2. Purpose of this charter
The purpose of this charter is to inform you about the means we use to collect your personal data, in the strictest respect of your rights.
We indicate to you on this subject that we comply, in the collection and management of your personal data, with law n ° 78-17 of January 6, 1978 relating to data processing, files and freedoms, in its current version (hereinafter: the “Data Protection Act”), as well as regulation (EU) 2016/679 of April 27, 2016 relating to the protection of individuals with regard to the processing of personal data and to the free circulation of this data (hereinafter: the “GDPR”).
3. Identity of the data collection manager
The person responsible for collecting your personal data is Flywallet, a Delaware corporation (hereinafter: "We").
4. Collection of personal data
The legal basis for our collection of your personal data is as follows:
(i) The legitimate interest when you voluntarily provide us with personal data during your visit to our Site / Application, the data then being collected to allow us to better respond to your requests for information about our Services;
(ii) Your consent regarding social media cookies, advertising cookies and Google Analytics cookies referred to in Article 10 "Cookies".
(iii) this collection is necessary in order to execute the contract concluded when you use our Services on our Site / Application.
(iv) the processing of your data is necessary to comply with a legal obligation to which we are subject.
Your personal data is collected to fulfill one or more of the following purposes:
(i) Manage your access to the Services accessible on the Site / Application and their use,
(ii) Perform operations relating to customer management concerning contracts, invoices, loyalty programs, monitoring of customer relations,
(iii) Build a file of registered members, users, customers and prospects,
(iv) Send newsletters, solicitations and promotional messages. In the event that you do not wish this, we give you the right to express your refusal on this subject during the collection of your data;
(v) Develop commercial statistics and frequentation of our Services,
(vi) Organize contests, lotteries and all promotional operations excluding online games of chance subject to the approval of the Online Games Regulatory Authority,
(vii) Manage the management of opinions / testimonials from users of the Services,
(viii)Manage unpaid debts and possible disputes regarding the use of our Services,
(ix) Personalize the responses to your requests for information,
(x) Respect our legal and regulatory obligations.
We will inform you, when collecting your personal data, whether certain data must be completed or whether it is optional. Mandatory data is necessary for the operation of the Services. Regarding optional data, you are entirely free to indicate it or not. We also tell you what the consequences are.
5. Recipients of the data collected
The personnel of our company, the services responsible for control (notably the statutory auditor) and our subcontractors will have access to your personal data.
Public bodies may also be recipients of your personal data, exclusively to meet our legal obligations, judicial officers, ministerial officers and bodies responsible for collecting debts.
6. Transfer of personal data
Your personal data will not be transferred, rented or exchanged for the benefit of third parties.
7. Duration of storage of personal data
(i) Concerning the data relating to the management of customers and prospects:
Your personal data is kept for the period strictly necessary for the management of our commercial relationship with you.
Regarding any prospecting operations that may be intended for you, your data may be kept for a period of 3 (three) years from the end of the commercial relationship.
The data used to establish proof of a right or a contract, which must be kept for compliance with a legal obligation, will be kept for the period provided for by the law in force.
Personal data relating to a prospect, who is not a client, may be kept for a period of 3 (three) years from their collection or the last contact from the prospect.
At the end of this period of 3 (three) years, we can contact you to find out if you wish to continue receiving commercial requests.
(ii) Regarding identity documents:
In the event of the exercise of the right of access or rectification, the data relating to the identity documents may be kept for the period provided for in article 9 of the Code of Criminal Procedure, i.e. 1 (one) year. In the event of the exercise of the right of opposition, this data may be archived for a period of 3 (three) years.
(iii) Regarding data relating to bank cards:
Financial transactions relating to the payment of purchases and fees via the Site / Application are entrusted to Mangopay as a payment service provider who ensures their smooth running and security.
For the purposes of the services, this payment service provider may be required to be the recipient of your personal data relating to your bank card numbers, which it collects and stores in our name and on our behalf.
We do not have access to this data.
(iv) Regarding the management of opposition lists to receive prospecting:
The information allowing you to take into account your right to object is kept for at least 3 (three) years from the exercise of the right to object.
(v) Regarding cookies:
The shelf life of cookies referred to in Article 10 "Cookies" is 13 (thirteen) months.
We inform you to take all necessary precautions, organizational and technical measures appropriate to preserve the security, integrity and confidentiality of your personal data and in particular, to prevent it from being distorted, damaged or that unauthorized third parties have access to it. . We will also use secure payment systems that comply with the state of the art and applicable regulations.
We inform you that your data is kept and stored, during the entire period of their conservation on the servers of the company Amazon Web Services, located in the United States.
The company Amazon Web Services has adhered to the “Privacy Shield”, which was deemed to offer an adequate level of protection by a decision of the European Commission of July 12, 2016 (Decision). To find out more about the protection offered by the “Privacy Shield”, you can consult its website.
We remind you for all practical purposes that you can oppose the deposit of cookies by configuring your browser / smartphone. Such a refusal could however prevent the proper functioning of the Site / Application.
11. Access to your personal data
In accordance with the law n ° 78-17 of January 6, 1978 relating to data processing, the files and freedoms, and GDPR, you have the right to obtain the communication and, if necessary, the correction or the erasure data concerning you, through online access to your file. You can also contact: firstname.lastname@example.org
Persons whose data is collected on the basis of our legitimate interest, as mentioned in article 4 "Collection of personal data", are reminded that they can object to the processing of data concerning them at any time. . However, we may be required to continue the processing if there are legitimate reasons for the processing which prevail over your rights and freedoms or if the processing is necessary to establish, exercise or defend our legal rights.
12. Right to define guidelines for the processing of data after your death
You have the right to define directives relating to the storage, erasure and communication of your personal data after your death.
These directives can be general, that is to say that they relate to all the personal data which concern you. In this case, they must be registered with a trusted digital third party certified by the CNIL.
The directives may also be specific to the data processed by our company. You should then send them to us at the following email address: email@example.com
By transmitting such directives to us, you expressly give your consent for these directives to be stored, transmitted and executed in the manner provided herein.
You can designate in your directives a person responsible for their execution. This one will then have quality, when you will be deceased, to take cognizance of the said directives and ask us for their implementation. In the absence of a designation, your heirs will have standing to take cognizance of your directives upon your death and to request their implementation.
You can modify or revoke your directives at any time by writing to us using the contact details above.
13. Portability of your personal data
You have a right to the portability of the personal data that you have provided to us, understood as the data that you have declared actively and consciously in the context of accessing and using the services, as well as the data generated by your activity in connection with the use of the services. We remind you that this right does not relate to data collected and processed on any other legal basis than the consent or the execution of the contract binding us.
This right can be exercised free of charge, at any time, and in particular when your account is closed on the Platform, in order to recover and store your personal data.
In this context, we will send you your personal data, by any means deemed useful, in a standard open format commonly used and machine-readable, in accordance with the state of the art.
14. Introduction of a complaint before a supervisory authority
You are also informed that you have the right to lodge a complaint with a competent supervisory authority, (the National Data Protection Commission for France), in the Member State in which your usual residence is located, your place of work or the place where the violation of your rights would have been committed, if you consider that the processing of your personal data object of this charter constitutes a violation of the applicable texts.
This recourse may be exercised without prejudice to any other recourse before an administrative or jurisdictional court. Indeed, you also have the right to an effective administrative or judicial remedy if you consider that the processing of your personal data which is the subject of this charter constitutes a violation of the applicable texts.
We reserve the right, at our sole discretion, to modify this charter at any time, in whole or in part. These changes will come into effect as of the publication of the new charter. Your use of the Site / Application following the entry into force of these modifications will constitute recognition and acceptance of the new charter. Otherwise and if this new charter does not suit you, you will no longer have to access the Site / Application.
17. Policy Update