Gleeph Privacy Policy

Version in effect from of 04/01/2022

Previous version accessible from here

PREAMBLE

Gleeph is a cellphone app offered by F-451, a simplified joint stock company with capital of 50 277,10 €, whose head office is at 1 rue Alexander Fleming, 17 000 LA ROCHELLE, registered with the LA ROCHELLE Trade and Companies Register under number 808 534 465 RCS LA ROCHELLE (hereinafter “F-451”).

F-451 acts as Data Controller for data made available to Users via the Gleeph application.

F-451 may be contacted by the following means:

Email: dpo@gleeph.net

In the event of any conflict between the English and French versions of GLEEPH PRIVACY POLICY, the French version shall prevail.

DEFINITIONS

“Application” or “GLEEPH Application”: Denotes the application provided to the User by F-451, downloadable from compatible cellphone downloading platforms and allowing the User to use the Services on his Smartphone or tablet.

“Library”: virtual library created by the User using the Application. The Library identifies those books that the User possesses, or has read, or wishes to read, or likes.

“User Account” or “Account”: Denotes the electronic account created by F-451, on the basis of information provided by the User and made available to the latter, so that he may gain access to all or part of Gleeph’s Services.

“Personal Data”: Denotes all information relating to the User allowing his identification in a direct or indirect manner that has been entrusted to F-451 by the User himself via any method.

“Services” or “Gleeph Services”: Denotes those services offered by F-451 via the Application, such as described in article 3 of these General Conditions of Use.

“User” Denotes the physical person who has created his User Account on the Application.

OBJECTIVE

This Privacy Policy has the objective of informing the User about Personal Data processed by F-451 in the context of his use of the Gleeph Application.

PURPOSES OF PROCESSING

Processing purposes implemented by F-451 are as follows:

Allowing the User to benefit from GLEEPH functionalities, such as:
- Creation of a User Account
- Listing of the Users’ books
- Access to other Users
- Receipt of reading suggestions
- Viewing the libraries of other Users
- The sending or receipt of Discussion Suggestions
- Notification to Friends of the User’s recent activities
- Book purchases from bookstores or partner websites
- Replying to Users’ requests
- Improvements to the Service or Customer Support
- The reading and writing of notes on books

The list of previous functionalities is given for indicative purposes and may change as the Application evolves.

Processing is undertaken on the basis of the contract accepted by the User while creating his User account.

The carrying out of statistical and marketing analyses in relation to using the Application and Services by Users.

This processing is undertaken on the basis of F-451’s legitimate interests in improving the familiarity of its Users via various indicators (time spent on the Application, average age, type of journey, etc.). Such analyses also allow improvements to be made to the Service’s functioning (e.g. optimizing the User experience; adding new functionality, etc.)

Displaying of personalized reading and friend suggestions and the displaying of sponsored reading suggestions, based on the User’s marketing profile.

Such processing is undertaken on the basis of F-451’s legitimate interests to personalize the reading and friend suggestions according to various personal aspects of Users (type of books registered in their libraries, book records added to the Wishlist, digitally-enhanced books, etc.).

This profiling has the consequence of displaying personalized reading and friend suggestions for each User and also allows third-party companies wishing to increase their visibility and their works among Users to display sponsored reading suggestions.

The sending of a communications and newsletter to Users by email or by cellphone messaging.

This processing is implemented on the basis of F-451’s legitimate interests in offering newsletters. The User may object to receiving such newsletters while creating his account and at any time by using the unsubscribe link at the foot of the email page.

Targeted advertising on social media

This processing is implemented on the basis of F-451’s legitimate interests to recruit new Users or encourage Users to re-connect. The User may object to this targeted advertising using the settings for his social media or by writing to dpo@gleeph.net.

The sending of Users’ review to partner platforms.

This processing consists in allowing the diffusion outside the Application by F-451 and the sharing outside the Application, in particular by sms, email, via social networks and any other means of sharing and diffusion that F-451 may implement, of the opinions, shelves, profile, book cards and other contents of the Users that may show their profile photographs and pseudonyms. This processing is implemented on the basis of the legitimate interest of F-451 to

- constitute a database of online content (reviews, shelves, book cards,...) accessible to third parties outside the Application,

- and to provide Users with the possibility to share their contents (reviews, shelves, profile, book cards,...), outside the Application.

PROCESSED PERSONAL DATA

Personal data communicated by the User:

Data relating to identity.

Registering for Services requires the mandatory sending of the following information: pseudonym and email address.

The User undertakes to verify that the email address used is valid in order to allow communications with F-451.

The User may also record his surname, first name, photo and date of birth.

The data collected via Facebook during User registration via his Facebook account:

Facebook login details, email address, nickname or, by default, surname and first name used on Facebook, profile photo.

Data collected via Apple during User registration via his Apple ID account:

Surname, first name, email address (if authorized by the User)

Messages sent by the User to Gleeph via the Application or to dpo@gleeph.net

Personal Data processed during the User’s usage of the Application:

Data relating to Libraries.

The booklist forming part of every User’s Library is recorded. This data is made visible to other Users according to the Privacy criteria chosen by the User for his settings.

Data relating to location.

The Application allows the User to find any given book at an independent bookstore. To do this, the User’s location is used. Authorization is requested from the User to use geolocation data.
The Application allows the User to find other Users around him with whom he may have common interests. To do so, the approximate location of the User is utilized, as well as those of the third-party Users concerned. The historic location data is saved. This data is made visible to other Users according to the Privacy criteria chosen by the User for his settings.

At any time, the User may decide to deactivate location-based functionalities by altering the settings on his device.

Data relating to private discussions.

Private discussions between Users are saved by F-451. These discussions are only visible to Users taking part in the particular discussion thread.

Data relating to the User’s device:

For the Application’s functioning requirements, F-451 collects and stores data relating to the User’s device: operating system used, device version, one telephone identifier (according to the device’s configuration).

Log files

When the User utilizes the Application, the requests generated by the Application are stored in the logfiles of F-451’s servers (User’s device IP address, time of the request, request’s URL, service requested).

RECIPIENTS OF PERSONAL DATA

F-451 is likely to send the User’s notes regarding any book (User’s pseudonym, photo and note) to partners for publishing of these notes on partners’ own platforms.

F-451 may be caused to divulge Personal data, in the case when it is compelled to do so in the context of legal or fiscal procedures by public authorities or in the context of a transfer, such as defined in the General Conditions Of Use. The new acquirer is then bound by the same rights and obligations as F-451.

Furthermore, Personal Data may be sent or collected by F-451’s service providers for the purposes described in the paragraph “Purposes”.

F-451’s service providers acting as sub-processors in the sense of the General Data Protection Regulation are as follows:

Hosting of data
Making available of a tool allowing the creation of links within the cellphone application
Making available of Facebook Connect
Making available of a promotional and traffic measuring tool
Making available of a Customer Services management tool
Web marketing execution activities
Making available of reporting and marketing analysis tools

DATA RETENTION PERIOD:

F-451 retains the User’s data for as long as the latter has an Account.

The User may, at any time, request the deletion of his account in the “My Settings” tab in the Application or by sending a request to dpo@gleeph.net. From the time of the User’s request, F-451 shall use its best endeavors to delete the User Account as soon as possible.

Once the User Account has not registered any activity for 3 years, the User shall receive an email indicating that, due to a lack of activity on his part, the account shall be deleted within a timescale of 6 months.

A User’s location data are kept for a period of 6 months.

LEGAL RIGHTS OF PERSONS

General rights

The User enjoys a right of access, correction, deletion and portability of Personal Data affecting him.

He may also object to processing of his Personal Data or request limits on them and draft advance directives on what happens to his data after his death. To exercise such rights, Users are invited to address their requests:

by mail to the address GLEEPH Customer Relations – F-451 – 1 rue Alexander Fleming, 17000 LA ROCHELLE;
or by email to the following address: dpo@gleeph.net.

A reply shall be sent to the User within a period of 1 month from exercising that right. In certain cases, linked with the complexity of the request and the number of requests, this timescale could extend to 2 months.

Rights to access, rectification, objection, limitation, removal and portability of Personal Data arising from the User’s Facebook Account must be taken up with Facebook.

Objection to profiling

The User may object to personalized friend and reading suggestions by using the address dpo@gleeph.net

By opting out of the profile allowing reading Recommendations on the Application, the User shall receive no further reading suggestions.

The User can also object to sponsored reading suggestions by using the address dpo@gleeph.net.

By opting out of the profiling allowing sponsored reading suggestions, sponsored reading suggestions displayed on the Application shall no longer be based on the User’s profile and will be less relevant.

COMPLAINTS

The User enjoys the right of making a complaint to the French National Commission for Data
Protection and Liberties (CNIL). For more information, the User may consult the CNIL website by following this link https://www.cnil.fr/en/home

PERSONAL DATA TRANSFER OUTSIDE THE EUROPEAN UNION

The User is informed that his Personal Data may be sent for the requirements of those purposes defined above to companies located in countries outside the European Union and whose legislation does not possess an adequate level of protection relating to the protection of Personal Data.

Prior to transfer outside the European Union, and in compliance with those regulations in force, F-451 implements all the required procedures to obtain those guarantees necessary for the security of such transfers.

Transfers outside the European Union may be carried out, especially in the context of activities carried on by those Service Providers listed above.

Transfers carried out by F-451 are as follows:

Countries of intended destination for the data	Framework of data transfer
United States	Standard contractual clauses
Australia	Standard contractual clauses

MANAGEMENT OF COOKIES, TAGS AND OTHER TRACERS

During use of the Application, information relating to its navigation and usage with the Smartphone are likely to be collected.

The term “Cookie” embraces several technologies allowing monitoring of navigation or a behavioral analysis of the User. These technologies are manifold and undergo constant change. There exist, in particular, Cookies, tags, pixels, JavaScript or SDK code.

There exist two types of Cookies:

first-party Cookies, deposited by F-451;
third-party Cookies, deposited by third-party partner companies. Third-party Cookies are directly managed by the companies that publish them and who must also observe data protection regulations.

Cookies that F-451 deposits from the website and the cellphone application allow:

the compilation of statistics and traffic volumes and usage of the various elements comprising the Service.
adaptation of the Application’s presentation according to the affinities of each User;
sharing of information on social media. In this regard, we use Cookies to permit sharing on such media.

The User may configure the Cookies in use according to the following methods:

Configuration of your Smartphone’s operating system

The User may control the depositing of Cookies on his Smartphone according to his operating system’s rules.

On iOS: https://support.apple.com/en-us/HT201265
On Android : https://support.google.com/chrome/answer/95589?hl=en&ref_topic=7438325

Opting-out of Cookies directly on the publisher’s site

The User may deactivate session-based cookies by going directly to the website of each publisher:

Branch: https://branch.app.link/optout
Leanplum: https://www.leanplum.com/privacy/
Facebook: https://fr-fr.facebook.com/policies/cookies/

DATA PROTECTION OFFICER

The Data Protection Officer nominated by F-451 has the task of ensuring observance of those rules and regulations described in this document.

He particularly ensures the establishment of a data processing register for personal data processed in the company and satisfies himself about the compliance of the latter with regulations and their evolution.

He ensures the periodic aware-raising among the teams and replies to Users wishing to exercise their rights in relation to Personal Data collected by F-451.

The Data Protection Officer may be contacted via the following:

Email: dpo@gleeph.net
Telephone: 09.67.67.22.21