DIGITAL VIRGO ENTERTAINMENT PRIVACY POLICY

Updated in August the 18^st 2016

 

 

 

INTRODUCTION

Digital Virgo Entertainment (‘DVE’ or the ‘Company’), a French société par actions simplifiée (SAS) (simplified joint stock company) with share capital of €497,040, registered in the Aix-en-Provence Trade and Companies Register under number 430 325 811, whose registered office is located at 350 Rue Denis Papin, – Parc de la Duranne – Domaine du Tourillon – 13100 Aix-en-Provence, France, EU VAT no. FR 80 430 325 811 (Telephone: 01 82 50 50 00 / Fax: 01 82 50 50 01) (Publishing Director: Guillaume Briche, Chief Executive Officer), respects your privacy.

The purpose of this Privacy Policy is to inform users of one or more websites, mobile websites and/or applications published by DVE (hereinafter the ‘Sites’), in a complete and transparent manner, about the Company’s use of Personal Data. This Privacy Policy is incorporated into and governed by the General Terms and Conditions of the Sites.

By navigating on the Sites or using the services offered by the Company on the Sites (hereinafter the ‘Services’), you expressly consent to the use of your Personal Data in accordance with the uses and provisions set out herein.

Data controller

 

All Personal Data that you provide us at the time that you register and when you navigate on our Sites and/or when you use our Services are managed by DVE and/or by a company of the Digital Virgo Group, of which the Company is a member. The processing of this Personal Data has been reported to the French National Data Protection Authority (CNIL) (nos. 1627091v0, 1625178 v0 and 6534).

 

 

Personal Data

 

Personal Data collected

Digital Virgo Entertainment publishes a range of Sites.

When you use any of our Sites (to register as a member and/or user for our free or fee-paying services), we may request that provide us with data that identify you personally.

Personal Data means all information that you provide us directly, in particular when your register on the Sites to open an account to access the Services or, indirectly, when navigating on the Site.

Personal Data collected on the Site are identification information that are recorded directly at the time a user registers to open an account, including, but not limited to, first name, surname, pseudonym, title, age, sex, date of birth, address, telephone number, e-mail address, internet access provider and telecommunications operator. Providing certain information may be optional. In all cases, we will request only those details that are strictly necessary for you to register on the Site and for the operation of the Site that you use, and to check your orders. Whenever you provide us with Personal Data, we will handle it in accordance with the provisions of this Privacy Policy.

Electronic identification data allow the user to be recognised indirectly when he/she logs on to the Site. Such data may include, for example, the user’s IP address or the pages visited on the Site. Such data is not Personal Data and cannot, by themselves, be used to identify the user. These anonymous data cannot be used to identify you and are generally grouped with your Personal Data. In general, we use these Site use data only for the purpose of providing you with better service and to personalise your experience on the Sites.

Localisation data, such as the user’s IP address or département (county) code, show the geographical location of the terminal the user uses to connect to the Site, and are collected using a cookie. These data enable the Company to provide the user with geographically personalised Services in relation with a specific location.

Accordingly, the Company may collect Personal Data when a user:

• opens an account;
• uses the Services;
• sends a claim or a request for information;
• navigates on the Sites and cookies are stored on the hard drive of the user’s computer and/or on the user’s mobile terminal.

Without the user’s agreement, DVE will in no event obtain other information that enables personal identification of our users’ profiles.

Personal Data provided by users

Each user is solely responsible for the data he/she provides.

The user agrees:

• to provide accurate and complete identification information and to update such information regularly. If necessary, the user may update his/her identification information at any time.
• to choose a user name (e-mail address/pseudonym) and a password that enable access to the Services.
• When appropriate, indicate a valid email address.
• not to use a pseudonym or an e-mail address that infringes the rights of third parties and, more specifically, the laws on names, trademark rights, copyright or neighbouring rights or, more broadly, that is in breach of the laws in force, public policy or good morals. Otherwise, the Company reserves the right to refuse any names, terms, expressions, etc. that may be contrary to these principles, without having to state a reason therefor.

The user may decide to allow other users of the Services to view certain of his/her Personal Data. In such case, the user is recommended to provide only Personal Data that he/she is comfortable sharing, and we strongly advise users not to provide information that can be used to contact them.

Personal data collected on users’ “Facebook” profile

The Company receives Personal Data from the user’s “Facebook” profile such as his language, name, first name, birthday date, country, home town, e-mail address, etc. Moreover the Company has access to information of the user which is published on the social network “Facebook”. The Company can update and store these Personal Data on its servers.

Data processing purposes

 

We may use the Personal Data collected on the Site or on the social network “Facebook” in order to provide you with a more efficient use of the Services offered on the Site, as well as for marketing, promotional, research and analysis purposes.

In all marketing or promotional communications that we may send you subsequently, we will offer you the possibility of withdrawing this consent and, therefore, not to receive such communications in the future.

Personal Data may be used for the following purposes:

• to register, maintain and authenticate the account;
• to provide the Services offered on the Site;
• to enable the user to take part in satisfaction surveys or games and contests offered on the Site;
• to enable the user to receive newsletters and sales offers from the Company, its subsidiaries or its partners, provided the user’s consent has been obtained;
• to enable the user to receive offers for products and services similar to the Service used;
• to compile anonymous statistics about Site use;
• to assess and improve the quality of the Services;
• to avoid any breach of the General Terms and Conditions of Use or Sale by the user or any party associated with him/her, and to reinforce security measures;
• to provide oversight for billing and accounting management for the Services;
• to comply with applicable statutes and regulations.

We reserve the right to monitor your account and files in order to verify any complaint or allegation of wrongful use, violation of the rights of third parties or any other unauthorised use of the Site.

Sharing of Personal Data with third parties

 

Provided the user’s consent is obtained, the user’s Personal Data may be the subject of a data leasing contract between the Company and selected trusted commercial partners and/or the companies of the Digital Virgo Group. The commercial partners and/or the companies of the Digital Virgo Group may use Personal Data to offer the user content that may be of interest to him/her. Without the user’s consent, they may not share or sell your personal information to or with any party.

The user is hereby informed that the Company may provide Personal Data to:

• its technical service providers (i) for the purpose of hosting said Personal Data and to register and maintain accounts, (ii) to assist in providing the Services and (iii) to manage the customer relationship. These technical service providers are required to keep Personal Data confidential, and may not use Personal Data for any purpose other than that for which the Company provides such Personal Data to them;
• to authorised administrative authorities in the event of a breach of the General Terms and Conditions of Use or Sale of each Site or if disclosure of Personal Data is required by law;
• the companies of the Digital Virgo Group;
• the Company’s partners as for example Exelate, Criteo which can send you exclusive promotional offers.

We may also process your Personal Data to make them anonymous and group them with other data for the purpose of disclosing such grouped and anonymous data to our affiliates and/or business partners.

 

We may collect and process data about your computer, including, if necessary, your IP address, type of operating system and type of web browser, for system management purposes. This is statistical data about the navigation actions and habits of our users and cannot be used to identify individuals.

However, we may make a connection between IP addresses and Personal Data (such as a user’s country) and/or non-personal data (such as use records or the place from which a user accesses the Site) to ensure compliance with our General Terms and Conditions of Use or other user contracts and, if necessary, to prevent certain IP addresses from accessing all or part of the Site in the event of wrongful use by the corresponding user.

Your rights to access, change and oppose use of your Personal Data

 

In accordance with the laws in force, the user has a right to access, correct, delete and oppose the processing of his/her Personal Data. He/she may exercise this right by writing to: Service Client – [NAME OF THE CONCERNED OFFER] Libre Réponse 94119, 13629 Aix-en-Provence 1, [France], or by sending an e-mail to support@contactdve.com or to the e-mail specified on the relevant Site.

In order to be able to comply with his/her request, and in accordance with the laws in force, the user must include with his/her request a copy of any official identity document showing his/her first name, surname and date and place of birth and proving his/her identity. The user is required to update his/her identification information in the event his/her situation changes.

In the event the user does not allow anymore the Company to access to his Personal data, he should uninstall the Company’s application available on the social network “Facebook”.

In accordance with the article L121-34 of the consumer code, users that do not want to receive telemarketing calls can register on a list of opposition for free. When our services collect the phone number of a user, this one is informed of his right to register on the list of opposition to telemarketing calls.

Langue source

Lorsque nos services recueillent les coordonnées téléphoniques d’un Utilisateur, ce dernier est informé de son droit de s’inscrire sur la liste d’opposition au démarchage téléphonique.

Personal Data retention period

 

The Company retains Personal Data for the time necessary for the purposes described above in the section entitled ‘Data processing purposes’ and in accordance with the recommendations of the French National Data Protection Authority, i.e. for a period of three years from the end of the commercial relationship or, in the case of prospective customers, from the time the Personal Data is collected or from the last contact originated by the prospective customer.

Data transfers outside the European Union

 

Data is transferred to recipients located outside the European Union for the purpose of managing (i) the provision of products and/or services and (ii) the customer relationship.

The Company has reported such data transfers outside the European Union to the French National Data Protection Authority, and such data transfers are governed by the standard contractual clauses approved by the European Commission.

Protection of your Personal Data

 

The Company applies all standard industry practices and implements strict security procedures to prevent any unauthorised access and comply with applicable Personal Data protection laws.

However, information transfers over the telecommunications networks are not entirely secure and, therefore, you acknowledge and accept that third parties may intercept the Personal Data you provide us, and that such transfers are at your own risk. After we receive your Personal Data, we will use strict security procedures and systems to endeavour to prevent any unauthorised access.

All personal information provided is stored on the secure servers of the Company or its technical service provider.

The secure servers encode all Personal Data that are input before they are sent to the Company. The servers of our technical service provider are located in the European Union. The purpose of the password that enables the user to log on to his/her account and use certain Services is to protect his/her Personal Data. The user must keep this password confidential and must never share or disclose his/her password to anyone.

The user is responsible for any use of the Sites and associated Services by any person who uses his/her account user name and password. The user must contact the Company immediately if he/she has reason to believe that his/her account user name and password have been misappropriated. As a security precaution, the user is advised to close his/her account at the end of each session.

You may at any time review and change the Personal Data we hold about you on the Site, or by contacting us by e-mail or by post.

Cookies

 

Cookies are data files sent to a web browser and stored on the computer’s hard drive. They do not allow internet users who visit the Site to be identified directly. However, they record information about the computer’s navigation on the Site (pages visited, date and time of the visit, etc.), which the Site can read during subsequent visits. The computer stores an identification code in the cookie. The cookie stores only the identification code in its memory, and no other personal information about the user.

Data collected using cookies enable inter alia improving the quality of the Site to make it more attractive or functional and to facilitate navigation thereon. More specifically, localisation data collected using cookies enables personalised Services to be provided.

The length of time during which this information is stored on the user’s computer depends on the Site(s) visited. After a cookie has been stored on his/her computer, the user may receive, or see displayed, advertising for products and services offered by the Company, its partners or subsidiaries of the Digital Virgo Group. Such advertising is broadcast under the sole responsibility of the relevant partners or advertising agencies.

The Company hereby informs the user that he/she may prevent cookies from being stored on his/her computer by configuring his/her web browser to inform him/her when cookies are sent to his/her computer. For example:

For Mozilla Firefox:

• Select the ‘Tools’ menu, then ‘Options’
• Click on the ‘Privacy’ icon
• Find the ‘Cookies’ menu and select the options appropriate for you

For Microsoft Internet Explorer:

• Select the ‘Tools’ menu, then ‘Internet Options’

• Click on the ‘Privacy’ tab
• Select the level desired using the slider

For Opera 6.0 and higher:

• Select ‘Files’ > ‘Preferences’
• Privacy

If the user uses another web browser, he/she should review the software’s options for disabling cookies. In general, cookies can be disabled in the ‘Options’ menu of the software. For additional information, the user should study the assistance provided with his/her web browser.

However, if cookies are disabled, the user may no longer be able to (i) access certain areas of the Site or (ii) use certain Services. In addition, our partner’s cookies may be placed on the Site.

The Company can share anonymous information with third parties, which can send you can send you exclusive promotional offers; for by the company Criteo, eXelate UK Ltd and its customers. In case you do not want to receive offers from “Le Club des Sites Marchands”, you can inform us by clicking on the url : http://www.clubdessitesmarchands.fr/charte/.

The purpose of the Criteo Email is to find people visiting the sites, applications or newsletters of Criteo’s partners and send them personalized emails. Criteo uses cookies to distinguish between users and to customize advertisements they receive based on their browsing history. To learn more about Criteo Email or deactivate the service, click on the url: http://privacy.criteoemail.com/fr/index.html.

To deactivate the services of the eXelate Company, user shall follow this process:

The user must go to the following site: http://exelate.com/privacy/opt-in-opt-out/

Where they are accessible on the territory of operation of the Site, the user should go to the website YOUR ON LINE CHOICES relative to behavioral advertising (http://www.youronlinechoices.com/ ), or the NETWORK ADVERTISING INITIATIVE website (www.networkadvertising.org) or the website of THE DIGITAL ALLIANCE WEBSITE (http://www.aboutads.info/) to learn more about eXelate.

To deactivate the services of the others partners of the company, the User can use the website Youronlinechoices: http://www.youronlinechoices.com/FR/controler-SES-cookies/.

On this website, the User can know companies listed on this platform and which offer him the possibility to refuse or accept some cookies. Particularly, this European platform provides a centralized interface enabling the user to indicate his refusal or acceptance of cookies which can be used to adapt to the navigation adverts which can be displayed on its terminal.

This procedure shall not prevent the display of adverts on the websites visited by the user. Technologies that allow to adapt adverts according to User’s interests are blocked.

The user also acknowledges that during navigation of the mobile internet, certain mobile websites may store cookies on his/her mobile terminal. Similarly to the Sites, these cookies store information about the User’s navigation. The length of time during which this information is stored in the user’s mobile terminal depends on the mobile website visited. After a cookie has been stored on his/her mobile terminal, the user may receive, or see displayed, advertising for products and services offered by the Company. Such advertising is broadcast under the sole responsibility of the relevant partners or advertising agencies.

DVE hereby informs the user that he/she may prevent cookies from being stored on his/her mobile terminal by configuring said mobile terminal appropriately. To do so, the user should go to his/her mobile terminal’s menu, tap the ‘Settings’ function and then delete cookies. This procedure is specific to each mobile terminal model.

Please note that, provided the user’s consent is obtained, the Company’s partners may also use cookies, to which the relevant partner’s privacy policy applies.

Other links

 

The Site may contain sponsored links that direct the user to the sites of other partners. The user is hereby informed that if he/she clicks on such links he/she will be directed to sites that have their own privacy policies. The Company declines all liability with respect thereto.

Changes to the Privacy Policy

 

We may at any time update this Privacy Policy or amend it in any other way. We will inform you of any changes made to our Privacy Policy by posting the amended version of the Privacy Policy on the Site. We encourage you to review the provisions of our Privacy Policy each time you visit our Sites.