Privacy Policy

This Privacy Policy is intended to inform users of the DATA FIGHT CLUB application (hereinafter referred to as "the Application") concerning the processing of personal data set up by the company REPUTATION SQUAD (hereinafter referred to as "the Editor') via the Application.

Any user of the Application must be aware of the conditions set out below.

Thus, it is specified that any user using the Application is deemed to have read this Privacy Policy and to have accepted it, during each of his visits, the Editor reserving the right to modify it at any time, in particular in order to take into account changes of the legal and regulatory context applicable in this area.

Personal Data process

This Privacy Policy applies to the processing of personal data carried out in the context of activities on the territory of the European Union; therefore, this policy and these processing operations are subject to the application of Regulation No. 2016/679 known as the "General Data Protection Regulation" (hereinafter referred to as "the GDPR").

1. Definitions

"Personal data": any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); is deemed to be an "identifiable natural person" a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more specific elements specific to its physical, physiological, genetic, psychological, economic, cultural or social identity;
"Processing": any operation or set of operations carried out or not using automated processes and applied to data or sets of personal data, such as collection, recording, organization, structuring, conservation, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, reconciliation or interconnection, limitation, erasure or destruction;
"Controller": the natural or legal person, public authority, service or other body which, alone or jointly with others, determines the purposes and means of processing; when the purposes and means of such processing are determined by European Union law or the law of a Member State, the Controller may be designated or the specific criteria applicable to his appointment may be provided for by the law of the European Union or by the law of a Member State;
"Processor": the natural or legal person, public authority or department which processes personal data on behalf of the Controller.

2. Controller and processor

REPUTATION SQUAD, the Editor, which edited the Application, is the data Controller.

All legal information concerning the Editor is indicated in the Legal Notice of the Application.

3. Principles relating to the processing of data by the Editor

In order to safeguard the privacy of users, and in order to offer them an optimum experience, the Editor accesses two hundred (200) Tweets from the Twitter account submitted to him, in order to process and analyze them. Of course, the vast majority of this data will not be recorded by the Editor, who will only keep the name and account ID, as indicated below.

3.1. Principles of proportionality and data minimization

Personal data collected through the Application will be used exclusively for the pursuit of the purposes set out below.

In addition, for each of the processing operations carried out, the Editor undertakes to collect and process only the data strictly necessary for the accomplishment of the objective pursued.

3.2. Principles of loyalty and transparency

For the sake of loyalty and transparency with users of the Application, the Editor takes care to inform the persons concerned of each of the processing operations carried out by means of information inserted directly on the interface of the Application when collecting data.

This data is collected fairly: no data is collected without the consent of the persons concerned, and without a clear information.

3.3. Principle of "Privacy by Design"

The Editor is committed to taking and implementing measures to protect the confidentiality of data and the privacy of users by default, and from the beginning of the project to develop the Application.

This principle has remained of major importance for the Editor when selecting and using applications, services and products that involve the processing of personal data.

4. Implementation of data processing by the Editor

4.1. Legal basis for data processing

In accordance with the provisions of article 6 of the GDPR, the processing carried out on personal data collected via the Application is justified by the consent given by each of the users of the Application for their data to be processed for the purposes set out below.

In certain cases, data may be processed or stored by the Editor for the purpose of pursuing a legitimate interest within the meaning of Articles 6-1 c) and 6-1 f) of the GDPR,

4.2. Purposes of data processing

Personal data is processed by the Editor via the Application for the following purposes:

Provide a personal social network account analysis service through the Application;
For the purpose of statistical analysis of data;
Respond to user requests as part of their use of the service;
Provide news and updates about the product.

Where applicable, personal data could be processed by the Editor for the following purposes:

Respond to requests from administrative or judicial authorities empowered for this purpose;
Comply with the regulations applicable to the activity of the Editor;
Manage any legal or extra-judicial dispute and establish the evidence necessary to defend the rights of the Editor and, where applicable, the users.

4.3. Nature of data processed

The personal data processed by the Editor via the Application may be the following:

User email (if user has subscribed to the newsletter);
Username;
User first name;
Twitter ID of the user;
Twitter profile pic URL;
Name of the user's Twitter account;
Last 400 tweets of users Twitter account (deleted instantly after each fight);
Data relating to the performance of the user's Twitter account (eg number of Tweets, etc.);
Content of a message sent by the user to the Editor via the Application.

Nature of data processing

The user accepts that the Editor, in order to provide the requested service, processes the user's personal data as follows:

Access to the user's personal data;
Registration of the username and name of the user's Twitter account exclusively.

It is specified that other data relating to the analysis of the performance of the user's Twitter account will be kept by the Editor for statistical analysis purposes, and possibly in order to classify users subsequently; this recorded data will be anonymized by the Editor.

4.5. Persons concerned

The persons concerned by the processing carried out by the Editor are the users of the Application.

4.6. Data recipients

In addition to the Editor, the data may be transmitted to technical service providers whose mission is to help the Editor to fulfil its obligations.

The data host, whose identity is set out in the Legal Notice of the Application, is one of these recipients, and it is emphasized that the user is deemed to accept the sharing of his data with this contributor as soon as he uses the Application.

In any case, the sharing of personal data with the recipients is carried out:

Only for exceptional cases requiring subcontracting;
Within the limits of the pursuit of the purposes stated above;
While recipients have been selected on the basis of their ability to comply with GDPR requirements;
While all the means necessary for data backup and protection have been implemented beforehand.

4.7. Data transfer outside the European Union

Personal data processed by the Editor is not transferred outside the European Union.

4.8. Data retention period

The Editor keeps the personal data it collects only for the time necessary to pursue the processing purposes set out above, and in accordance with applicable regulations.

4.9. Data security

The Editor attaches particular importance to the security of personal data processed on behalf of its customers.

It has implemented technical and organizational measures adapted to the degree of sensitivity of the personal data processed, in order to ensure their integrity and confidentiality and to protect them against any malicious intrusion, any loss, alteration or disclosure to unauthorized third parties.

As such, the Editor has taken measures to:

Guarantee a level of security adapted to the risks;
That only its agents having an interest in processing the data can do so (internal partitioning by cells);
Ensure that any natural person who has access to the data only processes it on the instructions of the Controller.

To this end, the Editor has:

Established security devices within its premises;
Installed of access badge doors;
Installed of surveillance cameras in the premises;
Implemented measures to secure paper media (constitution and storage of sensitive files in key cabinets, etc.);
Implemented measures to secure IT media: setting up complex passwords, back-up data, archives (accompanied by reliable restoration procedures), monitoring the deactivation of accounts following the departure of employees, etc.
Implemented security measures intended to ensure the security of external exchanges (protection of the network, etc.);
Contracted insurance contracts for various IT risks;

4.10. Rights of data subjects

Under the applicable regulations, each of the data subjects has the following rights:

Right to access their data;
Right to rectify data;
Right to erasure of their data (unless they are necessary for the performance of a service or the pursuit of a legitimate interest of the Editor);
Right to data portability;
Right to define directives relating to the fate of his data after death, with the Controller or with a trusted third party, certified and responsible for ensuring that his wishes are respected.

It is emphasized that each of the data processed being strictly necessary for the provision of the service of the Application, the persons concerned may not exercise their right to oppose or limit the processing during the collection of data, except to waive benefit from said service.

The rights of the persons concerned are exercised by contacting the Editor by post or e-mail at the following addresses:

REPUTATION SQUAD - 43 rue Beaubourg - 75003 PARIS
contact@reputationsquad.com

4.11. Complaint with a supervisory authority

Any data subject may, if they consider it legitimate, lodge a complaint with a supervisory authority for the processing of personal data.

In France, this supervisory authority is the Commission Nationale de l'Informatique et des Libertés located at 3 place de Fontenoy - TSA 80715 - 75334 Paris cedex 07; phone: +331 53 73 22 22.

Cookies & trackers

Cookies are small files that can be set on your computer or on the device you use when you visit a website; they are generally used to make websites work or improve their operation. In particular, they allow sites to recognize your device and record information relating to your browsing.

On the date of your consultation of this Privacy Policy, some cookies have been placed or used in any way through the Application by the Editor:

Google Analytics

When you browse the Application, an information banner appears to warn you of the use of these cookies.

You are informed that you can oppose the use of these cookies by clicking on the tab of the banner provided for this purpose.

In the event of a change in this matter, the Editor will first modify this Privacy Policy in order to inform the users.

Applicable law

The Application, its content and its use are subject to the application of French law.