PRIVACY POLICY

Updated : 12/16/2021

Preamble

This Privacy Policy is intended for users of the BETTER & STRONGER Platform, available at https://www.better-stronger.com/ (hereinafter "the Platform") and is intended to inform them as to how their personal information may be collected and processed.

Respect for privacy and personal data is a priority for BETTER & STRONGER, which is why we are committed to processing them in strict compliance with the French Computing and Civil Liberties Act of January 6, 1978 (hereinafter the “CCL Act”) as modified and the EU General Data Protection Regulation of April 27, 2016 (hereinafter the “GDPR”).

Under all circumstances, we will comply with these two basic principles:

• You remain in control of your Personal Data;
• Your Data will be processed in a secure manner with transparency and confidentiality.

2. Definitions

• « Data » : means personal data subject to processing under this Privacy Policy.
  
  
• « Personal Data » : means any information relating to an identified or identifiable natural person, as defined by article 4 (1) of the GDPR.
   
• « General data protection regulation » or « GDPR » : refers to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC. 
  
  
• « Processing » : means any operation or set of operations which is performed on Personal Data or on sets of Personal Data as referred to in article 4 (2) of the GDPR, in the context of this Privacy Policy. 
  
  
• « Plateform » : means the Internet Platform accessible at the following address: https://www.better-stronger.com/ The Platform includes all the web pages, Services and functionalities provided to Users. 
  
  

« User » : means any person who accesses and browses the Platform https://www.better-stronger.com/.

2. The Controller’s identity

BETTER & STRONGER, a simplified joint-stock company with a share capital of 270.000 € registered at the Trade Register of Lyon under number 529 770 372, having its registered office at 7, Place du Griffon, 69001 Lyon, France, managed by Simon Neouze (hereinafter BETTER & STRONGER) will act as Controller for all data Processing listed in article 5 hereinafter. 

3. Data collection & Origin 

As part of operating the Platform, BETTER & STRONGER is likely to collect Personal Data regarding the Users of said Platform.

In any case, you are informed of the reasons why we collect your data via online data collection forms, email or notifications on the Platform. 

4. Consent

In compliance with the principles of privacy by design and privacy by default, BETTER & STRONGER makes sure that the User’s consent is collected in accordance with the principles of privacy by design and privacy by default when BETTER & STRONGER collects personal data communicated via any contact form published on the Platform. 

5. Purposes and legal basis for data processing 

BETTER & STRONGER only collects the necessary data for the purposes explicitly identified below: 

• Management of contact and information claims 

• Sending of newsletters and marketing messages

• Managing of claims to rights granted by the data protection regulation 

• The proper functioning and continuous improvement of the Platform and its features

6. Recipients

As part of their respective responsibilities and for the purposes iterated in Article 5, the key persons who may have access to your data are the following:

• Authorized personnel at BETTER & STRONGER;

• Providers in charge of management and hosting of the Platform and the BETTER & STRONGER IT system; 
• If applicable, the authorized personnel of our processors; 
• If applicable, the relevant jurisdictions, mediators, accountants, auditors, attorneys, bailiffs, debt collection companies, police or military authorities in case of theft or judicial requisition;
• Third parties likely to deposit cookies on your devices when you give your consent.

Your data is not shared, exchanged, sold or loaned to anyone other than those mentioned above. 

7. Data retention period 

We only retain your Personal Data for as long as is necessary for the purposes listed in article 5. 

For information purposes, please click below for more detail on the legal retention periods. 

More information

8. Your rights

Pursuant to the French Computing and Civil Liberties Act and the GDPR, you have the following rights (for more information):

• A right to access (article 15 GDPR), rectify (article 16 GDPR), update and complete your data; 
• A right to lock or erase your personal data (article 17 GDPR), if it is inaccurate, incomplete, dubious, obsolete or is prohibited from being collected, used, shared or retained; 
• A right to withdraw your consent at any time (article 7 GDPR); 
• A right to restrict the processing of your data (article 18 GDPR); 
• A right to object to the processing of your data (article 21 GDPR); 
• A right of portability of the data you have provided us when your data has undergone automated processing based on your consent or a contract (article 20 GDPR); 
• Right to not be subject to a decision based exclusively on automated processing (article 22 du RGPD); 
• Right to file a complaint with the CNIL (article 77 RGPD);
• A right to determine what happens to your data after your death and to choose whether we should send your data to a third party whom you designate (article 85 LIL). In the event of death, and in the absence of any instructions from you, we undertake to destroy your data unless it proves necessary to retain it for evidentiary purposes or to comply with a legal requirement.

You may exercise your rights:

• By emailing the following address: support@better-stronger.com 
• By mailing a letter to: 7 place du Griffon - 69001 Lyon

You can also file a claim with the supervisory authorities, specifically the CNIL or any other competent authority. 

9. Security

BETTER & STRONGER and any processor shall implement appropriate technical and organizational measures to ensure the security of the processing and confidentiality of the personal data, according to current technical means and in accordance with the CCL Act and the GDPR. 

BETTER & STRONGER takes the necessary precautions, with regard to the nature of your data and the risks of our processing, to safeguard the security of personal data, and specifically prevent it from being altered, damaged, or that unauthorized third parties have access to it (physical protection of the premises, authentication process of our clients with personal and protected access via usernames and passwords, logging and tracking login sessions…).

10. Transferring data outside the EU 

BETTER & STRONGER will not transfer Users’ data outside the European Union. 

In the event that BETTER & STRONGER should do so, Users will be informed of the measures taken to control such transfer and to ensure the confidentiality of their data. 

11. Login data and cookies

For the proper functioning of the Platform, we use login data (date, time, IP address, page viewed) and cookies (small files saved on your computer) in order to identify you, log your visits and gather visitor traffic analytics and statistics for the Platform, particularly with respect to the pages viewed.

In this regard, BETTER & STRONGER has drafted a Cookie Management Policy in order to inform you more specifically about their use. To learn more, you can also refer to the CNIL’s website by clicking on the following link:

https://www.cnil.fr/fr/cookies-et-traceurs-comment-mettre-mon-site-web-en-conformite.

12. Updating of our Privacy Policy

The present Privacy Policy may be subject to updates, in particular in accordance with the various legislative and regulatory changes. To this end, the User may consult the updates directly on the Platform.

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