Privacy policy

 

This privacy policy is intended to inform you of the use of your personal data by COEO. We invite you to read it carefully.

 

COEO attaches great importance to protecting your personal data and respecting your privacy. This privacy policy (as well as our General Conditions of Use and any document referred to therein) is intended to inform you of how we handle the personal data you provide to us and that we collect in the course of your use. of the Application and the Services. We invite you to read this document carefully to understand our practices regarding the processing of your personal data and to know your rights in this regard. 

 

This Privacy Policy applies to all Services published by COEO that you use (excluding services provided and operated by third parties, in which case, the privacy policy of these third parties applies and not these provisions). 

 

Article 1. Definitions

 

Application : the COEO application, available on the Apple App Store and the Google

 

Profile: personal space dedicated to the User on the Application, which he accesses by registering and connecting to the Application. It allows the User to access the Services. A User can only have one Account.

 

Facebook Connect/Google Connect/ Apple Connect : feature that allows Members to use their third-party account to identify themselves on the Application in order to simplify the registration procedure.

 

COEO : Single-member simplified joint stock company, 69 Chemin des Vignes Prolongé, 13109 SIMIANE-COLLONGUE. Registered with the Aix-en-Provence RCS under number 890 808 793,, and owner and sole operator of the Application and the COEO brand.

 

Map (Cartography) : map that allows you to locate events and places

 

User : person registered on the Application.. 

 

Messages : Only Users who have established contact can initiate the "Chat" action in the App, and send each other Messages. Messages are visible in the messaging accessible in the Application.

 

Profile photos : profile photos allowing easy recognition of the User

 

Geolocation: your location recorded by COEO and regularly updated when this option is activated.  

 

Services : set of services offered by COEO to promote virtual or real meetings between Users who are in the same place or event

 

Article 2. Processing Manager - Hosting

 

2.1 Processing manager

 

The data collected is processed by the Company COEO SASU registered under number 890 808 793 of the Aix-en-Provence Trade Register, whose registered office is situated at 69 Chemin des Vignes Prolongé, 13109 SIMIANE-COLLONGUE, France and represented by its Chair, Mr Sacha GOEDER. 

 

2.2 Hosting

 

All data collected and processed by COEO is hosted by Google, in the Cloud Storage for Firebase in Frankfurt, Germany, called europe-west 3.

 

The data is therefore stored in the European Union.

 

Google has its parent company in the United States, the data stored is subject to Cloud Act legislation.

 

Article 3. Information we collect

 

COEO collects and processes personal data about you when you use the COEO application or when you communicate with COEO. This is information that you provide to us directly or data we collect automatically. 

 

In order to ensure the readability of our privacy policy, here is first an overview of the personal data concerning you, collected and processed by COEO. Below this overview you will find details about each item of data collected. 

 

  • ● Mandatory data:
    • o Identification details
    • o Depending on the registration method chosen: Email address and/or phone number
    • o Data relating to your activity on the application
    • o Technical data of the mobile or device
    • o Geolocation data while using the app to get nearby places and events, and in background to manage the automatical exit of places and events.

 

  • ● Data necessary for certain purposes
    • o Data relating to participation in events
    • o Text messages sent and received
    • o Data relating to reports and requests addressed to COEO customer service
    • o Data relating to the claim of a place

 

  • ● Optional data
    • o Professional career
    • o Areas of interest and lifestyle, characteristics of the User
    • o Depending on the registration method chosen: Email address and/or phone number 
    • o Description
    • o Profile picture and banner

 

3.1 Data you send us directly 

 

By using our Services, you send us information, some of which can identify you. When you provide this information, some of this data may be visible to other Users of the Application and is therefore made public on the Application. To allow you to easily identify them, this information is indicated to you below as "Public". COEO cannot be held responsible for data disclosed and made public by a User on COEO. However, other information is not visible to other Members and therefore cannot be accessed by them. This information is indicated to you below as "Private".  

 

COEO collects and processes data relating to your registration and data relating to your interactions with COEO. 

 

Data relating to registration and User profile

 

The information required for registration

 

This is the basic data necessary for registration to access the Services. 

This data is collected by COEO in different ways depending on the registration method you choose. 

 

If you choose to register with your Facebook, Apple or Google account, your data will be retrieved by them in order to minimise formalism. By clicking on the button "Connect with Facebook/Apple/Google", you agree that they communicate this data to us.

 

Otherwise, you have the option of registering via an e-mail address, in which case your data will be transmitted to COEO directly by you..

This data relates to your identity. 

 

Depending on how you register, some information is required for the provision of the Services. Failure to communicate them, will result in COEO not being able to provide you with the Services offered by the Application and you will not be able to create an Account. In all cases, your first name, your date of birth (private), as well as your gender are required to register on the Application.

 

When you register via Facebook, we must collect your first name and age, and your email address. You can also allow Facebook to transmit your last name, date of birth, gender to COEO.

 

When you register via Apple or Google, we must collect your first name, last name and email address.

 

Furthermore, if you refuse geolocation during your registration and therefore COEO's collection of your position data in order to offer you the events and places visited or in the surrounding area, you will not be able to use COEO's functionalities.

 

Optional information to complete your profile

 

You can provide other additional information to complete your profile. This information is optional and communicated at your sole discretion and under your sole responsibility. You can complete your profile directly on the Application.

 

This data is the following: 

 

  • ● Career and studies (public) : profession or studies;

 

  • ● Areas of interest and habits (public) : personal preferences, hobbies, musical preferences, lifestyle, User Characteristics;

  

  • ● Profile description(public) : if you wish, you can share additional information about yourself in the free entry field provided for this purpose and which is visible to COEO Members.

 

Your description is a free text area, COEO does not encourage the User to communicate data that may be qualified as sensitive to other Users or to COEO via the Application. 

 

“Sensitive data” means data legally qualified as “sensitive” under the General Data Protection Regulation (“GDPR”). This particularly includes data relating to racial or ethnic origin, political opinions, religious or philosophical convictions or trade union membership, as well as health, sexual life or sexual orientation ("Sensitive data"). If, despite everything, the User wishes to communicate such data on his profile, this communication is deemed to have been "manifestly made public" by the User concerned, within the meaning of the GDPR. 

 

Data relating to interactions with COEO

 

When you contact customer support, report a problem with our Services, report another user, request assistance, exercise your rights over your personal data or when you participate in events, visit places, share news, COEO will collect, as the case may be, the following personal data about you: 

 

  • ● Data relating to reports and requests to COEO customer service (private):ate and time of the report or request, nature and reason for the report or request, data relating to the reported user. In addition, proof of your identity may be requested in the exercise of your rights over your personal data for reasons of security and confidentiality.

 

This data is collected by COEO when you send a request for assistance to our customer service, exercise your rights over your personal data, report a problem or report another user. This information is necessary to process a report or to respond to your requests. This information is also processed when a report is made about you. Indeed, COEO has a legal obligation to collect reports from its Users bringing to its attention content or behaviour that may violate our General Conditions of Use.

 

  • ● Data relating to participation in events : participation, responses, level of satisfaction, suggestions, testimonials.

 

This data is collected by COEO when you participate in events or in the life of a place.

 

3.2 Data we collect automatically

 

When you use our services and features, we collect information about your activity on the Application: 

 

  • ● Data relating to your activity

 

  • ● Geolocation and intersection points with places and events (private)

 

  • ● Text messages sent and received (private)Text messages sent and received()

 

Messages are sent and stored on COEO's servers to provide the Transmission Service. Text messages are strictly private and are only binding on the Users concerned. COEO officials have no control over these conversations.

 

These Messages are not transmitted or communicated to third parties, except on judicial request and/or in accordance with applicable legislative or regulatory provisions. Furthermore, the Messages are strictly private and will not be accessible to other Members not involved in the exchange or to any third parties. 

 

  • ● Technical data of the mobileor of the device

3.3 Data collected by third parties

 

COEO is an application based on existing technologies such as

 

  • ● Google Maps (Android) and Plan (IOS) for map, location, and directions
  • ● Facebook, Google, Apple for registration and / or login through these apps.

 

When using the application, data may therefore be collected and processed by these third-party applications.

 

COEO cannot be held responsible for the processing of data resulting from this collection and invites the User to refer to the General Conditions of Use and to the confidentiality policies attached to these services and available on-line.

  

Article 4. Data use

 

4.1 Provision of services in accordance with our terms of use

 

  • ● Creation and management of your Account as a User:en tant qu’Utilisateur :
    • o Creation of your profile.
    • o Registration, unsubscription, deactivation of the User profile.
    • o Management of your settings and preferences.
    • o Management of access to the Services offered by COEO.

 

  • ● Management and storage of communications exchanged between Usersentre Utilisateurs  

 

Legal basis: Performance of the contract

 

The data collected by COEO is necessary for the proper functioning of the Application and for the provision of the Services that are offered to Users under the service contract between us (General Conditions of Use).

 

4.2 Suggest events and/or places

 

  • La ● Geolocationallows you to offer you the events and places closest to you. It also allows you to suggest a route to get there through Google Maps (Android) or Plan (IOS).

 

Legal basis: Consent 

 

When you have given your consent, you can withdraw it at any time by disabling the geolocation option on your smartphone. The withdrawal of your consent does not call into question the processing carried out prior to this withdrawal. Disabling location renders the application unusable.

 

4.3 Preventing and combating illegal or unauthorized activities

 

  • ● Analysis and processingof fraudulent/undesirable behaviour reports.

 

  • ● Management of unwanted behaviourand warning, suspension, blocking or deletion of the User Account.

 

  • ● Management of requests to exercise Users' rightsover their data.

 

Legal basis: Legal obligation

 

This processing is based on COEO's legal obligation, as a data host, to remove illegal content as soon as it becomes aware of it and on its obligation to respond to requests for the exercise of Members' rights over their personal data.

 

  

  • ● Claiming of places : to be able to claim a location, the COEO User must contact COEO by e-mail. COEO then returns the procedure to be followed and the supporting documents required (extract from K-bis, identity document, etc.) to allocate the place to a User.

 

Legal basis: Consent

 

You asked for your consent to collect and use your data for venue claim purposes when you first begin the claim process.

 

4.4 Provide help and technical support to Users

 

  • ● Respond to requests for assistance from Members in the use of the Application

 

Legal basis: Legitimate interest or contract

 

This processing is based on COEO's legitimate interest in allowing its Members to use the Application under good technical and operational conditions. 

 

Article 5. Sharing of data

 

Only COEO customer service processes Users' personal data for the purposes described above.

 

Des authenticated and reliable service providers and partners may also access and/or process Users' personal data on behalf of COEO in accordance with the Privacy Policy These service providers help us to operate and improve our Services, in particular concerning:

  • ● Our subcontractors for our infrastructure and data hosting;
  • ● Our analysis software suppliers;
  • ● Our technical service providers for the use of the Application and / or the proper functioning of the Application;
  • ● Our customer service for providing the necessary assistance to Members and handling reports.

 

Personal data may be transmitted to third parties, COEO customers for information purposes or advertising canvassing

Article 6. Transferring data outside the EU

 

The personal data of Users processed in the context of the use of the Application is hosted in the European Union.

 

However, Users' personal data is transmitted to COEO's subcontractor service providers who may be located outside the European Union..

 

COEO undertakes to do everything in its power to ensure that these transfers are carried out under conditions ensuring the confidentiality and security of data and an adequate level of protection in compliance with the regulations in force.

 

To obtain a copy of these, you can contact our Data Protection Officer at the following address: dpo@coeo.app 

 

 Article 7. User Rights

 

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (RGPD), each User has a right ofaccès, de rectification access, rectification and, where applicable, a right to the portability and thedeleting of personal data as well as the opposition to the processing or to its limitation and the right to define directives relating to the fate of his personal data after his death.opposition au traitement ou à sa limitation et du droit de définir des directives relatives au sort de ses données personnelles après son décès.

 

Mindful of the concerns of its Members, COEO undertakes to respect the protection of personal data and to process these requests as soon as possible. 

 

Terms of exercise

 

The User can exercise his rights, subject to proving his identity, by sending an email to dpo@coeo.com or by sending a letter to the following postal address: for the attention of the Data Protection Officer, COEO - 69 Chemin des Vignes Prolongé, 13109 SIMIANE-COLLONGUE. 

 

If in doubt as to the identity of the applicant, proof of identity may be requested.

 

For any other complaint, the User can make a request to the competent national data protection supervisory authority.

 

Detail of rights

 

  • ● The right of accessauthorizes the User to query COEO in order to obtain the communication of data concerning him in a form accessible under the terms and conditions of Article 15 of the GDPR.. 

 

  • ● The right of rectificationgives the User the right to require COEO to rectify, complete, update or delete personal data concerning him, which is inaccurate, incomplete, equivocal, out of date or whose use, communication or storage is prohibited under the terms and conditions of article 16 of the GDPR. You can modify or rectify certain data directly from the Application. 

 

  • ● The right to portabilitygives the User the right to receive the personal data that he has provided to COEO, in a structured, commonly used and machine-readable format and to transmit them to another controller, on the basis of Article 20 of the GDPR. 

 

  • ● The right of oppositiongives the User the right to oppose, free of charge and in a discretionary manner, that his data is used by COEO for prospecting purposes, in particular commercial and to processing based on the legitimate interest of COEO, on the basis of article 21 of the GDPR. 

 

  • ● The right to deletiongrants the User the right to demand the deletion without charge on a discretionary basis of the data communicated to COEO, within the limits of the rights based on Article 17 of the GDPR. In addition, you can delete your Account using the corresponding functionality directly on the Application..

 

  • ● The right to limitationgrants the User the right to temporarily freeze the use of certain data by COEO under the conditions of Article 18 of the GDPR.

 

  • ● The right of the user to define his guidelines for the retention, erasure and communication of personal data after death..

 

Article 8. Data retention period

 

COEO has set up a process for the manual deletion of your account and your personal data in accordance with the retention periods defined below.

 

COEO conserve les données de l’Utilisateur pendant toute la durée nécessaire à l’utilisation du Compte de l’Utilisateur c’est-à-dire : 

 

  • ● After an account has been inactive for two yearsit will be deleted, and the User's data will be permanently destroyed.

            An account is considered inactive when the User has not used the COEO application for 2 years.

 

After a ban,the account is deleted and the information of the banned account is kept for one year in an active database in order to compare them with the information provided during new registrations on the Application and, to prevent, as much as possible, any re-registration of an excluded user..

 

The User deletes his Account or requests its deletion from customer service, it is deleted from the Application. User data will be permanently destroyed.

 

Regarding geolocation, this is not stored. Only a history of the places visited is established automatically and is accessible to the User.

 

COEO is committed to providing the best efforts and all the means in its possession to guarantee the optimum security of the data stored. It remains the responsibility of the User to take the appropriate measures to protect his data.

 

Article 9. Personal data of minors

 

COEO refuses to collect data on minors. In the event of a lie from a User concerning his date of birth and more particularly in the event of a fraudulent attestation on his majority, the parents of the minor are invited to notify COEO by sending an email to mailto:contact@coeo.app in order to request the erasure of the data COEO undertakes to delete all personal data concerning the minor child as soon as possible.

 

COEO uses the maximum international majority present at 21 as a reference.

 

Article 10. Contact 

 

For any questions relating to this privacy policy or for any request relating to your personal data, you can contact us:

  • ● By sending an e-mail to our contact and contact e-mail mailto:contact@coeo.app
  • ● By sending an email to the Data Protection Officer dpo@coeo.app
  • ● By post to the following postal address: for the attention of the Data Protection Officer, COEO - 69 Chemin des Vignes Prolongé, 13109 SIMIANE-COLLONGUE.