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PERSONAL DATA PROTECTION POLICY
FULLFOOT
FULLFOOT (ci-après « nous », « notre ») (hereinafter „we“, „us“, „our“) undertakes to respect your privacy and your
personal data, we therefore invite you to read this notice carefully.
The purpose of this Personal Data Protection Policy (hereinafter the „Policy“) is to inform you about the personal data we
collect and use in the context of your use of the application (hereinafter the „Application“) and website (hereinafter the
„Site“) FullFoot (hereinafter collectively referred to as the „Plateform“).
We collect and process your personal data in accordance with the applicable law on the protection of personal data and, in
particular, the General Data Protection Regulation EU 2016/679 (hereinafter the “GDPR”).
This Policy includes a description of the data collected and the purposes justifying its collection. It also includes a
description of your rights, including your right to object to certain processing operations that we carry out on your data.
Data Protection Policy Index :
§ Who is responsible for processing your data ?
§ What types of data do we collect ?
§ Why do we collect your data ?
§ On what legal basis is your data processed ?
§ To whom is your data disclosed ?
§ Is your data transferred outside the European Economic Area (EEA)
§ How do we protect your data ?
§ If you are a minor
§ How long is your data kept ?
§ What are your rights and how can you exercise them ?
§ Contact
§ Changes to this Policy
Who is responsible for processing your data ?
Your data is collected by FULLFOOT, a simplified joint stock company, registered in the Vienna Trade and Companies
Register under the number 882 961 295, whose contact details are as follows :
Head office address : 301 Rue Denis Papin, 38090 Villefontaine, France
Telephone : +33 668 408 203
E-mail address : avi.dahan@fullfoot.com
What types of data do we collect ?
We collect and process :
- Identification data (user name, e-mail address, date of birth, gender) ;
- Data related to the user's preferences (favorite teams).
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The compulsory or optional nature of the data is indicated by a distinctive sign at the time of collection. Some data are
collected automatically as a result of your actions on the Platform.
We also collect certain technical data related to your activities on the Platform through the use of cookies and other
similar technologies. For more information, please see our Cookie Policy.
Our service providers, who are responsible for providing user support and advertising, may have access to certain data
that is strictly necessary for your use of the Platform and its functioning, namely your browsing history, your username
and your nationality. We have taken care to put in place with these service providers the contractual guarantees required
by applicable regulations in order to ensure the confidentiality and security of your data.
When users subscribe to the app with Facebook, we collect only the mail address and use it to ask to the users some
feedbacks for the app and sent commercials offers. We are not collecting and using all the others data from Facebook
such as: hometown, gender, age, location, friends, likes. As mentioned, the only data collected and used from Facebook is
the email address.
Why do we collect your data ?
We use your data for the following purposes (hereinafter the “Purposes”) :
§ To enable the creation, use and maintenance of your customer account ;
§ To send you any prizes won in the context of contests organized on the Application ;
§ To enable the provision of the Platform's services, their improvement and the maintenance of a secure
environment ;
§ To carry out statistics and analyses ;
§ To enable the sale of advertising space to advertisers in view of the business model of our company ;
§ To solicit your opinion or your participation in satisfaction surveys ;
§ To send you, from time to time, newsletters and/or similar communications to promote the contests and the
Platform;
§ To comply with our legal, regulatory and administrative obligations ;
§ To avoid prohibited or illegal activities.
On what legal basis is your data processed ?
You will find below the legal bases corresponding to the Purposes :
Legal bases
Purposes of processing
Performance of the contract or pre-
contractual measures
§ Your access and use of the Platform ;
§ Management of the functioning and optimization of the Platform ;
§ Implementation of user support ;
§ Data verification, identification and authentication
§ Management of possible disputes ;
§ Sending of commercial and advertising information based on
your preferences.
Legal obligations
§ Compliance with legal, administrative and regulatory obligations.
Legitimate interest
§ Statistics and analyses
To better understand your needs and improve the services of our Plateform.
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§ Commercial prospection
Personalization of services by displaying advertisements based on your
browsing history, according to your preferences, in order to present you with
offers or products that correspond to your needs.
§ Avoidance of prohibited or illegal activities.
Prevention and detection of fraud, malware (malicious software) and
management of security incidents in order to protect the interests of the users
of the Platform in accordance with the Terms of Use of the Platform and the
law, as well as the interests of FULLFOOT.
To whom is your data disclosed ?
Your data is communicated only to FULLFOOT employees who have been authorized for this purpose, such as
employees of the Legal Department or Data Analysts.
We communicate your data to third parties only insofar as this is strictly necessary and only in the cases exhaustively
listed below.
We may communicate your personal data to third parties acting on our behalf, for the sole purpose of operating the
Platform, and in particular to our service providers or subcontractors, who are responsible for the hosting, maintenance,
logistics and administration of the Platform and its services.
Your personal data may thus be shared with third party companies, provided that the latter are established in the European
Union, and therefore subject to European regulations on the protection of personal data, when you authorize a third party
website to access your data.
In addition, given our business model which is based on mobile advertising, some of your data, such as your browsing
history, your username and your nationality, will be communicated to advertisers for the purpose of selling advertising
space.
Your personal data will be communicated in compliance with the provisions of the GDPR and within the framework of
contracts that ensure compliance with the Personal Data Protection Policy.
In the event that we are merged with, acquired by or transferred to another company, we may share your personal data
with that company as permitted by applicable law and in accordance with this Policy.
In addition, we may be required to disclose your personal data in order to comply with any applicable law or regulation, a
court order, or if such disclosure is necessary in connection with an investigation or proceeding.
Is your data transferred outside the European Economic Area (EEA) ?
We may transfer some of your data, as described above, to advertisers outside the EEA in order to enable the sale of
advertising space in view our business model.
For these transfers, we have implemented the Standard Contractual Clauses established by the European Commission.
You can obtain a copy of the Standard Contractual Clauses as well as other warranty methods by writing to us at the
following address : contact@fullfoot.com.
How do we protect your data ?
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We take all necessary organizational and technical measures to protect your data against accidental or intentional
manipulation, loss, destruction, disclosure or unauthorized access. We strive to improve our security measures as new
technologies emerge.
If you are a minor
If you are under 16 years of age, we ask that you request the consent of your parents or legal guardians before providing
us with any data concerning you.
They should contact us at contact@fullfoot.com in order to provide us with their contact details (email address, telephone
number) so that they can confirm their agreement and so that we can contact them in the event of a problem or for any
further information. Otherwise, you must refrain from communicating your personal data to us.
How long is your data kept ?
In accordance with applicable regulations, we keep your data for a period of time commensurate with the Purpose for
which it was collected, or as required by law.
The personal data we collect when you create a customer account or place orders via our Platform are kept for the time
necessary to manage the commercial relationship and then for 10 years in our archives.
If you stop using your customer account for a period of two (2) years, it will go into an inactive state and will be deleted.
You can avoid this by logging into your customer account at least once every two (2) years. Prior to deleting your
customer account, we will send you a notification to give you the option to keep your customer account.
When you delete your customer account or when your customer account is deleted due to inactivity, we may need to
retain some of your personal data in order to ensure compliance with our General Terms and Conditions of Use and to
meet our legal and regulatory obligations.
Other personal data associated with your customer account is deleted.
What are your rights and how can you exercice them ?
You may at any time exercice your rights in accordance with the applicable European Union legislation :
§ Right of access : you have the right to know what data we process about you. You also have the right to obtain a
copy of the data being processed ;
§ Right of rectification : you have the right to request the rectification of any inaccurate or incomplete data
concerning you ;
§ Right to erasure : you have the right to request the erasure of your data under the conditions provided for in
Article 17 of the GDPR, in particular when they are no longer necessary ;
§ Right to the limitation of processing : you have the right to request the limitation of the processing of your data
under the conditions provided for in Article 18 of the GDPR ;
§ Right to object : you may at any time object to the processing of your data, in particular when it is used for direct
marketing purposes, pursuant to Article 21 of the GDPR ;
§ Right to withdraw consent : you have the right to withdraw the consent you have given for processing on this
legal basis. This withdrawal is valid for the future and does not call into question the lawfulness of the processing
already carried out ;
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§ Right to data portability : you can retrieve your data in a commonly used and machine-readable structured
format in order to transmit this data to another data controller under the conditions set forth in Article 16 of the
GDPR.
To exercise your rights you can send your request by e-mail to contact@fullfoot.com and / or by regular postal mail to :
FULLFOOT – 301 rue Denis Papin 38090, Villefontaine
How can you delete your account and the data with it ?
You can delete your account and the data in the app. In the profile section click on “account deletion” and the process will
start. We guarantee that your account and the data with it will be erased within 48 hours following your account deletion.
We hope to be able to answer all your questions regarding the processing of your data. However, you have the right to
lodge a complaint with the French Commission Nationale de l'Informatique et des Libertés (CNIL) (National Commission
on Informatics and Liberty), notably on its website : www.cnil.fr.
Contact
If you have any questions, comments or requests regarding your data or this Policy, you can send an email to
contact@fullfoot.com or contact us by phone at +33 6 68 40 82 03 or by regular postal mail at the following address :
FULLFOOT – 301 rue Denis Papin 38090, Villefontaine, France
Changes to this Policy
We reserve the right to change this Policy at any time. In the event that this Policy is modified, we will take the
appropriate steps to ensure that you are aware of the latest version of this Policy.
This Policy was last modified on 05/28/2021.
