PERSONAL DATA MANAGEMENT

ETNIDEV


RCS of Nanterre under number 531 972 479 25 rue Paul Bert 92800 Puteaux, France

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Entry into force: January 1, 2021

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1. DEFINITION AND NATURE OF PERSONAL DATA

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When you use the Citygem mobile application "(hereinafter:" the Application ") or the websites www.citygem.app or https://www.citygem.app/ (hereinafter together: the" Site ”), we may ask you to provide us with personal data concerning you, in order to use the services offered by Etnidev (hereafter: the“ Services ”). We may also need to collect your personal data attached to your accounts on social networks as part of your participation in the contests that we organize on said networks.

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In the context of this charter, the term "personal data" refers to all data that identifies an individual, which corresponds in particular to your name, first names, gender, city of residence, e-mail, telephone numbers. , name, first name and telephone number of the emergency contact you have provided as well as any other information you choose to communicate to us about yourself.

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In addition to this, you need to know more about it.

2. PURPOSE OF THIS CHARTER

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The purpose of this charter is to inform you about the means we implement to collect your personal data, with the strictest respect for your rights.

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We inform you on this subject that we comply, in the collection and the management of your personal data, with the law n ° 78-17 of January 6, 1978 relating to data processing, files and freedoms, in its current version, known as “Informatique et Libertés”, and Regulation (EU) 2016/679 of April 27, 2016 (hereafter: “RGPD”).

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In addition to this, you need to know more about it.

3. IDENTITY OF THE PERSON RESPONSIBLE FOR DATA COLLECTION

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The person responsible for collecting your personal data is Etnidev, a limited liability company, registered in the Nanterre Trade and Companies Register under number 531 972 479 with its registered office at 25 rue Paul Bert 92800 Puteaux, France (hereinafter: "We").

In addition to this, you need to know more about it.

In addition to this, you need to know more about it.

4. COLLECTION OF PERSONAL DATA

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

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  • The performance of a contract when you use our Services on our Site and the Application;

  • The legitimate interest when we send you information emails or ask us questions through our Site, the data then being collected to allow us to better answer these questions;

  • Your consent with regard to the newsletters for which you have subscribed, your participation in our contests as well as social network cookies, advertising cookies and Google Analytics cookies referred to in Article 11.


Your personal data is collected to fulfill one or more of the following purposes:

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  • Provide value-added services in the Application;

  • Manage your access to certain services accessible on the Site or the Application and their use;

  • Create a file of users of the Site or of the Application (hereafter: the “Users”), of members subscribed to the newsletter, of partners and prospects;

  • Send newsletters and email notifications, in order to inform Users of new updates to the Application. In the event that you do not wish it, we give you the option to express your refusal on this subject on the emails received;

  • Develop commercial statistics and traffic to our Services;

  • Organize contests, lotteries and all promotional operations with the exception of online gambling and games of chance subject to the approval of the Online Gaming Regulatory Authority, in particular on social networks;

  • Manage the management of people's opinions on Services or content;

  • Manage any disputes regarding the use of our Services;

  • Personalize responses to your requests for information;

  • Comply with our legal and regulatory obligations

We inform you, when collecting your personal data, whether certain data must be entered or if they are 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 are the possible consequences of a failure to respond.

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5. RECIPIENTS OF THE DATA COLLECTED

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Only the staff of our company, the services in charge of control (auditor in particular) and support of the Application and the Site (technical team), our partners and our possible subcontractors, will have access to your personal data. .

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Public bodies may also be recipients of your personal data, exclusively to meet our legal obligations, court officials, ministerial officers and bodies responsible for debt recovery.

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6. TRANSFER OF PERSONAL DATA

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Your personal data will not be transferred, rented or exchanged for the benefit of third parties without your consent.

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In addition to this, you will need to know more about it.

7. PERIOD OF CONSERVATION OF PERSONAL DATA

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Regarding data relating to User management:

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Your personal data will not be kept beyond the period strictly necessary for the management of our commercial relationship with you. However, the data making it possible to establish the proof of a right or a contract, to be kept for the respect of a legal obligation, will be kept for the period provided by the law in force. Beyond this period, only statistical data made anonymous will be kept and will not give rise to any exploitation of any kind.

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The CityGem application will continue to retrieve the User's position even if it is closed when he has launched a route.

.

Concerning cookies: The retention period for cookies referred to in article 11 is 13 months.

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In addition to this, you need to know more about it.

8. SAFETY

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We inform you to take all useful precautions, organizational and technical measures appropriate to preserve the security, integrity and confidentiality of your personal data and in particular, to prevent them from being distorted, damaged or that unauthorized third parties have access to them. .

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As such, we inform you to respect the security measures put in place by our provider of hosting your data, the company Google and its Firebase service, the measures of which are accessible on its website.

In addition to this, you need to know more about it.

In addition to this, you need to know more about it.

9. ACCOMMODATION

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We inform you that your data is kept and stored, for the duration of its conservation on the servers of the Google company in Europe and North America.

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This 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.

In addition to this, you need to know more about it.

In addition to this, you need to know more about it.

10. COOKIES

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Cookies are text files, often encrypted, stored in your browser. They are created when a User's browser loads a given website: the site sends information to the browser, which then creates a text file. Each time the User returns to the same site, the browser retrieves this file and sends it to the website's server.

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We can distinguish different types of cookies, which do not have the same purposes:

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Technical cookies are used throughout your browsing, in order to facilitate it and to perform certain functions. A technical cookie can, for example, be used to memorize the responses entered in a form or even the User's preferences with regard to the language or presentation of a website, when such options are available.

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We use technical cookies.

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Social media cookies can be set by social platforms to allow website designers to share their site content on such platforms. These cookies can in particular be used by social platforms to track the navigation of Internet users on the website concerned, whether or not they use these cookies.

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We use social media cookies. These cookies are only deposited if you give your consent. You can find out about their nature, accept them or refuse them.

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We also invite you to consult the privacy protection policies of the social platforms at the origin of these cookies, to learn about the purposes of use of the navigation information that they can collect thanks to these cookies and the terms and conditions. to exercise your rights with these platforms.

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Advertising cookies can be created not only by the website on which the User is browsing, but also by other websites broadcasting advertisements, announcements, widgets or other

items on the displayed page. These cookies can in particular be used to carry out targeted advertising, that is to say advertising determined according to the User's navigation.

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We also use advertising cookies These cookies are only placed if you give your consent. You can find out about their nature, accept them or refuse them.

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We use Google Analytics which is a statistical audience analysis tool that generates a cookie to measure the number of visits to the Site, the number of page views and visitor activity. Your IP address is also collected to determine the city from which you are connecting. This cookie is only placed if you give your consent. You can accept it or refuse it.

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We remind you for all useful purposes that it is possible for you to oppose the deposit of cookies by configuring your browser. Such a refusal could however prevent the proper functioning of the Site.

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11. ACCESS TO YOUR PERSONAL DATA

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In accordance with the law n ° 78-17 of January 6, 1978 relating to data processing, files and freedoms, and the RGPD, you have the right to obtain the communication and, if necessary, the rectification or erasure data concerning you, by contacting:

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Email address: contact@citygem.com

Postal address: Etnidev - 25, rue Paul Bert 92800 Puteaux France

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It is recalled that any person may, for legitimate reasons, oppose the processing of data concerning him. We may, however, be required to continue 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.

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In addition to this, you need to know more about it.

12. RIGHT TO SET GUIDELINES ON THE PROCESSING OF DATA AFTER YOUR DEATH

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You have the right to define guidelines for the retention, erasure and communication of your personal data after your death.

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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.

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The guidelines may also be specific to the data processed by our company. You should then send them to us at the following coordinates:

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Email address: contact@citygem.app

Postal address: Etnidev - 25, rue Paul Bert 92800 Puteaux France

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By sending us such instructions, you expressly give your consent for these instructions to be stored, transmitted and executed in the manner provided herein.

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You can designate in your directives a person responsible for their execution. This will then have the capacity, when you are deceased, to take cognizance of the said directives and ask us for their implementation. In the absence of designation, your heirs will have the capacity to take cognizance of your directives on your death and ask us to implement them.

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You can change or revoke your guidelines at any time by writing to us at the contact details above.

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In addition to this, you need to know more about it.

13. PORTABILITY OF YOUR PERSONAL DATA

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You have a right to the portability of the personal data that you have provided to us, understood as the data that you have actively and consciously declared in the context of access and use of the services. We remind you that this right does not apply to data collected and processed on a legal basis other than consent or the execution of the contract binding us.

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This right can be exercised free of charge at any time, and in particular when closing your account on the Application, in order to retrieve and store your personal data.

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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.

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In addition to this, you need to know more about it.

14. SUBMISSION OF A COMPLAINT BEFORE A SUPERVISORY AUTHORITY

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You are also informed that you have the right to lodge a complaint with a competent supervisory authority (the Commission Nationale Informatique et Libertés for France), in the Member State in which your usual residence is located, your location 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 covered by this charter constitutes a violation of the applicable texts.

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This recourse may be exercised without prejudice to any other recourse before an administrative or judicial jurisdiction. Indeed, you also have a right to an effective administrative or judicial remedy if you consider that the processing of your personal data covered by this charter constitutes a violation of the applicable texts.

In addition to this, you need to know more about it.

In addition to this, you need to know more about it.

15. LIMITATION OF PROCESSING

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You have the right to obtain the restriction of the processing of your personal data, in the following cases:

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• During the verification period that we carry out, when you dispute the accuracy of your personal data,

• When the processing of this data is unlawful, and you wish to limit this processing rather than delete your data,

• When we no longer need your personal data, but you want them to be kept in order to exercise your rights,

• During the period of verification of legitimate reasons, when you have objected to the processing of your personal data.

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In addition to this, you need to know more about it.

16. MODIFICATIONS

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We reserve the right, at our sole discretion, to modify this charter at any time, in whole or in part. These modifications will come into force as from the publication of the new charter. Your use of the Site and the 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.

MANAGEMENT OF PERSONAL DATA

ETNIDEV


RCS of Nanterre under number 531 972 479 25 rue Paul Bert 92800 Puteaux, France

In addition to this, you need to know more about it.

Coming into effect: January 1, 2021

In addition to this, you need to know more about it.

In addition to this, you need to know more about it.

1. DEFINITION AND NATURE OF PERSONAL DATA

In addition to this, you need to know more about it.

When using the “Citygem” mobile application (hereinafter: “the Application”) or the websites www.citygem.app or https://www.citygem.app/ (hereinafter: the "Site"), we may ask you to provide us with personal data concerning you, in order to use the services offered by Etnidev (hereinafter: the "Services"). We may also be required to collect your personal data attached to your accounts on social networks as part of your participation in contests that we organize on said networks.

In addition to this, you need to know more about it.

In the context of this charter, the term "personal data" designates all data which makes it possible to identify an individual, which corresponds in particular to your first and last name, sex, home city, email, telephone numbers, the first name, last name and telephone number of the emergency contact you have provided, as well as any other information you choose to communicate to us about yourself.

In addition to this, you need to know more about it.

In addition to this, you will need to know more about it.

2. PURPOSE OF THIS CHARTER

In addition to this, you need to know more about it.

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.

In addition to this, you need to know more about it.

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, known as " Computing and Liberties ", and regulation (EU) 2016/679 of April 27, 2016 (hereinafter:" GDPR ").

In addition to this, you need to know more about it.

In addition to this, you will need to know more about it.

3. IDENTITY OF THE DATA COLLECTION MANAGER

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The person responsible for collecting your personal data is Etnidev, a lilited liability company, registered in the Nanterre Trade and Companies Register under number 531. 972 479 having its registered office at 25 rue Paul Bert. 92800 Puteaux France (hereinafter: "We").

In addition to this, you need to know more about it.

In addition to this, you need to know more about it.

4. COLLECTION OF PERSONAL DATA

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

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  • The performance of a contract when you use our Services on our Site and on the Application;

  • The legitimate interest when we send you informational emails or when you ask us questions through our Site, the data then being collected to allow us to better answer these questions;

  • Your consent with regard to the newsletters to which you have subscribed, your participation in our contests as well as social network cookies, advertising cookies and Google Analytics cookies referred to in Article 11.

  • Manage the management of people's opinions on Services or content;

  • Manage any disputes regarding the use of our Services;

  • Personalize the responses to your information requests;

  • Respect our legal and regulatory obligations.

Your personal data is collected to fulful one or more of the following purposes:

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  • Provide value-added services in the Application (calculation of the number of calories burned, adapted running tips, etc.);

  • Manage your access to certain services accessible on the Site or the Application and their use;

  • Create a file of Site or Application users (hereinafter: the "Users"), members subscribed to the newsletter, partners and prospects;

  • Send newsletters and email notifications to notify Users of new updates to the Application. In the event that you do not wish this, we give you the right to express your refusal on this subject on the emails received;

  • Develop commercial and visitor statistics for our Services;

  • Organizes contests, sweepstakes and all promotional operations excluding online gambling and games of chance subject to the approval of the Online Games Regulatory Authority, in particular on social networks;

We inform you, during the collection of your personal data, if certain data must be obligatorily filled or if 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 are the possible consequences of a lack of response.

In addition to this, you need to know more about it.

In addition to this, you need to know more about it.

5. RECIPIENTS OF THE DATA COLLECTED.

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Only the staff of our company, the departments responsible for control (notably the statutory auditor) and the support of the Application and the Site (Technical team), our partners and our possible subcontractors, will have access to your personal data.

In addition to this, you need to know more about it.

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 debt.

In addition to this, you need to know more about it.

In addition to this, you need to know more about it.

6. TRANSFER OF PERSONAL DATA

In addition to this, you need to know more about it.

Your personal data will not be transferred, rented or exchanged for the benefit of third parties without your consent.

In addition to this, you will need to know more about it.

In addition to this, you will need to know more about it.

7. PERIOD OF STORAGE OF PERSONAL DATA

In addition to this, you need to know more about it.

Regarding data relating to User management:

In addition to this, you need to know more about it.

Your personal data will not be kept beyond the time strictly necessary for the management of our commercial relationship with you. However, the data making it possible to establish the proof of a right or a contract, which must be kept for the fulfillment of a legal obligation, will be kept for the duration provided by the law in force. Beyond this period, only statistical data made anonymous will be kept and will not give rise to any exploitation of any kind.

In addition to this, you need to know more about it.

The CityGem application will continue to retrieve the User's position even if it is closed when he has launched a route.

In addition to this, you need to know more about it.

Regarding cookies:
The storage period for cookies referred to in Article 11 is 13 months.

In addition to this, you need to know more about it.

In addition to this, you will need to know more about it.

8. SECURITY

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We inform you to take all necessary precautions, appropriate organizational and technical measures to preserve the security, integrity and confidentiality of your personal data and in particular, to prevent it from being distorted, damaged or from unauthorized third parties having access to it.

In addition to this, you need to know more about it.

As such, we ask that you respect the security measures put in place by our data hosting provider, Google and its Firebase service, whose measures are available on its website.

In addition to this, you need to know more about it.

In addition to this, you need to know more about it.

9. ACCOMMODATION

In addition to this, you need to know more about it.

We inform you that your data is kept and stored, throughout the period of its conservation on the servers of the company Google in Europe and North America.

In addition to this, you need to know more about it.

The latter 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.

In addition to this, you need to know more about it.

In addition to this, you need to know more about it.

10. COOKIES

In addition to this, you need to know more about it.

Cookies are text files, often encrypted, stored in your browser. They are created when a user's browser loads a given website: the site sends information to the browser, which then creates a text file. Each time the User returns to the same site, the browser retrieves this file and sends it to the website server.

In addition to this, you need to know more about it.

We can distinguish different types of cookies, which do not have the same purposes:

In addition to this, you need to know more about it.

Social network cookies can be created by social platforms to allow website designers to share the content of their site on these platforms. These cookies can, in particular, be used by social platforms to track the navigation of Internet users on the website concerned, whether or not they use these cookies.

In addition to this, you need to know more about it.

We use cookies from social networks. These cookies are only registered if you give your consent. You can inquire about their nature, accept them or refuse them.

In addition to this, you need to know more about it.

We also invite you to consult the privacy policies of the social platforms that are the source of these cookies, to learn about the purposes for using the navigation information they may collect through these cookies and to exercise your rights with these platforms.

In addition to this, you need to know more about it.

Advertising cookies can be created not only by the website the User is browsing, but also by other websites showing advertisements, announcements, widgets or other elements on the page displayed. These cookies can in particular be used to carry out targeted advertising, that is to say tailor-made advertising according to the navigation of the User.

In addition to this, you need to know more about it.

We also use advertising cookies. These cookies are only registered if you give your consent. You can inquire about their nature, accept them or refuse them.

In addition to this, you need to know more about it.

We use Google Analytics which is a statistical audience analysis tool which generates a cookie to measure the number of visits to the Site, the number of page views and visitor activity. Your IP address is also collected to determine the city from which you are connecting. This cookie is only registered if you give your consent. You can accept or refuse it.

In addition to this, you need to know more about it.

We remind you for all practical purposes that you can refuse that cookies be registered by configuring your browser. Such a refusal could however prevent the proper functioning of the Site.

In addition to this, you need to know more about it.

In addition to this, you will need to know more about it.

11. ACCESS TO YOUR PERSONAL DATA

In addition to this, you need to know more about it.

In accordance with the law n ° 78-17 of January 6, 1978 relating to data processing, the files and freedoms, and the RGPD, you have the right to obtain the communication and, if necessary, the correction or the erasure of data concerning you, by contacting:

In addition to this, you need to know more about it.

Email address: contact@citygem.app
Postal mail address: Etnidev - 25 rue Paul Bert 92800 Puteaux. France

In addition to this, you need to know more about it.

It is recalled that any person may, for legitimate reasons, oppose the processing of data concerning him or her. However, we may be required to continue processing it if there are legitimate reasons for its processing which prevail over your rights and freedoms or if its processing is necessary to establish, exercise or defend our legal rights.

In addition to this, you need to know more about it.

In addition to this, you need to know more about it.

12. RIGHT TO DEFINE GUIDELINES FOR DATA PROCESSING AFTER YOUR DEATH

In addition to this, you need to know more about it.

You have the right to define directives relating to the storage, erasure and communication of your personal data after your death.

In addition to this, you need to know more about it.

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.

In addition to this, you need to know more about it.

The directives may also be specific to the data processed by our company. You should then send them to us at one of the following addresses:

In addition to this, you need to know more about it.

Email address: contact@citygem.app
Postal mail address: Etnidev - 25 rue Paul Bert 92800 Puteaux. France

In addition to this, you need to know more about it.

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.

In addition to this, you need to know more about it.

You can designate in your directives a person responsible for their execution. This person will then have the right, after your death, to take cognisance of said directives and ask us for their implementation. In the absence of a designation, your heirs will have standing to take cognisance of your directives upon your death and to request their implementation.

In addition to this, you need to know more about it.

You can modify or revoke your directives at any time by writing to us using the contact details above.

In addition to this, you need to know more about it.

In addition to this, you need to know more about it.

13. PORTABILITY OF YOUR PERSONAL DATA

In addition to this, you need to know more about it.

You have a right to the portability of the personal data that you have provided to us, understood as the data that you have actively and consciously declared in the context of accessing and using 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.

In addition to this, you need to know more about it.

This right can be exercised free of charge, at any time, and in particular when closing your account on the Application, in order to recover and store your personal data.

In addition to this, you need to know more about it.

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.

In addition to this, you need to know more about it.

In addition to this, you need to know more about it.

14. INTRODUCTION OF A COMPLAINT BEFORE A SUPERVISORY AUTHORITY

In addition to this, you need to know more about it.

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.

In addition to this, you need to know more about it.

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 texts constitutes a violation of the applicable.

In addition to this, you need to know more about it.

In addition to this, you need to know more about it.

15. LIMITATION OF PROCESSING

In addition to this, you need to know more about it.

You have the right to obtain the limitation of the processing of your personal data, in the following cases:

In addition to this, you need to know more about it.

  • During the verification period that we implement, when you dispute the accuracy of your personal data.

  • When the processing of this data is unlawful, and you wish to limit this processing rather than delete your data.

  • When we no longer need your personal data but want to keep it to exercise your rights.

During the period of verification of legitimate grounds, when you have objected to the processing of your personal data.

16. MODIFICATIONS

In addition to this, you need to know more about it.

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 and the 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.