This privacy policy governs the processing of personal data carried out by POE&ME, a simplified joint-stock company (société par actions simplifiée) with a share capital of €12,000, registered with the Paris Trade and Companies Register under number 944 437 466, with its registered office at 61 rue de Lyon, 75012 Paris ("POE&ME" or "we"), in connection with the use of the platform (the "Platform") accessible via the "Loëly" application (the "Application"), available for download on online application stores, and on the website accessible at loely.io (the "Website").
POE&ME may process the personal data of any individual who accesses the Platform (the "User" or "you"), regardless of the conditions under which they do so.
Capitalised terms are defined in the Platform's General Terms of Use or in the General Data Protection Regulation EU 2016/679 (the "GDPR").
This privacy policy informs you of the manner in which we collect and process personal data concerning you. We invite you to read it carefully.
Why do we collect your data?
The processing of certain personal data is necessary for the provision of the Service on the Platform, in particular to:
- Create a User Account;
- Respond to your contact requests;
- Keep you informed of services and content that may be of interest to you;
- Conduct surveys and satisfaction studies to better understand your expectations and needs, and thereby improve the Service;
- Finance the Platform through the display of advertisements and measure their performance, including through third-party advertising partners integrated into the Application.
On what legal basis?
We only process your personal data in cases provided for by applicable regulations.
The processing of data you provide when creating a User Account or completing the contact form on the Platform is necessary to act on your requests. This processing is based on the performance of pre-contractual measures at your request (Article 6(1)(b) GDPR). Without this processing, we would not be able to create your User Account or respond to your questions.
These data may be used by POE&ME and its subcontractors to contact you in order to keep you informed of services and content that may be of interest to you, on the basis of its legitimate interest in communicating about its activities (Article 6(1)(f) GDPR), and for survey and research purposes, on the basis of its legitimate interest in improving its services (Article 6(1)(f) GDPR). You may object to these processing activities based on legitimate interest at any time, in accordance with Article 21 GDPR.
Where the Platform displays personalised advertisements or advertisements that may involve advertising profiling, certain data (including advertising identifiers and usage data) may be processed by a third-party advertising network. This processing is based on the User's prior consent, collected via a consent management module in accordance with applicable regulations (Article 6(1)(a) GDPR). The User may withdraw their consent at any time from the Application settings or via the settings of their device.
Who is responsible for this processing?
When the User accesses the Platform via the Website, POE&ME acts as data controller.
When the User accesses the Platform via the Application, certain processing of personal data may be carried out directly by the relevant store publisher, acting as a separate data controller, in accordance with its own privacy policy.
In addition, where the Platform integrates services provided by third-party partners (in particular for advertising purposes), these partners may process certain data as separate data controllers, in accordance with their own privacy policies. This is notably the case for Google AdMob, an advertising service operated by Google LLC, for processing carried out for advertising purposes.
What data do we collect, and in what circumstances?
We collect different categories of personal data about you.
Identity data (such as username, date of birth, country of residence), contact data (such as email address) and Platform usage data (such as reading language, reading time, reading lists, likes) are collected when you create a User Account or submit a request via our contact form.
When you subscribe to a Subscription, we also collect payment data, such as the banking information necessary for processing and managing payments, where applicable through our payment service providers. POE&ME does not have access to complete banking details and does not store them. If you subscribed to the Service via the Application, these data will be processed by the payment service providers or by the relevant online application store publisher.
When advertisements are displayed within the Platform, additional technical data may also be collected (such as the device's advertising identifier, IP address, device-related data (model, operating system, language), and data relating to interactions with advertisements). These data are collected via advertising technologies integrated into the Application and are processed by a third-party advertising network, in particular Google AdMob, an advertising service operated by Google LLC, in order to display, personalise and measure the performance of advertisements. In this context, Google LLC acts as a separate data controller for processing carried out for advertising purposes, in accordance with its own privacy policy.
Who may have access to the data we collect?
Our teams and technical service providers are recipients of this personal data, solely to the extent necessary for the performance of their duties and compatible with the purposes set out above.
The personal data collected in connection with the use of the Platform is intended for:
- Our authorised internal teams (user support, technical and administrative management);
- Our hosting and technical maintenance providers, acting as subcontractors and solely on our instructions;
- Our audience measurement providers;
- Our payment service providers, for the processing of transactions and management of subscriptions;
- Where applicable, third-party advertising networks involved in the display of advertisements within the Platform, in particular Google AdMob, an advertising service operated by Google LLC.
These recipients only access data strictly necessary for the performance of their duties and are subject to contractual obligations of confidentiality and data protection in accordance with the GDPR.
Is your data transferred outside the European Union?
Your personal data is hosted on servers located within the European Union.
The transfer of your data from POE&ME to its service providers, who may in turn share it with their own subcontractors in order to provide their services to POE&ME, may involve the transfer of your data to third countries outside the European Union or to international organisations.
Such transfers are governed by the implementation of appropriate safeguards adapted to the level of adequacy of the recipient country with European standards for personal data protection, in accordance with Articles 45 et seq. of the GDPR. You may contact us for further information on this subject and to obtain a copy of the safeguards put in place.
How long do we retain your data?
POE&ME adheres to the principles of data minimisation and storage limitation and therefore undertakes not to retain your personal data beyond the period necessary for the purposes pursued and, in any event, beyond a period of 3 years from the last contact received from the User or the end of the contractual relationship, whichever is the later, unless a longer retention period is required by applicable laws and regulations.
Upon expiry of these periods, POE&ME undertakes to delete your personal data.
The retention periods applicable to processing carried out by advertising partners and payment service providers acting as separate data controllers are governed by their own privacy policies.
How do we ensure the security of your data?
As data controller, we implement appropriate technical and organisational measures to protect your personal data, in accordance with applicable legal and regulatory requirements, including securing access to our systems, raising awareness among individuals with access to such systems of confidentiality requirements, and exercising diligence in the selection of our subcontractors.
We also ensure that our service providers implement appropriate measures to protect the personal data concerning you that they process on behalf of POE&ME.
What are your rights?
In accordance with applicable data protection legislation, you have the following rights:
- The right to information about the processing of your personal data;
- The right of access to your personal data;
- The right to rectification of your personal data;
- The right to object to the collection and processing of your personal data;
- The right to withdraw your consent, where processing is based on your consent, it being noted that the lawfulness of processing carried out prior to withdrawal is not affected by such withdrawal;
- The right to erasure of your personal data;
- The right to restriction of the collection and processing of your personal data;
- The right to portability of your personal data.
To exercise your rights, you may contact POE&ME at the following address: contact@loely.io.
If you receive no response or are not satisfied with the response provided, you have the right to lodge a complaint with the competent supervisory authority. In France, this is the Commission Nationale de l'Informatique et des Libertés (CNIL). If you are located in another EU member state, you may also contact the supervisory authority of your country of residence.
Cookies, trackers and similar technologies
Cookies are pieces of information transferred from a web server or third-party web servers to your browser, where they are stored for later retrieval. Cookies may be small files or other information storage tools. The information stored in cookies is linked to the specific end device used. Cookies contain a specific string of characters that allows the browser to be uniquely identified upon a subsequent visit to the Platform. A cookie also contains information about its origin and storage period. However, this does not mean that we have immediate knowledge of your identity.
When you use the Application, technologies similar to cookies (such as SDKs or application identifiers) may be used to ensure the proper functioning of the Application and to measure its usage. Such processing is subject to the rules applicable to mobile applications and, where applicable, to your consent via the mechanisms offered by your device's operating system.
These technologies are subject to your prior consent where such consent is required.
POE&ME uses essential technical cookies in order to ensure the proper functioning of the Platform and the provision of the Service, and to optimise your browsing experience. This processing is based on POE&ME's legitimate interest in ensuring the proper functioning of the Platform and the provision of the Service (Article 6(1)(f) GDPR).
The lifespan of cookies is limited to what is necessary to achieve the aforementioned purposes and does not exceed 13 months.
You may choose at any time to disable some or all of these cookies by modifying your browser settings. Please note that when all cookies are disabled, including the technical cookies necessary for the Platform to function, certain features of the Platform may not function correctly.