Privacy policy

Privacy policy (March 7, 2024)

 

When you access and use the Ping Pang & Co website (the " Site ") or through the Ping Pang & Co applications (collectively referred to as the " Platform "), PING PANG & CO , a société par actions simplifiée with a share capital of €3177, headquartered at 4 Place du Dix-Huit Juin 1940 75006 PARIS 6, registered with the Paris Trade and Companies Registry under number 878 154 103 (" Ping Pang & Co ", " we", "us ") may collect personal data (the "Personal Data").

You are fully informed that the Personal Data submitted and collected will be subject to automated processing.

We act as a controller under the EU General Data Protection Regulation (GDPR);

We have adopted this privacy policy (the "Policy"), which defines, among other things, the type of Personal Data that will be collected, its purpose, and how it will be used, as well as your rights with respect to it.

The Policy governs the manner in which we collect and use your Personal Data when you use our Platform. If you do not agree with our Policy and practices, you may choose not to use our Platform.

This acceptance will be expressed by ticking the box corresponding to the Policy acceptance sentence when registering on the Platform. Checking this box will be deemed to have the same value as a handwritten signature.

The Policy is incorporated into, and forms part of, the Terms of Service, which describe the terms you agree to when you access and use the Platform, and which can be viewed at the following address : (add URL).

The Policy may be amended from time to time to reflect changes in our practices, legal requirements or applicable standards. Material changes to the Policy will take effect on the earlier of the following two events:

  1. thirty (30) days after Ping Pang & Co has notified you of the material changes, whether such notification is provided via the Platform user interface, sent to the e-mail address associated with your account or otherwise; or
  2. when you expressly accept the material modifications or a version of this Policy incorporating the modifications. Your continued use of the Platform after we have made changes is considered acceptance of those changes.

 

  1. Security of your personal data

We are responsible for the security of the Personal Data we hold. Therefore, when collecting or using your Personal Data, we implement commercially reasonable safeguards to ensure its security.

We therefore implement appropriate technical and organizational measures to protect Personal Data against unauthorized access, disclosure, alteration, destruction and other forms of unlawful or unauthorized processing. We also require our subcontractors to implement appropriate security measures.

The security of your information also depends on you. When we assign you (or when you choose) a password to access our Platform, you are responsible for maintaining the confidentiality of that password. You are requested not to share your password with anyone. We emphasize that you should be particularly careful when disclosing information in public areas of our Platform, such as discussion forums. The data you disclose in these public areas may be viewed by any user of the Platform.

Unfortunately, the transmission of information over the Internet is never completely secure. Although we make every effort to protect your Personal Data, we can only guarantee the security of our Platform on a best-efforts basis. We cannot be held responsible for any breach of the confidentiality settings or security measures present on the Platform, beyond our legal obligations.

 

  1. Persons concerned

You must be over 15 years of age to use our Platform. The Platform is not intended for use by persons under the age of 15. Anyone under the age of 15 may only use our services in the presence of a responsible adult.

If we discover that we have inadvertently collected Personal Data from persons under the age of 15, we will promptly delete such information.

 

  1. Type of data collected and use

To use certain parts of the Platform, you must provide Personal Data that identifies you, such as :

  1. contact data, including your name, postal address, telephone number and e-mail address;
  2. data enabling you to contact your guests, in particular their name and e-mail address - in this case, you must ensure that you have their consent to provide us with this personal data;
  3. payment data, in particular relating to your credit card and the history of your spending on the Platform;
  4. unique identifiers such as username, account number and password;
  5. data on your preferences, such as product or content interests and communication or marketing preferences;
  6. data relating to your device, such as IP address, your location data and the site of origin, for technical purposes but also to examine our traffic and see how our customers use the Platform;
  7. the history of your reservations and voucher use;
  8. data from third-party sources (such as social media platforms), for example your identity on Google, Twitter and Facebook; and
  9. video and audio recordings of you on our premises.

You may provide such Personal Data by using the Platform, by filling out forms on the Platform, by requesting other services, by participating in a contest or promotion sponsored by us, by reporting a problem with the Platform, by corresponding with us (including with your e-mail address or telephone number), by responding to surveys we may ask you to complete for research purposes, by conducting transactions through the Platform, by conducting searches on the Platform, and by visiting our physical facilities.

You may, in certain cases, choose whether or not to provide certain Personal Data, it being understood that this may have an impact on the functionalities available on the Platform.

We use the Personal Data we collect for the following purposes, which may be subject to specific agreement:

  • Fulfill your orders, including confirming them and notifying your guests;
    • Legal basis: contract performance.
  • Manage your account ;
    • Legal basis: contract performance.
  • Send you push notifications or SMS messages when you use our Platform;
    • Legal basis: consent.
  • Manage access to the Ping Pang & Co club and reinforce security, notably via video surveillance;
    • Legal basis: legitimate interest.
  • Enhance your experience with our video replay technology, which records your activities in the Ping Pang & Co club for your use (e.g., ordering a video replay of a particular move);
    • Legal basis: contract performance.
  • To communicate with you about our products and services, for example to send you our newsletter or inform you about changes to our services or products, including new promotions, unless you have opted not to receive them. You may unsubscribe from these communications at any time by using the unsubscribe link or by contacting us at ([email protected]).
    • Legal basis: consent.
  • To establish and maintain a commercial relationship with you, and to improve the services we offer;
    • Legal basis: legitimate interest.
  • Facilitate your service to third-party service providers, upon your action (e.g. clicking on an affiliate link);
    • Legal basis: consent.
  • Anticipate and solve problems related to our services;
    • Legal basis: legitimate interest.
  • To personalize and improve our products and services, and to conduct research and analysis on the use of our products and services;
    • Legal basis: legitimate interest.
  • For marketing and social networking - if you do not want us to use your details to send you messages about our products or services, you can unsubscribe by using the unsubscribe link in any emails you receive or by emailing us at the contact address within this Policy;
    • Legal basis: consent
  • To meet our legal obligations ;
    • Legal basis: compliance with legal obligations
  • For any other purpose with your prior consent.
    • Legal basis: consent

In addition, Personal Data may be used and disclosed to the extent necessary to enforce the terms of any contract between you and Ping Pang & Co, including billing and collection, or to protect the rights, property or safety of any person or entity.

We will not use your Personal Data for any other purpose without your consent.

 

  1. Retention period of Personal Data

We will store Personal Data for the duration of the validity of your account on the Platform, or, if this duration is longer, the duration required by the recommendations of the CNIL for this type of data.

If the account has not been active for (duration), or if you delete your account, the Personal Data will be deleted automatically within the time required by the CNIL recommendations for this type of data.

 

  1. Location of Personal Data

Wherever possible, we endeavour to store Personal Data within the European Economic Area.

However, this is not always possible, as we use subcontractors who do not always allow this option.

Our subcontractors host the data as follows:

Service provider 

Activity 

Location

 

 

 

Each subcontractor has contractually agreed with us to comply with rules at least equivalent to those applicable within the European Economic Area.

To this end, we can rely on various transfer methods, such as standard contractual clauses (particularly for all transfers to the USA), adequacy decisions or Binding Corporate Rules.

 

  1. Data breach

In the event of a breach of Personal Data, we will inform you as soon as possible and in accordance with our legal obligations, at the e-mail address provided on your Account.

 

  1. Information request

You have the following rights with regard to any Personal Data you transmit to us:

  • Right of access: You have the right to request access to your Personal Data and to receive a copy of it.
  • Right of rectification: You have the right to ask us to correct any inaccurate or incomplete Personal Data that we hold about you.
  • Right to erasure: you have the right to ask us to erase your Personal Data in certain circumstances, for example when it is no longer necessary for the purposes for which it was collected.
  • Right to object: You have the right to object to the processing of your Personal Data in certain circumstances, for example when we process your information for our legitimate interests.
  • Right to restrict processing: You have the right to request that we restrict the processing of your Personal Data in certain circumstances, for example where you have challenged the accuracy of the information we hold.

You can exercise these rights by contacting us at our contact address below: [Insert your contact address here].

We undertake to respond to your request within one (1) month of receipt, in accordance with our legal obligations.

In some cases, we may need to verify your identity before responding to your request.

In some cases, we may not be able to give you access to all of your Personal Data (for example, if the information also concerns the Personal Data of another user), but this would be justified at your request.

 

  1. Sharing information with third parties

We may share your Personal Data with third parties to help us provide and improve our products and services. This may include service providers involved in payment, additional customer services or analyses relating to our services.

We ensure that these suppliers are subject to appropriate data protection obligations.

Marketing, advertising and social media. We may share Personal Data in the form of recorded videos, images and sounds of you and your guests in connection with Ping Pang & Co's marketing, advertising and social media, provided that, as part of the Terms and Conditions applicable to our services, you have agreed to assign your image rights in such materials to us. We may share aggregated Personal Data with third parties, including, but not limited to, for advertising or marketing purposes.

When you use the Platform, certain third parties may use automatic information gathering technologies to collect information about you or your device. These third parties include:

  • advertisers, ad networks and ad servers;
  • analysis companies ;
  • the manufacturer of your mobile device;
  • Your mobile service provider.

These third parties may use tracking technologies to collect information about you when you use the Platform. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control how these third-party tracking technologies operate or how they may be used. If you have any questions about any targeted advertising or other content, you should contact the relevant entity directly. You can also block such targeting via our cookies and trackers consent banner. We also invite you to consult the "Cookies and Tracers" section of this Policy.

 

Affiliated companies and service providers. We have entered into agreements with various subcontractors to facilitate the operation of the Platform and the services we provide, and we may share with them the Personal Data we have collected.

This includes :

  • Share your credit card information with the payment service provider to process your purchase. In this case, the payment data you provide is encrypted using SSL (Secure Sockets Layer) technology before being sent over the Internet. Payments on the Platform are made through our payment gateway provider, (indicate name). You will provide your credit or debit card information directly to this provider, who operates a secure server to process payment details, encrypt your credit/debit card information and authorize payment. The information you provide to the payment provider is not under our control and is subject to the payment provider's policy and terms and conditions.
  • Sharing video recordings of you and your guests with third-party service providers who help us improve our service and enhance the security of Ping Pang & Co. spaces.

When required by law. We may share Personal Data when required by law, including in response to a request from governmental authorities when such request meets legal requirements.

Transactions. We may transfer Personal Data following any merger, sale of business assets, financing or acquisition, or in any other situation where Personal Data may be disclosed or transferred as one of our business assets.

Within the Ping Pang & Co. Group, we may share Personal Data with our affiliates in order to provide our services to you and for our own operational processes.

For guests. If you provide us with an email address to use the "invite a friend" feature of the Platform, we use the email address or SMS messaging to transmit information and your email address to the recipients.

All subcontractors are bound by contractual obligations to keep Personal Data confidential and to use it only for the purposes for which we have communicated it to them.

 

  1. External links

The Applications contain links and references to other websites and social media sites. We are not responsible for the collection, use and disclosure of information or the privacy practices of such websites, and expressly disclaim any and all liability in connection therewith.

 

  1. Cookies and trackers

When you use our Platform, our web server sends a cookie to your computer or mobile device (as applicable). Cookies are small pieces of information that are stored on your computer or mobile device when you visit a Site or access or use a mobile application, and which store and sometimes track information about your use of a Site or application.

Some of the cookies we use last only as long as your web or mobile session and expire when you close your browser or leave the Platform. Other cookies are used to remember you when you return to the Platform and last longer.

Some of the cookies used by the Platform are set by us and others by third parties who provide services on our behalf.

Mobile applications use cookies and cookie-like technologies to collect information about your access to and use of the Platform.

The following cookies and tracers are used:

Company (if third party)

Cookie name

Cookie type

 

 

 

 

You can prevent the installation of cookies in the following ways:

Only technical cookies cannot be refused, as they are necessary for the proper operation of the Site. Please note, however, that by blocking or deleting the cookies used on the Platform, you may not be able to take full advantage of the Platform.

These cookies are installed for a maximum period of thirteen (13) months.

 

  1. Social media

You can log in to your account with us using social media plug-ins from social media platforms such as Twitter and Facebook. If you choose to log in via a social media platform, our Platform will connect to the social media platform's servers. When you connect, we will receive your basic profile information, as instructed by the relevant social media platform. You will also be able to share features of our Platform with the relevant social media platform, if you wish.

We invite you to consult the Provider Policy of the relevant social media platform to learn more about your rights and choices.

 

  1. Contact

If you have any questions or comments about this Policy and our Personal Data processing practices, or if you have any requests in this regard, please contact us at the following address: (email)

 

  1. Dispute

You may submit to the CNIL any dispute relating to the execution or interpretation of the Policy, if it is not resolved amicably between us.