Phone: +31 628 92 85 03
Within the context of making the Services available to Users by means of the Application, THERESHEGOES (hereinafter "ThereSheGoes"), be this on its own or in liaison with Users, is obliged to collect, process and store certain Personal Data.
In this regard, ThereSheGoes is particularly is particularly keen to respect the privacy of Users as well as to protect their Personal Data.
INTRODUCTION: IDENTIFICATION OF Data Controllers
ThereSheGoes is to be considered the Data Controller vis-à-vis the Users of the Application.
The users are to be considered to have the status of Data Controllers for all Personal Data entered by them or collected via the Application; within this context, ThereSheGoes can be considered a subcontractor.
- OUR RESPONSIBILITY IN OUR CAPACITY AS SUBCONTRACTOR
As a subcontractor and in accordance with Article 34 of the Electronic Data Privacy Bill, ThereSheGoes undertakes to take all necessary precautions to ensure the security of the Personal Data collected, including laying on all means to prevent Personal Data from becoming distorted or damaged or communicated to the unauthorized third parties.
In its capacity as subcontractor, and in compliance with the legal and regulatory provisions in force, ThereSheGoes and its personnel undertake to respect the following obligations:
- Process the Personal Data in accordance with the instructions of the Data Controller;
- Respect the Confidentiality of the Collected Data;
- Not to make any copy of the Collected Data, with the exception of any data that might be required to use the Services proposed by ThereSheGoes, including, in particular, data that might be required to back up the Services;
- Not to use the Collected Data for any purposes other than those which determine the end-purpose of the processing as described in article 3;
- Not to disclose the Data to unauthorized third parties;
- Take all necessary measures to avoid fraudulent or incorrect use of the Data collected via the Services;
- Take all Security Measures to ensure the preservation and integrity of the Data collected and processed via the Services, and to provide the Data Controller with all the information required to demonstrate compliance with the Data Controller’s obligations;
- Provide full and sufficient support to the Data Controller to ensure that the Data Controller can discharge his obligations;
- Provide full and sufficient support to the Data Controller in order to guarantee the security of the Data processing, to notify any data breaches to the French Data Privacy Authority (the “CNIL”), to inform the data subject of any violation of her data, to carry out an impact analysis on data protection as well as prior consultations, as defined in article 32 to 36 of Regulation 2016/679;
- Proceed, at the express request of the Data Controller, deletion of all Data collected as well as of all databases in which said Data was stored, in particular in the event of termination of the relationship between a given User and ThereSheGoes;
- Return, in the event of termination of membership and upon express request thereto from the Data Controller, the Data to the Data Controller, and delete all and any Personal Data;
- Never subcontract out the processing of personal data to any third party other than its shareholder, namely Orevon, except for the hosting service.
- PERSONAL DATA COLLECTED BY THERESHEGOES
- Data collected when signing up to the services
User Identification Data is collected when signing up to the Services; specifically, the data collected is as follows:
- Facebook IDs linked to the Facebook account, the email address, and the password;
- photograph of the User;
- current city of residence of the User;
- nationality of the User;
- languages spoken by the User;
- information which the User wishes to communicate about her/his personality and habits;
- additional personal information (centers of interest, etc.) if the User so wishes.
* This information can be share on the User description if she/he wants to, otherwise it will not be collected.
- BROWSING DATA:
Some Personal Data may be collected automatically as a result of a User browsing the Application. These include IP address, connection data and browsing data.
Anonymized and aggregated information, based on connection and traffic data, will be processed automatically in the form of statistics concerning using a browsing the Application.
- GEOLOCALIZATION DATA
ThereSheGoes can geolocate Users in order to provide them with information about Events in their sector.
If a User decides to avail of this Service, she/he expressly agrees that her/his geolocation Data will be collected, indicating her/his acceptance by ticking a box in the privacy settings of her/his phone or at the time of use of the Application, in accordance with the provisions of article 34-1-V of the Electronic Communications and Postal Code. If a User does not wish to provide her/his geolocation Data, she/he simply refrains from ticking the aforementioned box. However, it is considered that Users are aware that geolocalization enables the optimized use of the Application’s Services, in particular by suggesting nearby Events.
- BANK DATA
It is possible that some of the Events proposed by organizers have an admission fee.
ThereSheGoes collects banking data and then provided to its payment provider:
[STRIPE, HQ, Townsend st, San Francisco, United States].
- END-PURPOSES OF THE PROCESSING
The User is informed that her/his Personal Data is collected for the purpose of opening her/his Personal Account, enabling the strict execution of those Services to which she/his has voluntarily signed up. If the User does not provide the required Data, she/his is informed that she/his will not be able to sign up, and thus will not be able to avail of the Services provided by the Application.
In the same way, the collected Data is used to improve the Services by matching up Users efficiently based on their centers of interest and on Events corresponding to shared character traits.
In addition, Data relating to the browsing of Users on the Application enables ongoing improvement of the functionalities, of the Application’s user-friendliness, and of the rubrics and functions available via the Application.
Lastly, third parties may be called on to collect and process User data; these include, for example, business partners, so that the User be in a position to avail of and/or receive Services pertaining to her/his centers of interest and character traits.
- DATA HOSTING
The User is hereby informed that her/his Personal Data is not transferred outside the European Union.
- RECIPIENTS OF PERSONAL DATA OF USERS
The Personal Data of Users collected by means of the Application is made accessible to accredited ThereSheGoes employees for the purpose of carrying out administration or maintenance work on the Services or, as the case may be, for the purpose of enabling Users to execute their rights regarding their Personal Data (including Right of Access, Withdrawal, Rectification, Opposition and Portability, as well as the Right to Be Forgotten).
The Personal Data of Users is also communicated to other Users as part of the use of the Application.
The Personal Data of Users collected through the use of the Application may be communicated to third parties so that Users can avail of services related to their center of interests and character traits.
ThereSheGoes may disclose your data under the following circumstances, to the following persons:
- To our own technical subcontractors who may require to work with your Personal Data doing so however within a secure and confidential framework; or
- To meet our legal, regulatory, or judicial requirements, or upon request thereto from authorities; or
- To take preventive measures to prevent violation of the rights of other Users or of public order so as to comply with legislation in force;
- To business partners, so that the User be in a position to avail of and/or receive Services pertaining to her/his centers of interest and character traits.
- USER RIGHTS AS REGARDS THEIR PERSONAL DATA
In accordance with Regulations in force, Users whose Personal Data is collected have the right to access, modify, limit the processing of, and require the deletion of, their Personal Data. They also have a right of portability over their Personal Data.
Any User who wants to exercise her/his rights simply sends a request to this effect to ThereSheGoes:
- in writing at 6 rue Colbert, 92350 Le Plessis Robinson, France
- by phone by contacting the support at: +316 28 92 85 03
The application must be signed and accompanied by a photocopy of an identity card, indicating the reason, and indicating the address to which ThereSheGoes must send a response.
If a User whose Personal Data has been collected considers that her/his rights have not been respected, she/he is entitled to lodge a complaint with the CNIL. For any additional information, Users are requested to consult the CNIL site at www.cnil.fr.
- DURATION OF PROCESSING
ThereSheGoes retains user identification data doing so for a duration not exceeding the duration of her/his membership, plus the legal archiving duration of client file information.
The User is informed that, in the absence of express instructions to the contrary, User data is kept for a period of 3 years as from the end of her/his membership, and even then, is kept solely for the purpose of managing former memberships and personal accounts.
- COOKIES POLICY
Browsing Cookies on the Application
The browsing cookies improve the performance of the Services in order to provide the User with better use of the Application.
Audience and statistic measurement cookies
Audience and statistics-measurement cookies are used to prepare statistics and volumes concerning the number of visitors and use of the various elements making up the Application (rubrics and content visited, paths), enabling ThereSheGoes to improve the degree of interest and relevancy of the Services.
Cookies are used to push advertisements tailored to the User’s centers of interest. Cookies are also used to count and identify the displayed advertisements, and to assess the number of Users who clicked on a given advertisement. These cookies can be placed by ThereSheGoes or by its business partners.
Behavior-analysis cookies and Data Targeting
Behavior-Analysis cookies are used to identify the information of the Application which could be of most potential use to a User. They are also used to optimize the browsing experience.
ThereSheGoes may use several advertising servers ("adserver") for both the sale and purchase of advertising areas. These “adservers” rely on data collected by means of cookies or tags embedded in Application pages.
Using the Nugg.ad technology on the Application. As part of the implementation of this technology on the Application, where such be relevant, User data is measured for advertising purposes by means of cookies. Specifically, cookies are used to count the number of the visits for the various themes, depending on the use of the Application, and to save this information. These cookies are placed on the User’s smart phone for 26 weeks at most. At any time, the User can block the saving of information by going to the page: https://www.nugg.ad/en/privacy/general-information.html
Social network sharing cookies
ThereSheGoes gives Users the possibility to avail of a number of functionalities to share editorial content as well as any other type of content published on the Application by means of social network sites. Social network cookies are managed by the publisher of the social network site. The User is advised to familiarize herself/himself with the cookie-management policy for the social network sites concerned.
User agreement regarding cookies
It is assumed that the User has given her/his consent as follows:
- by clicking on the "X" icon or the "I understand" button on the information banner which displays upon first connection to the Application;
- by continuing to browse, i.e., when the User has clicked on an Application element (image, link, “search” button, etc.) or by going to another page of the Application.
If the User accepts, via her/his browser, that cookies be saved on her/his smartphone, then any cookies on pages or in content that she/he consults can be stored temporarily in a reserved area of her/his smartphone, where they can be read only by the sender.
The above-mentioned acceptance given by the User is only valid for a period of thirteen (13) months as from the date on which the cookies are firstly placed on the User’s smart phone, as indicated by the User’s explicit consent.
Refusal of Cookies
If the User does not give her/his consent to having cookies saved on her/his smartphone or browser, or if she/he deletes cookies which have already been saved on her/his smartphone/browser, she/he is informed that her/his browsing experience might suffer as a result. This could be the case where, for example, ThereSheGoes or one of its service providers is unable to recognize, owing to reasons of technical incompatibility, the nature of the browser used by the smart phone, the language or display settings, or the country from which the device apparently established a connection to the Internet.
In any case, ThereSheGoes declines any liability for any consequences related to the degraded operation of the Services resulting from (i) a refusal of cookies on the part of the User; (ii) ThereSheGoes not being able, as a result of actions undertaken by the User, to store or consult cookies required to ensure their proper operation.
A message is pushed to the User reminding him that she/he may block the saving of cookies.