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PRIVACY POLICY CONCERNING PERSONAL DATA OF EMPLOYEES, PARTNERS AND SUBCONTRACTORS OF LOUNGEUP SOLUTION CLIENTS

 

1.     Definition and nature of personal data

When using LoungeUp solutions software (hereinafter referred to the “Solution“), we may ask you to provide us with personal data about you.

The term “personal data” refers to all data that identifies an individual, including their surname, first names, photograph, postal and email addresses, telephone numbers, sex, date of birth, interests, bank card number, data relating to your transactions through Solutions, details of your purchases, reservations, queries and browsing history, as well as any other information you choose to provide to us about you.

 

2.     Subject matter of this Privacy Policy

This Privacy Policy is intended to inform you about the methods we use to collect your personal data, with the utmost respect for your rights.

In collecting and managing your personal data, we comply with French Act N. 78-17 of 6 January 1978, on Information Technology, Data Files and Civil Liberties, known as the “Information Technology and Civil Liberties Act” and (EU) Regulation 2016/679 of 27 April 2016, upon its entry into force (hereinafter: ‘GDPR).

 

3.     Who collects your personal data

The body tasked with collecting your personal data is LoungeUp, SAS company, registered with the Paris Trade and Companies Register under number 537 538 035, with its registered office at 62 Rue Doudeauville, 75018 Paris – FRANCE (hereinafter referred to as:  ‘Us’).

 

4.     The collection of personal data

The legal basis of our collection of your personal data is as follows:

(i) There is legitimate interest insofar as you voluntarily provide us with personal data during your visit to our website, and we collect this personal data to enable us to better respond to your requests for information on our Services;

(ii) Your consent regarding social networking cookies, advertising cookies and Google Analytics cookies referred to in Article 11;

(iii) This collection is necessary for the performance of the contract you enter into when you use our Services in the Solution.

Your personal data is collected for one or more of the following purposes:

(i) Manage your access to certain services available on the Solution and its usage,

(ii) Perform customer management operations for contracts, orders, deliveries, invoices, loyalty programs, customer relationship monitoring,

(iii) Create a file for users, customers and prospects,

(iv) Send newsletters, requests and promotional messages. In case you do not want this, we give you the chance to opt out when collecting and processing your data;

(v) Develop business and usage statistics for our services,

(vi) Organise contests, raffles and any promotional activities, excluding online gambling, subject to the approval of the Online Games Regulatory Authority,

(vii) Manage feedback on products, services or contents,

(viii) Manage unpaid bills and potential litigation regarding the use of our products and services,

(ix) Customise responses to your requests for information, as well as our discussions and communications,

(x) Fulfil our legal and regulatory obligations.

When collecting your personal data, we will inform you whether supplying certain data is compulsory or optional. Compulsory data is necessary for the Services to run smoothly. Regarding optional data, it is entirely your choice whether to supply them or not. We will also inform you of the possible consequences of not providing certain data.

 

5.     Recipients of collected data

Only our company’s staff, the departments responsible for audits (the auditor in particular) and some of our subcontractors will have access to your personal data.

Solely for the purposes of fulfilling our legal obligations, your personal data may also be sent to public bodies, as well as court officials, members of the legal or allied professions and debt collection agencies.

 

6.     The sale of personal data

We will not sell, lease to third parties, nor trade with them your personal data.

 

7.     The storage period of personal data

(i) Regarding data on customer and prospects management:

Your personal data will not be stored for a time longer than is strictly necessary for managing our business relationship with you. However, data which acts as proof of a right or a contract, which we must retain to fulfil our legal obligations, will be stored within the time frame set by the law in force.

Regarding possible prospecting operations for customers, their data may be stored for three years from the end of the business relationship.

Personal data on a prospect who is not a client may be stored for three years from their collection or the last contact from the prospect.

At the end of this three-year period, we will be able to contact you again to find out if you wish to continue receiving business communications.

(ii) Concerning the management of lists of contacts who do not consent to prospection:

The information which acts as a record of your right to deny consent is stored for at least three years from when you exercised this right.

(iii) Concerning cookies:

The length of time cookies referred to in Article 10 are stored is 13 (thirteen) months.

 

8.     Security

We take all necessary precautions, organisational and technical measures to maintain the security, integrity confidentiality of your personal data and to ensure they are not distorted, damaged, and unauthorised third parties cannot access it.

 

9.     Hosting

Your data is retained and stored on servers located in France (European Union), for the duration of their storage.

 

10.  Cookies

Cookies are text files, often encrypted, which are stored in your browser. They are created when a user’s browser loads a given website: the site sends information to the browser, which creates a text file. Each time the user returns to the same site, the browser retrieves this file and sends it to the website’s server.

There are various types of cookies, which have different purposes:

  • Technical cookies are used throughout your navigation to facilitate and perform certain functions. A technical cookie can, for example, be used to memorise the answers filled in a form or the user’s language or website presentation preferences, when such options are available.

We use technical cookies.

  • Social network cookies can be created by social platforms to enable website editors to share the content of their site on these platforms. These cookies may be used by social platforms to track users’ browsing habits on the website concerned, whether or not they use these cookies.

We do not use social network cookies. If we decide to do so later, we will inform you in advance and ask for your consent before using them. You will then be given the chance to find out about and accept or refuse them.

  • Advertising cookies can be created not only by the website the user is browsing, but also by other websites which have advertisements, promotional messages, widgets or other items on the page displayed. These cookies may be used to carry out targeted advertising, in other words, advertising based on the user’s browsing habits.

We do not use advertising cookies. If we decide to do so later, we will inform you in advance and ask for your consent before using them. You will then be given the chance to find out about and accept or refuse them.

  • We use Google Analytics, which is a statistical audience analysis tool that generates a cookie to measure the number of visits to Site, the number of pages viewed and visitor activity.

Please note that you may refuse cookies by configuring your browser. Refusing cookies may however, prevent the smooth running of the Solution.

 

11.  Accessing your personal data

In accordance with the French “Information Technology and Civil Liberties Act”, and the GDPR, you have the right to access, and where appropriate, correct or delete your data by accessing your file online. You may request this by contacting:

  • Email address: legal@loungeup.com
  • Postal address: 62, rue Doudeauville – 75018 Paris – FRANCE

Persons whose data are collected on the basis of our legitimate interest, as mentioned in Article 4, are reminded that they may at any time refuse consent to the processing of their data. We may, however, be required to continue processing data if there are legitimate grounds for it that prevails over your rights and freedoms or if processing the data is necessary to ascertain, exercise or defend our rights in court.

 

12.  Right to issue instructions for processing data after your death

You have the right to issue instructions for the storage, deletion and disclosure of your personal data after your death.

These instructions can be general, in that they relate to all your personal data. In this case, they must be registered with a trusted third party, certified by the CNIL (the French Data Protection Authority).

The instructions may also be specific to the data processed by our company.
Please, therefore, send these to the following:

  • Email address: legal@loungeup.com
  • Postal address: 62, rue Doudeauville – 75018 Paris – FRANCE

By sending us these instructions, you expressly give your consent for these to be stored, sent and carried out in the manner specified in this Privacy Policy.

You may, in your instructions, nominate a person tasked with carrying them out. Upon your death, the nominated person will then be tasked with taking note of your instructions and asking us to carry them out. In the absence of a nominated person, your heirs will be tasked with taking note of your instructions and asking us to carry them out.

You may amend or revoke your instructions at any time by writing to us, using the above contact details.

 

13.  The right to data portability

You have a right to receive the personal data you have provided us with, which is understood as the data you have actively and consciously declared in connection with the access and use of services, as well as data generated by your activity whilst using the services. Please remember that this right does not relate to data collected and processed on any other legal basis other than the consent or performance of the contract which binds us.

This right may be exercised free of charge, at any time, and when closing your account on the Platform, so your personal data can be recovered and stored.

In this context, we will send your personal data, by any means deemed convenient, in a standard, commonly used, open and machine-readable format, in accordance with the best current practice.

 

14.  Lodging a complaint with a supervisory authority

You also have the right to lodge a complaint with a competent supervisory authority, (for instance in France, CNIL, the French Data Protection Authority), in the Member State where your habitual residence is located, your place of work or the place where your rights were infringed, if you believe that the processing of your personal data as covered by this Privacy Policy constitutes a violation of applicable laws.

This action may be exercised without prejudice to any other administrative or jurisdictional court action. You also have the right to an effective administrative or judicial remedy, if you believe that the processing of your personal data as covered by this Privacy Policy constitutes a violation of the applicable laws.

 

15.  Processing restrictions

You have the right to set restrictions on the processing of your personal data, in the following cases:

  • During our verification period, should you dispute the accuracy of your personal data,
  • If processing such data is illegal, and you want to set restrictions on this processing rather than delete your data,
  • If we no longer need your personal data, but you would like to have it stored to exercise your rights,
  • During the period set for verifying legitimate reasons, if you objected to the processing of your personal data.

 

16.  Amendments

We reserve the right, at our sole discretion, to amend this Privacy Policy at any time, in whole or in part. These changes will come into effect once the Privacy Policy is issued. Your usage of the Solutions following the coming into force of these amendments will constitute your recognition and acceptance of the new Privacy Policy. Otherwise, if you do not agree with this new Privacy Policy, you may no longer access the Solutions.

 

17.  Entry into force

This Privacy Policy entered into force on 25 May 2018.