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Privacy Policy

Updated on: 

30

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06

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26

This personal data protection policy (the “Policy”) describes how the company Lotchi (“Lotchi”, “we”, “our”) processes the personal data of its contacts (“you”, “your”) collected via the contact form available on the website https://www.lotchi.live (the “Site”) and/or more generally, in connection with our exchanges with you in the context of our business relations.

Protecting your privacy and your personal data is a priority for Lotchi, which undertakes to process your data in accordance with French Data Protection Act No. 78-17 of 6 January 1978, as amended, Regulation (EU) 2016/679 of 27 April 2016 on the protection of personal data (hereinafter the “GDPR”) and the related standards and recommendations of the CNIL (together, the “Applicable Regulations”).

ARTICLE 1. IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER

When you browse the Site or, more generally, in connection with the management of our contractual relations with you, and unless otherwise agreed between the parties, the data controller for all data collected is the company Lotchi, a French simplified joint-stock company (société par actions simplifiée – SAS) registered with the Paris Trade and Companies Register (RCS) under No. 952 256 923, whose registered office is located at 60, rue François 1er – 75008 Paris (France).

ARTICLE 2. DATA COLLECTED

Lotchi collects your personal data when you complete the contact form available on the Site and/or when you communicate with us in connection with our business relations, and when you exercise your rights as provided for by the Applicable Regulations and described in article 5.2.

The data collected is the data enablingyour identification, namely: your surname, your first name, your email address; and any information you wish to send us in your contact request and/or in connection with our business relationship.

ARTICLE 3. PURPOSES AND LEGAL BASES OF PROCESSING

You may be required to provide certain personal data (enabling you to be identified, directly or indirectly). If you do not wish to provide the information requested, we invite you not to complete the contact form available on the Site and/or not to send us such data in the course of our exchanges.

Data marked with an asterisk (*) must be provided. Failing this, you will not be able to submit the contact form to our teams.

Your personal data is collected for specified, explicit and legitimate purposes. Depending on the case, personal data may be used for the following purposes:

  • Respond to your requests for information or contact (on the basis of the performance of pre-contractual measures taken at your request); personal data is retained for a period of 3 years from your last contact.
  • Build a database of prospective clients (on the basis of Lotchi’s legitimate interest in developing and promoting its business); personal data is retained for a period of 3 years from the prospective client’s last contact.
  • Carry out commercial prospecting operations or other marketing actions (on the basis of Lotchi’s legitimate interest in developing and promoting its business); personal data is retained for a period of 3 years from the prospective client’s last contact.
  • Enable Lotchi to comply with its legal obligations (on the basis of Lotchi’s compliance with its legal obligations); personal data is retained in accordance with the paragraph at the end of this article.
  • Manage and respond to your requests to exercise your rights (on the basis of Lotchi’s compliance with its legal obligations); personal data is retained for the period necessary to process the request, then archived for a period of five (5) years from the expiry of the maximum statutory period within which Lotchi must respond to you.
  • Manage litigation matters (on the basis of Lotchi’s compliance with its legal obligations or, as the case may be, its legitimate interest in ensuring its defence in legal proceedings); personal data is retained in accordance with the paragraph at the end of this article.

In all cases, Lotchi retains your personal data only for as long as necessary to achieve the purposes pursued, subject to the legal possibilities for archiving and the retention obligations applicable to certain data (in particular in the event of litigation or pre-litigation proceedings, or in order to respond to requests from authorised authorities), and/or the anonymisation of personal data. The retention period for data may vary depending on the purpose pursued. Lotchi accordingly applies the retention periods set out above (without prejudice to the archiving periods and retention obligations referred to above).

ARTICLE 4. RECIPIENTS WITH ACCESS TO THE DATA

Your data may only be disclosed to the following recipients or categories of recipients, within the limits of their respective duties and to the extent that such disclosure is strictly necessary to achieve the purposes set out in article 3 of this Policy:

  • Authorised personnel of Lotchi’s marketing, sales, administrative and IT departments;
  • The Site’s IT and hosting providers;
  • Lotchi’s processors: newsletter distribution provider, audience measurement and analytics provider, email service provider, cookie management tool, CRM provider, media agencies, artificial intelligence tools.
  • Persons responsible for internal and external audit and control functions.

Lotchi may also disclose data in order to respond to legal or regulatory requests, court decisions, summonses or legal proceedings, where compliance with applicable regulations so requires, as well as in the event that Lotchi transfers all or part of its assets to a third-party company.

ARTICLE 5. YOUR RIGHTS

5.1. Your rights regarding the processing of your data

In accordance with the Applicable Regulations and within the conditions and limits set out therein, you have all or part of the following rights:

  • Right of access to request confirmation as to whether or not data concerning you is being processed and, where it is, access to such data as well as to certain information about its processing;
  • Right to rectification of inaccurate or incomplete data;
  • Right to erasure of your data;
  • Right to withdraw consent to the processing of your data (only where such processing is based on consent);
  • Right to restriction of processing of your data;
  • Right to object to the processing of your data (only where such processing is based on Lotchi’s legitimate interest and provided that you can demonstrate grounds relating to your particular situation);
  • Right to data portability of the data you have provided yourself (only where such processing is based on consent, given that contract, another possible legal basis for exercising this right, is not applicable in this case);
  • Right to determine the fate of your data after your death and to choose whether or not Lotchi must disclose your data to a third party previously designated by you.

5.2. Means of exercising your rights

If you wish to exercise any of the rights provided for by the Applicable Regulations and referred to in article 5.1 of this Policy, you may contact Lotchi using one of the means set out below, specifying your identity and the precise purpose of your request (proof of identity may be requested in the event of doubt as to the identity of the requester).

For any question relating to the use of your data and your rights, you may contact Lotchi by one of the following means:

  • by email at: dpo@lotchi.live
  • by post, at: 60, rue François 1er – 75008, Paris

Lotchi undertakes to respond to you as soon as possible, and in any event within one (1) month of receipt of your request.

If necessary, this period may be extended by two (2) months, taking into account the complexity and number of requests received. In such case, you will be informed of this extension and the reasons for the delay.

If your request is submitted electronically, the information will also be provided to you electronically where possible, unless you expressly request otherwise.

Where we are unable to act on your request, we will inform you of the reasons and you will have the right to lodge a complaint with a supervisory authority and/or to bring a judicial action.

In particular, if after contacting Lotchi and despite its efforts, you nevertheless consider that your rights have not been respected, you may lodge a complaint with the competent supervisory authority. In France, this is the Commission Nationale de l’Informatique et des Libertés (the “CNIL”): https://www.cnil.fr/fr/plaintes.

ARTICLE 6. TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN UNION

Your personal data is processed within the European Union.

Where transfers outside the European Union take place, Lotchi undertakes to ensure that the recipient is located in a country benefiting from an adequacy decision of the European Commission, or that measures (such as the European Commission’s Standard Contractual Clauses) are put in place to ensure that your personal data transferred to such countries benefits from adequate protection safeguards in accordance with the provisions of the GDPR.

You may obtain a copy of the legal or contractual instruments enabling the transfer of data outside the EU by contacting Lotchi using the contact details set out in article 5.2.

ARTICLE 7. UPDATES TO THE POLICY

Lotchi reserves the right to modify or update the Policy at any time. Any change or update will take effect immediately upon publication.

ARTICLE 8. GOVERNING LAW AND DISPUTE RESOLUTION

This Policy is governed by French law.

In the event of a dispute, where no amicable settlement can be reached, the competent court shall be determined in accordance with applicable procedural rules.