General Personal Data Protection Policy

To file a complaint or exercise your rights, please write to: contact@madeintracker.com

This “Personal Data Protection Policy” (the “Policy”) informs all data subjects (“you”, “your”) about:

• how MADE IN TRACKER(“Made In Tracker”, “we”) processes your personal data as data controller, in the context of operating the MD Atlas site (dm-atlas.fr / md-atlas.com, the “Site”);
• the rights you have in this respect.

1. Scope of this personal data protection policy

EU Regulation 2016/679 of the European Parliament and Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”), in force since 25 May 2018, applies to all undertakings that collect, store or process personal data.

The concept of personal data (“Personal Data”) refers to any information relating to an identified or identifiable natural person. An “identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

Made In Tracker transparently processes your Personal Data in the following situations:

• when you create a user account on MD Atlas;
• when you subscribe to our newsletter;
• when you contact us via our contact forms or by email;
• when you visit the Site dm-atlas.fr / md-atlas.com.

2. Processing of your Personal Data when creating a user account

2.1 Purpose, legal basis and Personal Data processed

When creating an account on MD Atlas, the following Personal Data is collected and processed:

• email address (required);
• password, stored hashed (never readable in clear text).

This Personal Data is used to create, manage and secure your user account, grant access to the Site's features and authenticate you. It is collected and processed on the basis of MD Atlas's legitimate interest in managing its public relations and replying to you, in accordance with Article 6.1.f) GDPR.

2.2 Retention period

Made In Tracker retains this Personal Data for the entire active life of your account. In the event of prolonged inactivity, the account and associated data are deleted after 5 years of inactivity. You may also request deletion of your account at any time.

2.3 Transfer and recipients of Personal Data

Made In Tracker does not transfer the collected data outside the European Union.

2.4 Recipients of Personal Data

Personal Data may be communicated to Made In Tracker staff who need it for the performance of their duties, to services in charge of controlling Made In Tracker, and to authorities where Made In Tracker is legally required, or where such disclosure is necessary to enforce the general terms or other agreements, protect your rights, your property or those of Made In Tracker.

2.5 Your rights over your Personal Data

Under the GDPR, you have rights of access, rectification, erasure, restriction of processing, data portability, objection to processing, and the right to decide what happens to your data after your death.

Exercise your rights by writing to contact@madeintracker.com.

If you believe the processing does not comply with the regulation, you may lodge a complaint with the CNIL:

CNIL – Complaints department
3, place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07
Tel: +33 1 53 73 22 22
www.cnil.fr

3. Processing of your Personal Data for the newsletter subscription

3.1 Purpose, legal basis and Personal Data processed

When you subscribe to our newsletter, the following Personal Data is processed:

• email address;
• consent record (date, timestamp, source).

This Personal Data is used to send you editorial communications, news and information about MD Atlas. It is collected and processed on the basis of your consent, under Article 6.1.a) GDPR.

You can withdraw your consent and unsubscribe at any time via the unsubscribe link in every email, or by writing to contact@madeintracker.com.

3.2 Retention period

Your data is retained until you unsubscribe. After unsubscription, the email address may be kept as evidence of consent withdrawal for the applicable limitation period.

3.3 Transfer and recipients of Personal Data

Newsletter technical management is handled by our provider Brevo (formerly Sendinblue SAS), headquartered in Paris, France. Data is processed within the European Union. Made In Tracker does not transfer the collected data outside the European Union.

3.4 Recipients of Personal Data

Personal Data may be communicated to Made In Tracker staff who need it for the performance of their duties, to services in charge of controlling Made In Tracker, and to authorities where Made In Tracker is legally required, or where such disclosure is necessary to enforce the general terms or other agreements, protect your rights, your property or those of Made In Tracker.

3.5 Your rights over your Personal Data

Under the GDPR, you have rights of access, rectification, erasure, restriction of processing, data portability, the right to withdraw your consent at any time, and the right to decide what happens to your data after your death.

Exercise your rights by writing to contact@madeintracker.com or file a complaint with the CNIL.

4. Processing of your Personal Data when sending a message via the contact form

4.1 Purpose, legal basis and Personal Data processed

If you contact Made In Tracker via the Site's contact form or by email, Personal Data concerning you may be transmitted to us and processed on that occasion:

• name;
• email address (required);
• organization (if applicable);
• message content;
• and any Personal Data you choose to share with Made In Tracker in your messages.

This Personal Data is used to handle your message and reply if a reply is required, as well as to improve Made In Tracker's services. It is collected and processed on the basis of Made In Tracker's legitimate interest in managing its public relations and replying to you, under Article 6.1.f) GDPR.

4.2 Retention period

Made In Tracker retains this Personal Data for the entire time necessary to handle your message and any follow-ups, then for an additional period of 5 years from the date of the message as evidence, in accordance with the applicable limitation period. After these periods, the Personal Data is deleted.

4.3 Transfer and recipients of Personal Data

Made In Tracker does not transfer the collected data outside the European Union.

4.4 Recipients of Personal Data

Personal Data may be communicated to Made In Tracker staff who need it for the performance of their duties, to services in charge of controlling Made In Tracker, and to authorities where Made In Tracker is legally required, or where such disclosure is necessary to enforce the general terms or other agreements, protect your rights, your property or those of Made In Tracker.

4.5 Your rights over your Personal Data

Under the GDPR, you have rights of access, rectification, erasure, restriction of processing, data portability, objection to processing, and the right to decide what happens to your data after your death.

Exercise your rights by writing to contact@madeintracker.com. You may also file a complaint with the CNIL.

5. Processing of your Personal Data when you visit the Site

5.1 Purpose, legal basis and Personal Data processed

When you visit our website, the browser used by the visitor automatically sends data to our Site's server and stores it in a log file for a limited period. The following data is stored without further input from the visitor until automatic deletion:

• the visitor's device IP address (anonymized for audience measurement);
• date and time of access by the visitor;
• name and URL of the page visited by the visitor;
• website from which the visitor arrives on the Site (referrer URL);
• the browser and operating system of the visitor's device, and the name of the visitor's access provider.

Processing of this personal data is justified under Article 6.1.f) GDPR. Made In Tracker has a legitimate interest in processing the data in order to:

• quickly establish a connection with the Site;
• allow a user-friendly use of the Site;
• recognize and ensure system security and stability;
• facilitate and improve Site administration.

Processing does not expressly aim to personally identify the visitor of the Site.

5.2 Retention period

In the context of your visit to the Site dm-atlas.fr / md-atlas.com and in accordance with applicable European regulation, Made In Tracker retains the data listed above for a period of 12 months, along with any other applicable legal periods.

5.3 Transfer and recipients of Personal Data

Personal data is transferred to third parties if:

• the data subject has expressly consented under Article 6.1.a) GDPR;
• disclosure is necessary to assert, exercise or defend legal claims under Article 6.1.f) GDPR and there is no reason to assume that the data subject has an overriding legitimate interest in not disclosing their data;
• a legal obligation to transmit the data exists under Article 6.1.c) GDPR; and/or
• it is necessary for the performance of a contractual relationship with the data subject under Article 6.1.b) GDPR.

In other cases, personal data is not transmitted to third parties.

5.4 Recipients of Personal Data

Personal Data may be communicated to Made In Tracker staff who need it for the performance of their duties, to services in charge of controlling Made In Tracker, and to authorities where Made In Tracker is legally required, or where such disclosure is necessary to enforce the general terms or other agreements, protect your rights, your property or those of Made In Tracker.

5.5 Your rights over your Personal Data

Under the GDPR, you have rights of access, rectification, erasure, restriction of processing, data portability, objection to processing, and the right to decide what happens to your data after your death.

Exercise your rights by writing to contact@madeintracker.com. You may also file a complaint with the CNIL.

5.6 Cookies

Our Site uses “cookies”. They are small data packets exchanged between the Site's server and the visitor's browser. They are stored on the devices used (PC, laptop, tablet, smartphone, etc.) during the visit to the Site.

Cookies cannot harm the devices used. In particular, they contain no viruses or other malicious software. The information stored in cookies comes from the specific device used. Made In Tracker cannot, by these means alone, obtain direct knowledge of the identity of the Site visitor.

Cookies are used to:

• make the online service more practical to use (session cookies, automatically deleted after leaving the Site);
• improve Site usability (temporary cookies that recognize the visitor on a new visit so they do not need to repeat certain entries or settings);
• analyze Site visits for statistical purposes and improve the service (audience-measurement cookies automatically deleted after a defined period).

The data processed by cookies serves the purposes above to safeguard Made In Tracker's legitimate interests under Article 6.1.f) GDPR, or, where required by law, on the basis of your prior consent collected via the cookies banner.

Summary of cookies used on MD Atlas

You can prevent these cookies from being stored by selecting the appropriate settings in your browser, or by withdrawing your consent via the Site's cookies preferences module.

5.7 Google Analytics 4

We use Google Analytics 4on our Site, an audience-analysis service provided by Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA — “Google”).

Google Analytics 4 allows us to measure Site traffic and usage (pages viewed, session duration, traffic source, device type) to improve content and user experience. IP addresses are anonymized before any processing.

Processing is based on Made In Tracker's legitimate interest in measuring and improving Site audience, under Article 6.1.f) GDPR, or, where required by law, on your consent collected via the cookies banner.

The transfer of data to the United States, which cannot be excluded when using Google services, is based on EU Standard Contractual Clauses. Details are available here:
https://policies.google.com/privacy/frameworks
https://privacy.google.com/businesses/controllerterms/mccs/

You can opt out of Google Analytics tracking by installing the browser add-on Google provides for that purpose, or by refusing analytics cookies via the Site's cookies preferences banner.

6. Security of Personal Data

In line with the state of the art, Made In Tracker has put in place physical, electronic, organizational and technical safeguards to prevent any loss, misuse, unauthorized access or disclosure, alteration or destruction of your Personal Data. These measures include:

• password hashing;
• encryption of communications via HTTPS/TLS;
• database hosting within the European Union (Supabase, EU region – Frankfurt);
• access controls limiting data access to authorized personnel only;
• use of reputable providers offering sufficient guarantees of security and GDPR compliance.

7. Links to websites not controlled by Made In Tracker

The Site may offer links to third-party websites that may be of interest to you.

Made In Tracker has no control over the content of third-party sites or over the personal data protection practices of those third parties. Accordingly, Made In Tracker declines all responsibility for the processing of your Personal Data by such third parties on those sites.

It is your responsibility to inform yourself about those third parties' personal data protection policies.

8. Data controller and contact

The data controller is:

MADE IN TRACKER
Email: contact@madeintracker.com

For any question concerning this Policy, or to request exercise of rights over your Personal Data, you can contact us at the email address above.

9. Evolution of the personal data protection policy

This Policy may be modified or amended at any time, in particular in the event of legal, judicial or regulatory developments, CNIL decisions or recommendations, or evolving practices.

Any new version of this Policy will be brought to your attention by any means chosen by Made In Tracker, including electronic means (distribution by email or online notice published on the MD Atlas Site).

We invite you to consult the Policy regularly for updates.