Last Updated: May 10th, 2016

PRIVACY POLICY

Make The Link SAS is taking privacy and web data protection seriously

Make The Link provides a Platform that enables our Clients to manage their digital data subject to their own privacy policies. In that way, we enable our Clients to manage their data in a responsible way and we empower both account holders and non-account holders (either, the “Users”) to better understand what data is collected via the Platform and how it is used.

Make The Link Technology Platform

Make The Link is an agent working under the direction of our Clients that use our Platform to generate a dedicated landing page including a player showcasing our Clients content (a “Campaign”). Once a Campaign is launched, we offer a data management Platform that collects certain personal information that can be used to identify Users, via their name and email address (“Personally Identifiable Information” or “PII”) when they accept the “Social Connect” applications from the Platform. We don’t place sensitive PII on the Platform nor do we allow our Clients to do so. We use a number of different technologies to maintain user state, collect data, and to help us operate the Platform and describe some of them below.

HTTP Cookies

Make The Link uses cookies on the Platform. Cookies are small, often encrypted text files, located in browser directories. All Make The Link cookies other than the Make The Link Opt-Out cookie expire automatically if inactive for six (6) months. When visiting the Platform, Users are assigned a Make The Link user ID that is placed into an HTTP cookie which is then placed on Users computer or device.

Pixel Tags

We also use pixel tags in connection with the Platform. Pixel tags (also known as web beacons) are small strings of html or JavaScript code that provide a method for delivering a graphic image on a Web page or other document. Pixel tags may be used to obtain information about the computer or device being used to view a particular Web page such as the IP address of the computer or device to which the pixel tag is sent, the time it was sent, the computer or device’s operating system and browser type, and similar information.

How we collect and use PII via our Platform

Make The Link offers our Platform for our Clients to collect PII related to Users visits (our Client’s “Session Data”). This Session Data may include information about how Users came to the Platform, which search engines they use, the search terms used to find the Platform, their experience Platform, information about how they interact with the Platform, demographic information, data from third-party data providers, browser type and language settings, access times, and referring website addresses. We use Session Data to administer the Platform and analyze. Our clients may engage third parties to analyze Session Data to enable Clients to better understand Users across multiple computers and devices, to better target messages, advertisements and for reporting purposes. We make Session Data accessible only to each individual Client. 

Information we collect automatically when you use a “Social Connect” App

Account holder Information

Our Clients can choose to create a Campaign allowing Users to connect to the Platform via a “Social Connect” app. We’ll extract from Facebook Account, Google Account, Spotify Account, Deezer Account, Twitter Account or SoundCloud Account (as applicable) PII, the privacy settings that the Users have established on Facebook, Google, Spotify, Deezer, Twitter, SoundCloud, and  permit us to access. Our Clients we’ll be able to access and collect certain information, including Users PII, that Users privacy settings on such Third Party Account permit us to access. We may also collect Users gender, zip code and other information posts that Users liked, music, movies, books that Users listened, watched, read and other statistics, that are not considered PII because it cannot be used by itself to identify Users. Our Clients may use location information to improve and personalize their communications to the Users. In the event we are required to disclose information in response to legal process or a government request, we will attempt to notify affected Users to the extent we are legally permitted to do so.

Make The Link does not directly share Non-PII with either partners or third parties. Clients may choose to share their Non-PII data with others at their discretion.

Our Policy Toward Children

Our Clients are not directing our Platform to children under 13 and we do not knowingly collect PII from children under 13. If we learn that we have collected PII of a child under 13 we will take steps to delete such information from our files as well as our clients files, as soon as possible.

Your Choices

Opt-Out

Make The Link offers a one click opt-out solution located at: www.mtl.fm/login for Users who wish to opt-out of targeting.  If you choose to opt-out, Make The Link deletes any targeting data it may have for your browser, and we will no longer enable our Clients to target that browser using our  Platform.

Modifying Your Information

Users can access and modify the PII associated with their profile on their account by editing it through web forms available on www.mtl.fm/login. If you want us to delete data related to your account, please contact us at privacy@makethelink.com with your request. We’ll take steps to delete your information as soon we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.

Responding to Do Not Track Signals

Our Platform does not have the capability to respond to “Do Not Track” signals received from various web browsers. Users may opt out for the collection of their social metrics using the features available on the services.

Data Retention

Our cookies and similar tracking technologies expire six (6) months from the last time our systems encounter a particular computer or device. We do not use any Session Data that is more than twenty-four (24) months old for user profiling or targeting. After 24 months, we remove any unique identifiers and store the data for up to 5 (five) years.

Security / Integrity

We take commercially reasonable efforts to maintain security protections in accordance with industry “best practices” to protect data we collect from loss, alteration, destruction, misuse and unauthorized access or disclosure. All Make The Link employees are bound by confidentiality obligations and may be subject to disciplinary or legal action if they fail to meet these responsibilities.

We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.

Make The Link is based in France, and this Privacy Policy will be governed by the laws of France without giving effect to any conflicts of law principles that may require the application of the laws of a different country.

Changes and questions

From time to time, we may update this Privacy Policy to reflect changes in industry standards or evolving legal requirements when necessary and all changes will comply with regulatory, legal, and industry standards. Please review this Privacy Policy from time to time to remain informed regarding how Make The Link is protecting Users information.

If you have any questions regarding this Privacy Policy, or if you would like additional information, please contact us at privacy@makethelink.com or postal mail at 11 rue Carpeaux, 75018 Paris France.

Last Updated: May 10th, 2016