Policy on the General Data Protection Regulation (GDPR)

Last update: December 2023

Article 1 - Preamble                                                    

This privacy policy applies to the : Moove (flymoove.com) and its application (app.flymoove.com).

The purpose of the present confidentiality policy is to inform users of the

● How their personal data is collected and processed. Personal data is data that can identify a user (e.g. first name, surname, age, postal address, IP address, etc.);

● What rights do users have regarding this data?

● Who is responsible for processing the personal data collected and processed?

● To whom these data are transmitted ;

● The site's policy regarding fichiers "cookies".

This confidentiality policy complements the Legal Notice and General Conditions of Use that users can consult.

Article 2 - General principles of data collection and processing  

In accordance with the provisions of Article 5 of European Regulation 2016/679, the collection and processing of site users' data complies with the following principles:

● Legality, fairness and transparency: data is only collected and processed with the consent of the user who owns the data. Whenever personal data is collected, the user will be informed that his or her data is being collected, and for what purpose the data is being collected;

● Limited purposes: the collection and processing of data is carried out to meet one or more purposes determined in these general terms of use;

● Minimization of data collection and processing: only the data necessary for the proper execution of the objectives pursued by the site are collected;

● Time-limited data storage: data is stored for a limited period, of which the user is informed;

● Integrity and confidentiality of collected and processed data: the data controller undertakes to guarantee the integrity and confidentiality of collected data to the best of its ability.

Afin order to be lawful, and in accordance with the requirements of Article 6 of European Regulation 2016/679, the collection and processing of personal data takes place only if at least one of the conditions listed below isvérifiée:

● The user has expressly consented to the processing ;

● Processing is necessary for the proper performance of a contract ;

● Processing is required by law;

● Processing is necessary in order to safeguard the vital interests of the data subject or another natural person;

● Processing may be necessary for the performance of a task in the public interest or in the exercise of official authority;

● The processing and collection of personal data is necessary for the fins of the legitimate and private interests pursued by the data controller or by a third party.

Moove collects and processes data from its Users:

● by obtaining and respecting the necessary consent, which any User may revoke at any time by sending a written request by e-mail to the Moove customer service department;

● to meet its legal obligations ;

● in the public interest, and in particular to offer a personalized, innovative and secure online biography writing service.

● For its legitimate interests, in particular as regards the provision of a service for the practice of labiography accessible to all, unless these interests are overridden by the interests or fundamental rights and freedoms of Users requiring the protection of their personal data

Article 3 - Personal data collected and processed when browsing the site              

A. Data collected and processed and method of collection

a. The personal data collected on the Moove website are the following:

Customer data: e-mail, first name, last name, postal address, connection information. This data is collected when a user registers for the application, via a dedicated form clearly indicating to the user that he or she is making a payment. The data controller will store all the data collected in the site's computer systems under reasonable security conditions for a period of 5 years from the finding of the commercial relationship between the user and Moove.

Data for prospects: e-mail, telephone, exchanges with Moove teams. This data is collected when the user performs one of the following operations on the site: (1) the user subscribes to the website newsletter, (2) the user requests a call back to obtain information, (3) the user communicates with Moove (email, chat).

In the event of a visit to the site, if the user accepts cookies, connection information will be transmitted to third-party services for analysis purposes: advertising/social network trackers (e.g. facebook pixel), site activity tracker (Hotjar), session tracking (Google Analytics). The data controller will store all data collected in the site's computer systems under reasonable security conditions for a period of 5 years from the last visit to the site.

Data for companions mentioned by users ("Beneficiaries"): first name, surname, gender, date and place of birth, passport. This data is collected when a user who subscribes to the solution communicates data for a flight on the Moove site: the user who transmits the data undertakes to communicate clearly with on the fact that he collects and transmits personal data to Moove, with the agreement of the accompanying person. The data controller will store all the data collected in the site's computer systems under reasonable security conditions for a period of 3 years after the finding of the contractual relationship between Moove and the user who transmitted the data.

b. The collection and processing of data meet the following finalities

● Customer relationship management: make it easier to get started with the service, monitor customer interactions, enable service purchase

● Communication with prospects afin order to facilitate the marketing of the Moove service;

● Using the Moove service

B. Transmission of data to third parties

The personal data collected by the site is not transmitted to any third party, and is processed solely by the site editor.

Some of the personal data collected may be passed on to third parties acting as operators/suppliers. This includes emailing services used by the publisher, digital analysis tools (Facebook, Google Analytics), and parties involved in aircraft operations. Some of these suppliers/providers may be located outside the European Union. They are Privacy Shield approved.

C. Data hosting

The Moove website is hosted by : Squarespace, whose head office is located at the following address:

Squarespace, 225 Varick Street, 12th Floor, New York, NY 10014

                                     

Article 4 - Data controller and data protection officer                    

A. The data controller

The person responsible for processing personal data is Arthur Ingles. He can be contacted as follows:

info@flymoove.com

The data controller is responsible for determining the finalities and means of processing personal data.

B. Obligations of the data controller

The data controller undertakes to protect the personal data collected, not to pass it on to third parties without the user's knowledge, and to respect the finalities for which the data was collected.

Furthermore, the data controller undertakes to notificate the user in the event of rectification or deletion of the data, unless this would entail disproportionate formalities, costs and steps for the user.

In the event that the integrity, confidentiality or security of the user's personal data is compromised, the data controller undertakes to inform the user by any means.

C. The Data Protection Officer

Furthermore, the user is informed that the following person has been appointed as Data Protection Officer: Arthur Ingles.

The role of the Data Protection Officer is to ensure the proper implementation of national and supranational provisions relating to the collection and processing of personal data. He is sometimes called DPO (for Data Protection Officer).

The Data Protection Officer can be contacted as follows: info@flymoove.com

                                 

Article 5 - User rights                                              

In accordance with regulations concerning the processing of personal data, the user has the following rights.

In order for the data controller to comply with the request, the user must provide the following information: first name, surname and e-mail address.

The data controller undertakes to respond to the user's request as quickly as possible.

A. Overview of user rights regarding data collection and processing

a. Right of access, rectification and deletion

Users may view, update, modify or request the deletion of their personal data by following the procedure set out below:

● The user may contact the Moove teams (info@flymoove.com) afin requesting the provision, updating, modification or deletion of his or her personal data collected by the site.

b. Right to data portability

The user has the right to request the portability of his personal data, held by the site, to another site, by following the procedure below:

● Send an email to info@flymoove.com

c. Right to limit and object to data processing

The user has the right to request the limitation of or to oppose the processing of his/her data by the site, without the site being able to refuse, unless it can demonstrate the existence of legitimate and compelling reasons, which may prevail over the interests and rights and freedoms of the user.

Afin order to limit the processing of your data or to object to the processing of your data, please follow the procedure below:

● Send an email to info@flymoove.com

d. Right not to be subject to a decision based exclusively on an automated process

In accordance with the provisions of Regulation 2016/679, the user has the right not to be subject to a decision based exclusively on an automated process if the decision produces legal effects concerning him, or affects him significatively in a similar way.

e. Right to determine the fate of data after death

Users are reminded that they can organize what should happen to their collected and processed data if they die,in accordance with law no. 2016-1321 of October 7, 2016.

f. Right to appeal to the competent supervisory authority

In the event that the data controller decides not to respond to the user's request, and the user wishes to contest this decision, or if he believes that one of the rights listed above has been infringed, he is entitled to refer the matter to the CNIL (Commission Nationale de l'Informatique et des Libertés) or to any competent court.

B. Personal data of minors

In accordance with the provisions of Article 8 of European Regulation 2016/679 and the French Data Protection Act, only minors aged 15 or over may consent to the processing of their personal data.

If the user is a minor under the age of 15, the consent of a legal representative will be required afin order for personal data to be collected and processed.

The site editor reserves the right to verify by any means that the user is over 15 years of age, or that he/she has obtained the consent of a legal representative before browsing the site.

                                     

Article 6 - Conditions for modifying the privacy policy

This confidentiality policy may be consulted at any time at the address below:

https://www.flymoove.com

The site editor reserves the right to modify it afin order to ensure that it complies with current legislation.

Consequently, the user is invited to consult this confidentiality policy on a regular basis in order to keep abreast of the latest changes.

The user is informed that this confidentiality policy was last updated on: 01/01/2024.

Article 7 - Acceptance by the user of the privacy policy    

By browsing the site, the user certifies that he/she has read and understood the present confidentiality policy and accepts its conditions, particularly with regard to the collection and processing of his/her personal data.