MOBILE APP PRIVACY POLICY

Last update on: May 20, 2020

Recitals

This Policy is an integral part of the Terms of Use; therefore the definitions used therein are reused in this Policy.

This Policy sets out the minimum rules that Pandaroo (hereinafter “Pandaroo”, “We”, “us”, “our”) has established with regard to the protection of Personal Data so that the collection, use, storage, and communication of Personal Data are carried out in a fair, transparent, and secure manner.

This Policy defines our approach to the processing of your Personal Data that we collect from you and the purposes of such processing. It also sets out your rights with regard to our processing of your Personal Data.

Definitions

The following terms, whether used in the singular or plural form in this Policy, shall have the following meanings:

  • “Application(s)“: shall refer to the Chic & Win mobile application, available from the Apple and Google Download Platforms, published by Pandaroo;;

  • “TUS“: refers to the Terms of Use of the Application available here;

  • “Personal Data“: shall refer to the User’s personal data, under the Personal Data Regulations, collected and processed in connection with the use of the Platform and Applications.

  • “Policy“: shall refer to this Privacy Policy;

  • “Personal Data Regulations“: shall refer to French Act No. 78-17 of January 6, 1978 on information technology, data files, and civil liberties (Loi relative à l’informatique, aux fichiers et aux libertés), amended pursuant to EU Regulation of April 27, 2016 published in the Official Journal of the European Union on May 4, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”, General Data Protection Regulation);

  • “Service(s)“: shall refer to the service(s) provided by the Application

  • “User/You“: shall refer to any natural person of legal majority and capable of, or with parental authorization to do so, using the Application without being subject to any legal, regulatory, or contractual prohibition and/or restriction preventing him from posting Content and having complied, where applicable, with all legal, regulatory, and contractual formalities in order to use the Services;;

  • “Terminal(s)“: shall refer to the physical equipment (Tablet, smartphone, etc.) used by the User to use the Application.

Who is responsible for processing your Personal Data?

Pandaroo, whose registered office is located at 1111, chemin de Monternoz, 01960 Péronnas, FRANCE, registered with the Bourg-en-Bresse Trade and Companies Register (Registre du Commerce et des Sociétés de Bourg-en-Bresse) under number 837 602 259, is the controller of your Personal Data.

Minimum age

Preserving the safety and privacy of children is very important to us. We do not voluntarily collect or use Personal Data from persons under the minimum age required by local legislation (e.g., 15 years old in France) without the consent of both the child and the holder(s) of parental responsibility.

You also confirm that you are at least of the required age or older when you provide your Personal Data in connection with the use of our Products or Services and/or those of our Partners. If you are under the required age, you must ask your parents or legal guardian for permission to provide us with your Personal Data. To do so, please contact us using the details indicated in Article 9 below.

What Personal Data do we collect from you?

Pandaroo collects no Personal Data in order to grant access to the Application. It is not necessary to create a User Account in order to access the Application and its Services.

In the event of technical issues regarding the Points of Interest used with the Application, You will be given the option to report such issues back to Pandaroo.
If you decide to do so, the Application will require your authorization to collect data necessary to resolve the issue:

  • GPS location

  • Email adress

If authorized, this data will be used for the sole purpose of resolving technical issues and will in no way be saved or disseminated. Upon closing the issue, all related data collected will be erased by Pandaroo. Technical issues may also be directly reported by sending an email to contact@pandaroo.fr.

How do we process your Personal Data?

We process your Personal Data for the following purposes. Whenever we process your Personal Data, we do so on the basis of a legal “justification” (or legal basis) for processing, which we have identified in the table below.

Purposes : In order for Pandaroo to locate the Point of Interest that is not functioning properly in case of Technical Issues

Legal Basis : This processing is necessary for the resolution of Technical Issues relative to the performance of the Application, part of the agreement made between you and Pandaroo.

Purposes : To communicate with you, solely regarding the circumstances and details of the technical issues you encountered

Legal Basis : This exchange can be necessary to the resolution of the technical issues reported. The email address you provided will be exclusively used for this purpose, and never for commercial or information purposes.

 

With whom do we share your Personal Data?

Pandaroo shares the Personal Data collected for Technical Issue Resolution with ABSOLUTELY NO-ONE. Upon the resolution of the technical issue reported, all Personal Data provided will be deleted. No other Personal Data is collected while using the Application.

How long do we keep your Personal Data?

All Personal Data collected for Technical Issue Resolution, and for this sole purpose, is deleted upon the resolution of said issue.

Security of your Personal Data

We are committed to ensuring the security of your Personal Data and we have established information system security policies as well as appropriate technical rules and measures to protect it from unauthorized access, modification, use, and disclosure or unlawful destruction or accidental loss.

What rights do you have?

In accordance with the Personal Data Regulations, you have a number of rights to your Personal Data when it comes to the use of the Chic & Win application, but also on any other website of while using any other application.

Pandaroo collects no Personal Data to allow Users to use the Chic & Win Application, but it’s always useful to remind you of your rights.

Each of these rights is further detailed below:

Withdrawal of consent. At any time, you may revoke your consent to any processing of your Personal Data based on your consent.

Access. You may ask to confirm whether your Personal Data is being processed and, if so, to provide you with the following information:

  1. the purposes of the processing;

  2. the types of Personal Data;

  3. the recipients or types of recipients to whom the Personal Data has been or will be communicated;

  4. where possible, the intended storage period of the Personal Data or, where this is not possible, the criteria used to determine this period;

  5. the existence of the right to request the rectification or deletion of Personal Data, or a limitation on the processing of Personal Data, or the right to object to such processing;

  6. the right to file a complaint with the supervisory authority for personal data (in France, the CNIL);

  7. when Personal Data is not collected from you, any information available regarding their source of information;

  8. the existence of automated decision-making, including profiling, and, at least in such cases, relevant information about the rationale, as well as the importance and expected consequences of such processing for you.

Where Personal Data is transferred to a third country or an international organization, you have the right to be informed of the relevant safeguards with regard to the transfer.

You can be provided with a copy of the Personal Data that is subject to processing.

When you make your request electronically, the information will be provided to you in an electronic form that is commonly used, unless you otherwise request.

Your right to obtain a copy of your Personal Data must not infringe on the rights and freedoms of others.

Rectification. You have the possibility to have your Personal Data rectified promptly if it is incorrect. You also have the option of having your Incomplete Personal Data completed, including by providing a supplementary declaration.

Deletion. You may ask to delete your Personal Data promptly in the following cases:

  1. when it is no longer required for the purposes for which it was collected;

  2. you have revoked your consent and there is no other legal basis for the processing;

  3. following the exercise of your right to object;

  4. your Personal Data has been unlawfully processed;

  5. or to comply with a legal obligation. One is not obliged to comply with your request to delete your Personal Data, in particular if its processing is necessary to comply with a legal obligation or to recognize, exercise, or defend legal rights.

Limitation. You may ask to limit the processing of your Personal Data (i.e., to retain it without using it) where:

  1. its accuracy is disputed;

  2. its processing is unlawful but you do not want it to be deleted;

  3. it is still required for the recognition, exercise, or defence of legal claims;

  4. it is needed to verify the existence of compelling reasons for exercising your right to object. Your Personal Data may continue to be used following a request for restriction: with your consent; for the recognition, exercise, or defence of legal rights; or to protect the rights of any other natural or legal person.

Portability. You may ask to be provided with your Personal Data in a structured format, commonly used and readable by a machine, or you may request that it be transmitted directly to another controller, but only if:

  1. the processing is based on your consent;

  2. within the performance of an agreement made with you and that the processing is automated.

The right to the portability of your Personal Data must not infringe on the rights and freedoms of others.

Right to object. You may at any time, for reasons related to your specific situation, object to the processing of your Personal Data based on one’s legitimate interest. Your Personal Data will then no longer be processed, unless it is demonstrated that there are compelling and legitimate grounds for processing that prevail over your interests and your rights and freedoms, in which case it may be kept for the purpose of recognizing, exercising, or defending legal rights.

You may at any time object to the processing of your Personal Data for the purpose of prospecting.

Digital will. You may define guidelines (general or specific) regarding the treatment of your Personal Data after your death, including the storage, deletion, and disclosure of your Personal Data, which guidelines may also be registered with a “certified digital trusted third party”. These guidelines may designate a person to carry them out; otherwise, your heirs will be designated.

In the absence of any directive, your heirs may contact us to:

  1. access to the processing of Personal Data allowing “the planning and arrangement of the deceased’s estate“;

  2. receive communication of “digital property” or “data similar to family memories, transmissible to heirs“;

  3. have your Account closed and oppose the further processing of your Personal Data.

In any case, you have the possibility of informing whoever is collecting your Personal Data, at any time, that you do not wish your Personal Data to be communicated to a third party in the event of death.

Contact and claims

In order to exercise your rights, please contact us at anytime using the following email address : contact@pandaroo.fr

In order to assert your rights under the terms referenced above and in the event that Pandaroo has doubts about the applicant, Pandaroo may ask you to prove your identity by specifying your surname, name, and e-mail address, and submitting a copy of a valid proof of identity along with your request.

You will receive an answer within a maximum of one (1) month following the date of receipt of the request.

If required, this period may be extended to two (2) months by Pandaroo, who will inform you of the response in consideration of the complexity and/or number of requests.

Policy update

Pandaroo, whose registered office is located at 1111, chemin de Monternoz, 01960 Péronnas, FRANCE, registered with the Bourg-en-Bresse Trade and Companies Register (Registre du Commerce et des Sociétés de Bourg-en-Bresse) under number 837 602 259, is the controller of your Personal Data and may amend this Policy from time to time, for instance to take into account legal changes, technological advances, and good business practices.

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