FTK is a French SAS (société par actions simplifiée). It has designed FrandAvenue.com (hereafter “FrandAvenue”), a virtual negotiation space in which SEP licensors and SEP users find and/or exchange information necessary to the negotiation of a FRAND licence agreement.
“Personal data” has the meaning ascribed to it in the French Data Protection Act n°78-17 dated 6 January 1978 modified in 2018. It means any information relating to an identified or identifiable person; an identifiable person being one who can be identified, directly or indirectly by reference to an identification number or to one or more elements specific to the person.
3. PERSONAL DATA COLLECTED BY FTK ON FRANDAVENUE
FTK undertakes to collect on FrandAvenue.com only the personal data necessary to achieve the purposes for which your personal data are collected with your consent as mentioned in a specific consent request and/or as necessary to meet our contractual and legal obligations, protect the security of our systems and our users, or fulfil other legitimate interests.
FTK collects your personal data on FrandAvenue.com or through FTK services only when you have provided it voluntarily and interact with us.
4. PERSONAL DATA COLLECTED BY FTK ON INTERNET AND SOCIAL NETWORKS
As part of its activity, FTK processes data indexed on the Internet and in particular data from social networks. This indexed data is not considered sensitive with regard to the definition given by the Commission Nationale de l’Informatique et des Libertés (CNIL), an independent French administrative authority that exercises its functions in accordance to the French Data Protection Act.
In addition, in application of article 6 of the GDPR, FTK only indexes data whose status is public on the internet and which has been the subject of an express consent as to their use by third parties. Information with a private status is therefore never collected and FTK cannot access profiles or pages, on the internet and more specifically on social networks, if access has been restricted by the user.
The indexing of data from the web allows FTK to create consolidated analyses of public data from the net for its own use and for its client companies.
As part of its web-based data indexing activity, FTK may use proprietary automated indexing systems, also known as "crawlers". This is done through application programming interfaces, through agreements with websites or with third party content providers.
FTK crawlers respect the terms and conditions of each website. They study the access conditions of each platform and comply with the protocols of each site. FTK does not use an identifier bypass system and only collects data when the site authorizes it.
FTK “crawlers” are also identifiable, by the sites visited, as belonging to FTK. They can therefore choose to block them or contact FTK for any information.
The indexes of data from the web are stored at subcontracting hosts subject to the same level of requirements, as provided by Article 28 of the GDPR.
5. PROTECTION OF THE DATA COLLECTED BY FTK ON INTERNET
Pursuant to Article 32 GDPR, FTK makes sure to implement all organizational and technical measures to guarantee a level of security adapted to the type of data collected.
To meet these requirements, the data is indexed according to type, sensitivity and processing. Each treatment is listed in a register, as provided for by article 30 GDPR, and is subject to appropriate protection defined after a Private Impact Assessment (PIA) as framed by articles 35 and following of the GDPR.
In this context, FTK has established a policy of “privacy by design”, which means that FTK pursues the objective of collecting only the data strictly necessary for its use as recommended by article 25 GDPR.
Once the data has been indexed, it is not kept longer than necessary for the nature and purpose of the processing.
At the same time, FTK implements the physical and application security measures necessary to ensure the tightness of its databases and their protection from the outside. These measures can be shared with FTK customers under specific confidentiality agreements.
Likewise, in order to guarantee strict security and prevent any damage linked to unauthorized access to data, FTK, in compliance with article 33 of the GDPR, will notify its customers as soon as it becomes aware of any unauthorized access to data.
6. RESPECT FOR THE PERSONAL CHARACTER OF THE DATA AND WILL OF THE PERSONS CONCERNED
FTK is aware of the importance of controlling the personal data it collected, and guarantees to any person concerned by the processing of their data, the full collaboration of its services.
Statistical or survey purposes to improve FrandAvenue.com and FTK services for you
To administer and provide you with the content of FrandAvenue.com and FTK services
8. COMMUNICATION OF THE DATA COLLECTED ON FRANDAVENUE
FTK never sells, leases or rents your personal data collected on FrandAvenue.com.
FTK communicates the personal data collected on FrandAvenue.com to third parties only with your consent or when it is necessary to provide you with the service you have requested or authorized and for which you have provided your personal data.
FTK may also share your personal data collected on FrandAvenue.com with suppliers working on our behalf when required by law or to respond to legal process, to protect our users, to protect lives, to maintain the security of our products, and to protect the rights or property of FTK.
9. TRANSFER OF THE DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA
By using FrandAvenue.com and its services or by otherwise providing your personal data to FTK, you agree that your personal data may be transferred to a country outside of the European Economic Area that may not provide an equivalent level of privacy or data protection law than that obtaining in France. In such a case, FTK requests that adequate protection for your personal data is provided by our service providers and partners.
10. ACCURACY OF THE DATA
FTK takes all reasonable measures to keep the personal data we process accurate and to delete incorrect or unnecessary personal data.
11. RIGHTS OF ACCESS, RECTIFICATION, OBJECTION AND DELETION
You have rights of access, rectification, objection and deletion related to your personal data collected on FrandAvenue.com and that FTK holds about you. When updating your personal data, we may ask you to prove your identity before acting on your request. We may also reject requests that are repetitive, require disproportionate technical effort, conflict with legal requirements, harm the privacy rights of others or would be extremely impracticable.
12. LINKS TO OTHER WEBSITES
FTK may provide links to other websites for your convenience and information, but these websites may operate independently from FTK and have their own privacy notice or policy which FTK strongly recommends that you review those organizations’ policies insofar as they apply to your visit to those websites. FTK is not responsible for the content of those websites and their privacy practices.
Wherever your personal data may be held by FTK, FTK will take reasonable and appropriate measures to protect the personal data that you share with FTK from unauthorized access or disclosure.
You are responsible to safeguard your credentials, IDs and passwords. If you suspect that your credentials, IDs and/or passwords have been compromised, please inform FTK immediately, using the contact methods detailed below.