1. Scope and roles
This policy covers professional contacts at clients, prospects and partners, and information needed to prepare, deliver and monitor TPTA services. For the management of its own contacts, prospects, clients, suppliers and partners, THE PLACE TO AD acts as controller. When TPTA processes information on a client’s instructions, the roles of TPTA and the other parties are defined in the contractual documents for the project.
2. Geo-Personas and SAT
Geo-Personas and the Territorial Affinity Score (SAT) are designed to qualify audience segments and geographic areas. TPTA does not seek to identify people or assign a score to an individual. SAT helps prioritise areas for a media campaign and does not produce legal or similarly significant effects for a person.
3. Categories of information
- professional contact details, roles and organisations;
- briefs, objectives, campaign parameters and project communications;
- contractual, administrative and billing information;
- aggregated or contextual information about areas, points of interest and audience segments;
- delivery, performance and reporting indicators supplied by media partners.
TPTA does not ask clients to provide sensitive or directly identifying data to build a Geo-Persona unless this has been agreed in advance under an appropriate contractual and legal framework.
4. Sources of information
Information comes from the people concerned, clients and partners involved in the project, media and measurement platforms used for the campaign, and public sources or data suppliers selected according to the project’s needs.
5. Purposes and legal bases
- prepare a recommendation and respond to a brief: pre-contractual steps;
- design Geo-Personas, define the media plan, activate, monitor and report on campaigns: performance of a contract;
- manage client relationships, secure operations and defend TPTA’s rights: legitimate interests;
- manage billing, accounting and regulatory duties: legal obligations;
- send relevant business communications: legitimate interests or consent where required.
6. Recipients
Information is accessible to authorised TPTA personnel and, depending on the service, necessary processors and partners: communications and billing providers, data suppliers, programmatic platforms, DSPs, SSPs, media owners, measurement partners and other media service providers. Each recipient only receives information necessary for its role. Some partners may act as independent controllers under their own obligations.
7. Retention
- prospect information: up to three years after the last contact;
- client and project information: for the contractual relationship, followed by the period needed to establish and defend legal rights;
- invoices and accounting records: ten years under applicable requirements;
- campaign operational data: for the period specified in the contract and relevant partner rules, then deleted or anonymised when no longer required.
8. International transfers
International campaigns or certain providers may involve processing outside the European Economic Area. Where required, TPTA relies on an adequacy decision, standard contractual clauses or another appropriate safeguard.
9. Security and confidentiality
TPTA applies organisational and technical measures proportionate to the risks and requires its providers to protect entrusted information. Access is limited to people who need it to deliver the service.
10. Your rights
You may request access, correction, deletion or restriction and, depending on the processing, object or request portability. Contact operations@theplacetoad.com. You may also lodge a complaint with the French data protection authority (CNIL).
11. Project-specific information
Where TPTA processes personal data on a client’s behalf, instructions, safeguards, retention periods, data subjects and assistance arrangements are set out in the contract or a data-processing agreement. If they differ, those project-specific terms apply to the relevant project.