DATA PROTECTION AND PRIVACY POLICY Version dated 21/4/2023
This Privacy Policy is intended for users of the FIQ REPUBLIC platform accessible at the following address: www.fiqrepublic.com (hereinafter “ the Platform”) for the purpose of informing them on the way in which their personal data may be collected and processed. Respect for privacy and personal data is a priority for us, which is why we undertake to process your data in strict compliance with the French Data Protection Act of 6 January 1978 (hereinafter referred to as the "IEL Act"), as amended, and the General Data Protection Regulation (EU) of 27 April 2016 (hereinafter referred to as the "GDPR").
1. General information and details of the Data Controller SNX Company, a simplified joint stock company with a registered capital of 3 000 EUR, registered with the Paris Trade and Companies Registry under number 497 933 408. Headquarters is 25 rue de Ponthieu 75008 Paris, France. SNX Company (FIQ REPUBLIC) is the Data Controller for processing related to:
- managing and tracking accounts and contracts
- providing and managing services
- managing payments
- managing requests for information from the customer relations service
- the sending of emails
- managing requests related to rights
- the correct functioning and ongoing improvements of the Platform
Legal reminder: Under the IEL Act and the GDPR, the Data Controller is the person who decides the methods and purposes of the processing. In cases where two or more Data Controllers jointly decide the methods and purposes of the processing, they are Joint Data Controllers (or Joint Controllers). The Data Processor is a person processing of personal data on behalf of the Data Controller, acting under the authority and on the instructions of the Data Controller. 2. Definitions
- “Data”: means the personal data subject to the Processing within the framework of this Privacy Policy.
- “Personal Data”: means personal data as defined in article 4 (1) of the GDPR.
- “General Data Protection Regulation” or the “GDPR”: means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
- “User”: means any person browsing on the Platform www.fiqrepublic.com, whether a subscriber, Creator, Ambassador or simple internet user.
- “Processing/Process”: means any of the operations specified in article 4 (2) of the GDPR, carried out on the Personal Data within the context of the performance of this Privacy Policy.
- “Data Processor”: means the natural or legal person, public authority, department or other body that processes Personal Data on behalf of and on the instructions of SNX COMPANY in accordance with article 4 (8) of the GDPR.
3. Purpose of the treatment and legal bases SNX COMPANY (Fiq Republic) solely collects the Data necessary for the explicit purposes specified below:
Main purpose | Detail | Legal basis |
Managing and tracking accounts and contracts |
| User consent |
Providing and managing services |
| Performance of a contract or performance of pre-contractual measures |
Managing payments |
| Legal obligation: article L. 102 B et seq. of the Tax Procedure Code |
Managing requests for information from the customer relations service |
| Performance of a contract or performance of pre-contractual measures |
Sending mailshots by email |
| User consent |
Managing requests related to rights under the GDPR and the IEL Act | This processing covers all operations necessary for following up requests for rights addressed to SNX COMPANY (FIQ REPUBLIC) (classifying the request, investigations, performance of specific technical operations, etc.). It only concerns cases in which SNX COMPANY (FIQ REPUBLIC) acts as Data Controller. | Our legal obligation under articles 15 et seq. of the GDPR and articles 48 et seq. of the IEL Act |
The correct functioning and ongoing improvements of the Platform and its functions | Ensuring the correct functioning and ongoing improvements of the Platform and its functions | Our legitimate interest to guarantee the optimal functioning and quality of the Platform, largely due to audience statistics. User consent, when this is required. |
4. Collected data The compulsory or optional nature of the personal data collected and the possible consequences of a failure to respond are explained during the various contacts with the data subjects. Below, you can find details about the personal data that we are likely to have about you. NB: the detail of the information provided below is not intended to be exhaustive and aims above all to inform Users about the categories of data that SNX COMPANY (FIQ REPUBLIC) is likely to process.
Purpose | Data processed |
For managing and tracking accounts and contracts | Data regarding User identity: last name, first name(s), address, telephone number, email addresses, username, date of birth, data provided in the biography, photos, copy of passport/ID card |
For providing and managing services | |
For managing payments |
|
For managing requests for information from the customer relations service |
|
To send mailshots by email |
|
For managing requests related to rights |
|
For the correct functioning and ongoing improvements of the Platform |
|
5. Personal data collected automatically When you browse on the www.fiqrepublic.com Platform, SNX COMPANY (FIQ REPUBLIC) automatically records information about your browsing. When you use our services, connection data may be automatically recorded in our server logs, such as your IP address, your unique identifier, your operating system and its location, the type of browser you are using and the pages you have visited.
6. Data recipients Only the authorized persons specified below can access User data.
- The other Platform Users;
- The authorised personnel of SNX COMPANY (FIQ REPUBLIC);
- Service providers responsible for managing and hosting the Platform and IT system of SNX COMPANY (FIQ REPUBLIC);
- Service providers responsible for managing customer relations and moderating content;
- Service providers responsible for managing payments;
- Email service providers;
- If applicable, the authorised personnel of our Data Processors;
- Where appropriate, the relevant courts, mediators, accountants, statutory auditors, lawyers, bailiffs, debt collection agencies or police authorities in the case of theft or judicial requisition;
- Third parties that may place cookies on your terminals when you provide your consent
Your data will not be communicated, exchanged, sold or hired to any other person than those mentioned above.
7. Data retention periods SNX COMPANY (FIQ REPUBLIC) undertakes that the data collected will be kept in a form that allows your identification for no longer than is necessary for the purposes for which the data is collected and processed.
Purpose | Retention periods |
Managing and tracking accounts and contracts | Data is kept throughout the period of contractual relations and then archived. It is then stored for a period of five (5) years for evidentiary purposes, in accordance with the legal and regulatory obligations to which SNX COMPANY (FIQ REPUBLIC) is subject. In addition, accounting records are kept for a period of 10 years. |
Providing and managing services | |
For managing payments | For payments by bank card, in accordance with Article L.133-24 of the French Monetary and Financial Code, this data may be kept for the purpose of proof in the event of a dispute over the transaction or claim, in intermediate archives, for a period of thirteen (13) months following the date of debit (this period is extended to fifteen (15) months for deferred debit payment cards). In all cases,
Data relating to the PAN and cryptogram is not stored and data relating to the expiry date is deleted once the expiry date is reached. Invoices and accounting data is kept for ten (10) years as from the date of issue. |
For managing requests for information from the customer relations service | Data is kept for the time necessary for processing the request and then for a period of three (3) years as from the last contact with SNX COMPANY (FIQ REPUBLIC). |
To send mailshots by email | Data is kept until the User unsubscribes using the link provided for this purpose. |
For managing requests related to rights | Data relating to managing rights requests is kept for the period necessary for processing the request. It is then archived for the duration of the criminal statute of limitations applicable to intermediate storage |
For the correct functioning and ongoing improvements of the Platform | Cookies and other commercial tracers may be placed on the User’s terminal for a maximum period of thirteen (13) months. After this period, the raw traffic data associated with an identifier is either deleted or anonymised. Information collected by cookies and tracers is kept for a maximum period of twenty-five (25) months. After this period, the data is either deleted or anonymised. |
8. Your rights In accordance with the French Data Protection Act and the GDPR, you have the following rights:
- Right of access (GDPR article 15), rectification (GDPR article 16) and updating;
- The right to erase your personal data (GDPR article 17), if it is inaccurate, incomplete, ambiguous, out of date, or if its collection, use, disclosure or storage is prohibited;
- The right to withdraw your consent at any time (GDPR article 13-2c);
- The right to oppose the processing of your data (GDPR article 18);
- The right to oppose the processing of your data (GDPR article 21);
- The right to the portability of the data you have provided to us, in cases where your data is subject to automated processing based on your consent or on a contract (GDPR article 20);
- The right to file a complaint with the CNIL in France (GDPR article 77);
- The right to decide what happens to your data after your death and to choose whether or not we pass on your data to a third party that you have designated. In the event of your death and in the absence of instructions from you, we undertake to destroy your data, except if we need to keep it for evidential purposes or to meet a legal obligation.
These rights can be exercised by making a simple request, by email to the address contact@fightiqrepublic.com or by post to SNX COMPANY (FIQ REPUBLIC) - 25 rue de Ponthieu 75008 Paris. If you send us a copy of your identity document to prove your identity, we will keep it for one (1) year, or three (3) years if it is provided within the framework of the exercise of a right of opposition. For more information about your rights in France, you can also visit the website of the Commission Nationale de l’Informatique et des Libertés at the following address: http://cnil.fr.
9. Security SNX COMPANY (FIQ REPUBLIC) and any Data Processors undertake to implement all technical and organizational measures to ensure the security of the processing of personal data and the confidentiality of your data, according to the current resources available and in application of the IEL ACT, the European General Data Protection Regulation (GDPR) and French law 2018-133 of February 26, 2018 "regarding various provisions of adaptation to the law of the European Union in the field of the security". SNX COMPANY (FIQ REPUBLIC) takes appropriate precautions, as regards the nature of your data and the risks presented by our processing, to preserve the safety of the data and, in particular, to prevent it from being distorted, damaged, or from unauthorized third parties gaining access to it.
10. Transfers outside of the EU SNX COMPANY (FIQ REPUBLIC) principally processes your data within the European Union. Due to the nature of its activity, SNX COMPANY (FIQ REPUBLIC) may need to transfer your data outside the European Union. In this event, such transfers are covered by the appropriate guarantees in accordance with regulations. Details of these guarantees are available on request from contact@fightiqrepublic.com
11. Updates to our privacy policy This Privacy Policy is subject to modification, in particular due to legislative and regulatory changes. As such, Users may consult updates directly on the Platform.