Effective Date 8th September 2021
1. Data Protection
We are responsible for the handling of your data, which we process according to your wishes and the requirements of the French and EU data protection laws. Personal data is data that identifies you or makes you identifiable. We only process personal data if this is permitted by law or if you have given your prior consent.
2. Data Collected
If you register for our platform, with your prior consent, we shall collect and process the following data:
- first and last name;
- physical addresses;
- email addresses;
- telephone numbers;
- date of birth (as our offer is only aimed at persons who have reached the age of 18).
Further data to be collected shall be listed in Appendix 1.
The provision of personal data and registration data is necessary for the conclusion of the contract (legal basis: Art. 6(1) (b) GDPR).
When visiting our website, our web server records the domain name or the IP address of your computer when you visit our internet page. This procedure is technically necessary and customary to enable the use of our website. Here we are supported by our technical service providers, which we use as contract processors. The above-mentioned data is logged and used for the purpose of defense against illegal use or attempted attacks on our web server (Art. 6 (1) (f) GDPR). The data will be deleted when no longer needed.
[If certain data fields are designated as mandatory fields and/or marked with an asterisk ( * ), the provision of this data is either required by law or contract, or we need this data for the conclusion of the contract, the desired service, or the stated purpose. Of course, you also have the right to specify the data in the mandatory fields at your discretion. Failure to provide this information may result in the contract not being fulfilled by us or the desired service not being provided, or the stated purpose not being achieved.]
3. Our Services
Data are used only for managing your membership activity (membership, event booking, payment, emailing…). We only hold the data necessary to offer the services provided on our website. We do not ask for or use more data than necessary to provide you with a proper membership service. This means we only process and hold data related to [purchases and subsequent support related to those purchases], in accordance with Article 6(1)(b) of the General Data Protection Regulation (GDPR). Any processing of your data is only done to provide or perform the services or products you have purchased.
4. Required Period and Security
We only hold personal data for as long as necessary. Once the data is no longer needed, we delete it. We ensure that the appropriate physical, technical and organisational measures are taken to prevent alterations, loss of your data, or unauthorised access to your data.
5. Rights in Data Protection
Personal data is yours. As a Club MojoCircle user, you have the following rights regarding the processing of personal data:
1. Right of access by the data subject to the personal data concerned
2. Right to rectification or erasure or restriction of processing
3. Right to data transfer
4. If the processing of your personal data is based on your consent (Art. 6 (1) (a) or Art. 9 (2) (a) GDPR), you have the right to withdraw your consent at any time. We will inform you about this in detail in the following sections.
5. Right of appeal to a supervisory authority
You have the right to object to the processing of your data at any time for reasons arising from your particular situation if the legal requirements are met. If you object to the processing of your data for advertising purposes or wish to revoke your consent, a short message to contact firstname.lastname@example.org is sufficient at any time. Your data will then no longer be processed for the advertising purposes covered by the advertising objection or the revocation of consent. This does not affect the legality of the processing carried out until the objection or revocation. After your objection to the processing of your personal data for advertising purposes or the revocation of your consent, we are obliged under data protection law in accordance with the requirements of the French data protection supervisory authorities to include the necessary data (name, address, e-mail address) in our internal advertising blacklist and – only for this purpose – to permanently store/block and use for comparison with our future advertising files. (Art. 21 (3), Art.17 (3) (b), Art.6 (1) (c) GDPR). Moreover, you have a right to correction, deletion, restriction of processing, objection, and the right to data transfer if the legal requirements are met. In all these cases, please contact email@example.com. Finally, you have the right to complain to a competent data protection supervisory authority.
6. Card & Payment Processing Data
We use third-party payment providers to handle card and payment processing data securely, so we can provide our contractual service to you (legal basis: Art. 6 (1) (b) GDPR). We never see or store any card or payment information. In accordance with Article 6(1)(b) of the General Data Protection Regulation (GDPR) any other data is only used to process your purchase securely. Furthermore, we use companies as contract processors in order to be able to offer our customers payment methods customary in the market. These include credit card via PayPal and Stripe (Art. 6 (1) (f) GDPR). In accordance with Article 6(1)(c) of the General Data Protection Regulation (GDPR), we need to retain data related to all purchases to fulfil our existing legal obligations to account for tax on all transactions.
7. Backup & Data Storage
For storage and backup purposes, customer data and email subscription data may be passed to and stored securely with third party service providers located outside the EEA (European Economic Area). This is done to backup and preserve your data where it is needed to carry on offering a service to you. The service is provided in compliance with EU data protection regulations using a data processing agreement. At any time, you have access to the details of such third-parties and you can file a request for information using this email: firstname.lastname@example.org or our contact form on our website.
8. Email Updates
If you subscribe to our [updates/newsletter/e-magazine/email service], you agree that we will regularly email Club MojoCircle news and information, updates about current offers as well as interesting information about living in France and event invitations. All subscription emails sent by us contain clear information on how to unsubscribe from our email service, although being able to receive administrative emails is necessary as an active member. Our email service is an opt-in service only; with your prior consent required in accordance with Article 6(1)(a) of the General Data Protection Regulation (GDPR). This means to subscribe you must enter your details into the email subscription page and submit them to us. You can revoke your consent at any time, e.g. in your account settings, via the email address email@example.com, [or by clicking on the unsubscribe link in any newsletter (to unsubscribe from that newsletter)]. We will use your data until you revoke your consent.
9. Data Sharing with Partners
The list of the partners we use can be found in Appendix 2.
11. Our Promise
We never sell, rent or exchange mailing lists without your prior written consent.
13. Contact Us
This policy was last updated on 08 September 2021 by
Janeen Sonsie, 283 Avenue Henri Giraud, 06140, Vence, France
From within France: 07 73 27 48 46
International: +33 7 73 27 48 46
SIREN Number: 849934252 – Registered in France
Appendix 1: DATA TO BE COLLECTED
1. Email address
2. First name
5. Current Address
6. Country of origin
7. Expat Women Facebook group member (y/n)
8. Expat Women Meetup group member (y/n)
9. Birthday (year optional)
10. Work status
12. Number of children
13.What do you want to get from this Club?
14. What would you like to enhance in your life?
Appendix 2 : Partners we use
The MojoCircle.com and ClubMojoCircle.com domains and websites are hosted with SiteGround.com
Payment gateways are PayPal and Stripe
ActiveCampaign is used as the auto-responder and for CRM functionality
Survey Monkey may be used from time to time for surveys
WordPress is the website content management
Various WordPress plugins – a list can be made available on request to firstname.lastname@example.org