Privacy Policy
As part of its activities, STRICS ADS SA processes information concerning you. You provide us with information, some of which is of a nature that can identify you (“personal data”).
This Privacy Policy informs you of how STRICS ADS SA collects and processes your personal data via its website relead.tn relead.tn and Platform, in its capacity as data controller, within the meaning of the provisions of Organic Law No. 63 of July 27, 2004 on the protection of personal data (hereinafter referred to as the “Regulation”).
We invite you to read it carefully.
- We only use your personal data in the cases provided for by the applicable regulation:
- The performance of a contract we have concluded with you.
- Compliance with a legal obligation.
- Your consent to the use of your data.
- The existence of a legitimate interest in using your data.
The collection of personal data can only be carried out for lawful, specific, and explicit purposes.
1. Definitions from the Regulation
The following definitions are those set out in Law No. 63-2004.
Personal data
Means any information, regardless of its origin or form, which directly or indirectly identifies or makes identifiable a natural person, except for information related to public life or considered as such by law.
Data Controller
Means any natural or legal person who determines the purposes and means of the processing of personal data.
Processor
Means any natural or legal person who processes personal data on behalf of the data controller.
Processing
Means any operation, whether automated or manual, carried out by a natural or legal person, the purpose of which includes in particular the collection, recording, storage, organisation, modification, exploitation, use, sending, distribution, dissemination, destruction or consultation of personal data, as well as any operation relating to the exploitation of databases, indexes, directories, files, or interconnection.
2. Who is responsible for the processing of personal data carried out through the site?
The company STRICS ADS SA (hereinafter “Relead” or the “Company” or “We”) is a limited liability company whose registered office is located at: Pépinière d’entreprises SoftTech, Technopole de Sousse – 4011 Tunisia, represented by its Manager, Mrs. Hadhami Rjiba, Chief Executive Officer of Relead. Whenever Relead determines the purposes and means of processing your personal data, it will be considered as the data controller and will assume all obligations imposed on it by the Regulation. A dedicated contact person for data protection matters can be reached at:
- Email: support@relead.tn
- Phone: +216 51 536 919
3. How is your personal data collected ?
➢ We collect the personal data that you provide to us directly:
This refers to personal data that you, the visitor to our website (hereinafter “the Visitor”), provide directly by filling in our collection forms, in particular those available online on our Website (e.g. name, email address, phone number, website). This includes contact data as well as any other information you choose to share with us, including via email, telephone, or messaging. We also collect personal data that you, the visitor in the area covered by our free Wi-Fi (hereinafter “the Visitor”), provide in the context of using the Platform and performing our Services, namely data relating to gender, age, and MAC address, which are necessary to respond to your requests and enable the provision of the Service. We may also collect data that you voluntarily provide when contacting our teams, during physical meetings (appointments, trade shows, events…) or remotely (by phone call or software demonstration, for example). The data collected by Relead may be mandatory or optional. Mandatory data is indicated in each form with an asterisk. When data is collected orally, we will inform you whether it is mandatory or optional. Any data you provide voluntarily is, by definition, optional.
➢ We collect some of your personal data automatically
When you visit the Site or Platform, certain data is automatically recorded through your browsing traces, either
indirectly via third-party cookies or directly via server event logs (log files) by those managing the site or Platform.
This is your browsing data.
When the collection of this navigation data is mandatory, they are collected in order to ensure the provision of the Site or the Platform, its improvement and the maintenance of a secure environment.
When collection is optional, your consent is previously obtained for the browsing data used to measure the audience of our site and the performance of our campaigns, optimize prospect management, offer you targeted advertising, analyze your online behavior. Internet user and/or to increase the interactivity of our Site and our Platform by offering you a news feed.
These may include :
For example, your IP address, the address of the website you are visiting, your search engine and its settings, the date and time of connection, the way you browse the site and all other data tracking your use of the site.
Depending on the equipment you use and the activated settings, the following data may in particular be collected: the type of equipment (mobile phone, tablet, PC, MAC, etc.) and the operating system you use as well as their settings.
Data collected indirectly
Relead may also collect data indirectly through prediction and detection models,
We may collect data identified as professional about you, from your profiles:
Audiences originating from a professional social network that you use,
Derived through prediction and detection models.
In any case, from the first contact, we remind you that this Policy will be made available to you by means of a hypertext link.
4. For what purpose and for how long do we use your personal data ?
We use your data for the following purposes:
Relead helps advertisers reach target audiences via Wi-Fi advertising and monetise Wi-Fi access points in its partner network. Relead provides users with free Wi-Fi and customised advertising.
This data is collected in one of the cases provided for by the Regulations.
Your personal data is only used in the cases provided by the Regulation. It is automatically deleted 2 years after your last contact with Relead.
Identity document data relating to the exercise of rights (access, rectification, deletion, limitation, erasure, portability) is retained for 1 year from receipt.
In case of legal proceedings, personal data will be retained to allow Relead to defend its interests.
5. Who receives your personal data?
➢ Within Relead (internal recipients)
Personal data is processed by Relead staff members authorised according to their role and bound by confidentiality obligations. This includes:
Relead’s legal representatives
Relead’s sales manager.
Your account manager.
Technical team members handling data subject rights.
➢ Outside Relead (external recipients)
Authorised third parties such as service providers, partners, suppliers, distributors, and processors may access personal data necessary for performing the Services.
Examples include:
– In charge of the administration, hosting and maintenance of the Site.
– In charge of the administration, hosting and maintenance of the Platform, the hosting of which as well as certain technical services associated with the technological base of the Application Service (in particular maintenance) are provided by the company.
– Suppliers of computer and telephone equipment.
Our subcontractors Marketing service providers (marketing agency and SEO management, professional contact enrichment and validation solution):
Accounting expertise, our banking institution, and payment intermediaries (for managing transactions for payment purposes).
Companies providing third-party cookies to which you give your consent for their installation (see Cookie Policy). Exceptionally, competent authorities (administrative, judicial, or law enforcement) due to a legal obligation or to protect the rights, property, or safety of Relead.
Relead may also call on subcontractors likely to access Personal Data, particularly in terms of specific technical services, for the execution of certain Related Services. We ensure that in terms of personal data, these subcontractors contractually undertake to implement levels of protection equivalent to ours and, in any case, in compliance with the Regulations.
Relead undertakes not to transmit your Personal Data to third parties unless:
1. you have given your prior consent for the sharing of your Personal Data with third parties.
2. sharing your Personal Data with said third party is necessary for the provision of the products or services requested.
3. a competent judicial or administrative authority requires Relead to communicate said Personal Data to it.
In any case, Relead can only transfer, communicate, share your data following notification or authorization from the INPDP and within the framework of strict compliance with the Law.
➢ Transfers outside Tunisia
Your data is hosted on Tunisian territory and in France.
Relead, concerned with the security and confidentiality of your data, informs you that whenever your data is transferred outside Tunisia, we require all our service providers and their subcontractors to comply with confidentiality obligations and ensure that all transfers are made to the following destinations:
Or from a country recognized as ensuring an adequate level of protection.
Either to a country that does not offer adequate protection but whose transfer is permitted in application of the applicable regulations, in particular governed by contractual clauses which the INPDP has previously recognized as guaranteeing a sufficient level of protection of life privacy and fundamental rights of individuals.
Any transfer of your data to a territory other than Tunisian territory is subject to prior authorization from the INPDP.
6. What are your rights regarding your personal data?
6.1 Right of access
You have the right to obtain from Relead confirmation as to whether or not personal data concerning you is being processed. If such data is being processed, you have the right to access that data and the following information:
The purposes of the processing.
The categories of personal data concerned.
The recipients or categories of recipients to whom the data has been or will be disclosed.
The envisaged retention period of the data, if possible, or, if not possible, the criteria used to determine that period.
The right to request from Relead the rectification or erasure of data concerning you, the restriction of processing, or the right to object to processing.
Where the personal data has not been collected directly from you, any available information about its source.
When the personal data is transferred to a third country, the right to be informed of the appropriate safeguards relating to the transfer. Relead will provide you, upon request, with a copy of the data undergoing processing. It may require payment of a reasonable fee based on administrative costs for any additional copies you request. If you request a copy electronically, Relead will provide it in a commonly used electronic format unless you request otherwise. The right to obtain a copy of personal data must not adversely affect the rights and freedoms of others. A form for exercising your right of access is available at the following link [link provided in the original French version]. If Relead fails to respect your right of access, you may lodge a complaint with the INPDP using its model complaint form, available in the link.
6.2 Right of rectification
You have the option of requesting Relead of rectify your data which is inaccurate, as soon as possible. You also have the option of having incomplete personal data concerning you completed, including by providing an additional declaration.
Relead provides a form for exercising your right to rectification of personal data.
To learn more about your right to erasure of your personal data, you can consult the the request to exercise the right of access provided by Relead.
If Relead fails to respect your right to rectification, you may lodge a complaint with the INPDP.
6.3. Right to erasure
Right to restriction of processing
6.5. Right to portability
6.6. Right to object
6.7. Fate of post-mortem personal data
In application of the law, in the event of death, you, your heirs or your guardian, may request to rectify the data concerning you, complete it, modify it, clarify it, update it.
6.8. Regarding consent
7. How to exercise your rights ?
7.1. Conditions for exercising rights
7.2. Response time
8. Use of your data by third-party platforms
The website relead.tn uses a third-party cookie collection plugin through connection habits on the website to better reach them with advertising. Likewise, other sites may reference or contain a link to our site. We do not have no control over these other areas and websites. This is also the case when using third-party cookies. We invite our users to read privacy policies "of each website and each application with which they may interact. We do not endorse, verify, or approve, and we are not responsible for the privacy practices or the content of such websites or applications. If you visit these other websites or applications, you do so at your own risk and are subject to their privacy policies.
8.1. Social media sharing buttons
Our website provides icons related to various social networks, provided by third-party companies (e.g., Facebook, Twitter, Google+, etc.).
Si vous interagissez en cliquant sur lesdites icônes disponibles sur nos pages, une fenêtre s’ouvrira vers le site du réseau social concerné. Il s’agit de pages tierces totalement indépendantes du site.
On this occasion, some of your personal data, in particular your technical and browsing data, will be transmitted and stored on a server of the third-party company operating the social network corresponding to the icon you clicked on. This data will then be processed by that third-party company in accordance with its terms and the settings of your account on that social network.
Vos données sont à ce titre susceptibles d’être hébergées hors de la Tunisie.
Si vous ne souhaitez pas qu’une société tierce exploitant un réseau social relie les données personnelles collectées par l’intermédiaire du Site à votre compte utilisateur ouvert au sein du réseau social considéré, vous devez vous déconnecter de ce réseau social avant de visiter le Site et paramétrer les cookies sur le site tier sur lequel vous avez été redirigé.
In any case, the use of these icons may involve plug-ins managed by the third-party social network providers and is exclusively governed by the terms binding you to the social network of which you are a member. We encourage you to review the terms applied by these third-party social network providers.
8.2. Google services
Ce site utilise plusieurs fonctionnalités proposées par Google. A ce titre certaines de vos Données personnelles et notamment vos données de navigation sont susceptibles d’être transférées à cette société dont les serveurs peuvent être situés aux Etats-Unis. L’usage qui est fait de vos Données personnelles par Google est soumis aux conditions d’utilisation édictées par cette dernière. Nous vous conseillons de les lire attentivement afin de pouvoir pleinement exercer vos droits à cet égard.
9. Policy Change
We reserve the right to modify this privacy policy from time to time. If we do, we will notify you by changing the date at the bottom of this policy and, in some cases, by posting a statement on the home pages of our Site or Platform or by sending you an email . We encourage you to regularly consult our personal data confidentiality policy and cookies to stay informed of our practices in this area and to know the means at your disposal to control the use of your personal data and protect your privacy.
Date this privacy policy was updated: January 19, 2023
