Privacy policy

PREAMBLE

LITTLE IDEA attaches importance to your personal data and your privacy.

In this respect, this personal data protection policy details the conditions under which LITTLE IDEA, EURL registered with the Registre du commerce et des sociétés under SIRET number 88798916800018 (hereinafter referred to as "We" or "LITTLE IDEA"), acting as data controller, processes your personal data.

In order to build a relationship of trust with its clients, LITTLE IDEA undertakes to process your personal data in compliance with the applicable regulations on the protection of personal data, and in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the "GDPR"), and Law No. 78-17 of 6 January 1978 on information technology, files and freedoms (hereinafter together referred to as the "Regulations").

To this end, we implement the general principles of the Regulations relating to personal data as follows:


Lawfulness: your personal data is collected for specific, explicit and legitimate purposes, and on the basis of an appropriate legal basis;
Transparency and fairness: you are informed of the processing operations we implement and their modalities through this data protection policy or any other document provided for this purpose, no processing of your personal data is implemented without your knowledge;
Minimisation: we only collect personal data that is strictly necessary for the purpose of the processing;
Limitation of the retention period: we keep your personal data for the time necessary to achieve the processing for which they were collected or, if applicable, for the period specified by law;
Data security: we have implemented technical and organisational measures adapted to the personal data collected, in order to ensure the integrity and confidentiality of this data and to protect it against any malicious intrusion, loss, alteration or disclosure to unauthorised third parties;
Commitments of our subcontractors and partners: we carefully select our subcontractors, service providers and partners and require them to ensure a level of protection of your personal data equivalent to ours, to use your personal data only to the extent necessary for the provision of the services we have entrusted to them, and to comply with the Regulations.

In application of the GDPR, the term "personal data" refers, within the framework of this policy, to any information concerning you and allowing you to be identified directly or indirectly as a natural person.

This policy applies to all our websites and applications (hereinafter referred to as "our Offers").
We may make changes to this policy depending on changes in the applicable Regulations or changes in our business. Of course, we will inform you of any changes to this policy and we also invite you to consult this page regularly.

WHAT DATA DO WE COLLECT?

We collect the personal data of any user of our products. The term "user" covers any user registered on our website (hereinafter the "Site") and our application (hereinafter the "Application").

Personal data collected directly from you:

The personal data we collect are those you communicate to us directly, in particular during your registration and the creation of your online account.

This data includes identification data (name, first name, email address), bank data (bank card)

Cookies:

We use cookies and other trackers to collect personal data about you in order to pursue certain of the purposes described below. This data may be, for example, your connection data, navigation data, IP address, etc. You can find information about cookies in the dedicated section of this policy and in the "Cookies -- Cookie management" section.

HOW DO WE USE YOUR PERSONAL DATA?
We implement various processing operations on your personal data, the purposes of which are precisely determined, legitimate and proportionate, and the legal bases of which are as follows: compliance with our legal and regulatory obligations, your consent, the performance of a contract concluded with you or our legitimate interest.

In accordance with the Regulations, the personal data we collect are used to accomplish the purposes for which they were collected and for the time strictly necessary to achieve the objectives of the processing. This retention period depends on the nature of the processing and its purposes.

At the end of the retention periods, we delete your personal data with the exception of the data we are legally required to keep or which are necessary for the preservation of our rights, which are kept in an archiving database for the time necessary to comply with our legal obligations or to preserve our rights, and then deleted at the end of these periods.



Management of your account:
We process your personal data to manage your account and ensure the follow-up of our relationship.

The creation of an account is necessary to access the Offers and use the services of the Application. To obtain account validation, you must provide the required personal data when creating it.

Finally, subject to your consent, your bank details may be recorded to facilitate payment transactions. Your bank card details are used for the payment of the subscription for the Pro features of the application. You can at any time manage the recording and deletion of these bank data on your player account in the "My Subscription" section. Your bank details are collected only by our PCI-DSS certified (banking security standard) payment service provider, which ensures the security of payments.

Use of the Site:
We process your personal data to allow you to use our Site and navigate through it.

The processing operations implemented for this purpose allow us to identify you as a user of the Site.

Furthermore, your navigation on the Site results in the deposit and reading of cookies essential to the functioning of the Site, which are not subject to obtaining your consent. You can find out more about cookies and how to manage their deposit on your terminal in the "Cookies -- Cookie management" section.


Use of the Application:
We process your personal data when you log in to the Application from your mobile device for the purpose of managing your online account.

Social networks:
We may collect certain of your personal data in the context of your interactions with our pages and accounts on social networks, in particular when you communicate with us directly on these platforms.

However, these platforms are managed by third-party companies and we have no control over the management and use of your data by these platforms. We recommend that you read the privacy policy of these platforms.


HOW LONG DO WE KEEP YOUR DATA?

Within the framework of the above-mentioned processing, we keep your personal data according to the modalities explained below:


Data necessary for the management of your online account This data is kept for 1 year from the closure of your account
Cookies and other trackers Trackers and cookies and the data collected by them are kept for 13 months from their deposit.


WHO ARE THE RECIPIENTS OF YOUR DATA?

To achieve the purposes described above and to the extent necessary to pursue these purposes, the personal data we collect may be transmitted to all or part of the following recipients:


LITTLE IDEA's subcontractors, including in particular technical service providers and payment institutions, to the extent necessary to carry out the tasks we entrust to them (we require our subcontractors to apply strict rules and measures to ensure a level of guarantees for the protection of your data in line with the Regulations);
LITTLE IDEA's partner companies, subject to your prior consent;

SECURITY OF YOUR DATA

We take all the necessary precautions and technical, physical and organisational measures to ensure the security and confidentiality of your data, in particular to prevent its loss, alteration, destruction or use by unauthorised third parties.

In addition, LITTLE IDEA requires its subcontractors to implement appropriate technical and organisational security measures to ensure the confidentiality of personal data and a level of security adapted to the risk.

TRANSFERS OF YOUR DATA

We process and store your data within the European Union. Thus, we do not transfer your data outside the European Union.

However, if LITTLE IDEA were to transfer your data outside the European Union, it would take appropriate measures to ensure that your personal data is adequately protected in the country of destination. In this case, we put in place contractual measures and controls concerning the technical and organisational measures in accordance with the Regulations to ensure that personal data is processed with the same level of security as that required by European regulations.

COOKIES AND OTHER TRACKERS

When using our sites and applications, information relating to the navigation of your terminal (computer, tablet, smartphone, etc.) on the sites and applications may be recorded in text files called "cookies", installed on your browser. Cookies will be used to recognize your browser during the validity period of the cookie concerned and to send certain information back to the Site (e.g. a session identifier or a language choice).

Some cookies may also be used to store the content of a password, others to record the language settings of a site, and still others to provide you with personalized services.

Only the issuer of the cookie concerned is likely to read or modify the information contained therein.

There are different types of cookies:

Session cookies that disappear as soon as you leave the site;
Permanent cookies that remain on your terminal equipment until the expiry of their lifetime or until you delete them using the features of your browser.

You are informed that, during your visits to this site, cookies may be installed on your terminal equipment.

These cookies may come from different issuers:

LITTLE IDEA cookies: these are cookies that may be placed by LITTLE IDEA on your terminal during your navigation on our sites and applications. These cookies allow us in particular to personalize and continuously improve your experience on our sites and applications;
Third-party cookies: these are cookies that may be placed by third-party companies (e.g. advertising agencies, social networks, LITTLE IDEA partners, etc.) on your terminal during your navigation on our sites and applications. They allow these third-party companies, during the validity period of their cookies, to identify your interests, to collect navigation information relating to the consultation of our sites and applications and to personalize advertisements that may correspond to your interests and your user profile, to which you may be exposed on our sites and applications.


Operation of our services: These cookies are strictly necessary for the proper functioning of the Site and the Application. They allow you to navigate on our Site and our Application and to use their functionalities.
Audience measurement and content improvement: These cookies allow us to measure the number of visitors to our Site and our Application and the performance of our marketing operations in order to improve the content and services for all users.
Improvement of the user experience: These cookies allow us to remember the options you have chosen in the past in order to improve the functionalities of our Site and our Application and their personalization (for example, your preferred language) during your visit. If you do not authorize these cookies, some or all of these services may not function properly.
Social networks: These cookies allow you to share content from our Site and/or our application via social networks.

Rejection or consent cookies must remain on your terminal equipment. You can at any time modify your choices using the cookie management tool in the "Cookie management" section. This cookie management tool allows you to manage and modify the use of cookies at any time. You can also manage cookies from the settings of your browser.

In accordance with the Regulations, cookies are kept for a period of 13 months.

You can also exercise your choices with the third-party cookie issuers:


Audience measurement and content improvement cookies:

These cookies allow us to measure the number of visitors to our Site and our Application and the performance of our marketing operations in order to improve the content and services for all users.
Google's privacy policy is available at the following link: https://policies.google.com/privacy?hl=en.

The privacy policies of third-party cookie issuers regarding advertising optimization are available at the following links:


Google: https://policies.google.com/technologies/ads

WHAT ARE YOUR RIGHTS AND HOW TO EXERCISE THEM?

In accordance with the Regulations, you have a number of rights set out below that you can exercise as soon as the conditions for their application are met by sending your request to [email protected].

The rights you have are as follows:

A right of access
You can obtain a copy of the personal data concerning you provided that their transmission does not infringe the rights and freedoms of third parties, intellectual property rights, business secrets or the confidentiality of correspondence.

A right of rectification
You can request the rectification of your data if the data we hold proves to be inaccurate or incomplete.

A right to erasure
You can obtain the erasure of your personal data if:
Their processing is no longer necessary with regard to the purposes for which we collected them;
You withdraw your consent when this was the legal basis for the processing;
You have exercised your right of opposition when this was applicable;
The data has been processed unlawfully;
The data must be erased to comply with a legal obligation.

A right to restriction of processing
You can request the temporary "freezing" of the processing in the only cases provided for by the Regulations.

A right to data portability
You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format, and the right to transmit this data to another data controller when:

This processing is based on your consent or on a contract;
This processing is carried out by automated means.

A right of opposition
In principle, you have the right to object to the processing of data concerning you according to the conditions defined by the Regulations. However, pursuant to Article 2 of Decree 2010-518 of 19 May 2010, you are informed that the creation of an account implies a waiver of your right to object to the processing of your personal data.

If you feel that your rights over your personal data are not respected after contacting us, you can file a complaint with the Commission Nationale de l'Informatique et des Libertés (3 place de Fontenoy - TSA 80715 -- 75334 Paris, cedex 07 FRANCE - telephone: +33 1 53 73 22 22).