Privacy Policy

Update to the Privacy Policy

We regularly update our Privacy Policy below (hereinafter referred to as the “Privacy Policy”).

Until an update of the Privacy Policy is published on our Site, the previous Privacy Policy remains applicable. Updates to the Privacy Policy will automatically take effect for all active users as of their publication on our Site. Continuing to use the SimplySurfers platform after updating the Privacy Policy is deemed to be an acceptance of the new Privacy Policy. Please read this Privacy Policy carefully. If you registered after the Privacy Policy has been updated, the updated Privacy Policy applies to your account.

Privacy Policy

Last updated: April 18, 2019

Translated from French

Please use SimplySurfers

Introduction

SimplySurfers makes a commitment to respect and to protect your private life thanks to the present Privacy policy (below the " Privacy policy "). We know that you grant(tune) a particular importance for the way your data are used and shared, that is why we exploit them in a reasonable and reasoned way. By using the Platform SimplySurfers (such as defined below), you accept the modalities of our Privacy policy.

Definitions:

The web site SimplySurfers and your use of this site, including its sub-domains and all other sites by means of which SimplySurfers supplies the SimplySurfers services are collectively called, the "Site".

Our applications for motives(mobiles), tablets and smartphones and the interfaces of application program are collectively called, the "Applications".

All the services associated to the Site and to the Applications are collectively called, "Services SimplySurfers".

The Site, the Application and the SimplySurfers services are collectively refered below by "Platform SimplySurfers", or “Marketplace”.

The term " SimplySurfers", "us", "our" or "ours" used in the present Privacy policy refers to the company Comonity France S.A.S., whose head office is in 55 avenue Marceau 75116 Paris, France, registered in the register of companies of Paris under the number 819.398.769 (below the “Company”).

The present Privacy policy describes the various personal information which we can collect or which you can pass on(transmit) us when you reach our Site, as well as the way we collect, use, store, protect and spread(broadcast) this information. These data allow us to know better our users and to improve their experience) on the continuous Site SimplySurfers.

The present Privacy policy is applicable to the collected information:

·                 On or from our Site;

·                 From your communications with SimplySurfers by e-mail, by seizure of form Typeform Typeform/GoogleForm or other type of form and electronic mail;

·                 When you create an account SimplySurfers;

·                 Or when you join our newsletters.

·                 The present Privacy policy does not apply to the collected information:

·                 By outstanding SimplySurfers or by other means, in particular by means of Web sites not managed by SimplySurfers or managed by third parties and,

·                 By any third party, including via applications or contents (including advertisements) redirecting the user towards the Site or accessible on or from the Site.

Please read the Privacy Policy carefully to clearly understand our practices regarding the processing of your personal data. If you do not accept our policies or practices, do not use our Site.

By consulting or using our Website, you agree to this Privacy Policy.

This Policy may be subject to change. After these changes, we consider that you accept the new Privacy Policy if you continue to use our Site. Please check the Privacy Policy regularly for updates.

1       Personal data collected by SimplySurfers and collection methods

We collect different types of user data, including information:

·                 That allow you to personally identify yourself as your name, postal address, e-mail address, telephone number, or any other information collected by our Site considered to be personal or to identify you according to the applicable law, or any other personal information allowing you to contact you (hereinafter collectively referred to as "personal information");

·                 That concern you, but do not allow you to identify yourself (example: the description you fill in in your profile and in your Seller ads);

·                 About your Internet connection, the equipment you use to access our site and other information about your use.

We collect this information (i) directly when you send it to us and/or (ii) automatically during your browsing on our Website. The information collected automatically may concern your use, your IP addresses and any other information collected using tracking technologies such as cookies.

2       The information you send to SimplySurfers

The information we collect on or through our Site includes the information you fill in forms on our Site (example: contact form, Seller approval form, etc.). This information includes the data entered when you register on our Site, in the forms you fill in, the submission of media or the request for additional services. We are also likely to ask you for more information when you report a problem on our Site: archives and copies of your exchanges (including e-mail addresses) If you have already contacted us and your responses to the surveys that we may send to you for information purposes.

You can also send us information intended for publication (hereinafter referred to as "published" information) on the pages of our Site in open access, or transmitted to other users of the Site or third parties (hereinafter collectively referred to as “User Contributions”). Your User Contributions are posted on our Site and transmitted to other users at your own risk. We cannot control the actions of other Site users with whom you share your User Contributions. Thus, we can under no circumstances guarantee that your User Contributions will not be accessed by unauthorized users.

To request the deletion of your User Contributions from our Site, please contact us at contact@simplysurfers.com. In some cases, we will not be able to delete said User Contributions. If so, we will inform you and explain the reason for the refusal.

3       Information collected using automated data collection technologies such as Google Analytics

During your browsing and interactions with our Site, we may use automated data collection technologies (such as Google Analytics) to collect information about your equipment and navigation habits, including:

o Data concerning your visits to our Site, including traffic data, log files and other data or communication resources that you use by accessing our Site;

o Information about your computer and internet connection, including your IP address, operating system and browser.

The information we collect automatically is statistical data and may include your personal data. We may record them or use them with other personal information that we collect using other methods or that is transmitted to us by third parties. This information helps us to improve our Site in order to offer you an optimized and personalized experience, in particular by:

·                 Estimating the size of our target audience and their navigation habits;

·                 accelerating your search;

·                 By automatically acknowledging you when you return to our Site.

The technologies we use to automatically collect this data include cookies (or browser cookies).

We cannot control third party tracking technologies or their use. If you have any questions about targeted advertising or other content, please contact the responsible provider directly.

4       Minors

Our Website is not intended for minors under thirteen (13) years of age, so we recommend that they do not enter any personal information on our Website. We do not deliberately collect any information from children under thirteen (13) without prior parental consent.

5       Use of personal data

We use the information collected or transmitted by you, including your personal data:

·                 To introduce you to our Site and its content;

·                 To offer you newsletters, products or services that you want to benefit from;

·                 For any other purpose for which you provide us with your data;

·                 To send you information about your account or subscriptions;

·                 To respect our rights and obligations under the contracts we have with you;

·                 To notify you of changes on our Site or in our offer of products and services;

·                 To allow you to use the interactive features of our Site;

·                 For any other detailed purpose when you send us your personal data or

·                 For any other legal purpose.

We may also contact you to suggest our products and services or products and services offered by third parties that may be of interest to you.

6       Disclosure of your personal data

We may reveal included data concerning our users as well as information with not personal character without limitations. We reserve the right to share, to lend, to rent, to sell or to reveal your information in third parties at any time, at any legal end, without advance notice nor compensation.

We may reveal the personal information which we collect or that you pass on us according to the capacities of the present Privacy policy:

·                 to subcontractors, service providers or other third parties used within the framework of our activity and forced by contractual obligations to respect the data privacy personal and to exploit them only in the purposes for which we pass on them;

·                 to our partners owners of the modules of payment which you use within the framework of payment of reservation on our Site, which case we can perceive a compensation;

·                 to a buyer or other successor in case of fusion, transfer, restructuring, reorganization, dissolution or other sale or transfer of a part or of all of the assets of SimplySurfers because of uncertainties or because of bankruptcy, liquidation or other processes in the frame of which the personal data of the users of the Site appear among the given up assets;

·                 for the end for which you pass on us your data or with your consent.

We may also reveal your personal information:

·                 to shape us to any legal mandate, any law or any legal process, including to the governmental and statutory demands;

·                 to execute or apply our conditions of use and other agreements, including, without limitation, for purposes of collection or

·                 If we consider that the disclosure is made necessary or adequate within the framework of the protection of the rights, the property or the safety of SimplySurfers, his customers or other stakeholders. The aforementioned disclosure includes the information exchange with other companies and organizations for purposes of protection against the fraud and the forgeries

7       Choose how SimplySurfers will use your personal data

We would like to leave it to you to choose how the personal data you provide us will be used. SimplySurfers allows you to access information about your account and your interactions with the SimplySurfers.com Site for reference or, in some cases, update purposes. You can update or modify your information from your user account.

You are never obliged to provide mandatory information, but you will not be able to use the full functionality of our services if necessary. You can update or modify certain information from your user account.

·                 If you no longer wish to receive e-mails, newsletters or other types of mail from us, please modify your preferences by following the links included in these emails and provided for this purpose.

·                 On most browsers, the help section contains information about blocking cookies, sending notifications when new cookies are received, or completely disabling cookies.

You can also contact us at contact@simplysurfers.com if you wish to view, modify or delete the personal data you have provided to us. We cannot delete your personal data without deleting your user account. We may refuse your requests for amendments if we believe they are in violation of existing regulations or legislation or are incorrect.

 

8       Information passed onto third parties

Any information which you pass on in third parties is subjected to the Privacy policy and to the practices the aforementioned third parties. We cannot be held responsible for these Privacy policy and practices, that is why he falls to you to inform you about these politics and practices before passing on your information in third parties.

  

9       Safety of the data

We set up measures intended to guarantee the safety of your personal data in case of accidental loss and in case of access, in case of use, in case of modification and in case of disclosure unauthorized. All the personal information which you pass on to us is stored in reassured waiters protected by firewalls. By using our Site or by passing on us your personal data, you accept the transfer of your information on our waiters.

The safety of your information is also within your competence. If you have a password (that you chose yourself) allowing you to reach certain sections of our Site, he falls to you to keep him secret. Reveal on no account this password in thirds. Are all eyes when you reveal information in certain sections of our Site as the module of messaging.

Unfortunately, it is impossible to guarantee the optimal safety of information exchanges on the Internet. We try hard to protect your personal data, but we cannot guarantee the information security passed on in our Site. You agree that you pass on your personal data at your own risks. We cannot be held responsible for the failure to respect the parameters of confidentiality or for security measures ready on our Site.

10   Updates of our Privacy policy

In the course of our evolution, our general Conditions and our Privacy policy can be subjected to changes. We undertake to publish any modification brought to our Privacy policy on this page. If we change the way we handle the personal data of our users, we shall inform you about it by email. We may also send you reminders concerning our legal notices and our conditions of use, but we recommend you to consult our Site regularly to hold you informed about the last updates. He falls to you to supply us an e-mail address up to date, active and functional and to consult regularly our Site and our Privacy policy to inform you of the last modifications. The date of the last update of the Privacy policy is shown at the top of the page. Unless otherwise specified, our politics of current confidentiality is applicable to all the information which we have concerning your account and your identity.

If you choose to use or to consult our Site, your visit and any conflict concerning the confidentiality will be subjected to the present Privacy policy as well as to our conditions of use including, but without limitations, the limitation of the damage, the resolution of the disputes and the application of the right and the so applicable, French legislation.

11   Remarks

We invite you and encourage to express us of your remarks comments and suggestions so that we can improve the Platform SimplySurfers. If you have questions or comments to be passed on us concerning the present Privacy policy and our practices, thank you for contacting us at the following address:  contact@simplysurfers.com.