PRIVACY

The company LiveHappier, which operates the SquadEasy services (hereinafter "SquadEasy" or "LiveHappier" or "we"), SAS, a simplified joint-stock company with a capital of €17,447.50, headquartered at 157 boulevard MacDonald, 75019 Paris, registered with the Paris Trade and Companies Register under number 808 330 377 and having the intra-community VAT number FR 67 808330377.

- Site and application manager: SquadEasy represented by its current President Brice Chapignac
- Publication Director: SquadEasy represented by its current President Brice Chapignac
- Data Protection Officer (DPO): SquadEasy represented by its current Product Manager Benoît Keirle
- Host of the website and application content:
  - This site is hosted in Europe, in France on servers of the company Amazon Web Services (AWS):
  - Amazon Web Services Inc.
  - 410 Terry Avenue North,
  - Seattle, WA 98109-5210, USA
  - http://aws.amazon.com
  - And by AMAZON WEB SERVICES EMEA SARL
  - 831 001 334 RCS NANTERRE
  - 31 PL DES COROLLES 92400 COURBEVOIE

For more information, contact: dpo@squadeasy.com

CONFIDENTIALITY OF PERSONAL DATA

LiveHappier SAS is subject to the applicable rules regarding the protection of personal data, in particular, the General Data Protection Regulation No. 2016/679 of April 27, 2016 (GDPR), as well as all national rules enacted in application thereof, subsidiarily.

The purpose of this Privacy Policy is to inform in a clear, simple, and comprehensive manner all concerned individuals ("You" or "Your") about how LiveHappier, as the data controller, collects and uses personal data concerning You ("Personal Data") and the means You have to control this use and exercise Your related rights.

This privacy policy deals with personal data collected through the websites "squadeasy.com" or the mobile application "SquadEasy".

Consent

By signing up for our services via the mobile application or the website https://www.squadeasy.com/ or other websites owned by the SquadEasy service, you agree and accept that we may collect, process, store, and/or use the personal data submitted in accordance with the rules outlined below.

By giving us your consent, you also have the right to rectification, the right of access, the right to be forgotten and/or the right to deletion of your personal data, the right to portability, the right to limit processing, as well as the right to decide the fate of your data after death.

Article 1: WHAT PERSONAL DATA MAY BE COLLECTED?

The SquadEasy services collect information about you, including identifiable personal information, if you choose to share it with the SquadEasy services, if you register an account, or if you follow, complete, or download activities using the SquadEasy services. The SquadEasy services also collect information about how you use them. This information includes, as a mandatory requirement, your first name, last name, email address, and password, optionally gender, country, equipment usage, activities, routes (including information on date, time, and geographic location, as well as your speed and pace), IP address, your profile picture, and other images you provide on the chat, social wall, team photo, activity sharing, publication of any kind on our platform.

If you choose to use location-based features through the SquadEasy services, we will collect the geographic location of your device. The SquadEasy services may also collect and upload data from your device, such as speed and direction. You have the option to disable our use of certain location data via your device or browser settings by disabling "Location Services".

Third-party services

The SquadEasy services allow you to register and log in to the SquadEasy services via accounts you create from third-party products and services such as Facebook or Google (collectively, "Third-party Accounts"). These Third-party Accounts may ask for your permission to share certain information from your Third-party Account with SquadEasy. We use this information to verify your identity and provide you with features of our products and services. This information may include your first name, last name, email address, profile information, and preferences with the relevant Third-party Account. This information is collected by the Third-party Account provider and provided to the SquadEasy services as part of its privacy policy. You can generally control the information we receive from these sources through privacy settings in your Third-party Account.

Article 2: WHO COLLECTS YOUR PERSONAL DATA?

When you fill out a form on the mobile application "SquadEasy" or on the websites with the domain name "squadeasy.com", you expressly agree that your personal data may be collected by or on behalf of LiveHappier.

Article 3: LEGAL BASIS AND PROCESSING OF YOUR PERSONAL DATA

By submitting a form request on the mobile application "SquadEasy" or on the websites with the domain name "squadeasy.com", you expressly give us your consent to process your personal data in order to provide you with services or support as offered on the site.

The processing of your personal data being based on your consent, you have the right to withdraw your consent at any time.

We use all the information we have to help us operate, provide, improve, understand, customize, support, and market our Services.

We operate and provide our services, which includes providing user support and improving, fixing, and customizing our services. We understand how people use our services, and we analyze and use the information we have to evaluate and improve our services, research, develop, and test new services and features, and troubleshoot activities. We also use your information to respond to you when you contact us.

The SquadEasy services collect the information you provide to us. You can also upload location-based activities to the SquadEasy services, such as a run or a route. You can join challenges, contests, and communicate with other members. You can also provide additional personal information.

The SquadEasy services also collect various technical information, including information about location, devices, and networks, as well as cookies, log files, and analytics services.

On the website "squadeasy.com", we use cookies to operate, provide, improve, understand, and customize our services.

Article 4: PURPOSE OF PROCESSING

The main purpose of collecting your personal data is to offer you a connected, social, and playful physical activity experience that is safe, optimal, efficient, and personalized. To this end, you agree that we may use your personal data to:

- Provide our services and facilitate their operation, including by conducting checks on you;
- Solve any problems in order to improve the use of our site and services;
- Customize, evaluate, and improve our services, content, and documentation;
- Analyze the volume and history of your use of our services;
- Inform you about our services and those of our partner companies if you have authorized to receive our newsletter on SquadEasy and if your company has expressly authorized us to do so on the SquadEasy enterprise version;
- Prevent, detect, and investigate any potentially prohibited and illegal activities or activities contrary to good practices, and ensure compliance with our terms of use and our sending policy;
- Comply with our legal obligations;
- Enforce our rights and take any action in connection with disputes and compliance with our terms of use.

Article 5: PROTECTION AND STORAGE OF PERSONAL DATA

We take technical and organizational security measures to protect your personal data against accidental or intentional manipulation, loss, destruction, or against access by unauthorized persons. Our security measures are continuously improved in line with technological developments.

Your personal data is stored on secure servers within the European Union. We ensure that your personal data is processed in a way that guarantees its confidentiality, integrity, and availability.

Article 6: SHARING OF YOUR PERSONAL DATA

We may share your personal data with our service providers and partners, and for legal or safety reasons. We may also share aggregated and/or anonymized data with others for their own uses.

Your personal data may be shared with:

- Subsidiaries and affiliated companies;
- Service providers who perform services on our behalf;
- Other third parties as required by law or to protect SquadEasy and our users;
- Corporate affiliates for internal administrative purposes.

We may also share aggregated and/or anonymized data with others for their own uses.

Article 7: TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN UNION

Your personal data may be transferred to countries located outside the European Union for the purposes described in this privacy policy. We ensure that appropriate safeguards are in place to protect your personal data, in particular through the use of standard contractual clauses adopted by the European Commission.

Article 8: RETENTION PERIOD OF PERSONAL DATA

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, to provide our services, to resolve disputes, to enforce our rights, and to comply with legal obligations.

We are committed to ensuring that your personal data is stored for a limited period of time in accordance with the data retention principles and rules.

Article 9: YOUR RIGHTS

In accordance with the regulations applicable to personal data, you have the following rights:

- Right of access: You have the right to access your personal data.
- Right of rectification: You have the right to rectify inaccurate personal data concerning you.
- Right of deletion: You have the right to request the deletion of your personal data.
- Right to limit processing: You have the right to request the limitation of the processing of your personal data.
- Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
- Right to object: You have the right to object to the processing of your personal data.

To exercise your rights or for any question regarding the processing of your personal data, you can contact us at the following address: dpo@squadeasy.com

Article 10: MODIFICATION OF THE PRIVACY POLICY

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

Article 11: APPLICABLE LAW AND JURISDICTION

This privacy policy is subject to French law. In the event of a dispute concerning the processing of your personal data, you have the right to lodge a complaint with the competent supervisory authority in France.

Article 12: CONTACT

For any questions concerning the processing of your personal data, you can contact our Data Protection Officer (DPO) at the following address: dpo@squadeasy.com

 

or by postal mail at the address below:

LiveHappier

The Cargo

157 Boulevard Macdonald

75019 Paris

Before evaluating your request, we may ask you for additional information to identify you. If you do not provide the requested information and, consequently, we are unable to identify you, we may refuse to proceed with your request.