Governing language notice. This English version is provided for the convenience of international users. The French version (privacy-fr.html) is the legally binding text. In case of any discrepancy between the two versions, the French version shall prevail.
The essentials in one sentence: Popularoo collects the minimum amount of data necessary for its operation (technical device identifier, votes, purchases), does not require registration or password to use the Service, and never resells any data to third parties.
The data controller for personal data processing within the framework of the Popularoo application (hereinafter the "Service") is:
EN HAUT DES MARCHES
French société à responsabilité limitée (SARL), Paris Trade and Companies Register no. 504 747 932
Registered office: 147 rue Léon-Maurice Nordmann, 75013 Paris, France
SIRET: 504 747 932 00011
The Publisher has not designated a Data Protection Officer (DPO) within the meaning of Article 37 of the GDPR (Règlement Général sur la Protection des Données), as its structure and processing operations do not require it. Any question relating to personal data may nevertheless be addressed to the contact email above, to which the Publisher undertakes to respond within the legal deadlines.
The Publisher applies the following principles to personal data processing, in accordance with the General Data Protection Regulation (GDPR):
Three categories of data are collected within the framework of the Service.
This data is necessary for the technical operation of the Service and is collected from the first launch of the application:
This data is collected only if the User chooses to provide it:
This data is created by User actions on the Service:
Data NOT collected: the Publisher does not collect your real name, telephone number, postal address, date of birth, contacts, photos, or address book. Precise geolocation (GPS) is not used.
In accordance with Article 13 of the GDPR, the purposes for which your data is processed and the legal basis applicable to each processing are as follows:
| Purpose | GDPR legal basis |
|---|---|
| Provide access to the Service and its technical operation | Performance of the contract (Terms) |
| Count votes and calculate the Popularoo Index | Performance of the contract |
| Process Booster purchases and send receipts | Performance of the contract / legal obligation (invoicing) |
| Prevent fraud and abuse (multi-accounts, vote manipulation) | Legitimate interest of the Publisher |
| Detect bugs and improve the quality of the Service | Legitimate interest of the Publisher |
| Measure aggregate audience and use of the Service | Legitimate interest of the Publisher |
| Respond to public figure removal requests | Legal obligation (LCEN, DSA) |
| Respond to GDPR rights exercise requests | Legal obligation (GDPR) |
No advertising processing or commercial profiling is performed.
The retention periods applied are as follows:
| Data category | Retention period |
|---|---|
| Device identifier and associated activity | Duration of use of the Service, then 13 months after last use |
| Votes cast | Retained for score calculation; individual votes are anonymised after 24 months |
| Purchase data (Boosters) | 10 years, in accordance with French accounting and tax obligations |
| Email address (if provided) | 3 years from last interaction |
| Outsider social media accounts (if provided) | Until deletion by the User |
| Administrator audit logs | 90 days |
| Data of public figures removed upon request | Effective deletion within 30 days, retention only of removal metadata for evidentiary purposes |
The User may at any time request the early deletion of their data under the conditions of Article 9, subject to the legal retention obligations of the Publisher.
Your data is accessible only to the Publisher and to its technical processors, strictly within the framework of their respective missions. No data is transmitted to third parties for commercial purposes.
| Processor | Role | Location |
|---|---|---|
| Render Services, Inc. | Hosting of application servers | United States (Oregon) |
| MongoDB Atlas | Hosting of the database | United States |
| Apple Inc. | iOS distribution, In-App payments processing | United States |
| Google LLC | Android distribution, In-App payments processing | United States |
| Infomaniak Network SA | Hosting of the website and emails | Switzerland |
The Publisher does not use any third-party analytics tracking (such as Google Analytics, Mixpanel or equivalent) or any advertising audience measurement. If such tools were to be added in the future, this Policy would be updated beforehand and Users would be informed.
All processors listed above are bound to the Publisher by contractual commitments compliant with Article 28 of the GDPR, requiring them in particular to process data only on the Publisher's instructions, to guarantee its confidentiality, and to apply appropriate security measures.
Several technical processors of the Publisher (Render, MongoDB Atlas, Apple, Google) have their headquarters or servers in the United States. The processing of your data may therefore involve a transfer outside the European Union.
These transfers are framed in accordance with Chapter V of the GDPR by the following safeguards:
For other processors located in the European Union or in countries benefiting from an adequacy decision (notably Switzerland), no additional safeguard is required.
The Publisher implements appropriate technical and organisational measures to protect processed data against unauthorised access, disclosure, alteration or destruction. These measures notably include:
In the event of a data breach presenting a risk to Users, the Publisher undertakes to notify the CNIL within 72 hours and, where applicable, the affected Users, in accordance with Articles 33 and 34 of the GDPR.
In accordance with Articles 15 to 22 of the GDPR, you have the following rights regarding your personal data:
To exercise any of these rights, send your request by email to popularoo@popularoo.com, specifying the subject of your request and attaching any element allowing your identity or your link with the relevant device identifier to be verified.
The Publisher undertakes to respond within a maximum period of one (1) month from receipt of the request, in accordance with Article 12 of the GDPR. This period may be extended by two (2) months in case of complex requests, in which case the User shall be informed of such extension and its reasons.
If you consider, after having contacted the Publisher, that your rights are not respected, you have the right to lodge a complaint with the French Data Protection Authority (CNIL — Commission Nationale de l'Informatique et des Libertés):
CNIL — Commission Nationale de l'Informatique et des Libertés
3 place de Fontenoy — TSA 80715
75334 Paris cedex 07 — France
www.cnil.fr
The entries of Public Figures featured on Popularoo (artists, athletes, political officials, media personalities) include a limited number of pieces of information strictly necessary for their identification in the Service: name, public photograph, activity category.
This information is used within the framework of the right to information and the right of short citation, applicable to persons who have voluntarily exposed their image and their action to the public.
In accordance with Article 7 of the Terms of Service, any Public Figure, or their duly mandated legal representative, has an absolute right to request the removal of their entry, without having to provide any reason, by writing by email to popularoo@popularoo.com. The Publisher undertakes to process any request within a maximum period of 72 working hours.
The Service is strictly reserved for persons aged at least sixteen (16) years, in accordance with Article 8 of the GDPR relating to consent of minors and Article 3 of the Terms of Service.
The Publisher does not knowingly collect personal data concerning persons under 16 years of age. If a User under 16 registers despite this prohibition, their parents or legal guardians may request the immediate deletion of their data by email to popularoo@popularoo.com.
The Publisher reserves the right to amend this Privacy Policy at any time, in particular to reflect legislative, jurisprudential or technical developments.
Any substantial amendment shall be brought to the attention of Users by notification in the application at least fifteen (15) days before its entry into force. Continued use of the Service after the entry into force of the new version shall constitute acceptance thereof.
For any question relating to this Policy or to the processing of your personal data, contact the Publisher at popularoo@popularoo.com. Full postal contact details are mentioned in Article 1.