Tonteo (whose head office is located at 24, rue Tourville 69007 Lyon, France), in its capacity as controller, attaches great importance to the protection and respect for your privacy. The purpose of this policy is to inform you of our practices regarding the collection, use and sharing of information that you are required to provide us through our platforms (the “Platforms”) accessible from the www.tonteo website. com or our web and mobile applications.
This policy (together with our General Terms and Conditions of Service and any document referred to herein and our Cookie Management) outlines how we handle the personal data we collect and provide to you. We invite you to read this document carefully to know and understand our practices regarding the processing of your personal data that we implement.
2. The information we collect
We are likely to collect and process the following data:
2.1. The information you send us directly
By using our Platforms, you are required to send us information, some of which is likely to identify you (“Personal Data”). This is particularly the case when you fill out forms (such as the registration form), when you participate in one of our games, contests, promotional offers, studies or surveys, when you contact us – whether it is by phone, email or any other means of communication – or when you tell us about a problem.
This information contains the following data:
2.1.1. The data needed to register for the service we provide on our Platforms or access to any other service provided by Tonteo. This data includes your username, first and last name, email address, date of birth, address, sex, interests, phone number and password. This information is necessary for the proper functioning of your account. Otherwise, Tonteo may not be able to provide you with the services offered by our Platforms;
2.1.2. A photograph ;
2.1.3. A postal address
2.1.4. Details of the financial or accounting transactions carried out on our Platforms;
2.1.5. The details of your visits to our Platforms and the content you have accessed;
2.1.6. If applicable, your answers to our surveys and questionnaires, this information being particularly likely to be used in the context of research and analysis of user behavior;
2.1.7. The data we may ask you to provide when you report a problem with our Platforms or services, such as the subject of your request for assistance;
2.1.8. The data related to your location when you accepted that we collect and process this data;
2.1.9. A copy of your passport, driver’s license, ID card or other similar document that you have agreed to provide;
2.2. The data we collect automatically
2.2.3. We also collect information about your use of our Platform that may be displayed on your public profile.
2.3. Shelf life of your data
2.3.1. With the exception of the categories of Personal Data referred to in Articles 2.3.2. and 2.3.3. below, your Personal Data is archived at the end of the following periods:
10 years after your last use of our Platforms, if you have not closed your account;
1 year after the closure of your account, unless you have received a report, in which case your data are kept for 2 years following the report received if this duration is longer.
2.3.2. The following categories of Personal Data may be retained for different durations:
Financial data (eg payments, refunds, etc.) are kept for the time required by applicable tax and accounting laws;
The contents created by you on our Platforms are rendered anonymous past the deadlines mentioned in 2.3.1 but remain visible on our Platforms.
2.3.3. In the event that your account has been suspended or blocked, we keep your data for a period ranging from 2 to 10 years from the suspension in order to avoid any circumvention by you of the rules in effect on our Platforms.
3. How do we use the data we collect?
We use the data we collect in order to:
3.1. execute the contracts concluded between you and us or between you and one of our partners (for example regarding payment services), and provide you with the requested information and services;
3.2. send you information about our services (such as, for example, confirmation of actions) by e-mail, SMS or any other means of communication;
3.3. collect your payments or send you the sums collected for your account;
3.4. allow you to customize your profile on our Platforms;
3.5. enable you to communicate and interact with other members of our community;
3.6. to ensure compliance with (i) the applicable law, (ii) our general conditions of service, (iii) our confidentiality policy and (iv) the by-laws of the association and its by-laws. In the event of breaches on your part, we may suspend your account on our Platforms;
3.7. send you, in accordance with the applicable legal provisions and with your agreement when the legislation so requires, marketing, advertising and promotional messages and information relating to the use of our services, or suggest and advise you of goods or services likely to to interest you. We may also use your data to send you advertising messages that may be of interest to you on social media platforms or third party sites. If you want more information on this subject, we invite you to read the contractual documents of these platforms;
3.8. to inform you of changes to our services;
3.9. verify the information contained in your passport, driver’s license, identity card or any other document of identity that we would have collected during your registration or your use of our Platforms;
3.10. manage our Platforms and perform internal technical operations for problem solving, data analysis, testing, research, analysis, studies and surveys;
3.11. improve and optimize our Platforms, in particular to ensure that the display of our content is adapted to your device;
3.12. enable you to use the interactive features of our services if you wish;
3.13. help us maintain a healthy and secure environment on our Platforms; and
3.14. evaluate the effectiveness of the advertising messages we send and adapt them to our members.
4. Who are the recipients of the information we collect and why do we share this information with them?
4.1. As part of the use of our services, some of your information is passed on to other members of our community.
4.2. We may also share information about you, including Personal Data, with other entities of the Tonteo Project within the scope of this policy.
4.3. We also work closely with third-party companies that can access your Personal Data, including:
social networking platforms that can offer you functionalities allowing you to integrate information from your account on their own platform into your Tonteo profile;
the subcontractors we use in terms of technical services, payment services, identity verification or the suppliers of analytical solutions and collection companies.
4.4. We do not share your data with third parties mentioned in 4.3. above only in the following cases:
4.4.1. When we use a service provider in the performance of any contract between you and us or to provide or improve our services (for example, payments made through our Platforms);
4.4.2. when you make a specific request (for example when you use the authentication methods provided by social networks), subscribe to a service provided by one of our partners, ask to benefit from an offer or a good plan d one of our partners);
4.4.4. If Tonteo or all or part of its assets are bought back by a third party, the data in our possession will, if necessary, be transferred to the new owner.
4.4.5. In accordance with applicable law and with your consent when required, we may aggregate data about you that we receive or send to our business partners, including all or part of your Personal Data and information collected through cookies. This aggregated information will only be used for the purposes described above.
4.4.6. We draw your attention to the fact that if you decide to let us access some of your information, including your Personal Data, through connection services provided by our business partners, their privacy policies are also available to you. opposable. We have no control over the collection or processing of your data by our trading partners on their own platform.
5. How do we use and moderate your messages?
5.1. We can read the messages that you exchange with other members of our community via our Platforms, in particular for fraud prevention, improvement of our services, user assistance, verification of our members’ compliance with contracts concluded with us and in particular our General Conditions of Services. For example, to prevent a member from bypassing our system, we allow ourselves to browse and analyze the messages exchanged on our Platforms.
5.2. We never see your communications with other members of our community for promotional purposes or advertising targeting. Whenever possible, we use automated systems to moderate messages sent between members via our Platforms.
6. Targeted advertising, emails and SMS that we send you
In accordance with applicable law and with your consent when required, we may use the data you provide to us on our Platforms for business purposes (for example, to (i) send you our newsletters, (ii) send you invitations to our events or other communications that may be of interest to you; and (iii) display targeted advertising on social media platforms or third-party sites).
With regard to promotional emails: You may at any time withdraw your consent by (ii) clicking on the unsubscribe link provided in each of our communications or (iii) by contacting us in the manner described in Article 13 below. below.
With regard to targeted advertising:
- On social media platforms (for example Facebook, Twitter): you can oppose this process at any time by configuring the parameters relating to the advertising of your account;
- On third-party sites: You can refer to our Cookie Management to understand how to withdraw your consent.
7. Are your data transferred, how and where?
We keep your Personal Data in the European Union. However, it is possible that the data we collect while using our Platforms or as part of our services may be transferred to other countries, some of which may have less protective personal data protection legislation than in the country where you reside.
This is particularly the case with regard to the data transmitted to our subcontractors located outside the European Union. We can use their services to respond to your requests, moderate the photographs published on our Platforms, provide online payment tools, provide us with commercial and advertising services or email and SMS services.
This is also the case for companies affiliated with Tonteo located outside the European Union to which we can transfer some of your data as part of the provision of our services in these countries.
In case of such transfer, we make sure that the processing is carried out in accordance with this policy and that it is framed by the standard contractual clauses of the European Commission that ensure a sufficient level of protection of life privacy and fundamental rights of individuals.
On simple request, we can provide you with the list of countries where we store your data and those where they pass occasionally.
8. What are your rights to your personal data?
8.1. Where provided by applicable law, you have the right to obtain a copy of the personal data about you that we hold. Before responding to your request, we may (i) verify your identity and (ii) ask you to provide us with more information to respond to your request.
8.2. We will endeavor to comply with your request within a reasonable time and, in any event, within the time limits set by law. If you wish to exercise this right, contact us as described in Article 13 below.
As a member of our Platforms, you also have the option to access the Personal Data we hold through your account to correct, modify or delete any incorrect information. You can also rectify or erase this information by contacting us directly (see article 13 below). You can also close your account online at any time and have the right to oppose or limit the processing of your Personal Data.
You can also modify or delete this information by contacting us directly (see article 13 below).
Please note that we may retain certain information about you when required by law or when we have a legitimate reason to do so. This is the case, for example, if we believe that you have committed fraud or violated our Terms and Conditions of Service and that we wish to avoid circumventing the rules applicable to our community.
8.3. You have the right to lodge a complaint with the competent supervisory authority or to obtain compensation from the competent courts if you consider that we have not respected your rights.
8.4. You also have the right to the portability of your data, that is to say the right to receive the Personal Data that you have provided in a structured, commonly used and machine readable and the right to transmit this data to another controller.
8.5. You also have the right to set guidelines regarding the fate of your Personal Data after your death.
9. Cookies and similar technologies
To learn more, check out our Cookies management.
10. Confidentiality of your password
You are responsible for the confidentiality of the password we have chosen to access your account on our Platforms.
You agree to keep this password secret and not to communicate it to anyone.
11. Links to other websites and social networks
- sending an email to our data protection officer at firstname.lastname@example.org
- filling this form online
- or by sending us an email to the following address: Tonteo SAS – Attention: Data Protection Officer – 24, rue Tourville – 69007 Lyon – France
Version updated on january 2nd, 2020