Last Updated: 15 AUG 2022
At Les Amis, your privacy is our top priority. Privacy is at the core of how we design our product and services. We don't take the trust of our users for granted, and so we make everything possible to protect it.
We take your privacy seriously
We design all of our products and services with your privacy in mind. We involve experts from various fields, including legal, security, engineering, product design and others to make sure that no decision is taken without respect for your privacy.
This policy applies only to information we collect in the App or the Website, and in email, text and other electronic communications sent through or in connection with the App or the Website. This policy DOES NOT apply to information that we collect offline or on any other websites, including website you may access through the App or the Website, or the information you provide to or is collected by any third parties.
Why do we collect your personal information
Consistent with our mission of helping people to connect with each other, the primary reason we collect information is to assist you in finding and communicating with other Les Amis users and provide the best possible user experience.
To achieve this goal, we collect your personal information:
- to apply for membership to the Service: you will be asked to begin an application using certain credentials such as your social media account details (Instagram handle), contact information, and phone contacts, among other things. Upon doing so, you authorize us to access information from your social media account provided, such as your username, profile picture, biography, website, list of followers, list of people you follow, and number of pictures, as well as your phone contacts. This information is used to verify your identity and to evaluate your real-world connection to our existing members, among other things.
- to make inferences about you and your preferences to recommend content we believe you will find relevant, useful and interesting. If you like a particular musician, for example, we may infer that you like other people with similar music taste and suggest that you make a connection with them;
- to assess the performance of the Service and to understand how our app is used, improve its functions, add new features, enhance its security, guard against threats or risks to safety, identify and fix any bugs, send you news and updates, contact users and respond to their questions and comments, and compile aggregated, anonymized data that we analyze for our research and development purposes;
- to deliver targeted content based on user profiling and location;
- to record your likes and preferences, for better navigation, experience recommendation, and Service functionality;
- to suggest upcoming Les Amis Experiences based on your feedback and history of visited experiences, and other users you connected with;
- to process and respond to a complaint or request you may make;
- to contact you in relation to our Services, particularly if we believe there are any particular Offers you might be interested in; or
- for the provision of services or the administration of our business (including fulfilling and exercising our obligations and rights, exercising or defending legal claims and managing the relationship with you).
The legal basis for collecting and using personal information will depend on the specific circumstances in which it is collected. However, we will collect personal information from you where:
- you have given consent for our use of the personal information for one or more purposes;
- it is necessary for the performance of a contract to which you are a party;
- it is necessary for the legitimate interests pursued by us and those interests are balanced against your rights to information privacy (e.g., to communicate useful content updates); or
- we have legal obligations that we need to comply with, and are allowed to use your personal information in order to comply with such legal obligations.
Personal information we collect
Personal information means information or opinion about an individual, or an individual who is reasonably identifiable (whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form). Personal Information includes any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address or other contact information.
We may collect and use different kinds of information in the course of providing the Services which we have grouped together as follows:
- Contact data, such as your first and last name, email address, and phone number.
- Demographic information, such as your gender and age.
- Profile information: such as the username and password that you may set to establish an online account on the Service, date of birth, biographical details, photograph, links to your profiles on social networks, interests, preferences, and any other information that you add to your account profile.
- Sensitive information: includes information regarding your racial or ethnic origin, religious and philosophical beliefs, political or sexual orientation information, and other sensitive information;
- Communications that we exchange with you, including when you contact us through the Service, social media, or otherwise.
- User-generated content, such as profile pictures, photos, images, music, videos, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
- Content information: this includes the content of communications, people you are connected with and how you interact with them (such as people you communicate with, connected with during the event, or groups that you select to join), and your preferences and choices;
- Marketing information: includes your preferences in receiving marketing communications from us; and any other personal information that you provide to us either directly or indirectly when using the Service.
We may combine personal information we receive from you with personal information we obtain from other sources, such as social media services, that you use to log into, or otherwise link to, your account on the Service. This data may include your username, profile picture, and other information associated with your account on that third-party service that is made available to us based on the information you provide during the Application or in your account settings on that Service.
Automatic Data Collection
We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
- Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
- Location data based on your device and online activity data.
Some of the automatic collection described above is facilitated by the following technologies:
- Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both "session cookies" that are deleted when a session ends, "persistent cookies" that remain longer, "first party" cookies that we place and "third party" cookies that our third-party business partners and service providers place.
- Flash Cookies. Certain features of the Service may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Service. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see “Choices About How We Use and Disclose Your Information” below.
- Web Beacons. Pages of the Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).
If you do not want us to collect this information from you, you may opt out at any time by contacting us.
How we use your personal information
We may use the personal information we collect from you to:
- notify you about any changes in or to the Service or our services;
- fulfill our legal obligations and respond to any litigation or law enforcement/government inquiry;
- insure that the Service is presented to you in the most efficient manner for you and us;
- improve the design and performance of the Service;
- deliver to you communications, emails, newsletters and marketing materials from us and third parties as you request them or which we feel may interest you, where you have consented to be contacted for such purposes;
- allow you to participate in any interactive features of the Service, when you choose to do so;
- administer the Service and keep it safe and secure;
- facilitate internal operations, including research, statistics, troubleshooting, data analysis, testing, survey and similar purposes;
- share it with third party service providers (as we describe in more detail below);
- disclose as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to protect our operations or those of any of our affiliates; (c) to protect our rights, privacy, safety or property, or property that belongs to you or others; or (d) to allow us to pursue available remedies or limit the damages that we may sustain;
- evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred;
- fulfil any other purpose disclosed by us when you provide the information; or
- otherwise, with your consent.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
- technology partners in connection with services that these third parties perform for us;
- our lawyers, accountants, professional advisors, and other third-party service providers;
- to our affiliates;
- to law enforcement authorities where we are required to do so by law or pursuant to a legal process, or when we believe disclosure is reasonably necessary or appropriate to prevent harm in connection to a suspected illegal activity; or
- to any entity in the event that we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to require that the transferee uses the personal information you have provided to us in a manner that is consistent
Your profile and other user-generated content (except for messages) may be visible to other users of the Service and the public. For example, other users of the Service or the public may have access to your information if you chose to make your profile or other personal information available to them through the Service, such as when you provide comments, reviews, survey responses, or share other content, or if you set your profile to public. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.
Personal information collected within the European Union may be transferred to and processed by third parties located in a country outside of the European Union. In such instances, we shall ensure that the transfer of such personal information is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures are in place.
Choices about how we use and disclose your information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the Service may then be inaccessible or not function properly.
- Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt out at any time by contacting us at firstname.lastname@example.org.
- Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by contacting our Privacy Officer at email@example.com or by using the opt out mechanism included in such advertisements.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
When we collect or transmit sensitive information, we use industry standard methods to protect that information.
We have also put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit CCPA Privacy Notice for California Residents.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our SERVICE that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact our Privacy Officer at firstname.lastname@example.org
Children Under the Age of 13
The Service is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see “California Privacy Rights” above for more information.
We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.
Additional services and links to other sites
Address: Les Amis, Carrer del Codols, Barcelona, Spain, 08002