Privacy policy

Personal data protection charter

The company MOLOKOY (hereinafter “the Controller”) wishes by this Charter to inform the users of its application (hereinafter “the Users”) of the processing of personal data collected via its application accessible from the address https://molokoy.app. (hereafter “the Application”).

1. Which actors?

Company MOLOKOY

5, rue de la Carierette – 34160 ST DREZERY

represented by Mr. Jean-Yves ZINSOU

2. What personal data? At what time?

The Data Controller collects the following data:

• Identification data of the User (such as name, first name, identifier, date of birth);

• User connection data (such as IP address, country of connection).

This data is collected when the User :

• accesses the Data Controller’s Application;

• subscribes to the Application of the Data Controller ;

• creates or modifies his customer account on the Application;

• contact the customer service of the Data Controller;

3. Cookies and social networks

3.1 Cookies

Operational navigation on the Application requires the use of cookies, which are miniature “tracer” software programs implanted on the User’s terminal, and which give the Data Controller access to standard connection information. Cookies have multiple uses: they can be used to memorize your customer ID with a merchant site, the current contents of your shopping cart, an ID that allows your navigation to be tracked for statistical or advertising purposes, etc.

All the information collected will be used only to monitor the volume, type and configuration of traffic using the Application, to develop the design and layout of the Application and more generally to improve the service offered by the Data Controller.

The Controller uses cookies offered and stored by the company Google LLC, located in the United States. For more information, the User may consult the Google privacy information page.

The Google Analytics service allows to count the Users and to identify the way they use the Application. These cookies are deposited and read on the equipment of the Users of the Application and as soon as the User agrees to receive them. The data generated by these cookies concerns the use of the Application and the country of connection of the Users through the collection of their abbreviated IP addresses. This data is immediately anonymized by the Google Analytics service and is not communicated to the Data Controller. Under no circumstances can the Data Controller trace this data back to a natural person.

The Data Controller recommends that the User accepts these cookies in order to facilitate the process of browsing the Application. If the User wishes to refuse these cookies, the Controller invites him/her to set the parameters of the cookies on a case-by-case basis or in their entirety, or to refuse them systematically by setting the parameters of his/her Internet browser. The Controller reminds the User that if he refuses all the cookies, he will not be able to take advantage of some of the services of the Application.

The personal data collected (cookie identifier) is kept by the Data Controller for a period of 13 months. They are not transferred to third parties or used for any other purpose than those described herein.

3.2. Social networks

The Processor is present on various social networks, including Facebook, Instagram, LinkedIn. As such, the Processor is likely to process public data from the profiles of social network users who share, subscribe, follow or contact the Processor on these platforms.

The Data Controller shall not be responsible for the User’s public data accessible on these networks and platforms. The User is therefore advised to read the privacy policies applicable to each of these platforms in order to configure his/her privacy settings.

4. What are the reasons for this?

The processing of the User’s personal data by the Data Controller has the following purposes:

• The sending of newsletters by electronic communication to Users;

• The execution and billing of subscriptions on the Application;

• Responding to the User’s requests for information on the services offered by the Data Controller;

• The development of business statistics;

• The realization of audience measurements, in particular the number of pages seen, the number of visits to the Application, the activity of users of the Application and their frequency of return;

• Participation in games, contests or promotional operations;

• The provision by third parties of technical, logistical or other functions on behalf of the Controller;

• The customization of the services it offers;

• Management of requests for access, rectification and opposition rights;

• The collection of debts and the exercise of any legal rights by the Data Controller…

Should the User’s personal data be processed for different purposes, the Data Controller undertakes to inform the User and, when required by law, to obtain his prior consent.

5. On what basis?

Users’ personal data are processed by the Data Controller in accordance with the regulations in force, and in particular under the following conditions:

• when the User has given free, specific, informed and unambiguous consent to the processing of his or her data (e.g.: request for information, subscription to the newsletter, use of cookies, etc.);

• when it is necessary for the execution of a contract within the framework of the User’s subscription;

• when this is necessary to comply with the legal or regulatory obligations of the Data Controller as imposed by the legislator (e.g.: fight against fraud…);

• when justified by the legitimate interests of the Data Controller (e.g. security measures, operation of the Application…);

• when this is necessary for the exercise or defense of a legal right of the Data Controller (e.g.: debt collection, civil or criminal liability action, etc.).

6. Personal data and profiling?

The Data Controller does not carry out any profiling activities using the data processed hereunder.

7. Who are the recipients of the User’s personal data?

The Data Controller communicates the data collected to the technical service providers responsible for hosting its computer system and the Application, as well as to the service providers in charge of the online payment service, the marketing department, the sales department, the legal department, the legal department, the accounting department and those in charge of processing the relationship with the User, solely for the purposes previously mentioned and within the limits necessary for the performance of the tasks entrusted to them.

These recipients may contact the User directly using the contact information provided.

The Data Controller requires these recipients to use the User’s personal data only to administer the services for which they are responsible and in accordance with the applicable laws and regulations on personal data protection.

If necessary, the User’s personal data may be communicated to third parties authorized by law (in particular in the context of an express and motivated request from the legal authorities).

Similarly, if the Data Controller is involved in a merger, acquisition, transfer of assets or receivership, it may be required to transfer or share all or part of its assets, including the User’s personal data. In this case, the User will be informed before any transfer of his/her personal data to a third party.

Finally, the Data Controller reserves the right, after express authorization from the User, to use directly or indirectly (by transmitting them, for example, to its partners) the personal data of Users for commercial prospecting purposes.

8. How is the User’s personal data stored and is it transferred outside the European Union?

The User’s personal data is stored within the European Union in the databases of the Data Controller or those of its service providers.

However, some of the User’s personal data may be processed by service providers established in a third country that does not offer equivalent guarantees in terms of personal data protection (United States). In this respect, the Data Controller has concluded agreements with these service providers that comply with the standard data protection clauses adopted by the European Commission. These clauses can be communicated to Users on request.

9. What protection for the User’s personal data?

The Data Controller implements organizational, technical, software and physical measures for digital security to protect the User’s personal data from alteration, destruction and unauthorized access. However, it should be noted that the Internet is not a completely secure environment and that the Controller cannot guarantee the security of the transmission or storage of the User’s data on the Internet.

10. How long are the User’s personal data kept?

The data is kept in accordance with the law for a period justified by the purpose of the processing and, in any case, for the legal retention periods.

11. What are the User’s rights?

In accordance with the provisions of Regulation No. 2016/679 of 27 April 2016 and Law No. 78-17 of 6 January 1978, as amended, the Data Controller clearly and fully informs the User of the rights available to him/her. In the event of further questions from the User, the dedicated service of the Data Controller remains available to refer the User and give him/her all useful information in order to preserve his/her rights.

The User has :

• a right of access to his/her data: the User has the right to obtain confirmation as to whether or not his/her data is being processed, as well as the communication of a copy of his/her data and information regarding the characteristics of the processing carried out by the Data Controller on such data;

• a right to rectification of inaccurate and incomplete information;

• a right to erase data that are no longer necessary for processing, a right to withdraw consent to processing, a right to object to the processing of his data when there are no legitimate and compelling reasons justifying the processing, a right to object to commercial prospecting;

• a right to limit the processing in case of inaccuracy of the data during the time of their verification, or when they are no longer necessary for the exercise of a legal right;

• a right to the portability of his data, in order to request the transmission to another person in charge of the data provided with his consent or on the occasion of the conclusion of the contract;

• a right not to be subject to a decision based exclusively on automated processing that produces significant legal effects concerning him/her;

• a right to define directives concerning the fate of his or her data after his or her death.

The User may exercise his rights at any time with the Data Controller:

• By mail at the following address

Company MOLOKOY

5, rue de la Carierette

34160 ST DREZERY ;

• By email to the following address: contact@molokoy.io ;

The User must specify in his request his name, surname, e-mail address or postal address to which he would like the Data Controller’s reply to be sent.

For security reasons and to avoid any fraudulent request, this request must be accompanied by a proof of identity. After processing the request, this proof will be destroyed.

In accordance with the law, this request will be answered within one month of receipt.

Finally, the User has the right to lodge a complaint with the CNIL or any other competent supervisory authority in his or her country of residence.

The User can make this claim to the French CNIL:

• By mail at the following address

3 Place de Fontenoy

TSA 80715

75334 PARIS CEDEX 07

• By phone at 01 53 73 22 22 (Monday to Thursday from 9am to 6:30pm / Friday from 9am to 6pm);

• By fax to 01 53 73 22 00 ;

• Via the CNIL Internet Application at the following address: https://www.cnil.fr/fr/plaintes.