SAS DigiCoachMe.

Type of Site: Website and Marketplace
Effective from 28/02/2024

As part of our privacy policy, the term "site" refers to both the DigiCoachMe website and mobile application.

The purpose of this privacy policy is to inform users of our site about the personal data we will collect as well as the following information, where applicable:

1. The personal data we will collect
2. The use of the collected data
3. Who has access to the collected data
4. Users' rights
5. The site's cookie policy

This privacy policy operates in parallel with the general terms of use of our site.

Applicable Laws

In compliance with the General Data Protection Regulation (GDPR), this privacy policy adheres to the following regulations:

Personal data must be:

1. Processed lawfully, fairly, and transparently concerning the data subject (lawfulness, fairness, transparency);
2. Collected for specified, legitimate, and explicit purposes, and not further processed in a manner incompatible with those purposes; further processing for archiving in the public interest, scientific or historical research, or statistical purposes is not considered incompatible with the original purposes (purpose limitation);
3. Adequate, relevant, and limited to what is necessary for the purposes for which they are processed (data minimization);
4. Accurate and, if necessary, kept up to date; all reasonable steps must be taken to ensure that personal data that is inaccurate, concerning the purposes for which it is processed, is erased or rectified without delay (accuracy);
5. Kept in a form which permits identification of data subjects for no longer than necessary for the purposes for which the data is processed; personal data may be kept for longer periods where it will be processed solely for archiving purposes in the public interest, scientific or historical research, or statistical purposes, in accordance with Article 89(1), provided that appropriate technical and organizational measures required by the regulation to safeguard the rights and freedoms of the data subject are implemented (storage limitation);
6. Processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures (integrity and confidentiality).

Processing is lawful only if, and to the extent that, at least one of the following conditions is met:

1. The data subject has consented to the processing of their personal data for one or more specific purposes;
2. The processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the data subject's request;
3. The processing is necessary for compliance with a legal obligation to which the data controller is subject;
4. The processing is necessary to protect the vital interests of the data subject or of another natural person;
5. The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller;
6. The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, particularly where the data subject is a child.

For residents of the State of California, this privacy policy is intended to comply with the General Data Protection Regulation (GDPR). If there are inconsistencies between this document and the legislation, the legislation will apply. If we identify inconsistencies, we will amend our policy to comply with the relevant law.

Consent
‍Users agree that by using our site, they consent to:

1. The terms outlined in this privacy policy
2. The collection, use, and storage of the data listed in this policy.

Personal data we collect

Automatically Collected Data :

When you visit and use our site, we may automatically collect and retain the following information:

1. IP Address
2. Device
3. Hardware and Software Details
4. Links (if a user clicks while using the site)
5. Content that the user views on our site

We may also collect the following data when you perform certain functions on our site or mobile application:

For all app users:

• Personal Information
  • Name, Email Address, User ID, Address, Phone Number, Other Info
• Collected Data and Purpose
  • Name: App operation, Developer communications, Advertising or marketing, Account management
  • Email Address: App operation, Fraud prevention, Security and compliance, Advertising or marketing, Account management
  • User ID: Fraud prevention, Security and compliance
  • Address: App operation
  • Phone Number (Optional): App operation, Account management
  • Other Info: App operation, Analytics, Fraud prevention, Security and compliance
• Financial Information
  • User payment information, Purchase history
• Collected Data and Purpose
  • Purchase History: App operation, Analytics
• Health and Fitness
  • Physical activity information
• Collected Data and Purpose
  • Physical Activity Information (Optional): App operation, Analytics
• App Performance Information
  • Other app performance data
• Collected Data and Purpose
  • Number and type of courses taken: Analytics, Fraud prevention, Security and compliance
  • Other Actions: Fraud prevention, Security and compliance

This data may be collected through the following methods:

Please note that we only collect data that helps us achieve the purpose outlined in this privacy policy. We will not collect additional data without informing you beforehand.

How We Use Personal Data :

The personal data collected on our site will only be used for the purposes specified in this policy or stated on the relevant pages of our site. We will not use your data beyond what we disclose. The data we collect automatically is used for the following purposes:
a. We may use this analytical data internally to optimize your user experience and provide you with the best content.

The data we collect when the user performs certain functions may be used for the following purposes:

1. Communication
2. Analytics
3. Fraud prevention, moderation, security, and compliance
4. User account creation and validation
5. Account management

With Whom We Share Personal Data :

• Employees
  We may disclose user data to any member of our organization who reasonably needs it to achieve the objectives outlined in this policy.
• Third Parties
  We may share user data with the following third parties:
  • None
• We may share user data with third parties for the following purposes:
• • None
• Third parties will not be able to access user data beyond what is reasonably necessary to achieve the specified purpose.
• Other Disclosures
  We are committed to not selling or sharing your data with third parties, except in the following cases:
  • If required by law
  • If required for any legal proceedings
  • To prove or protect our legal rights
  • To potential buyers of this company in the event that we seek to sell the company
• If you follow links from our site to another site, please note that we are not responsible for and have no control over their privacy policies and practices.

How Long We Store Personal Data

We do not retain user data beyond what is necessary to achieve the purposes for which it was collected.

How We Protect Your Personal Data

Afin d’assurer la protection de votre sécurité, nous utilisons le protocole de sécurité HTTPS sur toutes nos pages.

Toutes les données stockées dans notre système sont bien sécurisées et ne sont accessibles qu’à nos employés. Nos employés sont liés par des accords de confidentialité stricts et une violation de cet accord entraînerait le licenciement de l'employé

Nous sécurisons vos données avec la mise en place de différentes actions :

To ensure the protection of your security, we use HTTPS security protocol on all our pages. All data stored in our system is securely protected and only accessible to our employees. Our employees are bound by strict confidentiality agreements, and a breach of this agreement would result in the employee's dismissal.

We secure your data through various measures:

• Raising user awareness
• Authenticating users
• Managing permissions
• Tracking access and managing incidents
• Securing workstations
• Securing mobile computing
• Protecting the internal IT network
• Securing servers
• Securing websites
• Backing up and ensuring business continuity
• Secure archiving
• Overseeing data maintenance and destruction
• Managing subcontracting
• Protecting premises
• Overseeing IT development
• Encrypting, ensuring data integrity, or signing

While we take all reasonable precautions to ensure our users' data is secure and users are protected, there remains a risk of harm. The Internet as a whole can be, at times, unsafe, and we cannot guarantee the security of user data beyond what is reasonably practical.

Minors
‍
The GDPR specifies that persons under the age of 15 are considered minors for the purposes of data collection. Minors must have the consent of a legal representative for their data to be collected, processed, and used. We do not intend to collect or use data from minor users. If we discover that we have collected data from a minor, that data will be immediately deleted.

Your Rights as a User

Under the french GDPR, users have the following rights as data subjects:

• Right of access
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right to data portability
• Right to object

Further information on these rights can be found in Chapter 3 (Art 12-23) of the GDPR.

How to Modify, Delete, or Challenge Collected Data

If you wish to have your information deleted or modified in any way, please contact our Privacy Officer at:

SAS DigiCoachMe
CHEMIN DES MANUFACTURES
62800 LIEVIN
privacy@digicoachme.com

You also have the option to delete your account via the application by following these steps:

• Go to the "Settings" section and select the "Delete my account" option

Contact
‍If you have any questions, please do not hesitate to contact us at:

privacy@digicoachme.com
‍
CHEMIN DES MANUFACTURES, 62800 LIEVIN