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ARMSTRONG’S PRIVACY POLICY

Armstrong is now a brand of the MFC company:
  • Our company registration number (RCS) is 83276108400017
  • Our VAT registration number is FR55832761084
Armstrong helps his clients to optimize their online Paid media advertising strategies. Armstrong can be controller for his own activity and a processor for his clients. The MFC Company has nominated a Chief Data Office who is in charge of the GDPR compliance. You can contact him by sending an email at: privacy@byarmstrong.com.

HOW TO CONTACT US?

If you have any questions about this Privacy Policy or would like to contact us about any other matter, please use the following contact information: Mail address:
Headquarters: 14 rue de Tournon 75006
Paris Office : 127 avenue Ledru- Rollin 75011 Paris
Contact email privacy@byarmstrong.com
Phone number : + 33 1 84 79 73 91

This privacy policy applies to personal data collected and processed by Armstrong, as a controller and as a processor. Armstrong is committed to protecting the privacy of our clients. We endeavour to comply with the “Loi Informatique et Liberté” (amended 2018), the EU General Data Protection Regulation (GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 (amended) and other relevant legislation.
  1. ARMSTRONG AS A CONTROLLER
 
  1. Purposes, legal basis and data collected
We may use your personal data for the following purposes:
  • Request to try and/or use our products and services;
  • To send email newsletters to you
  • To maintain records of prospective, current and past clients and our suppliers
The legal basis for processing those data is our legitimate interest; What information we collect? We collect the following information: name and first name, email, phone number, company name, job title,
  1. Your rights regarding your personal data
You have a number of rights under data protection law, which have been strengthened under the General Data Protection Regulation (GDPR): • Access: You have the right to access the personal data we may hold about you and the purposes for which we are using it; • Rectification: You have the right to request that we amend any personal data which is incorrect or requires updating; • Erasure: You have the right to request that we delete any personal information pertaining to you. We will assess any deletion request on a case by case basis and will endeavour to respond to you as soon as possible, at most within one calendar month;
  • Objection: You have the right to object to or to request restriction of the processing;
  • Portability: You have the right to receive your Personal Information in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
  • Object to profiling: You have the right to object to profiling;
  • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority;
  • The right to withdraw your consent. Again, there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.
If you would like to exercise any of these rights, please use the following contact details:
Office : 127 avenue Ledru-Rollin 75011 Paris
Contact email privacy@armstrong.com
  1. Security, storage and transferring personal information
We will not share your personal information with any third parties for them to use for their own marketing purposes. We store and process your personal data at our registered offices in Paris. Armstrong take the protection of your personal data very seriously and we take appropriate steps to ensure your personal data is stored in a secure environment to prevent any unauthorised access. We will only retain personal data for as long as is necessary for the purposes we are using it for. How long we retain data will vary depending on the purposes it is used for. We routinely update our email newsletter lists to ensure those who are not engaged are removed. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
  1. Cookie Notice
We use cookies to operate our websites, to understand how visitors use our websites and to track your interaction with our newsletters. We will update this Notice if change the cookies we use. Cookies are text files which contain information about your internet usage that is held in your browser or on your computer’s hard drive. There are different types of cookie: some are essential for the site to operate properly, whereas others are aimed at enhancing and personalising your user experience. Cookies can help us to understand how consumers are interacting with our website, which helps us to improve our site and to deliver a better service to you.

What types of cookies do we use?

1. Strictly Necessary Cookies: These cookies are essential to enable you to move around the website and use its features. Without these cookies, we cannot provide some of the basic functionalities of our website.

2. Performance Cookies: These cookies generally collect information about how visitors use our website, for instance which pages visitors go to most often, and the pages that they don’t. This helps us to understand and improve the site, so it is easy to use and includes helpful content. They also allow us to fix bugs or glitches on the website. These cookies don’t collect information that identifies visitors, so we can’t identify you individually. We use Google Analytics to track usage of our websites and interaction with our newsletters.
  1. ARMSTRONG AS A PROCESSOR
Armstrong is a processor when processing data for a controller, in full service or not.
Definition of what we do for our clients
Armstrong is helping clients to optimize their paid media strategy by….
  1. Purposes, legal basis and data collected
The legal basis of processing the data here is the contract between Armstrong and their clients. Our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you, for example for the purpose of providing you with our services or creating your user account.
What kind of data we collect?
To create an user account, we need the following information: …..

Our clients accept to give us their customer databases (CRM data). The information of customers we can find in this files are: ………………;
  1. The rights for customers regarding their personal data
Customers have a number of rights under data protection law, which have been strengthened under the General Data Protection Regulation (GDPR):
As a processor, Armstrong is not accountable for responding this kind of request from customers. It is the responsibility of Armstrong’s client, as a controller.
  1. Security, storage and transferring personal information
We store and process the personal data at our registered offices in Paris. Armstrong take the protection of personal data very seriously and we take appropriate steps to ensure personal data is stored in a secure environment to prevent any unauthorised access. We will only retain personal data for as long as is necessary for the purposes we are using it for. How long we retain data will vary depending on the purposes it is used for. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

According to what is defined in the contract between Armstrong and his client, CRM files can be transferred to media platforms such as Facebook, Linkedin, Google, Twitter, Instagram, … that are not processed in the EEE.

But it is Armstrong’s client responsibity to be sure that the final customer agrees that his data could be used for retargeting. Armstrong’s client have to obtain the consent and, as a controller, has to be able to give Armstrong the proof of consent.

Armstrong will not create new profiles on the precited platforms but only matches the CRM files with already created profiles on the platforms. So the customers have already accepted the platforms’ policy privacy.