PRIVACY POLICY

Last updated: February 8, 2021

1. Data Controller

The data collected is processed by PENGYOU & CO, a simplified joint-stock company (SAS) with a capital of €2,028.9, registered under number 843 671 819 in the Auxerre Trade and Companies Register (RCS), with its head office at 9 place du Maréchal Leclerc, 89000 Auxerre, France, represented by its President, Mr. Daniel Cheaib.

As the publisher of the FEELS application, PENGYOU & CO. attaches great importance to the protection of your personal data and the respect of your privacy. The purpose of this Privacy Policy (as well as our Cookie Charter, our General Terms and Conditions, and any other document mentioned therein) is to inform you about how we handle the personal data you provide to us and that we collect in the context of your use of the Application and the Services.

We invite you to read this document carefully to understand our practices regarding the processing of your personal data and to know your rights in this regard. This Privacy Policy applies to all services published by PENGYOU & CO. that you use (excluding services provided and operated by third parties; in which case, the privacy policy of those third parties applies).

2. Data We Collect

When you use our services, we only collect and process the data necessary for the operation of the application and the provision of the services. This includes data that you provide to us directly or data that we collect automatically with your consent.

2.1 Data You Provide Directly

By using our services, you are required to provide us with data, some of which may identify you. By sharing this data, you accept that some of this data may be visible to other members of the application and thus made public within the application. To help you identify them, this information is marked as "Public" below.

FEELS cannot be held liable for data disclosed and made public by a member on FEELS. Other information is not visible to other members and is therefore not accessible. The information you provide includes the following data:

Registration Data: These are the data required for registration when you use the Facebook login option. This data is retrieved by the FEELS application via Facebook Connect to minimize formalism. By clicking the "Facebook Connect" button, you accept that Facebook shares this data with us:

• Your photo (Public): At least the public Facebook profile picture. You then have the option to change your photos and/or add more photos from your smartphone to your account.
• Your last name (Public).
• Your first name (Private).

This information is mandatory. If you do not provide it, FEELS cannot provide you with the services offered by the application and you cannot create an account. You may provide additional information to complete your profile. This information is optional and provided with your prior consent and under your sole responsibility:

• Your email address (Private).
• Your friend list (Private).
• Your city (Public).
• Your gender (Private).
• Your date of birth (Private): Only the age derived from the date of birth is visible to other FEELS users (Public).
• Professional activity (Public): Such as profession, employer, or studies.

Data Related to Interactions: We may ask you to provide data when you contact customer service, report a problem, request support, exercise your rights, or participate in surveys, contests, and tests.

2.2 Data We Collect Automatically

• Activity Data: We collect information on how you use the application (registration date, last login, number of interactions).
• Location Data: We never ask for geolocation permission during registration. However, as the purpose of the application is to find members near you, you can voluntarily enter your location (city/region). This data never identifies your exact location.
• Messaging Data: Messages are stored on our servers solely to provide the service. They are strictly private. FEELS managers do not exercise any right of surveillance, except by court order.
• Search Preferences: Data regarding the age and gender of the people you are looking for.
• Device Data: IP addresses, app version, device model, operating system, advertising IDs. FEELS has no access to your browsing history. Data may, however, be collected via cookies.

3. Use of Collected Data

Data processing is based on the service contract (T&Cs) for the following purposes:

• Management of your account and customer service.
• Location based on your city for partner suggestions.
• Storage of messages.
• Sending notifications and newsletters (no sharing with third parties for marketing purposes).

The collected data is also necessary for the legitimate interests of FEELS (improvement and optimization of services, better knowledge of its members, and how our services are used) and allows FEELS to conduct studies, surveys, and marketing analyses.

FEELS may process personal data in response to a legal request (search warrant, court order, or similar) or to fulfill legal, regulatory, or administrative obligations. We may also process your data to detect or prevent fraudulent activities or security breaches.

4. Sharing of Your Data

Only a limited number of customer service and support employees, as well as authorized FEELS managers, process the personal data of members for the purposes described above. FEELS may also contract with authenticated and reliable service providers and partners who may access and/or process certain personal data of members in accordance with this Privacy Policy and who guarantee security and confidentiality.

5. Rights of Members

In accordance with the French Law No. 78-17 of January 6, 1978 ("Loi Informatique et Libertés") and the GDPR, every member has the right to access and rectify their personal data. Members also have the right to data portability, erasure, and the right to object to or restrict processing.

The member can exercise these rights by proving their identity through the application's features or by sending an email to contact@feels-app.com.

• Right of access: To obtain communication of the data concerning them.
• Right of rectification: To correct, complete, or update inaccurate or incomplete data.
• Right to portability: To receive their data in a structured, commonly used, and machine-readable format.
• Right of erasure: To request the deletion of data provided to FEELS (available via the "Delete my account" feature in the application).

6. Legal Basis for Processing

We use your personal data under the following conditions ("Legal Bases"):

• Contract: Necessary to provide our services as described in our Terms of Use.
• Legitimate Interest: To improve services, protect information, or answer support requests, provided it does not override your right to privacy.
• Consent: When requested specifically (e.g., for certain phone permissions).
• Legal Obligation: To comply with the law or valid court orders.

7. Data Retention

FEELS keeps member data as long as necessary for the use of the account:

• Duration of registration plus one year.
• A period of two years if the account was suspended.
• 13 months for cookies.

8. Data Transfer Outside the EU

By registering, the user expressly consents that their data may be transferred to FEELS subcontractors located outside the European Union for statistical studies, support, and hosting. FEELS guarantees that these transfers take place under conditions that ensure confidentiality and security (e.g., Standard Contractual Clauses of the European Commission).

9. Cookie Policy

FEELS uses cookies to facilitate access to our service and study application usage. A cookie is a small file stored on the user's device. You can object to the storage of cookies by contacting us at contact@feels-app.com.

10. Contact

For any questions, please contact:
PENGYOU & CO.
9 place du Maréchal Leclerc
89000 Auxerre, France
Email: contact@feels-app.com