Privacy Policy
This Privacy Policy explains how we use your personal data (your "Information").
It applies to Information we collect about you when:
- you are a Teacher in our Marketplace (see our "Teacher Policy")
- you are a Student in our Marketplace (see our "Student Policy")
- you are a 52 ENTERTAINMENT Prospect (see our "Prospect Policy")
- you are browsing our Marketplace (see our "Cookie Policy").
Finally, it contains information applicable to all of our Policies (see our "Information Applicable to All Policies" section).
This Privacy Policy is effective as of 03/01/2023.
We may change this Privacy Policy at any time if we change the way we treat your Information. We will notify you by the means most appropriate to our relationship with you (sending an email, posting a notice on our Marketplace).
- Basic information
- Definitions
When we use capitalized terms in this Policy, we refer to the definitions below:
"Student" means any person registered on the Marketplace to purchase bridge-related products (live lessons, replays, digital content) offered for sale by Teachers.
"Information" means personal data about you, whether such information directly or indirectly identifies you.
"Marketplace" means our online marketplace allowing Teachers to offer their products related to the practice of bridge (live lessons, replays, digital content) to Students and on which 52 ENTERTAINMENT is a third party to the commercial relationship. The Marketplace is accessible at the following address: www.???
"We", "us", "our" and "52 ENTERTAINMENT" means our company as identified in the About Us section.
"Privacy Policy" means this document in its entirety.
"Policy" means any of the policies in our Privacy Policy that apply to a particular class of individuals.
"Teacher" means any person who is registered on the Marketplace to sell bridge-related products.
"Prospect" means you if you have expressed a commercial interest in our company or Marketplace or if we have identified you as potentially interested in our company or Marketplace.
- Who are we?
We are 52 Entertainment, a simplified joint stock company whose head office is located at 28 rue Parmentier, 59 650 Villeneuve d'Ascq, France, registered in the Lille Metropole Trade and Companies Register under number 823 375 894.
- How can you contact us?
If you have any questions about the protection of your personal data, you can contact us by one of the following means :
- By email : contact@aristotlebridgeacademy.com
- By mail : 52 ENTERTAINMENT, 28 rue Parmentier - 59 650 Villeneuve d’Ascq - France
- By contact form : : Contact us
- Policy for Teachers
This section applies to Information we collect about you when you register as a Teacher in our Marketplace.
- What information do we collect about you?
When you are a Teacher, we may use different categories of Information about you that you may provide to us or that we may collect indirectly.
| Categories of Information Collected | Information collected |
|---|---|
|
Identity |
Company name and SIREN number (only for companies), first and last name and title, address (billing address, delivery address), telephone number, email, fax number, date of birth, customer code that we assign internally. |
| Teacher's account |
Username, password and email associated with the account |
| Professional situation |
Profession and socio-professional category |
| Settlement / Payment |
Payment, terms and conditions of payment (discounts, deposits, rebates) of our invoices, information relating to the means of payment, repayment of the price of orders made on the Marketplace. |
| Transactions made on the Marketplace |
Number of transactions made on the Marketplace, amount, quantity and products/services sold on the Marketplace, identity of your Student buyers, calculation of the amounts due to you. |
| Follow-up of the commercial relationship |
Requests for documentation or tests, products purchased or services and subscriptions taken out, orders, invoices and payment terms and deadlines, history of purchases made, correspondence with you, after-sales service, exchanges and comments between you and our customer relations manager |
| Technical support |
Requests addressed to the technical support, processing of requests, exchanges with the technical teams. |
| Unpaid |
Identity data, payment incident concerned (date of the unpaid invoice, invoice concerned, amount of the unpaid invoice, possible reason), payment means used |
|
Reviews |
Reviews of your products, date of the review, rating and content of the review. |
| Connection data when creating content |
Username used, IP address, date and time and type of content created on the Marketplace. |
| Usage metadata |
This metadata is about the actions you take in our Marketplace, such as the features you use the most, the types of files you upload to your account, interactions with Students, etc. |
- Why do we use your Information and for how long?
We may use your Information for a variety of purposes: :
- We may need it in order to provide you with our Service (Performance of a contract);
- We may need it to comply with a legal obligation (Compliance with the law);
- We may have a legitimate interest in processing your Information (Legitimate Interest);
- We do so because you have given us your consent (Consent).
Below are the purposes for which we process your Information (the purposes of our processing) and the lengths of time we keep your Information :
|
Purpose |
Legal basis |
Shelf life |
| Management of our contractual relationship with you in the context of access to our Marketplace (CGA) | Execution of a contract | For the duration of the contractual relationship |
| Provision of our intermediation service | Execution of a contract | For the duration of the contractual relationship |
| Management of our legal, accounting and tax obligations in the context of our contractual relationship | Compliance with the law | Retention in the form of an archive for the legal retention period to which we are bound (e.g.: up to 10 years for our accounting obligations) |
| Management of payments made on our Marketplace | Execution of a contract | Until reception of the products, increased by the time allowed to contest the good reception of the products in order to manage the refunds |
| Management with the payment service provider (PSP) of the distribution of the amounts between the teachers and 52 ENTERTAINMENT | Execution of a contract | For the duration of the contractual relationship |
| Management of unpaid invoices (Identification of unpaid invoices and exclusion of any future transaction in case of unpaid invoices) | Execution of a contract | No later than 48 hours after the unpaid amount has been settled |
| Claims and litigation management | Legitimate interest of 52 ENTERTAINMENT to establish the proof of a right or of the good execution of our contractual obligations | For the duration of the statute of limitations applicable to our business relationship (e.g., up to 5 years for civil statute of limitations) |
| Management of student reviews published on our Marketplace about teachers or their products | Legitimate interest of 52 ENTERTAINMENT to set up a notification system allowing students to evaluate their purchases | Publication of notices for 10 years |
| Retention of login data when publishing content in the Marketplace | Legal obligation | 12 months |
| Marketplace security (prevention and detection of computer attacks) | 52 ENTERTAINMENT's legitimate interest in detecting malicious behavior to malicious behavior in order to preserve the security of its Marketplace, as well as the availability, the integrity and the confidentiality of the data it contains (including personal data). |
6 months |
| Sending transactional emails related to the operation of the Marketplace | Execution of a contract | For the duration of the contractual relationship |
| Verification of the quality of the services provided by the professors | Legitimate interest of 52 ENTERTAINMENT to verify that the Teachers provide quality services in accordance with their contractual contractual commitments. | During the entire duration of the contractual relationship. |
| Processing of reasons for suspension/restriction/termination of Marketplace services | Execution of a contract | For the duration of the contractual relationship |
| List of Professors excluded from the Marketplace | Legitimate interest of 52 ENTERTAINMENT to ensure that excluded Teachers cannot re-register to the Marketplace for a certain period of time. time. | 3 years from the decision of exclusion |
| Statistics of the Professor's commercial activity on the Marketplace |
Legitimate interest of 52 ENTERTAINMENT to establish economic statistics by Professor and by products sold. | Last 3 years |
| Conducting satisfaction surveys or requesting feedback | Legitimate interest of 52 ENTERTAINMENT to carry out satisfaction surveys satisfaction surveys to collect the impressions of the Professors on the Marketplace | For 5 years |
| Sending of our newsletter, white papers |
Consent |
For 3 years after our last contact with you or until you withdraw your consent |
| Organization of our webinars | Legitimate interest | Up to 15 days after the last event you registered for. |
| Prospecting in connection with services similar to those already subscribed by you | Legitimate interest of 52 ENTERTAINMENT | Up to 3 years from our last contact with you. You have the right to object to receiving our commercial prospecting |
| Management of an opposition list | Legitimate interest of 52 ENTERTAINMENT to no longer send prospecting to its clients who have opposed it | For 3 years from the date you exercise your right to object |
- Who do we share your Information with ?
- To our teams
Your Information may be communicated to all our teams who need it to carry out their missions in the framework of the commercial management of our Marketplace. For example: our sales team to contract with you, our support / after-sales service team to handle your questions or complaints, etc.
- To the payment service provider
When you register with the Marketplace, some of your Information will be processed by our payment provider, Stripe Company to create an account for you with them in order to collect the money due to you from the sales you make.
Stripe will process your Information as the processor of its own Information and will inform you why and how your Information is processed.
- To our subcontractors
We use different technical providers for different reasons:
| Identity of the subcontractor | Reasons for outsourcing |
|---|---|
|
Cocolabs - AWS |
Hosting of the Marketplace |
|
|
|
|
|
|
- To administrative or judicial authorities
We may be required to disclose some of your Information to administrative or judicial authorities when we receive a court order.
- Where do we store your Information?
We store and host your Information in France.
Some of our technical subcontractors may host some of your information outside the European Union. When this is the case, we ensure beforehand that they take adequate guarantees in accordance with the General Data Protection Regulation (GDPR).
Below is a list of data transfers outside the European Union that may occur and the appropriate safeguards we take:
| Recipient's identity | Guarantee adequate plugs |
|---|---|
|
n/a |
n/a |
|
|
|
- Student Policy
This section applies to Information we collect about you when you register as a Student in our Marketplace.
- When does our Student Policy not apply?
This Policy does not apply to the processing of personal data that Professors perform on you when you place an order with them.
In this case, the Professor acts as a data controller within the meaning of the law and must inform you of the way in which your Information will be processed by him and for what reasons he processes your Information. This information is contained in the T&Cs which you agree to before placing an order.
- What information do we collect about you?
When you are a Student, We may use different categories of Information about you that you may provide to Us or that We may collect indirectly.
| Categories of Information Collected | Information collected |
|
Identity |
Company name and SIREN number (only for companies), first and last name and title, address (billing address, delivery address), telephone number, email, fax number, date of birth, customer code that we assign internally. |
|
Student's account |
Username, password and email associated with the account. |
| Personal situation |
Profession and socio-professional category |
| Settlement / Payment |
Payment, terms and conditions of payment (discounts, deposits, rebates), information on the means of payment: Credit card (credit card number, expiry date, name of the holder, visual cryptogram). |
| Transactions made on the Marketplace |
Transaction number, details of the purchase (product, service or subscription), identity of the teacher to whom the order is placed. |
| Follow-up of the commercial relationship |
Correspondence with you, after-sales service, exchanges and comments between you and our customer relations manager. |
|
Reviews |
Product reviews, date of the review, rating and content of the review, Professor involved. |
| Login data when creating content: |
Username used, IP address, date and time and type of content created on the Marketplace. |
| Usage metadata: |
This metadata is about the actions you take in our Marketplace, such as the features you use the most, interactions with Teachers, etc. |
- Why do we use your Information and for how long ?
We may use your Information for a variety of purposes :
- We may need it in order to provide the Service to you (Performance of a Contract);
- We may need it to comply with a legal obligation (Compliance with the law);
- We may have a legitimate interest in processing your Information (Legitimate Interest);
- We do so because you have given us your consent (Consent).
Below are the purposes for which we process your Information (the purposes of our processing) and the lengths of time we keep your Information :
| Purpose | Legal basis | Shelf life |
| Management of our contractual relationship (GCU) | Execution of a contract | For the duration of the contractual relationship |
| Provision of our intermediation service | Execution of a contract | For the duration of the contractual relationship |
| Management of our legal, accounting and tax obligations in the context of our contractual relationship | Compliance with the law | Retention in the form of an archive for the legal retention period to which we are bound (e.g.: up to 10 years for our accounting obligations) |
| Management of payments made on our Marketplace | Execution of a contract | Until reception of the products, increased by the time allowed to contest the good reception of the products in order to manage the refunds |
| Retention of credit card information following a one-time online payment | Legitimate interest | Up to 13 months for instant debit cards and up to 15 months for payment cards, in accordance with payment cards, in accordance with article L.133-24 of the French monetary and Code. |
| Retention of credit card information to facilitate future purchases |
Consent |
Until the consent is withdrawn or until the validity date of the registered credit card |
| Claims and litigation management | Legitimate interest of 52 ENTERTAINMENT to establish the proof of a right or of the good execution of our contractual obligations | For the duration of the statute of limitations applicable to our business relationship (e.g.: up to 5 years for the civil statute of limitations) |
| Management of student reviews published on our Marketplace about teachers or their products | Legitimate interest of 52 ENTERTAINMENT to set up a notification system allowing students to evaluate their purchases | Publication of notices for 10 years |
| Retention of login data when publishing content in the Marketplace | Legal obligation | 12 months |
| Marketplace security (prevention and detection of computer attacks) | Legitimate interest of 52 ENTERTAINMENT to detect malicious behavior malicious behavior in order to preserve the security of its Marketplace, as well as the availability, the integrity and the confidentiality of the data it contains (including personal data). | 6 months |
| Management of the Student's personal account on the Marketplace | Execution of a contract | For the duration of the contractual relationship. |
| Sending transactional emails to the Student related to the operation of the Marketplace | Execution of a contract | For the duration of the contractual relationship. |
| Processing of the reasons for suspension/restriction/termination of the Marketplace services provided for in our GTC | Execution of a contract | For the entire duration of the contractual relationship + Archiving beyond the time of the prescription. |
| List of students excluded from the Marketplace | Legitimate interest of 52 ENTERTAINMENT to ensure that excluded Students not be able to re-register to the Marketplace for a certain period of time. | 3 years from the decision of exclusion |
| Statistics of the student's commercial activity on the Marketplace | Legitimate interest of 52 ENTERTAINMENT to establish economic statistics by Student and by products sold. | Last 3 years |
| Conducting satisfaction surveys or requesting feedback | Legitimate interest of 52 ENTERTAINMENT to carry out satisfaction surveys aiming at collecting the impressions of the Students on the Marketplace | For 5 years |
| Sending of our newsletter, white papers |
Consent |
For 3 years after our last contact with you or until you withdraw your consent |
| Organization of our webinars | Legitimate interest | Up to 15 days after the last event you registered for. |
| Prospecting in connection with services similar to those already subscribed by you | Legitimate interest of 52 ENTERTAINMENT | Up to 3 years from our last contact with you. You have the right to object to receiving our commercial prospecting |
| Management of an opposition list | Legitimate interest of 52 ENTERTAINMENT to no longer send prospecting to its clients who have opposed it | For 3 years from the date you exercise your right to object |
- Who do we share your Information with?
- To our teams
Your Information may be communicated to all our teams who need it to carry out their missions in the framework of the commercial management of our Marketplace. For example: our sales team to contract with you, our support / after-sales service team to handle your questions or complaints, etc.
- To the teachers from whom you place your orders
We pass on some of your Information to the Teachers in our Marketplace from whom you place an order. These Professors will in turn process your Information as a controller; we are not responsible for their processing. For more information, see "When does our Student Policy not apply?" above.
- To the payment service provider
When you make an online payment, your Information will be processed by our payment provider, Stripe, to secure the financial transaction.
- To our subcontractors
We use different technical providers for different reasons :
| Identity of the subcontractor | Reasons for subcontracting |
|---|---|
|
Cocolabs - AWS |
Hosting of the Marketplace |
|
|
|
|
|
|
- To administrative or judicial authorities
We may be required to disclose some of your Information to administrative or judicial authorities when we receive a court order.
- Where do we store your Information?
We store and host your Information in France.
Some of our technical subcontractors may host some of your Information outside the European Union. Where this is the case, we will first ensure that they take adequate safeguards that comply with the General Data Protection Regulation (GDPR).
Below is a list of data transfers outside the European Union that may occur and the appropriate safeguards we take :
| Recipient's identity | Guarantee adequate plugs |
|---|---|
|
|
|
|
|
|
- Policy for Prospects
This section applies to Information we collect about you when you express an interest in our Marketplace: that is, when you are a Prospect.
- What information do we collect about you ?
We may use different categories of Information about you, which you may provide to us yourself or which we may collect indirectly (for example, from publicly available sources).
| Categories of Information Collected | Information collected |
|---|---|
|
Identity |
Company name and SIREN number, address of the head office (only for companies), name and surname and title, postal address, telephone number, email, fax number. |
| Personal situation |
Profession and socio-professional category |
|
Situation professionnelle |
Name of employer, position held |
| Follow-up of the prospecting relationship |
Canvassing carried out by 52 ENTERTAINMENT, requests for documentation or tests received from the Prospect, direct solicitations received from the Prospect, correspondence with you, making appointments for demonstrations, etc. |
- Why do we use your Information and for how long?
We may use your Information for a variety of purposes:
| Purpose | Legal basis | Shelf life |
|---|---|---|
| Management of our prospecting relationship (follow-up of our solicitations, responses to your solicitations, making appointments, etc.) | Legitimate interest of 52 ENTERTAINMENT to develop its commercial activity | Up to 3 years from the last contact with you. |
|
Sending out our newsletter Mailing of our white papers |
Consent |
For 3 years after our last contact with you or until you withdraw your consent |
| Organization of our webinars | Legitimate interest | Up to 15 days after the last event you registered for. |
| Prospecting by e-mail to professionals for offers related to the Prospect's profession | Legitimate interest of 52 ENTERTAINMENT to send its commercial offers to Prospects who may be interested. | For 3 years from the date of our first canvassing or our last exchange with you. You may object to our prospecting operations. |
| E-mail prospecting to consumers |
Consent |
For 3 years after our last contact with you or until you withdraw your consent |
| Prospecting by SMS |
Consent |
For 3 years after our last contact with you or until you withdraw your consent |
| Prospecting by mail | Legitimate interest of 52 ENTERTAINMENT to send its commercial offers to Prospects who may be interested. | For 3 years from the date of our first canvassing or our last exchange with you. You may object to our prospecting operations. |
| Telephone prospecting | Legitimate interest of 52 ENTERTAINMENT to send its commercial offers to Prospects who may be interested. | For 3 years from the date of our first canvassing or our last exchange with you. You may object to our prospecting operations. |
| Management of an opposition list | Legitimate interest of 52 ENTERTAINMENT to no longer send prospecting to people who have objected to it | For 3 years from the date you exercise your right to object |
- Who do we share your Information with?
- To our teams
Your Information may be communicated to all our teams who need it to carry out their missions in the framework of the commercial management of our Prospects. For example: our sales team to send you commercial solicitations, to answer your requests for documentation.
- To our subcontractors
We use different technical providers for different reasons :
| Identity of the subcontractor |
Raisons de la sous-traitance |
|---|---|
|
AWS |
Hébergement de la Marketplace |
|
|
|
|
|
|
- Where do we store your Information?
We store and host your Information in France.
Some of our technical subcontractors may host some of your Information outside the European Union. Where this is the case, we will first ensure that they take adequate safeguards that comply with the General Data Protection Regulation (GDPR).
Below is a list of data transfers outside the European Union that may occur and the appropriate safeguards we take :
| Recipient's identity | Guarantee adequate plugs |
|---|---|
|
|
|
|
|
|
- Cookie Policy
This section applies to the Information we collect about you :
- by means of cookies that we place on the Marketplace,
- when you visit our Marketplace, whether you are a teacher, student, prospect or visitor.
- What is a cookie?
A cookie is a small file placed or read on your terminal (computer, tablet, smartphone).
They allow us to store information on your terminal in connection with your navigation on our Marketplace.
Reading and placing cookies generally requires your consent; however, some so-called technical cookies may be placed without your consent.
- Who sets the cookies?
Only 52 ENTERTAINMENT deposits cookies on your terminal.
- What types of cookies do you use?
We use different types of cookies :
- Technical cookies
We use technical cookies necessary for the operation of our Marketplace :
These cookies do not require your prior consent due to their technical nature.
| Name of the cookie | Purpose | Lifetime of the cookie |
|
[A compléter avec le nom de votre cookie] |
[A compléter avec la finalité du cookie] |
[A compléter avec la durée de vie du cookie] |
- Cookies for audience measurement
We use cookies to measure the number of visitors to our Marketplace.
| Name of the cookie | Purpose | Lifetime of the cookie |
|
[A compléter avec le nom de votre cookie] |
[A compléter avec la finalité du cookie] |
[A compléter avec la durée de vie du cookie] |
- Social network cookies and platforms
We use cookies to allow you to share content on social networks and platforms on our Marketplace.
| Name of the cookie | Purpose | Lifetime of the cookie |
|
[A compléter avec le nom de votre cookie] |
[A compléter avec la finalité du cookie] |
[A compléter avec la durée de vie du cookie] |
- How do I withdraw my consent?
You can withdraw your consent at any time by setting it on our cookie manager accessible by clicking on the icon at the bottom left of your screen.
- Information applicable to all our Policies
- What are your rights?
The regulations on the protection of personal data give you several rights :
| Right of access |
You may ask us to access any Information we have about you. |
| Right of rectification |
You may ask us to correct your Information if it is inaccurate. |
| Right to object |
You may ask us to stop using your Information where we have a legitimate interest in doing so. You may also ask us to stop receiving commercial prospecting. |
| Right to withdraw your consent |
Where any of our processing is based on your prior consent, you may withdraw your consent at any time. We will then stop using your Information for that processing. |
| Right to erasure |
You may request that we delete your Information and stop using it. |
| Right to limitation |
You may ask us to temporarily stop using your Information while requiring us to temporarily retain it. |
| Right to portability |
You may ask us to provide you with an export of your Information in a reusable format and, where possible, ask us to provide it to another organization for reuse. |
| Right not to be subject to an automated individual decision |
You have the right not to be subject to a decision based exclusively on automated processing that produces legal effects concerning you or significantly affects you |
| Right to set up instructions regarding your data in case of death |
You have the right to set, update or revoke instructions regarding the retention, deletion or disclosure of your Information after your death. |
| Right to file a complaint |
You can lodge a complaint with the authority responsible for protecting personal data (in France, the CNIL, www.cnil.fr) if you feel that your rights have not been respected. |
- How do I exercise my rights?
To exercise your rights, contact us using the contact information in the "How to Contact Us" section.
We will do our best to provide you with a response within one month.
The rights you can exercise are defined by the GDPR and depend on the legal basis of our processing. It may therefore happen that a request to exercise rights cannot be processed because the right invoked cannot be exercised. If this is the case, we will inform you.
We may also ask you for proof of identity to ensure that it is you who is exercising your rights and when we have no other means of ensuring this. You should only send us proof of identity if we ask for it.
Please also note that we will only be able to respond to requests to exercise your rights in relation to the personal data processing operations that we carry out and that are identified in this Privacy Policy.
