Privacy Policy

Foreword

VODALYS (the “Company”) publishes and makes available the websites https://www.vodalys.events and (the “Website(s)”) to any professional user (the “User”) for the purpose of streaming various live events via the platform accessible at the following address: (the “Vodalys.Studio Platform”).

Your rights and obligations under the use of the Vodalys.Studio Platform are governed by the Company’s current general terms of service, available on said Platform (the “GTS”).

The protection of your personal data is fundamental to the Company. It ensures the confidentiality and integrity of your data by implementing the necessary means to guarantee their protection, integrity, availability and security.

It is within this framework that the Websites’ privacy policy has been drafted (hereinafter, the “Privacy Policy”).

TABLE OF CONTENTS

Purpose of the Privacy policy
Collection of your Personal Data
Collection of User Data
Collection of Browsing Data
Use of your Personal Data
Sharing Personal Data
Sending offers and information
Data storage
Information and exercising your rights
Security and protection of Personal Data
Localization of Personal Data
Modification of the Privacy Policy
Contacting the Company
Data Processor

1. PURPOSE OF THE PRIVACY POLICY

1.1. Definitions

All capitalized terms in the Privacy Policy that are not specifically defined herein shall have the meaning given to them in the GTS accepted by the User.

For the purposes of the Privacy Policy, the following capitalized terms shall have the following definitions:

“Content”: means any audiovisual content provided or published by Users on the Vodalys.Studio Platform (e.g. live events).

“Personal Data”: means any information that directly or indirectly identifies you. Common examples include: name, username, phone number, photograph, date of birth, city of residence.

“Services”: means all the services provided by the Company to the Users, in particular on the Vodalys.Studio Platform, namely:

Content collection and generation;
Content enhancement;
Content broadcasting and storage.

“User Account”: means the User’s personal account, which they use to access their user space on the Vodalys.Studio Platform.

1.2. Scope of the Privacy Policy

The Privacy Policy applies to the Company’s policy regarding the collection and use of your Personal Data when browsing and using the Websites and/or Services.

This document explains the origin and nature of the data the Company collects, the reason for their collection, the way the Company uses your data and your rights regarding the data in accordance with Law No.78-17 of January 6, 1978, known as the French Data Protection Act, as amended, and EU Regulation No.2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data known as “GDPR”, (hereinafter jointly, the “Applicable Regulations”).

The Privacy Policy is important both to ensure that you have a positive and reliable experience when browsing the Websites or using the Services and to allow us to accurately and completely answer your queries concerning the collection and use of your Personal Data.

The Privacy Policy does not apply to third-party websites to which you may be redirected when using the Websites and Services, including networks and social media on which the User may share Content or on which the Company has created an account (e.g. Facebook, Instagram, LinkedIn, Twitter, YouTube, Zoom). We recommend that you refer to the legal notices and privacy policies of these third-party websites.

By using the Websites, you acknowledge that you fully understand and agree to the terms of the Privacy Policy.

2. COLLECTION OF YOUR PERSONAL DATA

2.1. Obtaining your consent.

To achieve the purposes listed in Article 5 of the Privacy Policy, the Company may create a file with your Personal Data sent when creating a User Account, when filling in the contact form on one of the Websites, when using the chatbot and/or when using the Services.

You hereby acknowledge the terms and conditions applied by the Company when processing your Personal Data.

You may express your prior and express consent to the collection and processing of your Personal Data by the Company, when using the Websites, creating a User Account, submitting the contact form, using the chatbot and/or the Services in accordance with the terms of the Applicable Regulations (in particular by means of check boxes).

You acknowledge that the Company may process Personal Data for the performance of an agreement signed between you and the Company, to exercise a legitimate interest or under a legal obligation, without requiring you to express your prior consent.

The legal framework under which the Company processes your data is detailed in Article 5 “Use of your Personal Data”.

2.2. Your Personal Data

The Company may collect the following Personal Data directly from you, when you create a User Account, fill in contact forms, use the chatbot or the Services, by e-mail or by postal mail, in particular:

your first and last names;
your login details (username and password);
your e-mail address;
your mailing address;
your phone number;
your image (e.g. photograph; video);
your bank details.

When we collect Personal Data through our forms, we indicate mandatory Personal Data by a (*) in front of the box to be completed in the form or by any other device.

You hereby acknowledge that the processing of such Personal Data is required in particular for the performance of our contractual obligations arising from the GTS.

3. COLLECTION OF USAGE DATA

This data relates to your use of the Websites and Services and includes information such as the features you use and the frequency and duration of your activities on the Website.

We may collect information from the devices (such as computers, phones, tablets or other devices) which you use to access the Websites, depending on the authorizations you have granted and your settings. This information may, for example, include your IP address, device identification number, browser and software specifications (e.g. operating system type and version or language setting).

4. COLLECTION OF BROWSING DATA

Browsing data is collected by installing cookies and other identifiers on your terminal (computer, tablet, smartphone, etc.) and includes in particular:

The identifier and content of a cookie file stored by us in your terminal;
The IP (Internet Protocol) address of the terminal connected to the Internet;
The date and time when your terminal was connected to an electronic communication service;
The type of operating system used by the terminal (Windows, iOS, etc.);
The language used on the terminal when using the browser.

When browsing the Websites, a control panel is displayed and gives you the possibility to consult the purposes of cookies or other identifiers and to configure your choices regarding your consent or refusal to install cookies or other identifiers.

You can also configure the settings of your terminal or your Internet browser for the installation of cookies or other identifiers.

5. USE OF YOUR PERSONAL DATA BY THE COMPANY

The Personal Data that the Company collects directly or indirectly from you, in particular when you create a User Account, use the Websites, fill in a contact form, use the chatbot or the Services, may be processed for the following purposes:

Performing the agreement with the Company	Legal framework	Personal Data categories
– Provision of the Services agreed especially upon the current GTS – Provision of Websites maintenance services – User Account administration – Payment transaction management – Accounting operations and tax obligations.	– Legal obligation – Performance of an agreement – Legitimate interest.	– Contact information and titles – Bank details – Website and Service usage data – Photographs/videos.

Carrying out “customer management” operations relating to:	Legal framework	Personal Data categories
– Your requests (e.g. request for information or quotation, in particular via the contact form or the chatbot) – Provision of the Services agreed especially upon the current GTS – Monitoring “customer relations” (such as satisfaction surveys, claim management, etc.).	– Performance of an agreement – Legitimate interest (business transactions).	– Contact information and titles – Website and Service usage data.

Improving your User experience on the Websites	Legal framework	Personal Data categories
– Management of your requests for access to your Personal Data, correction and opposition – Management of your reviews and questions regarding the Services and the Websites (as well as the content/services made available through the Websites) – Identification of the User when using the Websites and, if necessary, adapting the Websites and the contents which they disseminate (I) to the characteristics which you have entered yourself and of which the Company may be aware and (II) to your previous browsing history of which the Company may be aware, as the case may be – Website use statistics processing – Enabling you to enjoy a number of additional services (such as receiving a newsletter, etc.).	– Legal obligation – Performance of an agreement – Legitimate interest.	– User Account registration data – Website and Service usage data – Browsing data.

Managing third party requests:	Legal framework	Personal Data categories
– Receipt of applications – Receipt of partnership requests.	User consent	– Contact information and titles – Curriculum vitae and cover letter.

The Company does not sell your Personal Data to its partners or third party service providers.

6. SHARING PERSONAL DATA

The Company ensures the privacy of your Personal Data and restricts its distribution to the recipients listed below:

The Company’s staff in charge of the marketing department, sales department, technical department in charge of the deployment of the Websites and Services, department in charge of customer relations, administrative departments, legal departments, departments in charge of internal inspection procedures, logistics and IT departments, as well as their line managers;
Data processors offering sufficient guarantees as regards the security and confidentiality of Personal Data in compliance with the Applicable Regulations;
Any company controlled by the Company, controlling the Company or under joint control under Article L233-3 of the French Commercial Code, as well as any company in the context of a transaction involving the transfer of control of the Company (acquisition of a majority shareholding, partial contribution of assets, transfer of business, merger or acquisition, without limitation);
Any jurisdiction, administration, law enforcement agencies, judicial officers who may be called upon to intervene under a judicial procedure or administrative order;
The CNIL (French Data Protection Authority) and any other body with jurisdiction.

If the User shares Content with third party websites via the Vodalys.Studio Platform, the User should consult their Personal Data protection policies before sharing any Personal Data. Whatever the circumstances, the Company shall not be held liable for this reason, on any grounds whatsoever, nor shall it be held accountable for any damage of any nature whatsoever pertaining to the sharing of Content containing Personal Data with these third party websites (e.g. data subject claim, sanctions by the supervisory authority, etc.). For any request for information or complaint relating to the processing of Personal Data by these third party websites, the User must contact the third party website concerned directly and will be solely responsible for the said processing, in particular with regard to the data subjects, in keeping with the terms agreed with the said third party websites, if applicable.

7. SENDING OFFERS AND INFORMATION

You may receive direct information from the Company by e-mail or notification via the Websites, regarding the Company’s activities or services similar to those we have provided to you in connection with your registration for our Services.

You may express your objection to any new contact at any time, free of charge, via the hypertext link contained in the e-mails sent by the Company or exercise your rights in accordance with the terms of Article 9 “Information and exercising your rights” below.

8. DATA STORAGE PERIOD

We retain your Personal Data for as long as you use the Websites, as long as your User Account exists, or as long as necessary to provide you with the relevant Services under the GTS and other agreements you have entered into with the Company.

For Personal Data used for information purposes or commercial prospecting, we keep them for a period of three (3) years from the end of the business relationship.

You may of course delete your User-Account or unsubscribe from the Company’s mailing lists by exercising your rights as listed below.

If your User Account remains unused for a continuous period of two (2) years, the Company will delete it and any related data, with the exception of data that we are legally required to continue storing. Deletion of your Account will occur thirty (30) days after our notification to you by e-mail, if you have not logged into your User Account in the meantime.

You hereby acknowledge that we only retain your Personal Data in our information system for legitimate administrative, legal and security purposes.

Storage of your data beyond the term specified in Article 5 “Use of your data” may be necessary to carry out your requests to oppose, restrict the processing operations and delete your Personal Data and to comply with any legal, accounting or fiscal obligation to store personal data (in particular for the provision of evidence) or to transfer it to the relevant authorities (administration, police services, etc.).

Throughout the Personal Data storage period, the Company undertakes to maintain a high level of security and privacy of the Personal Data, to restrict access to the data only to authorized persons and not to process it for purposes other than those agreed to herein or in the applicable GTS.

9. INFORMATION AND EXERCISING YOUR RIGHTS

Pursuant to the Applicable Regulations and in particular to articles 15 to 22 of the GDPR, you have a right to:

Send us any request for information about the Privacy Policy and the processing of your Personal Data;
Access information on the processing of your Personal Data (data category, purpose, etc.);
Delete your User Account by logging into your User Account and changing the settings (when this option is available) or by contacting us by e-mail;
Rectify or update any inaccurate Personal Data by logging into your User Account and changing the settings (if the option is available) or contacting us by e-mail;
Delete your Personal Data by logging into your User Account and changing the settings (if the option is available) or contacting us by e-mail;
Restrict any processing of your Personal Data that we undertake, if you believe the data to be inaccurate (for a limited period during which we will check the accuracy of the data), or if you believe the processing to be unlawful (while allowing us to continue), by sending us an e-mail;
Receive a copy of the Personal Data you have provided directly to us, in a structured, commonly used and device-readable format, by contacting us by e-mail; it being specified that any request for a copy beyond the first one may generate administrative processing costs that will be charged to you. You hereby acknowledge that any Personal Data that is derived, calculated or inferred by us from the data that you have provided is excluded from the right to portability in so far as such data was not provided by you but created by us;
Unsubscribe from the Company’s mailing list by clicking on the dedicated hyperlink in the information e-mail;
Decide to object to the use of automated decision-making: your right to refuse decisions entirely based on automated decision-making, including profiling, in cases where the decision may result in judicial consequences for you or may produce a similar significant effect;
File a complaint with the Commission Nationale de l’Informatique et des Libertés, 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07, Tel: +33 (0)1 53 73 22 22.

In the event of excessive claims, particularly of a repetitive nature, we reserve the right not to follow up any requests for access once we have satisfied one of your requests for access to your Personal Data.

Your requests must be submitted in writing by postal mail or by e-mail sent to the addresses shown below, be signed and enclose a photocopy of an ID document bearing the holder’s signature. The request must specify the address to which the reply should be sent. We are bound to reply within one (1) month of receiving the request. This deadline may be extended by two (2) months, in the event of a large number of particularly complex requests.

? : VODALYS, 6 rue du Quatre Septembre – 92130 ISSY-LES-MOULINEAUX

@: info@vodalys.com

10. SECURITY AND PROTECTION OF PERSONAL DATA

Acting under its responsibility for data controller, the Company implements organizational and technical security measures designed to guarantee the privacy and integrity of your Personal Data.

Security measures for the Company’s operating and administrative environment:

All Personal Data stored on the Company’s servers is protected by the following measures:

Dedicated network;
Access rights management;
Password policy and password lockout;
Use of antivirus and intrusion detection protection;
Firewall protecting each network zone;
Restricted number of authorized requests to prevent abnormal or improper use of the Websites;
Automatic expiration of the session when using the User Account.

User environment security measures

All Personal Data stored on the Company’s servers is protected by the following measures:

Hosting of Personal Data in a datacenter within the European Union;
Encrypted database;
Secure user account under SSL, SSH and HTTPS protocol;
Cloud provider with numerous security certifications;
Use of antivirus software;
Access control;
Protection of hosted sensitive files from malicious direct access;
Restricted number of authorized requests to prevent abnormal or improper use of the Website;
Verification of the Users’ e-mail address, in case of fraud or suspicious form, access can be suspended manually;
Automatic expiration of the session when using the User Account.

However, given the very nature of a public network such as the Internet, you hereby acknowledge and accept that the security and integrity of any Personal Data transmitted via the Internet cannot be guaranteed.

In the event of a security breach resulting in a violation of Personal Data, we shall inform you of the nature of the breach and any likely consequences resulting from it.

We undertake to promptly implement corrective measures and to notify the CNIL of the breach, unless the said breach is not likely to jeopardize the rights and civil liberties of natural persons, pursuant to the Applicable Regulations.

You acknowledge that your password protects your User Account and that it is necessary to choose a secure and unique password and to take all reasonable precautions to control or limit access to the terminals that allow access to your User Account (password, PIN code, logout after use, etc.).

11. LOCALIZATION OF PERSONAL DATA

The Company hosts and has your Personal Data hosted within the European Union.

If the processing and purposes referred to in Article 5 require the transfer of Personal Data outside the European Union, the Company will ensure that your Personal Data is suitably protected.

All data transfers take place with recipients located:

In countries which, according to the criteria established by the European Commission, provide a adequate level of protection for personal data; or
In countries where the transfer is covered by the standard contractual clauses for data transfers between EU and non-EU countries provided by the European Commission or by binding corporate rules.

12. PRIVACY POLICY MODIFICATIONS

We may modify our Privacy Policy from time to time. We will notify you of any significant changes by sending a message that will be displayed when you log into your User Account, or by e-mail sent to the address supplied when you created your User Account, so that you can examine the modifications before they come into effect.

You may delete your User Account if you object to any such modifications.

If you continue to visit our Websites and/or use the User Account after we have published or sent a notification relating to modifications of our Privacy Policy, you shall be deemed to have unreservedly accepted the updated Privacy Policy.

13. CONTACTING THE COMPANY

If you have any questions or comments about this Privacy Policy, please contact us at: info@vodalys.com

14. DATA PROCESSOR

Under the GTS, the performance of the Services may involve one or more Personal Data processing operations on behalf of the User; where applicable, the terms and conditions of such processing by the Company are governed by Appendix 1 – DATA PROCESSOR.

Figure in the Appendix: Appendix-Data_Processor