Privacy Policy

Last update: 19/12/2022

This privacy policy (the “Policy”) is issued by ONE DIGITAL NATION, a société par actions simplifiée (corporation) with a share capital of EUR 5.000,00€, registered at the Nanterre Trade and Companies Registry under number 830 355 699, whose head office is located at 11, rue des Closiaux 92140 Clamart (France), represented by its CEO (hereinafter, “ODN”).

The Policy applies to the service CINEVR edited by ODN, in particular the website available at www.cinevr.io and the various applications in virtual reality (the “Services”).

In the framework of the Services, ODN may collect and process specific personal data, as defined by the EU General Data Protection Regulation No 2016/679 on data protection and privacy dated April 27, 2016 (hereinafter, the “GDPR”) and French Law No 78-17 of 6 January 1978 entitled “Loi Informatique & Libertés” (the “Data Protection Act”), in the version currently in force.

The purpose of this Policy is to explain how and for what purpose ODN collects and processes such personal data and the rights of the data subjects under the above-mentioned laws and regulations.

The Policy completes the general terms of use applicable to each Service. It may be amended at any time. The applicable version is the version available on the ODN website. You acknowledge that if you continue to use our Services after the publication of an amended version of the Policy or after notice is given in such respect, your personal data will be collected, used and shared in accordance with the said updated version of the Policy.

Article 1 - What is personal data ?

Personal data is defined by the GDPR and the Data Protection Act as being “any information concerning an identified or identifiable natural person”. It can be a last name, first name, telephone number, email, as well as technical information concerning the browsing of a website or the use of an application on a smartphone.

For convenience, all personal data of any type that is or may be collected and processed by ODN in the framework of the Services is hereinafter collectively referred to as the “Data”.

Article 2 - Who is the data controller ?

ODN is the controller of the Data submitted through our Services or collected by or for our Services or processed in connection with our Services.

Article 3 - What type of data is collected by ODN ?

3.1 –Data provided by you

Subscription

To create an account for one of our Services, you must provide certain Data such as your last name, first name, nickname, country, birthday date, email and password.

Publication and downloading on the ODN platform

We also collect your Data if you provide any via our Services, e.g., when you indicate your interest for a series or give your opinion on a movie on the ODN website or application. You have no obligation to do so. However, if you do not do so, this may limit the recommendations that we provide to you through our Services concerning movies or series.

3.2. Data concerning use of the Services

We automatically store Data concerning use of the Services when you access our Services (or use them in any way), particularly when you do a search, watch a content, credit your user account with virtual currency, process a paid transaction or when you install or update one of our mobile applications. We use logins, cookies and information concerning terminals and IP addresses to identify you and record your activity. We only analyze anonymous aggregate statistics.

3.3. Cookies, web beacons and other similar technologies

We use cookies and similar technologies (such as web beacons, pixels, ad tags and terminal identifiers) to identify you and/or your terminals when you connect or disconnect or pass from one Service or terminal to another. You can configure cookies in your browser preferences or by using other tools. Moreover, you can refuse our use of cookies and similar technologies to track your activity on third-party websites for third-party advertising purposes.

List of cookies used on the Services

Domain: Third party, Cookie name: _ga, Description: Google Analytics, Expiry: 2 years, How to deactivate: Read here
Domain: Third party, Cookie name: _gat, Description: Google Analytics, Expiry: < 1 day How to deactivate: Read here
Domain: Third party, Cookie name: _gid, Description: ID for Google Analytics, Expiry: 1 day How to deactivate: Read here

3.4. Your terminal and location

We obtain information on the IP address, server proxy, operating system, web browser, add-ons, terminal functionalities and ID and/or the name of your mobile operator or Internet access provider. If you use our Services on a mobile device, the device sends us Data on your location, depending on how your telephone is configured. We will request your consent before using the GPS or other tools to identify your precise location; however, we do not store this Data on our servers.

3.5. Other

As we permanently develop our Services, we frequently propose new functionalities that can require the collection of new Data. If, in future, we collect Data in a way that materially modifies our use of your Data, we will inform you and amend this Policy accordingly.

Article 4 - On what legal basis does ODN collect and process the data ?

All the Data collected and processed by ODN is done so on a duly identified legal basis, as required by the GDPR and the Data Protection Act:

the Data can be collected based on your consent as a user, for example when you create an account for the Services or when you contribute to the Services;
the Data collected automatically through the Services is necessary for our legitimate business purposes. They enable us to identify you, whatever the terminal you use. They also enable us to provide you with customized Services.

Article 5 - For what purposes doas ODN use your data ?

ODN uses your Data for specific purposes.

5.1. Customization of the Services

We use your Data to enable us to customize your access to and use of our Services.

Recommendations

We have developed a tool to enable us to recommend movies or series that may interest you, based on the Data you provide us with, such as the movies you did or did not like, the series you watch and the intentions you state concerning the movies. We therefore use your Data to offer you Services as customized as possible for a satisfactory user experience.

These recommendations are not intrusive and can be viewed in each movie or series file that you browse. You alone can view them, and they are not shared with other users.

Geolocation

Our Services enable you to geolocate yourself to find the nearest movie theatre. Therefore, if you agree, we use the geolocation Data obtained from your mobile device or your IP address on the website. We never share this information with other visitors.

5.2 Support

We use your Data to resolve any potential problems that you may encounter when using our Services.

5.2 Security

We use your Data, if necessary, for security purposes or to investigate any suspected fraud or other breaches of ODN’s TCU or Policy and/or any attempts to cause damage to our Users and Visitors (as these terms are defined in the terms and conditions of use applicable to the Service concerned).

Article 6 - With whom does ODN share your data ?

As a principle, all the Data collected by ODN in the framework of the Services is used exclusively by ODN and is not shared with any third parties. However, the use of the Services can potentially result in the communication of your Data to third parties, in the following circumstances.

6.1. Profile

Your profile picture, first name and the initial letter of your last name are only visible to ODN’s other Users (as this term is defined in the terms and conditions of use applicable to the Service concerned). We only display your full name to Users who follow you and whom you follow in return. You can at any time, and without limitation, modify your last name, first name and your profile picture.

Visitors (as this term is defined in the terms and conditions of use applicable to the Service concerned) do not have access to ODN’s Users’ profiles.

6.2. Your activity in the framework of our Services

The comments and feelings you post on the movies, series, collections and characters are displayed to Visitors on an anonymous basis.

Only your profile picture and nickname are visible to the registered Users of the Services.

However, the Data concerning your activity in the framework of our Services can be transferred to and analyzed by Google Analytics, who provide us routine statistics.

6.3. Legal obligation

We may be required to disclose information concerning you if we are required to do so by the law, a court order or any other judicial decision, or if we believe in good faith that such disclosure is reasonably necessary to:

investigate any established or suspected illegal activity, prevent any such activity or take measures against it, or assist the court authorities;
comply or ensure compliance with the agreements concluded with you;
investigate any third-party allegations or claims, and ensure our defense;
guarantee the security and integrity of our Services;
enforce or protect the rights and security of our Services, our Users, our personnel or third parties.

Where appropriate, we will endeavor to warn Users who are concerned by a legal obligation for the disclosure of their personal data, except in urgent situations or if prohibited by the law or a court order. We may object to such requests if we consider, at our discretion, that they are excessive, unclear or not duly authorized; however, we do not make any commitment to challenge them all.

Moreover, we may be required to disclose any relevant Data to our various external consultants and legal counsels. All our external consultants are bound by professional secrecy and/or a strict confidentiality undertaking.

6.4. Business transfer

We may be required to share your Data in the context of the sale of our business, a merger or a takeover, or when preparing for any such events. Any third-party entity who purchases all or part of our business will be entitled to use your Data, but only in compliance with this Policy, except if otherwise stated by you.

Article 7 - For how long is your data stored ?

We store your Data for as long as your account exists or as is necessary to provide you the Services. This includes the Data that you or third parties provide to us, as well as the Data generated by or deducted from your use of our Services. Even if you only use our Services to search for a movie without adding any comment, for example, we store your Data and maintain your profile until you close your account.

However, after two (2) years of inactivity in respect of the Services, i.e. if you do not connect to your user account, for example, we will send you an email to warn you that, failing a connection within thirty (30) days, we will delete your entire account and, therefore, all your Data.

Article 8 - What are your rights in respect of your personal data ?

ODN scrupulously complies with all the rights granted to data subjects under the GDPR and the Data Protection Act.

8.1. Right of access to and control over your Data

We provide you the possibility to manage all the Data you entrust to us. You can therefore:

Authorize us, or not, to process you Data to offer you customized recommendations;
Authorize us, or not, to use your email address to send you information on the new features we offer;
Modify your Data without limitation, provided however that they remain accurate;
Delete your account by sending a request by email to support@cinevr.io

8.2. Closing of your account

If you close your ODN account, your Data is in general no longer visible within our Services after 24 hours. We usually delete the Data in closed accounts within 30 days, subject to the following exceptions.

We will store your Data after the closing of your account where reasonably required to fulfill our legal obligations (including requests from the authorities), comply with regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce the terms and conditions of use of the Services and/or reply to your request to no longer receive messages from us.

8.3 – Other rights

ODN will inform you in the event of a security breach resulting in the unauthorized disclosure of your Data.

Concerning Google Analytics, you can prevent the collection by cookies of data concerning your use of Our Services (including your IP address) and the processing of such data by Google by clicking on the link below and downloading the plug-in for your browser: http://tools.google.com/dlpage/gaoptout

Lastly, all data subjects have the right to lodge a complaint at any time with the relevant data protection supervisory authority. For this purpose, it is possible to contact the relevant data protection supervisory authority in the region where the person lives or, in any event, the CNIL in France at www.cnil.fr.

Article 9 - How does ODN protect your personal data ?

In its capacity as data controller, ODN undertakes to implement and maintain, at its cost, appropriate technical and organizational measures for the processing and security of personal data, in compliance with Articles 32 to 34 of the GDPR.

9.1 Technical measures

We implement security measures designed to protect your Data, such as HTTPS. We regularly monitor our systems to detect potential vulnerabilities and attacks

9.2. Organizational measures

Only certain members of ODN’s personnel are authorized to access the Data on a strictly need-to-know basis to perform their duties. Moreover, all our employees are subject to a strict confidentiality undertaking in respect of all the information they may be aware of in the scope of their duties under their employment contract. Any external service providers that we may use are also bound by contract to a confidentiality undertaking.

9.3. Records

ODN furthermore undertakes to keep, update and store full and accurate records concerning its Data processing activities.

Article 10 - Do any international transfers of data take place ?

No. All the Data is stored on servers located in the European Union, specifically in Ireland for Services.

Article 11 - Contact information

If you have any questions or complaints concerning this Policy, please contact our data protection officer at ODN at the following address support@cinevr.io. You can also send us a letter by post.