1. Types of data processed
Among the types of personal data we process, by ourselves or through third-parties, there are your:
- First name, last name, date of birth, profession, company name, phone number, email address, password, profile picture;
- Contacts permission, approximate location permission (non-continuous), photo library permission, camera permission (without saving or recording);
- Cookies, geographic position, usage data;
- Crash information, device information, universally unique identifier (UUID), unique device identifiers for advertising (e.g. Google Advertiser ID or IDFA);
- Other necessary types of personal data.
Complete details on each type of personal data processed are provided in the “Purposes of processing” section below or by specific explanation texts displayed prior to the personal data processing.
Personal data may be freely provided by you, or, in case of usage data, obtained automatically when using our systems.
Unless specified otherwise, all personal data requested by our systems is mandatory and failure to provide such personal data may make it impossible for our systems to provide our services. In cases where our systems specifically state that some personal data is not mandatory, you are free not to communicate this personal data without consequences to the availability or the functioning of our systems and services. If you are uncertain about which personal data is mandatory, you are welcome to contact us.
You are responsible for any third-party personal data obtained, published or shared by you through our systems and confirm that you have the third-party’s consent to provide such personal data to us.
2. Legal basis of processing
We may process your personal data if one of the following applies:
- You have given you consent for one or more specific purposes. Please note that under some legislations outside the European Union and the European Economic Area, we may be allowed to process your personal data until you object to such processing (“opt-out”), without having to rely on consent or any other of the following legal basis;
- Provision of your personal data is necessary for the performance of a contract with us and/or for any pre-contractual obligations thereof;
- Processing is necessary for compliance with a legal obligation to which we are subject;
- Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;
- Processing is necessary for the purposes of the legitimate interests pursued by us or by a third-party.
In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of your personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
3. Method of processing
We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of your personal data.
Personal data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the indicated purposes.
In addition to us, in some cases, your personal data may be accessible to certain types of persons in charge of or involved with the operation of our systems (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by us.
4. Place of processing
Your personal data is processed at our operating offices and in any other places where the parties involved in the processing are located.
Depending on your location, data transfers may involve transferring your personal data to a country other than yours, including outside the European Union and the European Economic Area.
To find out more about the place of processing of such transferred personal data, you can check the “Purposes of processing” section below.
5. Purposes of processing
Your personal data is processed by us and other third-parties in order to allow us to:
- Provide our services;
- Comply with our legal obligations;
- Respond to enforcement requests;
- Protect our rights and interests (or yours or those of third-parties);
- Detect any malicious or fraudulent activity;
- Perform other activities such as: access to third-party accounts, contacting you, handling payments, hosting and backend infrastructure, infrastructure monitoring, location-based interactions, managing contacts and sending messages, platform services and hosting, registration and authentication, remarketing and behavioural targeting, social features, advertising, analytics, backup saving and management, device permissions for personal data access, registration and authentication provided directly by our systems, selling goods and services online.
For specific information about the personal data used for the listed purposes, please see below:
By default, this includes certain personal data such as id, name, picture, gender, and your locale. Certain of your connections, such as Friends, are also available. If you have made more of your personal data public, more information will be available.
Provides access your contact email address.
Provides access to your primary email address.
Provides access to your hometown.
Allows to add or modify your photos.
Device permissions for personal data access
Depending on your specific device, our systems may request certain permissions that allow them to access your device data as described below. By default, these permissions must be granted by you before the respective information can be accessed. Once the permission has been given, it can be revoked by you at any time. In order to revoke these permissions, you may refer to your device settings or contact us for support. The exact procedure for controlling app permissions may be dependent on your device and software. Please note that the revoking of such permissions might impact the proper functioning of our systems.
Used for accessing your approximate device location. Our systems may collect, use, and share your location data in order to provide location-based services. Your geographic location is determined in a manner that is not continuous. This means that it is impossible for our systems to derive your approximate position on a continuous basis.
Used for accessing the camera or capturing images and video from the device. Our systems do not save or record the camera output.
Used for accessing contacts and profiles on your device, including the changing of entries.
Allows access your photo library.
Access to third-party accounts
This type of service allows our systems to access personal data from your account on a third-party service and perform actions with it. These services are not activated automatically but require explicit authorization by you.
Backup saving and management
This type of service allows us to save and manage backups of our systems on external servers managed by service providers. The backups may include the source code and content as well as the personal data that you provide to our systems.
By registering on the mailing list or for the newsletter, your email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning our systems and services. Your email address might also be added to this list as a result of signing up to our systems or after making a purchase. Personal data processed: email address, first name, last name, phone number.
If you provide your phone number you might be contacted for commercial or promotional purposes related to our systems and services, as well as for fulfilling support requests. Personal data processed: phone number.
Unless otherwise specified, our systems process any payments by credit card, bank transfer or other means via external payment service providers. In general and unless otherwise stated, you are requested to provide your payment details and personal information directly to such payment service providers. Our systems are not involved in the processing of such information: instead, they will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
Hosting and backend infrastructure
This type of service has the purpose of hosting personal data and files that enable our systems to run and be distributed, as well as to provide a ready-made infrastructure to run specific features or parts of our systems. Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the personal data is stored.
This type of service allows this our systems to monitor the use and behaviour of their components so their performance, operation, maintenance and troubleshooting can be improved. The type of personal data processed depends on the characteristics and mode of implementation of the service, which function is to filter the activities of our systems.
Our systems may collect, use, and share your location data in order to provide location-based services. Most browsers and devices provide tools to opt-out from this feature by default. If explicit authorization has been provided, your location data may be tracked by our systems.
Our systems may collect, use, and share your location data in order to provide location-based services. Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, your location data may be tracked by this our systems. Your geographic location is determined in a manner that is not continuous, either at your specific request or when you do not point out your current location in the appropriate field and allows our systems to detect the position automatically.
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with you. The service may also collect data concerning the date and time when the message was viewed by you, as well as when you interacted with it, such as by clicking on links included in the message.
Platform services and hosting
These services have the purpose of hosting and running key components of our systems, therefore allowing the provision of our systems from within a unified platform. Such platform provides a wide range of tools to us – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of personal data. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the personal data is stored.
Registration and authentication
By registering or authenticating, you allow our systems to identify you and give you access to dedicated services. Depending on what is described below, personal data may be collected and stored for registration or identification purposes only. The personal data collected is therefore only that necessary for the provision of the service requested by you. Third-parties may also provide registration and authentication services. In this case, our systems will be able to access some personal data, stored by these third-party services, for registration or identification purposes.
You register by filling out the registration form and providing your personal data directly to our systems. Personal data processed: first name, last name, date of birth, profession, company name, email address, profile picture and other types of personal data.
Remarketing and behavioural targeting
Selling goods and services online
In order to be purchased, some products available for sale may require extra verification steps to comply with merchant’s local sales regulations and/or local applicable governmental laws. To do so, we reserve the right to ask for an official identity documentation and/or a boarding pass scan to complete the order process. All collected information is used with the sole purpose of local sales regulation compliance and/or local applicable governmental laws and are only kept for the time necessary to fulfil this purpose.
You may have public profiles that other users can display. In addition to the personal data provided, this profile may contain your interactions with our systems. Personal data processed: first name, last name, company name, geographic position, picture.
Our systems may request access to your address book.
6. Retention time
Your personal data shall be processed and stored for as long as required by the purpose they have been collected for:
- Personal data collected for purposes related to the performance of a contract between you and us shall be retained until such contract has been fully performed;
- Personal data collected for the purposes of our legitimate interests shall be retained as long as needed to fulfil such purposes;
- We may be allowed to retain your personal data for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn;
- We may be obliged to retain your personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, your personal data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
7. Your rights
You may exercise certain rights regarding your personal data processed by us. In particular, you have the right to do the following:
- Withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your personal data.
- Object to processing of your personal data. You have the right to object to the processing of your personal data if the processing is carried out on a legal basis other than consent. Further details are provided below.
- Access your personal data. You have the right to learn if personal data is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the personal data undergoing processing.
- Verify and seek rectification. You have the right to verify the accuracy of your personal data and ask for it to be updated or corrected.
- Restrict the processing of your personal data. You have the right, under certain circumstances, to restrict the processing of your personal data. In this case, we will not process your personal data for any purpose other than storing it.
- Have your personal data deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your personal data from us.
- Receive your personal data and have it transferred to another controller. You have the right to receive your personal data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your personal data is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.
- Lodge a complaint. You have the right to bring a claim before your competent data protection authority.
Where personal data is processed for a public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection.
Should your personal data be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn whether we are processing your personal data for direct marketing purposes, you may refer to the “Purposes of processing” section above.
Our systems do not support “Do Not Track” requests. To determine whether any of the third-party services our systems use honour the “Do Not Track” requests, please read their respective privacy policies.
9. Legal action
Your personal data may be used for legal purposes by us in court or in the stages leading to possible legal action arising from improper use of our systems or our related services.
You declare to be aware that we may be required to reveal personal data upon request of public authorities.
10. System logs and maintenance
For operation and maintenance purposes, our systems and any third-party services may collect files that record interaction with our systems (System logs) and personal data (such as the IP address) for this purpose.
11. Information pertaining to children
We do not knowingly collect or solicit personal data from anyone under the age of 18. If you are under 18, please do not attempt to register for our services or send any personal data about yourself to us.
If we learn that we have collected personal data from a child under age 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us personal data, please contact us a soon as possible.
12. Additional information
13. Contact information
191-195 Avenue Charles de Gaulle
Registered in France under SIREN 811169812
Data Protection Officer:
Should the changes affect processing activities performed on the basis of your consent, we shall collect new consent from you, where required.
Latest update: September 30, 2020