LEGAL NOTICE

 

The company LiveHappier which operates the services Squadeasy (hereinafter "Squadeasy" or "Livehappier" or "we"), SAS, simplified joint stock company with a capital of 17 447.50 € whose headquarters is located at 157 boulevards McDonald, 75019 Paris, registered in the Paris Trade and Companies Register under number 808 330 377 and having the intra-community VAT number FR 67 808330377.

- Responsible for the site and the application : Squadeasy represented by its President Brice Chapignac

- Director of Publication : Squadeasy represented by its President Brice Chapignac

- Data Protection Officer (DPO) : Squadeasy represented by its current Product Manager Benoît Keirle

- Host of the website and the content of the application :

o This site is hosted in Europe, in France on servers of the company Amazon Web Services (AWS) :

o Amazon Web Services Inc.

o 410 Terry Avenue North,

o Seattle, WA 98109-5210, USA

o http://aws.amazon.com

o And by AMAZON WEB SERVICES EMEA SARL

o 831 001 334 R.C.S. NANTERRE

o 31 PL DES COROLLES 92400 COURBEVOIE

 

For more information, please contact : dpo@squadeasy.com

CONFIDENTIALITY OF PERSONAL DATA

LiveHappier SAS is subject to the applicable rules on the protection of personal data, and, in particular, to the European General Regulation on the Protection of Personal Data n°2016/679 of 27 April 2016 (known as "RGPD"), as well as all the rules of national law taken in application of it, on a subsidiary basis.

The purpose of this Privacy Policy is to provide clear, simple and comprehensive information to all data subjects ("You" or "Your/Your") about how LiveHappier, as data controller, collects and uses personal data about You "Personal Data/Personal Data" and the means available to You to control such use and exercise Your rights in relation to it.

This privacy policy deals with personal data collected via the " squadeasy.com " websites or the " squadeasy " mobile application

Consent

By registering for our services via the mobile application or website https://squadeasy.com/ or other sites belonging to the Squadeasy service, you agree and consent that we may collect, process, store and/or use the personal data submitted in accordance with the rules set out below.

By giving us your consent, you also have the right to rectification, the right to access, the right to be forgotten and/or the right to have your personal data deleted, the right to portability, the right to limit processing, as well as the right to decide on the fate of your data post mortem.

Article 1: WHAT PERSONAL DATA MAY BE COLLECTED?

The Squadeasy Services collect information about you, including personally identifiable information, if you choose to share it with the Squadeasy Services, if you register an account or if you track, complete or upload activities using the Squadeasy Services. The Squadeasy Services also collect information about how you use the Squadeasy Services. This information includes, mandatorily, your first and last name, email address and password, optionally, your title, country, equipment usage, activities, routes (including date, time and geographic location information, as well as your speed and pace), IP address, profile picture and other images you provide in chat, social wall, team picture, activity sharing, and posts of any kind on our platform.

If you choose to use geolocation-based features through the Squadeasy Services, we will collect the geographic location of your device. The Squadeasy Services may also collect and download from your device data such as speed and direction. You have the ability to disable our use of certain geolocation data via your device or browser settings by turning off "Location Services."

You can use Squadeasy Services to access your contact information to connect with your contacts on Squadeasy Services.

Third party services

The Squadeasy Services allow you to register and log in to the Squadeasy Services via accounts you create from third-party products and services such as Facebook or Google (collectively, "Third Party Accounts"). These Third Party Accounts may request your permission to share certain information from your Third Party Account with Squadeasy. We use this information to verify your identity and provide you with features of our products and services. This information may include your first name, last name, email address, profile information and preferences with the applicable Third Party Account. This information is collected by the Third Party Account provider and is provided to Squadeasy Services under its privacy policy. You can generally control the information we receive from these sources through the privacy settings in your Third Party Account.

Article 2: WHO COLLECTS YOUR PERSONAL DATA?

 

When you fill in a form on the mobile application "squadeasy" or on the website(s) of the domain name "squadeasy.com" you expressly agree that your personal data may be collected by or on behalf of LiveHappier

 

Article 3 : LEGAL BASIS AND PROCESSING OF YOUR PERSONAL DATA

By submitting a request form on the mobile application "squadeasy" or on the website(s) of the domain name "squadeasy.com" you expressly give us your consent to process your personal data in order to provide you with services or support as proposed on the site.

The processing of your personal data being based on your consent, you have the right to withdraw your consent at any time.

We use all the information we have to help us operate, provide, improve, understand, personalize, support and market our Services.

We operate and provide our Services, which includes providing user support and improving, correcting and personalizing our Services. We understand how people use our Services, and we analyze and use the information we have to evaluate and improve our Services, research, develop and test new services and features, and perform troubleshooting activities. We also use your information to respond to you when you contact us.

The Squadeasy Services collect the information you provide to us. You may also upload activities to the Squadeasy Services based on your geographic location, such as a race or ride. You can join challenges, contests and communicate with other members. You may also provide additional personal information.

The Squadeasy Services also collect various technical information, including location, device and network information, as well as cookies, log files and analytics.

We use cookies to operate, provide, improve, understand and personalize our services.

Article 4: PURPOSE OF PROCESSING

The primary purpose of collecting your personal data is to provide you with a safe, optimal, efficient and personalized social and fun connected fitness experience. To this end, you agree that we may use your personal data to:

Provide and facilitate our services, including conducting checks on you to do so;

Resolve any problems to improve the use of our site and our services;

To customize, evaluate and improve our services, content and materials;

To analyze the volume and history of your use of our services;

Inform you about our services and those of our partner companies if you have authorized to receive our newsletter on Squadeasy and your company has expressly authorized us to do so on the Squadeasy corporate version

Prevent, detect and investigate any potentially prohibited and illegal or unethical activities, and ensure compliance with our terms of use and our mailing policy;

To meet our legal and regulatory obligations.

Newsletter and email marketing

An unsubscribe link is included in every newsletter and email marketing we send.

For those of you who have explicitly opted-in to receive the Squadeasy Services newsletter you can easily unsubscribe by following the unsubscribe links included in each of these emails.

Analytics Service

The Squadeasy Services use analytics providers such as Google Analytics to understand how the Services are used and to help us improve the Services.

Article 5: DURATION OF RETENTION OF YOUR PERSONAL DATA

We keep your personal data only for the time necessary to fulfill the purposes for which it was collected, except to meet legal and regulatory obligations.

We delete the personal data we collect after a certain period of time. Concerning personal data collected through the mobile application Squadeasy or the sites of the domain name Squadeasy.com, the time to process the request, with in any case a limited duration of detention

Article 6: Recipients of your personal data

Your personal data are strictly confidential and cannot be transferred to a third party for commercial and/or promotional purposes. Only persons duly authorized by LiveHappier by virtue of their functions may access Your Personal Data, without prejudice to their possible transmission in the cases required by the applicable regulations.

All persons under LiveHappier's responsibility who have access to Your Personal Information are bound by a confidentiality agreement.

You provide Your Information when you use our Services, we share Your Information to help us operate, provide, improve, understand, customize, assist and market our Services.

Third Party Services

When you use third-party services that are integrated with our Services, they may receive information about what you share with them. If you interact with a third party service linked to our Services, you may provide information directly to that third party. Please note that when you use third party services, the terms and conditions and privacy policies of those third parties govern your use of those services.

Recipient of personal data

Squadeasy Services does not sell or rent your personal data to third parties for marketing purposes under any circumstances.

In addition, Squadeasy Services does not disclose your personal data to third parties unless (1) you (or your account administrator acting on your behalf) request it; (2) disclosure is required to process your requests.

Information Shared by You

If you link your Squadeasy Services account to other social networks and share your activities there, they will be visible outside the Services. If you choose to share or post your location information through these third parties, it is possible that people with malicious intent could gain access to this information. You should exercise caution when sharing information through third parties and you should carefully review the privacy practices of such third parties.

Article 7: SECURITY OF YOUR PERSONAL DATA

The protection of your Personal Data is important to us. Your Personal Data is collected, stored, processed and transferred in strict compliance with the purposes for which it was collected and in accordance with the strict rules set out in this privacy policy which complies with all the obligations of the European Regulation (RGPD) on personal data.

LiveHappier implements technical and organizational measures to ensure that Personal Data is kept in the most secure manner possible and for the period of time necessary to fulfill the purposes pursued, in accordance with applicable law.

Thus, and in accordance with the RGPD, Squadeasy undertakes to take all necessary precautions to preserve the security of the data and in particular to protect them against any accidental or illicit destruction, accidental loss, alteration, unauthorized distribution or access, as well as against any other form of illicit processing or communication to unauthorized persons.

To this end, Squadeasy implements industry standard security measures to protect personal data from unauthorized disclosure.

Furthermore, in order to prevent unauthorized access, ensure accuracy and proper use of data, Squadeasy has put in place appropriate electronic, physical and managerial procedures to safeguard and preserve the data collected through its services.

However, no one can consider themselves completely safe from a hacker attack. This is why, in the event that a security breach occurs, Squadeasy will inform you as soon as possible and will make its best efforts to take all possible measures to neutralize the intrusion and minimize its impact. In the event that you suffer damage as a result of the exploitation of a security breach by a third party, Squadeasy undertakes to provide you with all necessary assistance so that you can assert your rights.

It is important to keep in mind that any user, client or hacker who discovers a security vulnerability and exploits it may be subject to criminal sanctions. Squadeasy will take all necessary measures, including filing a complaint and/or taking legal action, to preserve the data and rights of its users and its own, and to limit the impact as much as possible.

Adopting the recommendations of the French personal data protection authority regarding the level of security of passwords, your account password must contain at least 8 characters, 1 number and 1 special character.

We take very strict measures to protect the collection, transmission and storage of the data we collect. These measures depend on the sensitivity of the data we collect, process and store. Squadeasy Services uses a company that is an industry leader in online security verification and services to enhance the security of our services. The services are registered with site identification authorities so that your browser can confirm the identity of the Squadeasy services before sending any personally identifiable information. In addition, Squadeasy Services' secure servers protect this information with advanced firewall technology.

To ensure that these measures are effective in preventing unauthorized access to your private information, you should be aware of the security features available to you through your browser. You must use a browser with security features to submit your credit card and other personal information to the Services. Note that if you do not use an SSL-enabled browser, you run the risk of having your data intercepted.

Most browsers are capable of informing you if you are switching from a secure to an unsecured communication, receiving invalid credentials for the services you are communicating with, or sending information over an unsecured connection. Squadeasy Services recommends that you enable these features in your browser to ensure that your communications are secure. You can also monitor the URL of services you visit (secure URLs begin with https:// rather than http://), as well as the security symbol in your browser to see if you are communicating with a secure server. You can also view the security certificate details of the services you are connected to. Check the validity of any service you connect to via secure communications.

Article 8 : YOUR RIGHTS

Subject to the limits provided by the regulations in force, You have the following rights with respect to your Personal Data:

- The right of access - you have the right to obtain confirmation from us as to whether or not your Personal Data is being processed by us, as well as certain other information (similar to that provided in this Privacy Policy) about how it is used. You also have the right to access your personal data, by requesting a copy of your personal data. This allows you to know and verify that we are using your information in accordance with data protection laws. We may refuse to provide information where it may reveal personal data about another person or adversely affect the rights of another person.

 

- The right to rectification - you can ask us to take steps to correct your personal data if it is inaccurate or incomplete (for example, if we have the wrong name or address).

 

- The right to erasure - also known as the "right to be forgotten", this right allows you, in simple terms, to request the erasure or deletion of your personal data where, for example, there is no compelling reason for us to continue using it or its use is unlawful. However, this is not a general right to erasure and there are some exceptions, for example where we need to use the information to defend a legal claim or to be able to comply with a legal obligation.

 

- The right to restrict processing - you have the right to "block" or prevent further use of your personal data when we are assessing a request for rectification or as an alternative to erasure. Where processing is restricted, we may still retain your personal data, but we may not use it further.

 

- The right to data portability - you have the right to obtain and reuse certain personal data held by third parties for your own purposes in different databases (which are separate data controllers). This only applies to personal data you have provided to us, which we process with your consent and for the purpose of contract performance, which is processed by automated means. In this case, we will provide you with a copy of your data in a structured, commonly used and machine-readable format or (where technically and financially feasible) we may pass your data directly to another controller.

 

- The right to object - you have the right to object to certain types of processing, on grounds relating to your particular circumstances, at any time, provided that such processing is for the purposes of legitimate interests pursued by our company. We will be allowed to continue processing personal data if we can demonstrate that the processing is justified on compelling legitimate grounds that outweigh your interests, rights and freedoms or if we need it for the establishment, exercise or defense of legal claims.

 

- The right to withdraw your consent - where we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time. However, such withdrawal does not affect the lawfulness of the processing that took place prior to such withdrawal.

 

- The right to provide us with instructions on the use of your personal data after your death - you have the right to provide us with instructions on the management (e.g. retention, erasure and disclosure) of your data after your death. You may change or revoke your instructions at any time.

Article 9: COOKIES

When you visit the Services, a cookie will be stored on your computer. A banner on the https://squadeasy.com/ websites will indicate that we use cookies to enhance your experience. Generally, cookies and similar items work by assigning your computer a unique number that has no meaning outside of the Squadeasy Services. Squadeasy Services cookies do not contain any personally identifying information; Squadeasy Services uses them to personalize your experience. The Squadeasy Services may also use cookies to help it deliver content specific to your interests. In addition, after you enter your member ID and password during a session on the Services, the Squadeasy Services saves this information so that you do not need to re-enter it again during that session. Most browsers automatically accept cookies. The only way to "opt out" of the collection of any information through cookies or other tracking technologies is to actively manage the settings on your browser or mobile device. See the technical information for your browser or mobile device to learn how to delete and disable cookies and other tracking/recording tools. If you have any questions about how to decline cookies and other tracking/recording tools, contact us at boogie@squadeasy.com. Rejecting cookies may make some features of the Services unavailable. The Squadeasy Services may also use your IP address to identify you, administer the Services, and diagnose problems with the Squadeasy Services' servers.

When you access third-party sites that advertise on the Squadeasy services or possibly when you view these advertisements, cookies may be created by the companies serving these advertisements. These third parties who may use cookies in connection with the Squadeasy Services (partners or other third parties providing content or services available on the Squadeasy Services sites) are responsible for the cookies they set and their cookie policies apply. Squadeasy Services assumes no responsibility for the possible use of cookies by these third parties. For more information, you are advised to consult directly on these advertisers or third party sites their policy on the use of cookies.

Article 10: UPDATES OF OUR POLICY

We may modify, supplement or update this Privacy Policy in order to take into account any legal, regulatory, jurisprudential and/or technical developments.

In the event of significant changes to this Privacy Policy (relating to the purposes of processing, the Personal Data collected, the exercise of rights, the transfer of users' personal data and our Cookie policy), Squadeasy undertakes to inform Users by any written means and will update the "last modified" date at the top of this Privacy Policy.

By continuing to use our services, you confirm your acceptance of our Privacy Policy as amended. If you do not agree with our Privacy Policy, as amended, you must stop using our services. Please feel free to review our Privacy Policy from time to time.

Article 11: HOW TO CONTACT US?

 

If you have any questions about this Privacy Policy, the use of your Personal Data and/or to exercise your rights as described above, please contact us by email at dpo@squadeasy.com or by post at the address below:

LiveHappier

Le Cargo

157 boulevard Macdonald

75019 Paris

 

Before evaluating your request, we may ask you for additional information to identify you. If you do not provide the requested information and, as a result, we are unable to identify you, we may decline to process your request.

If you are not satisfied with our response to your complaint or if you believe that the processing of your Personal Data does not comply with data protection laws, you may file a complaint with the competent data protection supervisory authority. The Commission Nationale de l'Informatique et des Libertés (CNIL) is the data protection authority in France.