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This document is provided in English for informational convenience. In the event of any discrepancy, ambiguity, or dispute, the official French version shall legally prevail under French law.
Personal Data Use Policy
Last updated: January 2024
At Meerabel, we place environmental protection at the same level as the protection of your privacy and therefore on how we manage your data.
1. PREAMBLE
MEERABEL SAS pays particular attention to the protection of personal data (hereinafter “Personal Data”). MEERABEL SAS undertakes to comply with all regulations relating to the protection of Personal Data, including in particular Law No. 78-17 of January 6, 1978 on data processing, data files and individual liberties, amended by European Regulation 2016/679 of April 27, 2016 on the protection of personal data (hereinafter the “Applicable Regulation”).
The purpose of this policy (hereinafter the “Policy”) is to inform Internet users (hereinafter the “Visitor” or the “Visitors”) who visit the website https://www.meerabel.com/ (hereinafter the “Site”), and/or users (hereinafter the “User” or the “Users”) of the Meerabel mobile application provided by MEERABEL SAS (hereinafter the “Service”), of how their Personal Data is processed and to outline MEERABEL SAS’s commitments to ensure the protection of this data.
The Policy is not contractual in nature and does not create any obligation beyond what is already provided for by the Applicable Regulation mentioned above or by contractual commitments between MEERABEL SAS and the User.
MEERABEL SAS reserves the right to modify the Policy at any time, notably to comply with regulatory, jurisprudential, editorial, or technical developments. Visitors and/or Users must refer to the latest version of the Policy before browsing.
Where applicable, the Policy applies concurrently with the General Terms of Use of the Site and Service.
2. THE DATA CONTROLLER
In accordance with the Applicable Regulation, the data controller for Personal Data is MEERABEL SAS, registered in the Trade and Companies Register of Rennes under number 913604278, with its registered office located at 4 PAS ANTOINETTE CAILLOT 35000 RENNES, France (hereinafter the “Company”).
3. THE DATA PROTECTION OFFICER
In order to ensure compliance with the Applicable Regulation, MEERABEL SAS has designated a Data Protection Officer (hereinafter the “DPO”).
The DPO is the primary point of contact for Visitors and Users regarding Personal Data protection. Visitors and Users may contact the DPO for any questions relating to the processing of their Personal Data as well as the exercise of their rights (see Section 11).
Designated Data Protection Officer:
Mathieu DÉJEAN-SERVIÈRES, contactable at [email protected], is available for any questions regarding your personal data protection.
4. THE PERSONAL DATA PROCESSED
“Personal Data” refers to any information that can identify a Visitor and/or User directly (e.g., their name) or indirectly (e.g., through pseudonymized data such as a unique identifier).
MEERABEL SAS strictly limits the collection and processing of Personal Data to what is necessary for the intended purpose (principle of data minimization). Photo triage and classification are executed 100% locally on your smartphone (Edge Computing): no photo files ever leave your device or reach our servers.
- Newsletter & Commercial Communications: To receive information from Meerabel, the Visitor and/or User provides an email address and name. In case of withdrawal of consent, an unsubscribe list is maintained.
- Registration for the Meerabel Application: Identification data: name, first name, email.
- Visitor/User Support: Name, phone, email, and the content of the support request.
- Statistics & Audience Tracking: Connection identifiers, cookies, device information, and IP addresses.
- Management of Rights Requests: Identification data, contact details, and proof of identity if required.
5. COLLECTION OF PERSONAL DATA
In some cases, Visitors/Users communicate data directly (e.g. newsletter subscription). In other cases, MEERABEL SAS collects data automatically (e.g. cookies) or receives data via third-party partners.
6. PURPOSES OF PERSONAL DATA PROCESSING
Processing responds to explicit, legitimate, and determined purposes:
- Use of the Service offered by MEERABEL SAS (the Meerabel mobile application);
- Provision of the requested service (support response, newsletter delivery);
- Compliance with legal obligations of MEERABEL SAS.
| Processing Purposes | Legal Bases |
|---|---|
| Commercial communications / newsletter | Consent of Site Visitor; Legitimate interest of MEERABEL SAS when the data subject is a Service User |
| Management of newsletter unsubscribe list | Legal obligation of MEERABEL SAS |
| Collection of identification data | User consent for data collection during registration and use of the Meerabel service |
| Commercial statistics | Legitimate interests of MEERABEL SAS (business development, service improvement) |
| Audience tracking and Site navigation facilitation | Consent of Visitors and/or Users |
| Visitor and User support | Legitimate interests of MEERABEL SAS (service quality, user retention) |
| Management of disputes and claims | Legitimate interests of MEERABEL SAS (defense of rights) or legal obligations as applicable |
| Management of data subject rights requests | Legal obligation of MEERABEL SAS |
7. RETENTION PERIODS OF PERSONAL DATA
- Newsletter data: for the duration of subscription to the newsletter.
- Opposition list data: 5 years from withdrawal of consent or objection.
- Meerabel service access data: throughout the period of service use by the user.
- Commercial statistics data: for the duration of statistical analyses (results are anonymized).
- Cookies and web tracking data: 13 months from collection.
- Support request data: for the duration of processing the inquiry.
- Data subject rights requests: duration of request processing, then 5 years in intermediate archive.
8. RECIPIENTS OF PERSONAL DATA
Personal Data is strictly intended for internal MEERABEL SAS teams and vetted service providers acting on its behalf under strict data processing agreements guaranteeing confidentiality and security (e.g., website hosting, maintenance). MEERABEL SAS may also disclose data to legal professionals or regulatory authorities when legally compelled.
9. STORAGE AND TRANSFERS OUTSIDE THE EU
MEERABEL SAS carries out all processing and storage of Personal Data within the territory of the European Union.
10. PERSONAL DATA SECURITY
MEERABEL SAS implements all technical and organizational measures necessary to ensure data security and confidentiality, preventing alteration, loss, or unauthorized third-party access.
11. RIGHTS RELATING TO PERSONAL DATA PROTECTION
Under the Applicable Regulation (GDPR), Visitors and Users have the following rights:
- Right to information: clear, transparent information about how data is used.
- Right of access: request a copy of your Personal Data.
- Right to rectification: request correction of inaccurate, outdated, or incomplete data.
- Right to object: object to commercial communications or newsletter delivery at any time.
- Right to erasure: request deletion of Personal Data, subject to statutory retention requirements.
- Right to restriction: request temporary suspension of data processing under certain conditions.
- Right to portability: retrieve and transfer automated data processed on consent or contract bases.
- Right to withdraw consent: withdraw consent at any time where processing is based on consent.
- Right to lodge a complaint: file a complaint with the competent supervisory authority (CNIL in France, or your local data protection authority).
To exercise your rights, please contact our DPO at [email protected]. Proof of identity may be requested where required by law.