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INFORMATION ON THE PROCESSING OF YOUR PERSONAL DATA
A) Who is responsible for the processing of your personal data?
The person responsible for processing your personal data is our company (hereafter "we" or "us"): Panodyssey, a SAS company registered in the Nanterre Trade and Companies Register under the number 844 250 530, whose headquarters is located at 10 rue Bapst in Asnières sur Seine (92 600).
We manage the Panodyssey platform accessible at www.panodyssey.com (hereinafter the "Platform"), which allows its users, depending upon the role they choose, to create, distribute and consult content.
B) What personal data do we collect?
We collect and process personal data about you via the Platform. In this document, we explain which personal data we collect, why we collect it and what we do with it. We also explain to you what your rights regarding your personal data are and how you can exercise them.
When you create an account on the Platform (hereafter the "Account"), we collect the following personal data that we absolutely need :
- your email address
- and, if you want to be a creator or contributor, or if you communicate these data to us spontaneously, your first name, last name and date of birth (hereafter the "Personal Data").
Since the publication of paid content as a creator and the monetised participation in content as a contributor is reserved for users aged 18 or over and since the publication of content is not anonymous, we also collect a copy of an identity document of you at the time of your first publication if you are a creator or your first participation in content if you are a contributor. This copy is part of your Personal Data. We only keep a copy of your document, if you are a creator or a contributor, for the required time in order to verify your identity. We then keep this copy in intermediate archives, with reinforced security measures, to allow us to prove the verification made, for the time of the applicable data limitation period. This means that the data is no longer used to achieve the set objective, the case is closed, but it must be retained to meet a legal obligation. The data can then be consulted on an ad hoc basis and motivated by certain members of our staff, specifically authorized.
II) Definition and Principles
A) Why do we collect your Personal Data (purposes of processing) ?
We collect your Personal Data to :
- manage your Account and your activity on the Platform,
- provide you with the Platform's services,
- communicate with you in the context of the provision of these services,
- inform you about the evolution of these services and similar services that we may develop
- invoice you for the Platform's paid services and to monitor the payment of our invoices.
If you are a creator or contributor, we collect a copy of your identity document to validate your identity and age, also to manage the contractual relationship with you, in particular to ensure the validity and proper execution of the contract concluded with you. We only keep a copy of your document, if you are a creator or a contributor, for the required time in order to verify your identity. We then keep this copy in intermediate archives, with reinforced security measures, to allow us to prove the verification made, for the time of the applicable data limitation period.
B) What authorises us to collect your Personal Data (i.e. grounds for processing) ?
The processing of your Personal Data is done on the basis that they are necessary for the execution of the contract concluded with you.
Furthermore, the processing of your email address to send you prospecting messages on services similar to those of the Platform is based on our legitimate interest in sending you these messages.
III) Data processing and storage
A) Who are your Personal Data intended for ?
The recipients of your Personal Data are our corporate officers and our employees in charge of managing the contractual relationship with you and the execution of the contract and, indirectly and on an ad hoc basis, our employees in charge of the administration and maintenance of the Platform and its operating environment.
Your Personal Data is transmitted on the servers of the Platform's hosting service provider, the company OVH, and may be transmitted to other contractors involved in the above-mentioned tasks.
B) How long do we keep your Personal Data?
We keep your Personal Data for a period of 3 years from the end of the contract concluded with you.
Beyond this period, we keep in an intermediate archive in pseudonymous (non-nominative) form the data necessary to exercise and prove our rights and obligations, for the duration of the applicable limitation periods or by virtue of the legal obligations to which we are subject.
If you are a creator or contributor, we only keep a copy of your identity document for the time necessary to verify your identity. We then keep this copy in an intermediate archive, with enhanced security measures, to enable us to prove the verification carried out, for the duration of the applicable limitation periods.
C) Where are your personal data stored ?
We store your Personal Data on the servers of the Platform's hosting provider, the company OVH, whose servers are located in metropolitan France.
D) How are your Personal Data protected (security measures) ?
We are committed to the protection of your Personal Data. This is why we have implemented technical and organizational measures to ensure its security and confidentiality.
The corporate officers and employees of Panodyssey who have access to your Personal Data are bound by a confidentiality agreement which obliges them to keep it confidential. In addition, access to your Personal Data is restricted to those officers and employees who are the only ones who have identifiers enabling them to access it.
Data flows with the Platform use the secure https protocol. In addition, the Platform database is backed up every 2 hours.
IV) Your rights regarding your Personal Data
In accordance with the legislation applicable in France to the protection of personal data, i.e. the law of 6 January 1978 relating to information technology, files and freedoms as amended by subsequent laws and the Regulation of 27 April 2016 relating to the protection of individuals with regard to the processing of personal data and the free movement of such data, you may :
- obtain communication and, where appropriate, rectification or deletion of your personal data ;
- obtain the limitation of the processing of your personal data ;
- oppose the processing of your personal data, in particular for prospecting purposes;
- obtain a copy of your personal data in a structured and current format for transmission to another data controller;
- inform us of your specific instructions on the fate of your personal data in the event of your death; failing this, your heirs will be able to assert their rights under the applicable legislation.
You may access and correct your Personal Data in your Account and you may close your Account at any time.
In addition, you may exercise any of the above rights by providing proof of your identity and by sending your request to the following address Panodyssey, Panodyssey User Service, 10, rue Bapst, 92600 Asnières-sur-Seine. You can also exercise your rights by sending an email to the following address : firstname.lastname@example.org .
The above rights are not applicable in all cases. Hence we invite you, prior to any request, to consult the applicable legislation to find out in which cases you can exercise any of these rights. In particular, you may consult the information available on the website of the Commission Nationale de l'Informatique et des Libertés (CNIL) or any other competent supervisory authority.
We shall be entitled to charge you the costs associated with the exercise of these rights in the event of unjustified or excessive requests. In addition, we will automatically charge the cost of making an extraction or copy of the Personal Data.
In addition, we may suspend or close your Account or terminate the contract concluded with you in the event that we no longer have the Personal Data necessary for its execution following the exercise of these rights.
You also have the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL) or any other competent supervisory authority in the event of a dispute concerning the above-mentioned processing of your Personal Data.