MELUDIA – PRIVACY POLICY

 

Meludia SAS (“Company”) respects your privacy, is seriously committed to protecting the privacy of its users (“Users”) and has published this Privacy Policy to explain how Company treats information you submit to Company.

Please read this Privacy Policy carefully prior to your access to and/or use of the domain or domains managed by Company (currently www.meludia.com) and/or any related downloadable software (together, the “Site”) and your registration for or use of the Service (as defined in Company’s Terms and Conditions of Use Agreement (the “Terms of Use”)). If you do not agree to abide by this Privacy Policy, please do not access or use the Site or register as a Member.

By submitting information to Company, either by using the Site or by registering for or using the Service, you are accepting the practices described in this Privacy Policy and the Terms of Use. This Privacy Policy is governed by the Terms of Use, which includes all disclaimers of warranties and limitation of liabilities. All capitalized terms not defined in this Privacy Policy will have the meaning set forth in the Terms of Use.

The terms Personal Data, Controller, Processor, Data Protection Officer, Processing shall have the meaning given to them in Article 4 of Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation, hereinafter “GDPR”).

 

1.     CONTROLLER IDENTITY AND CONTACT INFORMATION

Meludia SA (hereinafter “Company”) is registered at the Paris Trade Registry under number B 751 891 490, and is established at 149 rue Saint-Honoré 75001 Paris, France.

If you have questions, comments, concerns or feedback regarding this Privacy Policy, please contact us via any of the methods set forth below:

Company undertakes to process your Personal Data in compliance with GDPR and applicable national laws regarding personal data protection. 

2.     DATA PROTECTION OFFICER CONTACT INFORMATON

Company’s Data Protection Officer may be contacted via email at [contact@meludia.com].

3.     PURPOSES AND LEGAL BASIS OF PERSONAL DATA COLLECTION

Personal Data is processed for the performance of the Service to the Users.

Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

  • To create your profile in order to use the Service provided by Company;
  • To manage your access to the Service, specifically on the Site;
  • To improve and customize the content you see via the Service;
  • To understand your needs and interests;
  • For the management and administration of our business;
  • To communicate with you in order to provide you with services or information about Company;
  • In order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
  • For the administration and maintenance of databases storing Personal Data;
  • Aggregation of data by Company for market research, project planning, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity,
  • To enforce the Terms of Use.

Company will obtain your consent for any use of your Personal Data beyond those set forth in this Privacy Policy and the original uses for which you provided your consent, such as:

4.     INFORMATION WE COLLECT

Company may collect and process the following Personal Data regarding its Users:

  • information in connection with the Service that could be directly associated with you without the aid of additional information, such as your full name, user name and password, phone number or e-mail address;
  • information that you submit (or that we collect) necessary for the proper functioning of our Service, such as the date regarding the start and end and the extent of your usage of the Service and your preferences, your browser, operating system, IP address, clickstream data and unique device identifiers;
  • other information such as age, musical instrument or genre preference (“Demographic and Usage Data”).

We may also combine Personal Data we collect online with information available from other sources, including information received from our advertisers and promotional partners.

5.     DISCLOSURE OF PERSONAL DATA TO RECIPIENTS

Except as expressly provided herein, absent your prior consent, Company does not share your Personal Data with any unrelated third parties.

With regard to payment information, other than in the case when a third party service provider handles billing for the Services on our behalf (in which case we will ensure that such provider only uses such information in connection with payment for the Services), we will not share such information with anyone.

There are, however, certain instances in which we may disclose your Personal Data in the normal scope of business to provide you with the Service. For example, if the Site provides social media capabilities, subject to your consent, Company may post certain information as a part of your User Profile, which will be viewable by other Users and visitors to the site, including but not limited to your username, age and location (but Company will not disclose your home address, email address, phone number, or full name in connection with your User Profile).

Company may also request your consent to disclose such Personal Data to advertisers and/or other third parties for their marketing and promotional purposes.

Further, Company may use third parties to outsource one or more aspects of its business (such as email service providers), in which case, Company would have to disclose to such third parties (who would be required by Company to comply with this Privacy Policy and any other obligation of Company with respect to any information provided by you in connection with the Site and/or Service, to the same extent as Company’s obligations) the Personal Data necessary for such third parties to provide such services.

In the event that you use the Site and/or subscribe to the Service via a third party, such as an educational institution, such institution may provide Company with information on your behalf. In any such event, we will treat all such information in the manner described herein, as if you provided such information directly.

Notwithstanding the foregoing, Company reserves the right, and you authorize Company, to share or disclose your Personal Data, including, without limitation, any content, records or electronic communications of any kind, when Company determines, in its sole discretion, that the disclosure of your personally identifiable information is necessary to identify, contact, or bring legal action against you if:

  • you are or may be violating the Terms of Use, this Privacy Policy or any applicable Rules;
  • you are interfering with Company’s or a third party’s rights or property;
  • you are violating any applicable law, rule or regulation;
  • necessary or required by any applicable law, rule or regulation; and/or
  • requested by governmental authorities in the event of any investigation, act of terrorism or instance of local, regional or national emergency.

You may allow the Service to interact with one or more third party social networks or platforms, which will provide data about you to us (“Platform(s)”). The information you allow Company to access varies by Platform, and it is affected by the privacy settings you and those that you are connected with establish using such Platforms. You can control and find out more about these settings through the Platforms directly. Platforms are operated, controlled and maintained by third parties that are not operated, controlled or maintained by Company. You should ensure that you read their terms of service and privacy policies to understand how they treat your data and what data they might share with us. By accessing the Service through a Platform, you are authorizing Company to collect, store, and use in accordance with this Privacy Policy any and all information that you agreed the Platform could provide to Company through its Application Programming Interface (“API”).

6.     TRANSFERS OUTSIDE THE EUROPEAN UNION

Information collected by Company may be stored and processed in the United States or any other country in which Company or its agents maintain facilities.

We may from time to time transfer or merge your Personal Data collected off-line to our online databases or store off-line information in an electronic format.

Where we transfer your Personal Data to another country outside the European Economic Area (EEA), we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of EEA, for example, this may be done in one of the following ways:

  • the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data ;
  • the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
  • where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
  • in other circumstances the law may allows transfer of your Personal Data outside EEA.

You can obtain more details of the protection given to your Personal Data when it is transferred outside EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us.

7.     HOW LONG WE STORE YOUR PERSONAL DATA

How long we will hold your Personal Data for will vary and will be determined by the following criteria:

  • the purpose for which we are using it – Company will need to keep the data for as long as is necessary for that purpose; and
  • legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.

8.     YOUR RIGHTS OVER YOUR PERSONAL DATA

In all the above cases in which Company collects, uses or stores your Personal Data, Users may have the following rights and, in most cases, Users can exercise them free of charge. These rights include:

  • the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
  • the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
  • in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Company;
  • the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
  • the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
  • the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and
  • the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

 

9.     HOW TO EXERCISE YOUR RIGHTS OVER YOUR PERSONAL DATA

You can exercise your rights by emailing Company your request along with proof of your identity (scan of your national identification card or your passport). Please include in the Subject line the purpose of your request.

You may request a change to or update the Registration Data you provide directly to Company by contacting Company via email at support@meludia.com (words “Change in Registration Data”).

You may also send us an email asking us to delete your account at cancellation@meludia.com (please include in the Subject line the words “Delete My Account”).

We will be happy to review, update or remove information as appropriate.

We may still retain your information to resolve disputes, enforce our user agreement, or comply with legal requirements; in this case, your Personal Data will not be used for any other purpose.

10.  NEWSLETTERS AND MARKETING COMMUNCIATIONS

Company maintains a strict “no-spam” policy. If you register for the Service, you may receive Company’s newsletter, notices and/or special offers via email, unless you have requested otherwise at the time of registration or as set forth below.

You may unsubscribe from Company’s electronic newsletters, notices and/or special offers at any time by following the instructions contained at the end of every such email, or if a third-party vendor provides Company’s newsletter, in accordance with the instructions provided by such third party.

If you are having problems unsubscribing please forward the entire newsletter here unsubscribe@meludia.com with the word “UNSUBSCRIBE” in the Subject line and you will be removed within seven (7) business days.

Please note that direct replies to any newsletter are processed by computer and are not always viewed by a human.

From time to time, Company may offer Users the opportunity to participate in contests, giveaways and other promotions, which may be conducted in partnership with a third party. Any information submitted in connection with such activities will be treated in accordance with this Privacy Policy. We will use the information you provide to conduct such events and for other purposes to which you consent in connection with the particular contest, etc. Company may publicize the user names and entries of the winners and other participants and may need to disclose Personal Data collected in connection with such promotions for prize fulfillment or tax purposes to partners, sponsors or third party administrators.

11.  COOKIES; WEB BEACONS

“Cookies” are alphanumeric identifiers in the form of text files that are inserted and stored by your web browser on your hard drive. Company (and, potentially, third party advertisers or other partners) may set and access cookies on your computer or mobile device to track and store preferential information about you, for purposes such as recognizing you when you return to the Site.

Company (and potentially third party advertisers) gathers anonymous information about Users through cookie technology on an aggregate level only. Such aggregated information is used within Company’s internal organization and is only shared with third party advertisers on an aggregated and non-personally identifiable basis.

Web Beacons, also known as pixel tags and clear GIFs, (“Web Beacons”), are electronic images embedded in website pages and/or emails that allow a website to access cookies to personalize user visits, help evaluate the effectiveness of marketing campaigns and analyze general usage patterns of visitors to the Site. However, through Web Beacons, we may collect general information about our Users such as Internet browsers, operating systems, IP addresses, most and least likely times of visits and Site navigation tendencies, all of which help us examine and improve Site and Service effectiveness and features.

12.  LINKS TO THIRD PARTIES

The Site may include links to third party websites, apps or services. Such links are not an endorsement by Company of those websites, apps and/or the products or services they offer. Third parties have different privacy policies, and Company is not responsible for the privacy practices of such third parties. If you click on a link to a third party website, app or service, Company encourages you to check the applicable privacy policy, as it may differ substantially from that of this Privacy Policy. Company makes no representations or warranties nor is Company responsible for the privacy policies of any third party. If you decide to access any third party links appearing on the Site, you do so at your own risk.

13.  SECURITY

Company takes a range of security measures designed to protect your Personal Data and keep it confidential (unless it is non-confidential by nature, for example, publicly-available information) and free from any unauthorized alteration. However, the internet by its nature is not a secure environment and the nature of security risks is constantly evolving, as are the technical and organizational industry standards relating to management of those risks. The complete security of any Personal Data collected, stored or used by us cannot therefore be guaranteed. In the unlikely event that an unauthorized third party compromises Company’s security measures, Company will not be responsible for any damages directly or indirectly caused by an unauthorized third party’s ability to view, use or disseminate such information.

14.  OTHER TERMS

To review other applicable terms and conditions that apply to this Privacy Policy, including, without limitation, intellectual property rights, disclaimer of warranties, limitation of liability and resolving disputes, please review the Terms of Use.

15.  CHANGES TO THIS PRIVACY POLICY

Company reserves the right, at its sole discretion, to update, amend and/or change this Privacy Policy without prior notice and at any time. Updates to this Privacy Policy will be communicated to Users via email and posted here.

16.  IN THE EVENT OF MERGER, SALE, OR BANKRUPTCY

In the event that Company is acquired by or merged with a third party entity, or sells all or substantially all of its assets, we reserve the right, in any of these circumstances, to transfer or assign the information and content we have received and collected from our Users and Members as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your Personal Data is treated, transferred, or used.