on your device. You will not, however, be denied access to our sites. Nevertheless, some features may not be available.

Marketing cookies are used to track visitors across websites. The aim is to display advertisements that are relevant and interesting to the individual user and therefore more valuable to third-party publishers and advertisers.

For example, if you visit our websites, a Glooh Media advertisement may be displayed on certain third-party websites that you visit later.

We may use cookies provided by third parties to track the performance of our advertisements. These cookies remember, for example, the browsers used to visit our websites. The information provided to third parties does not include any personal data, but may subsequently be associated with personal information. This helps us manage and monitor the effectiveness of our marketing strategies.

We also work with third-party advertising networks that may collect IP addresses and other information from web beacons on our websites, our emails and third-party websites. Advertising networks track your online activities over time by collecting browsing information using automated processes, such as cookies. They use this information to deliver advertisements for products and services that may interest you. You may see these advertisements on other websites. This also helps us manage and monitor the effectiveness of our marketing strategies.

Finally, we use

analytics

cookies that collect information about your use of the sites, which allows us to improve how they work. For example, analytics cookies show us the pages you visit most often on the Sites, help us record the problems you encounter on the Sites and show us how effective our advertising is. This allows us to see usage patterns of the Sites on an aggregate rather than individual basis. We use this information to analyze Site traffic.

3. Which cookies do we use?

*List of essential cookies*

*List of functional cookies*

(Not used at the moment)

*List of marketing and social media sharing cookies*

*List of analytics cookies*

Statistics cookies help website owners understand how visitors interact with websites by collecting and reporting information anonymously.

4. HOW CAN I SEE WHICH COOKIES ARE INSTALLED ON MY DEVICE AND HOW CAN I DELETE THEM?

You can delete or disable cookies in your browser if you wish. Refer to your browser's configuration documentation for the procedure for disabling or deleting cookies. Please note that disabling cookies may affect your ability to use our services properly. Enabling cookies allows you to take full advantage of our sites.

You will find further explanations on how to proceed via the links below:

[Internet Explorer](https://support.microsoft.com/fr-be/help/17442/windows-internet-explorer-delete-manage-cookies)

[Firefox](https://support.mozilla.org/fr/kb/effacer-les-cookies-pour-supprimer-les-information)

[Microsoft Edge](https://support.microsoft.com/fr-be/help/4027947/microsoft-edge-delete-cookies)

[Firefox (mobile)](https://support.mozilla.org/fr/kb/supprimer-donnees-perso-firefox-android)

[Chrome](https://support.google.com/chrome/answer/95647?hl=fr)

[Safari](https://support.apple.com/fr-be/guide/safari/sfri11471/mac)