- on how their personal data is collected. Personal data is any information that can be used to identify a user. We do not sell, trade, or rent out personal user data to or with any third party without user’s explicit prior written consent;
- on the rights they have concerning this data;
- on the responsible person for processing the collected personal data;
- on the recipients of this personal data;
- the website’s policy on cookies.
Article 1: Principles relating to the collection and processing of personal data
In accordance with Article 5 of the European Regulation 2016/679, personal data shall be:
- Processed lawfully, fairly and transparently with regard to the data subject;
- Collected for specified (see Article 3.1 hereof), explicit and legitimate purposes and not further processed in a way incompatible with those purposes;
- Adequate, relevant and limited to what is necessary for the purposes for which they are processed;
- Accurate and, where necessary, kept up to date. All reasonable steps must be taken to ensure that personal data which are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which they are processed
- Processed in such a way as to ensure appropriate security of the data collected, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, by means of appropriate technical or organisational measures.
Processing shall be lawful only if and insofar as at least one of the following conditions is met:
- The data subject has consented to the processing of his/her personal data for one or more specific purposes;
- The processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures taken at the request of the data subject;
- The processing is necessary for compliance with a legal obligation to which the controller is subject;
- The processing is necessary to protect the vital interests of the data subject or of another natural person;
- The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- The processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data prevail, in particular where the data subject is a child.
Article 2: Personal data collected and processed in the context of the use of 360SPORTS FRANCE' products : DEFIT Move2Earn mobile application and website https://defit.com
Article 2.1 : Collected data by DEFIT MOVE2Earn mobile application
User's personal data that could be collected in the context of mobile application usage are the following:
- Name and first name;
- Email address;
- Smartphone brand and IP address;
- Name and device model of your connected accessory (watch, app,…);
- Public address of your cryptocurrency wallet;
- Fitness activity data : sport, start time, end time, distance, duration, locations, speeds and heartrates.
The collection and processing of this data serves the following purposes:
- user account identification;
- processing of fitness activities;
- calculation of the reward according to the sports activity performed;
- management of the user account;
- customisation of the application ;
- operation of the application.
Article 2.2: Data collection method by DEFIT Move2Earn mobile application
When you use our products , the following data is automatically collected after your created a user account :
- Smartphone brand and IP address;
- Name and first name;
- Email address (if user registered with "Google login" feature).
Other personal data are collected when you perform the following operations on our products:
- When synchronising with the connected object (wearable);
- When syncing with the cryptocurrency wallet;
- When user performed an activity with a connected wearable;
- When user used the DEFIT Move2Earn in-app activity tracker to record a fitness activity.
They are kept by the controller in reasonable security conditions, for a maximum period of 36 months.
Article 2.3 : DEFIT Move2Earn mobile application location data tracking
For users not equipped with any compatible tracking wearable, the in-app activity tracker is available.
DEFIT Move2Earn mobile application collects user location data to enable fitness activity (walk, run or cycle).
User could start recording a walk, run or cycle activity with his smartphone. DEFIT Move2Earn application require background location tracking so user's activity data can be tracked when user have an other application displayed on foreground or smartphone is screen locked during the activity tracking.
This feature requires to collect information about user location data and physical movements to ensure a proper functionality of our mobile application, to compute distance and speed samples and validate forms of eligible movement for rewards (anti-cheat system).
Settings of user mobile device’s operating system, allow the user to switch location permission on and off when needed. When switched off, DEFIT Move2Earn mobile application will not be able to collect necessary activity data related to user GPS/Cell-ID location preventing tracking user movement and distributing rewards.
Article 2.4 : Data hosting
The products of the company 360SPORTS FRANCE are hosted by :
AMAZON WEB SERVICES
One Burlington Plaza, Burlington Road, Dublin 4, Dublin
Article 2.5 : Transmission of data to third parties
Some data is collected via MORALIS (crypto-currency wallet, excluding free-to-play mode), TERRA (sports activities) and AWS (data hosting).
Article 2.6 : Cookies Policy for website https://defit.com
360SPORTS FRANCE products use “cookies”. These cookies are used to store information, including visitors’ preferences and the pages of the website that the visitor has accessed or visited. The information is used to optimize the user experience by customizing the content of our Web page based on the visitor’s browser type and/or other information.
Article 3: Data controller and data protection officer
Article 3.1 : The data controller
Personal data is collected by 360SPORTS FRANCE, SAS with a capital of 20 588€, whose registration number is Pau B 898 026 943.
The person in charge of processing personal data can be contacted in the following ways:
- By post to the address: Technopôle Hélioparc – 2 avenue du Président Pierre Angot 64000 PAU;
- By e-mail: email@example.com
Article 3.2 : The data protection officer
The company’s or the person responsible for data protection is :
Kevin SEROU, Managing Director of 360SPORTS FRANCE
Technopôle Hélioparc – 2 avenue du Président Pierre Angot 64000 PAU
If you believe, after having contacted us, that your rights “Informatique et Libertés”, are not respected, you can send an information to the CNIL.
Article 4: The user's right regarding data collection and processing
Any user concerned by the processing of his/her personal data may avail him/herself of the following rights, pursuant to the European Regulation 2016/679 and the Data Protection Act (Law 78-17 of 6 January 1978):
- Right of access, rectification and right to erasure of data (laid down in Articles 15, 16 and 17 of the GDPR respectively);
- Right to data portability (Article 20 of the GDPR);
- Right to restriction (Article 18 of the GDPR) and to object to data processing (Article 21 of the GDPR);
- Right not to be subject to a decision based exclusively on an automated process;
- Right to determine the fate of data after death;
- Right to have recourse to the competent supervisory authority (Article 77 of the GDPR).
To exercise your rights, please write to 360SPORTS FRANCE – Technopôle Hélioparc – 2 avenue du président Pierre Angot 64000 PAU or by e-mail to firstname.lastname@example.org
In order for the data controller to process your request, you may be required to provide certain information such as your full name, e-mail address and account, personal space or subscriber number.
Consult the cnil.fr website for more information on your rights.
360 SPORTS FRANCE reserves the right to modify the present Policy at any time in order to ensure that the users of the site comply with the law in force.
The user is invited to take note of this Policy each time he/she uses our services, without it being necessary to formally inform him/her of this.
This policy, issued on 01/03/2022, was updated on 27th July 2023.