Charter concerning the protection of users’ personal data

Definition and nature of the personal data

When written with an initial capital letter, the following terms and expressions will be considered as having the meanings attributed to them in the General Terms and Conditions for the use of the Services.

During your use of the website www.playplay.com (hereafter referred to as the “Website”), we may require you to provide us with personal data concerning you, in order to access the Services proposed by the company PlayPlay.

For the purpose of this charter, the term “personal data” or “data” refers to all data making it possible to identify an individual, such as for example your last name, first names, company, postal addresses and e-mail addresses, telephone numbers, photos and videos uploaded to and generated on the Website, technical data (IP address, browser, operating system), data concerning your transactions on the Website, details of your purchases and subscriptions, bank card numbers and any other information you choose to provide about yourself.

Purpose of this charter

The purpose of this charter is to inform you of the means used by us to collect your personal data, in strict compliance with your rights.

We would like to inform you that during the collection and management of your personal data we comply with law number 78-17 of 6 January 1978 concerning information technology, files and personal liberties in its current version, (hereafter referred to as the “Informatique et Libertés” law) and (EU) regulation number 2016/679 of 27 April 2016 concerning the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereafter referred to as the “GDPR”).

Identity of the data collection manager

The data collection manager for the collection of your personal data is the company PlayPlay, a simplified joint stock company with a sole shareholder, registered in the Trade & Company Register of Paris under the no. 828 572 099, having its registered office at 30 rue Didot 75014 PARIS (hereafter referred to as: “Us” or “We”).

The collection of personal data

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

  • (i) Our legitimate interests when you voluntarily supply us with personal data during your visit to our Website, with this data then being collected to enable us to better respond to your requests for information concerning our Services.
  • (ii) Your consent concerning social networking cookies, advertising cookies and audience analysis cookies.
  • (iii) The collection of this data is necessary in order to fulfil the contract concluded when you use our Services on our website.

Your personal data is collected to meet one or several of the following end purposes:

  • (i) To manage your access to certain Services available on the Website and their use,
  • (ii) To perform customer management operations concerning contracts, training, invoices, customer relationship management and User training,
  • (iii) To constitute a database of registered Users, Clients and Prospects,
  • (iv) To send out newsletters, proposals and promotional messages. If you do not agree to this, we give the option to express your refusal on this point at the time your data is collected;
  • (v) To draw up sales statistics and visitor statistics for our Services,
  • (vi) To manage payment issues and any possible disputes concerning the use of our products and Services,
  • (vii) To personalise our responses to your requests for information,
  • (viii) To comply with our legal and statutory obligations.

During the collection of your personal data, we will inform you if certain data must obligatorily be entered or if it is optional. The compulsory data is required for the operation of the Services. Concerning the optional data, you are completely free to supply this or otherwise. We also inform you of the possible consequences of any failure to reply.

Recipients of the personal data

Our internal teams have access to the videos uploaded to and generated on the Website, for the following purposes:

  • (i) To provide you with advice to enable you to create outstanding videos: editorial advice, advice on how to use the Templates and Screens and advice on using the different functions and features,
  • (ii) Help with solving technical issues,
  • (iii) Identifying product improvements and new Screens and Templates to be created,
  • (iv) Selecting and choosing the videos for “PlayPlay of the week”.

Protecting your privacy is a key priority. For this reason, you can choose the “private” option on the Website. Choosing this feature will have the following consequences:

  • (i) Your colleagues will not be able to see the video on the Website,
  • (ii) Only our technical teams will have access to these videos, and only for the purpose of resolving technical issues.

Our company’s staff, the departments handling control and oversight (including the auditors of corporate accounts) and our subcontractors will have access to your personal data. Other possible recipients of your personal data may include public bodies, exclusively to fulfil our legal obligations, judicial officers, ministerial officers and debt recovery organisations.

Transfers of personal data

Your personal data will not be transferred, rented, leased or exchanged to/with third parties.

Personal data retention period

(i) Concerning data regarding the management of Clients and Prospects:

Your personal data will be stored for the time strictly necessary to the management of our business relationship with you.

Concerning any possible prospection operations targeting you, your data may be stored for a period of 3 (three) years as from the end of the business relationship.

Data making it possible to establish proof of a right or a contract, which must be stored to ensure compliance with a legal obligation, will be stored for the period stated in the applicable law.

Personal data concerning a prospect who is not a client may be stored for a period of 3 (three) years from the time it is collected or from the last contact initiated by the Prospect.

At the end of this 3 (three-) year period, we may contact you again to find out if you wish to continue receiving sales proposals.

(ii) Concerning ID documents:

In the event that a data subject chooses to exercise their right to access or rectify data, the data concerning ID documents will be retained for the period mentioned in article 9 of the code of criminal procedure, i.e. 1 (one) year. In the event that a data subject chooses to exercise their right to oppose the use of their data, this data may be archived for 3 (three) years.

(iii) Concerning bank card data:

The financial transactions concerning payment for purchases and costs via the Website are handled by a payment service provider who ensures their fulfilment and security. For the purpose of fulfilling the Services, this payment service provider may be a recipient of your personal data with regard to your bank card numbers, receiving and storing these in our name and on our behalf.

We do not have access to this data.

To enable you to regularly make purchases or to pay the costs related to the website, your bankcard data is stored from the moment you register on the website and until at least the date of your last transaction.

By ticking the box expressly provided for this purpose on the Website, you expressly consent to us storing this information.

Data concerning the visual cryptogram or CVV2 shown on your bank card is not stored.

If you refuse to allow your personal data concerning your bank card numbers to be stored under the above-mentioned conditions, we will not store this data any longer than the time needed to complete the transaction.

In all cases, data concerning these transactions may be stored for the purpose of providing proof and for any possible disputes concerning the transaction, in intermediate archives, for the period stated in article L 133-24 of the Financial and Monetary Code, i.e. 13 (thirteen) months following the debit date. This can be extended to 15 (fifteen) months to take account of the possibility of the use of deferred debit payment cards.

(iv) Concerning the management of lists of data subjects who do not wish to be contacted for prospection purposes:

Information making it possible to take account of your right of opposition will be stored for a minimum of 3 (three) years from the moment you exercise your right of opposition.

Security

We hereby inform you that we take all appropriate organisational and technical measures to protect the security, integrity and privacy of your personal data, which includes preventing it from being deformed, damaged or accessed by unauthorised third parties. We also use secure payment systems fully compliant with the current state of the art and the applicable regulations.

On this point, we would like to inform you that we comply with the security measures introduced by our data host for your data, the company Google Ireland Limited, with the said measures being consultable at the following address: https://cloud.google.com/security/.

Hosting

We hereby inform you that your data is retained and stored for its whole retention period on the servers of the company Google Ireland Limited, located in Belgium, in the European Union.

Your data will not be transferred outside the European Union during the use of the Services we propose.

Accessing your personal data

Pursuant to law number 78-17 of 6 January 1978 concerning information technology, files and personal liberties, and the General Data Protection Regulation, you have a right to access and where applicable to rectify or delete the data concerning you, by contacting:

  • email address: privacy@playplay.com
  • postal address: 210 rue Saint-Denis, 75002 Paris, France

The data subjects are reminded that the data is collected on the basis of our legitimate interests, as mentioned in article 4, and that at any time they may oppose the processing of the data concerning them. However, we may nevertheless continue the processing operations if legitimate grounds exist for this processing which take precedence over your rights and liberties or if the processing is necessary to establish, exercise or defend our rights before the courts.

The right to stipulate instructions concerning the processing of data after your death

You have the right to specify instructions concerning the storage, deletion and communication of your personal data after your death.

These instructions may be general, i.e. they cover all personal data concerning you. In this case they must be recorded with a digital trusted third-party certified by the CNIL (French data protection authority).

The instructions may also be specific to the data processed by our company. In this case, you should send them to us using the following contact details:

  • email address: privacy@playplay.com
  • postal address: 210 rue Saint-Denis, 75002 Paris, France

When you send us such instructions, you expressly grant your consent for these instructions to be stored, transmitted and implemented in accordance with the terms mentioned in this document.

In your instructions, you may appoint a person with responsibility for their implementation. When you are deceased, this person will then be authorised to familiarise him/herself with the said instructions and to request that we implement them. Unless you have designated someone, your heirs will be authorised to familiarise themselves with these instructions and to request that we implement them.

You may modify or revoke your instructions at any time by contacting us using the above- mentioned contact details.

The portability of your personal data

You have rights concerning the portability of the personal data you have supplied to us, with this term being understood as referring to the data you have actively and consciously declared when accessing and using the Services, and the data generated by your activities during the use of the Services. We would like to remind you that this right does not concern data collected and processed on any legal basis other than consent or the performance of the contract existing between us.

This right may be exercised free of charge, at any time, including at the time you close your account via the Website, in order to recover and store your personal data.

In implementing this right, we will send you your personal data by any means considered appropriate, in a standard, open, commonly used and machine-readable format pursuant to the state-of-the-art at the time.

Submitting a complaint to a supervisory authority

You are also hereby informed that you have the right to submit a complaint to the relevant supervisory authority, (the Commission Nationale Informatique et Libertés for France), in the member state in which you have your normal place of residence, your place of work or the place in which the violation of your rights occurred, if you consider that the processing of your personal data covered by this charter constitutes a violation of the applicable laws and regulations.

This referral to the supervisory authority may be performed without prejudice to any other referral to an administrative or judicial authority. You also have a right to refer the matter to the administrative or judicial authorities if you consider that the processing of your personal data covered by this charter constitutes a violation of the applicable laws and regulations.

Limiting processing

You have the right to limit the processing of your personal data in the following cases:

  • During the verification period we apply, if you discover that your personal data is inaccurate,
  • When the processing of this data is illicit and you wish to limit this processing rather than delete your data,
  • When we no longer require your personal data but you would like it to be retained in order to be able to exercise your rights,
  • During the verification period concerning legitimate grounds when you have opposed the processing of your personal data.

Modifications

We reserve the right to totally or partially modify this charter at any time at our sole discretion. These modifications will take effect when the new charter is published. Your use of the Website following the application of these modifications constitutes acknowledgement and acceptance of the new charter. Failing this, if you are unhappy with this new charter, you must no longer access the Website.

Applicability date

This charter takes effect on April 14th 2020.