PRIVACY POLICY

Purpose of the privacy policy:

The purpose of this privacy policy is to inform the user of the BEEBLI site, hereinafter the “Site” or of the BEEBLI application, hereinafter the “Application”, about the categories of personal data that BEEBLI can be brought to collect or treat, how this data is used, how it is protected as well as the rights available to the user on their personal data.

As part of their navigation on the site, their use of the Application and, in general, their trade with BEEBLI, the user is required to communicate a number of personal data, especially at the creation of an account, or when taking out a subscription to the services offered by BEEBLI.

In accordance with the provisions of European Regulation n° 2016/679 of April 27, 2016 known as the “General Data Protection Regulation” or “GDPR”, and of the amended Data Protection Act (in particular by law n° 2018-493, known as “LIL 3”, of June 20, 2018 and its implementing decree as well as the rewriting order n° 2018-1225 of December 12, 2018), BEEBLI ensures the collection and processing of personal data under the conditions described below.

This privacy policy also applies to users (natural persons) located outside the European Union. Certain special provisions applicable to natural persons residing in the State of California, in the United States of America, in application of Title 1.81.5 of the Civil Code of California made following the adoption of the “California Consumer Privacy Act” (CCPA ) are specified below.

Modification of the Privacy Policy:

BEEBLI may need to modify this confidentiality policy, in particular in order to comply with all regulatory, jurisprudential, editorial or technical changes. If necessary, the update date will be changed.

When necessary, users will be informed or solicited in order to possibly obtain their consent.

It is advisable to consult this page regularly to take note of any modifications or updates made to the confidentiality policy of the Site and the Application.

Date of the last update: [ to be completed ]

Identity and contact details of the controller:

The data controller is the company ELIE, operating under the trade name “BEEBLI”, SA RL registered with the RCS of Nîmes under the number 852 455 609, and whose registered office is located at 238 Rue Aramon, Domaine de la Clastre, 30640 BEAUVOISIN, hereinafter “BEEBLI”. The teams of the data controller can also be contacted at the email address [email protected] or by phone: +33 04 11 83 38 06.

Categories of personal data concerned :

The categories of personal data that BEEBLI may need to collect and process are as follows:

• Identification data: name, date of birth, sex.
• Contact details: country of residence, email address.
• Bank details: identity of the card holder, card number, security code, card expiration date, type of card
• Consumption data: type of subscription chosen, books read, books placed in favorites, preferred language, number of books read, percentage of books read, notes, annotations, highlighting, reading format (EPUB, PDF).
• Transaction data: currency of payment, subscription charged, date of subscription, duration of the subscription.
• Behavioral data: no behavioral data.
• Technical data: internet browser, date and time of connection, resolution of the terminal screen, OS, IP address, MAC number, terminal model, version of the Application used.

When collecting data through forms, the user is informed of the mandatory or optional nature of certain fields or data, by the presence of an asterisk. Personal data identified by an asterisk are required. If their data is not entered, the execution of the request (making contact, opening a user account ) will not be successful.

Data source:

BEEBLI collects personal data directly from users, especially when they come forward to it, in particular when creating a user account or when subscribing.

Purpose of processing:

The purpose of the processing carried out by BEEBLI is to:

• Accept and manage user subscriptions;
• Manage complaints, subscription changes;
• Bill subscriptions and manage direct debits;
• Respond to user requests;
• Manage user accounts;
• Allow the user to annotate, highlight works and create reading lists;
• Optimize the Site and Application for their display and their use;
• Comply with the applicable copyright provisions (respect for licenses);
• Settle copyright to partner publishers;
• Contact the user for information or marketing purposes, in particular by sending electronic communications (information emails or newsletters).

Legal basis for processing:

The legal basis for the processing is:

• The execution of a contract or of pre-contractual measures taken at the user's request, for the execution of subscriptions and ancillary services (subscriptions, complaints, withdrawals, invoicing) and, more generally, the management of user accounts;
• The execution of a contract concluded between the data controller and the user for the backup of annotations, highlighting and reading lists;
• The legitimate interest of the user for the responses to his requests;
• The legitimate interest of the data controller for the optimization of the Site and the Application on the user's digital terminal;
• The legitimate interest of the data controller for monitoring the titles consulted and the payment of copyright to partner publishers;
• A legal obligation imposed on the controller, for reasons of data retention for evidential purposes;
• The user's consent for actions for commercial or marketing purposes, it being specified that the user has the right to withdraw their consent at any time by email according to the terms indicated below (article right of persons);
• User consent for data collected through cookies not necessary for the operation of the Site or the Application.

Data recipients:

The data is only processed, within the limits of their respective attributions, by the services of BEEBLI, and especially its IT, communication and consulting, and customer service departments, as well as by its external service providers, in particular IT (e.g.: webmaster, host), banking services, marketing, advertising or communication agencies, collective management organizations.

Subject to the transfers mentioned above, the data is not transmitted to third parties. In particular, they are not sold, exchanged, transferred, or given to a third company, without the user's consent.

As such, it is specified that no personal data is transmitted to the partner publishers whose works are now accessible through the Site or Application. Only statistical anonymized data (number of pages read, ranking of books read, etc.) are communicated to these publishers.

In addition, in accordance with the regulations in force, the data collected may be transmitted to the competent authorities on request and in particular to public bodies, auxiliaries of justice, ministerial officers, bodies responsible for carrying out debt collection, exclusively to respond to legal obligations, as well as in the case of the search for perpetrators of offenses committed on the Internet.

Data retention period:

The data are kept only for the period strictly necessary for the purposes pursued as indicated above:

• For the duration of the contractual relationship in the event of subscription to the services offered by BEEBLI;
• For a period of five years from the closing of the user account with regard to the data processed for the creation, use and management of a user account for the use of the Site and the Application;
• For a period of three years from receipt of the last email, in the event of contact by the user via the contact form;
• For a period of one year from the termination of the subscription by the User, for the reading consumption data entered by the user;
• For a period of three years from the last contact for solicitations of a commercial nature and newsletters;
• For a period of 13 months from the deposit on the user's terminal with regard to connection data and other data collected by means of cookies. Note: The durations offered here are the maximum durations.

At the end of the periods mentioned above, the user's personal data may be kept by BEEBLI for evidential purposes, according to the legal limitation periods (five years under the Civil Code), and for the purposes of accounting archiving (10 years under the French Commercial Code), or when they have been subject to an anonymization process. Data security and confidentiality:

BEEBLI implements the technical, organizational and legal measures necessary to preserve the security and confidentiality of the data of the persons concerned, both online and offline. In particular, the computers and servers used to store personal data are kept in a secure environment.

Rights of individuals:

Regarding personal data, the user is warned that they have a right of access, rectification, erasure and opposition, right to limitation of processing, right to data portability, right not to be the subject of an automated individual decision (including profiling). To exercise one of these rights, they just need to write to BEEBLI or send an email to the contact details at the top of the present agreement, specifying in the subject line “personal data”.

In application of article L.223-1 of the Consumer Code, regardless of the relationship between the user and BEEBLI and in general, the user also has the right to register free of charge on a list of opposition to telephone canvasing if he does not wish to be prospected by telephone.

In all cases, in the event of a dispute concerning the processing of their personal data, the user can lodge a complaint with the supervisory authority, in this case the CNIL (https://www.cnil.fr).

Automated decision-making:

User data is not subject to automated decision-making.

Transfers outside the European Union:

The data are not subject to transfers outside the territory of the European Union.

Cookies:

For optimal use of the Site and the Application, BEEBLI uses files called “cookies”, which may be saved on the user's terminal. A cookie is a text file stored by the browser, which allows it to retain information between web pages and browsing sessions.

The user can refer to the CNIL website for additional information on cookies: https://www.cnil.fr/fr/les-conseils-de-la-cnil-pour-maitriser-votre-navigateur.

These cookies record information relating to the user's navigation on the Site and during the installation of the Application and store information that the user has entered during the use of the Site or during the installation of the Application. They allow BEEBLI to obtain statistical and advertising data and to combine the personal data that the user has provided to BEEBLI with the browsing information collected, in order to guarantee them personalized use of the functionalities of the Site and the Application.

The Website and Application use necessary cookies in their operation, but also cookies related to targeted advertising, realization of statistics as well as personalization features and finally social network sharing cookies. Some of these cookies may be provided by third parties.

These cookies are as follows:

Cookies necessary for the operation of the site:

• COOKIE NAME : PHPSESSID
• PURPOSE OF THE COOKIE : Session ID
• THE DURATION OF THE CONVERSATION : Duration of visit

If the user does not want such cookies to be installed on his terminal, he can modify the preferences of his browser to refuse them in whole or in part. Such a refusal may, however, affect the use of the site. When using the Application, the user can also refuse the installation of certain cookies and deactivate certain functions linked to them. Such a refusal may, however, affect the use of the Application.

To delete and manage cookies, the user is invited to refer to the dedicated help pages of his browser. The access links for the main browsers are as follows:

• Microsoft Internet Explorer: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies
• Google Chrome: https://support.google.com/chrome/answer/95647?hl=fr&hlrm=en
• Safari: https://support.apple.com/kb/PH19214?locale=fr_FR&viewlocale=fr_FR
• Firefox: https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences?redirectlocale=fr&redirectslug=Activer+et+d%C3%A9sactiver+les+cookies
• Opera: http://help.opera.com/Windows/10.20/fr/cookies.html

The user can also configure his browser so that it indicates to the sites consulted their wish not to be tracked (“Do Not Track”).

The user can also block the tracking coming from the buttons of the social networks in the reference pages of the networks concerned. The user is invited to read the policy for managing these social network cookies on the sites concerned. Button blocking can also be achieved using the open source Privacy badger software extension available at the following address: https://chrome.google.com/webstore/detail/privacy-badger/pkehgijcmpdhfbdbbnkijodmdjhbjlgp?hl = fr Law applicable to residents of California, United States of America

In application of the “California Consumer Privacy Act” (CCPA) of 2018, and in addition to the information mentioned above for the processing carried out by BEEBLI, the following elements are brought to the attention of and are applicable to individuals residing in California, in the United States of America.

BEEBLI does not proceed in any way to the resale of personal data without the consent of the users.

The rights a user has over their personal data are: (i) the right to erasure, (ii) the right to information, (iii) the right to refuse the resale of their personal data, (iv ) the right of access, (v) the right to portability, (vi ) the right not to be discriminated against in the event of the exercise of their rights with BEEBLI.

The users have several ways to exercise their rights, namely:

• By email by writing to: [email protected];
• By telephone, not surcharged, to: +33 04 11 83 38 06 ( 9 am-6 pm Monday to Friday).

In addition, it is specified that BEEBLI will not be required to accede to the request for the exercise of its rights by a user when this request:

• Would be likely to prevent BEEBLI from performing the contractual obligations it has towards the user;
• Would be such as to prevent the user from ensuring the security of their activity or computer system;
• Would affect other rights recognized by the law and in particular freedom of expression;
• Concerns anonymized data.

In order to exercise its rights, the user must allow for BEEBLI to verify their identity.

In application of articles 1798.100 and 1798.130 of the Civil Code of California made under CCAC, BEEBLI is not obliged to comply with requests to exercise the rights of access and obtain a copy of personal data, and information, from the same user more than twice a year.

The publication and provision of information in application of the rights granted to the user under articles 1798.100 to 1798.115 and 1798.125 of the California Civil Code is carried out free of charge and within a maximum period of 45 days from the receipt of a request from a user. The information provided to the user will relate only to the 12-month period preceding the receipt of the request.