1. Processing manager
Data are collected by the company BLIND registered under the number 849 245 105 at the RCS of Toulouse. Its headquarters are located at 18 rue du chant du merle, 31400 Toulouse and the company is represented by its CEO Fabrice Nkoa Zoa.
2. The information we collect
Your use of our Services makes it likely that we collect and process data necessary to the proper functioning of the Web app and to the supply of the Services. It can be information you share with us directly, or data we collect automatically.
2.1 Data you share directly
When you use our Services, you are required to share some information, some of which may serve to identify you. When you communicate this information, you accept that some of it will be visible to the other Members of the Web app, and therefore be made public on the Web app. In an effort to help you identify this information easily, it is signaled as “public” below. Blind Me cannot be held liable for data published on its platform and disclosed by a Member. However, the information not marked as Public will not be visible or accessible by other Members.
The information you share contains the following data :
Registration data : this is the basic data that is necessary for you to register and access our Services. This data is collected by Blind Me from Facebook, via Facebook Connect, to simplify the process. When you click on “Facebook Connect”, you let Facebook share this data with us. This identity data is :
- Your photo (public) : this is, at least, your public Facebook profile picture. You then have the option of removing this photo and/or adding other photos to your Account from your Facebook account or smartphone.
- Your birthdate (private) : only your age, as deducted from the birthday, will be visible to other members.
- Your gender (public).
- Your first name (public).
- Your last name (private).
Sharing this information is mandatory. If you do not share it, Blind Me will not be able to supply the Services offered in the Web app and you will not be able to create an account.
You may add additional information to improve your Profile. This information is optional, shared at your own discretion, and is your sole responsibility. You can add this information directly to your Profile on the Web app and/or via Facebook Connect by synching your Account with Facebook. This data is :
- Your email address (private). The Member commits to making sure the address collected from Facebook Connect is valid and/or to modify it to ease communications with Blind Me.
- Your mobile phone number (private).
- Your profile description (public) : If you would like to, you can share additional information about you in the space provided for this purpose. This information will be visible to Blind Me Members. Blind Me does not encourage Members to share data that can be perceived as sensitive with other Member, or with Blind Me through the Web app. Sensitive data refers to data that is legally qualified as “sensitive” by the General Data Protection Regulation (GDPR). More specifically, it includes information on race or ethnicity, political opinions, religious or philosophical beliefs or affiliation with a union, along with information on health, sexual life or sexual preferences (“Sensitive Data”). If a Member decides to share such information on his/her profile regardless, it is deemed to have been “clearly made public” by the Member who shared it, according to the GDPR.
Data on your interactions with Blind Me : we may ask you to share, or you may be in a situation where you need to give us information, for example when you contact our customer or support services, report an issue with our services, ask for help, exercise your personal data rights, or participate in a promo, game, contest, raffle, or survey, when you share your experience with our services, give testimonies, or answer one of our questionnaires.
2.2 Data we collect automatically
When you use our services and features, we collect information regarding your activity on the Web app :
Activity data : when you access our Services and use the Web app and its features, data on the way you use them may be collected and processed. More specifically, this includes your registration date, last connection, the type and number of interactions with other Members (like the “Hi” & “Flashs”) or the number of transactions performed (purchasing credits or subscription(s)).
Location Data (geolocation) : the Web app has for main interest and vocation to allow the Members to enter into a relationship with other Members (according to the chosen parameters) so as to facilitate virtual and/or real meetings. An authorization is asked the Member to collect and process the data relative to its geo-tracking so as to allow Blind Me to feed its homepage by presenting him the profiles of Members which correspond to his criteria of search and having also agreed to be geolocation-based. Blind Me can, in case of express consent, reach the position of the Member, approximately or more exactly according to the used technology. At no time the exact location or the route of a Member are visible for the other Members.
The Member can return free of charge and at any time on its consent and deactivate the option of geo-tracking on its computer, smartphone or tablet. In this case, the homepage of the Member is not any more updated and the Member cannot see any more which are the other Members that he / she had on its homepage in the deactivation of the option of geo-tracking.
Transaction Data : Blind Me does not collect or process any bank data. Paypal have opted to refrain from sending certain types data to Web app, which includes any banking and financial information. This data is collected and processed solely by the above platforms, and Blind Me does not have the option of changing this payment method. The only information exchanged between Blind Me and Paypal is technical data that doesn’t allow us to identify you (for example, a transaction number), which serves to confirm transactions.
Data on the use of the messaging service : sent messages are stored on Blind Me’s servers exclusively, to provide the Service to allow Members having a Reciprocity to have a conversation. Messages and voice notes are strictly private and only implicate the Members involved. BLIND’s authorized managers do not hold or exercise any rights to view these conversations, except in cases of judicial request, and/or in compliance with legislative or administrative dispositions. Additionally, Messages are strictly private and are not accessible to other Members not involved in the conversation, nor to any third party.
Search preferences data : the Web app lets you set search preferences for age and gender. You can change these settings in the Web app and specify the age range and, after agreeing to Blind Me collecting and processing your data, the gender of people you are looking for, so you can be matched exclusively with profiles with and who meet your search criteria. You will then only see the Members with and who share your search preferences on your newsfeed.
3. How we use the data collected
The data collected by Blind Me allows us to provide the Services and make sure the Web app is running smoothly, which it is contractually obligated to do, in virtue of the contract biding us with the Members (TOS). Your data is therefore processed for the following purposes :
1. Creating and managing your Member Account (including managing access to the Services and the customer or support services).
2. Geolocating to suggest Profiles of Members that match you.
3. Managing and storing messages exchanged between Members.
4. Sending information messages regarding the Services or your interactions with other Members (notifications).
5. Sending Blind Me or partner newsletters along with messages or marketing or advertising content by Blind Me or by its partners.
The data collected is also necessary to Blind Me fulfilling its legitimate interests (improving and optimizing its services, along with gaining a better knowledge of its Members and the ways in which they use the Services) and allow the company to run statistical studies, satisfaction surveys, and marketing analyses relating to the use of the Web app and Services by the Members.
As the data processing relies on the consent of Members to have their data processed, they can withdraw it at any time; withdrawal of the consent does not affect processing carried out before the withdrawal.
Blind Me may process Members’ personal data in response to a legal request (search warrant, court order, or the like) or to comply with its legal, regulatory, judicial, or administrative obligations.
Lastly, Blind Me can process your personal data to uncover or prevent fraudulent activities or breaches to the Service’s safety, in compliance with the law or analyze reports of Members displaying a behavior breaching the Terms of Service.
4. How data is shared
Only certain Blind Me employees from the customer or support services, and authorized managers process Members’ personal data for the purposes described above. These employees and authorized managers only have access to the data necessary to perform their duties.
A Member’s personal data marked as “public” in article 2 above and that appears on his/her profile, is visible to other Members he/she crosses paths with and who have compatible search preferences.
Blind Me may forward some data to a public body, if it is requested to do so, to comply with any judicial or legal request.
Lastly, we may be required to share your data for the purposes of a corporate operation, which include, but is not limited to, a restructuring, a change in control of the company, a merger, an acquisition, a transfer, or a termination of the company.
5. Overview of a Member’s rights
In compliance with the French Data Protection Act of January 6th, 1978 (Loi Informatique et Libertés), and the GDPR, every Member has a right to access, rectify, and a right to data portability and removal of his/her personal data, along with a right to contest or limit processing of his/her personal data, and the right to decide on the way to handle the personal data after his/her death. In an effort to address its Members’ concerns, Blind Me commits to respecting the protection of personal data and to process requests as soon as possible. A Member can exercise his/her rights, granted he/she can prove his/her identity, by sending a letter or email to[email protected]or by exercising his/her rights directly on the Web app.
For any other claim, the Member may lodge a claim with the national authority responsible for the protection of data.
- The right to access allows a Member to ask Blind Me for data pertaining to him/her in an accessible format, based on Article 39 of the French Data Protection Act (Loi Informatique et Libertés), and article 15 of the GDPR.
- The right to correct grants a Member the right to demand Blind Me corrects, adds to, updates or removes any personal data on him/her that is inaccurate, incomplete, ambiguous, out-of-date, or whose use, communication or storage is prohibited based on Article 40 of the French Data Protection Act (Loi Informatique et Libertés), and article 16 of the GDPR. You can modify or rectify your information directly on the Web app. You just need to go on your profile and make changes directly in the sections “My photos”, “Career and Education (Job, Company, University)”, and “About me”. To change your first name, age, or gender, go to your Facebook page and update the “About me – contact and basic info” section of your profile.
- The right to data portability grants a Member the right to receive the personal data he/she gave to Blind Me, in a structured, commonly used format, legible on a machine, and to forward them to another processing entity, in compliance with article 20 of the GDPR.
- The right to contest grants a Member the right to contest, free of charge and at his/her own discretion, the use of his/her data by Blind Me for prospection, especially commercial, and to the processing based on Blind Me’s legitimate interest, in compliance with Article 38 of the French Data Protection Act (Loi Informatique et Libertés), and article 21 of the GDPR.
- The right to delete grants a Member the right to demand the removal, free of charge and at his/her own discretion, of the data transmitted to Blind Me, within the limits of the rights based on article 17 of the GDPR. You can delete your account using the corresponding feature on the Web app.
- The right for the Member to set the guidelines for the retention, deletion and communication of his/her personal data after his/her death, in compliance Article 40-1 of the French Data Protection Act (Loi Informatique et Libertés).
These rights may only be exercised within the limits of Blind Me’s resources as it relates to its use of Facebook Connect. Some of the data is sent to Blind Me by Facebook Connect and cannot be corrected without Facebook's assistance.
The Member can also rectify most of his/her personal data, at his/her own initiative, on the Web app itself.
6. Storage of the data
Blind Me will store the Member's data for as long as required in order for the Member to use his/her Account, namely :
- For the length of the Member’s enrollment, plus one year.
- For the length of the reporting, to process a report on fraudulent behaviour.
- For three years when the account is suspended, in compliance with article 15.4 of the Terms of Service.
Furthermore, please note that in accordance with its status as a hosting provider, Blind Me has a legal obligation to retain some of its Members' personal data for a period of one year based on Article 6, II of the French Trust in the Digital Economy Act (Loi pour la Confiance dans l’Économie Numérique) of 21 June 2004.
Blind Me undertakes to make every effort and to invest all means at its disposal to guarantee that the stored data is as secure as possible. However, it is the Member's responsibility to take appropriate measures to protect his/her data.
Blind Me shall not collect data from minors. Should a Member lie about his/her date of birth, and particularly if he/she fraudulently claims to be over 18 years of age, the parents of the minor in question should inform Blind Me of this by sending an email to the address mentioned in article 9, requesting the data to be deleted. Blind Me commits to deleting all data on the minor in question as soon as possible.
7. Transfer of Personal Data outside the EU
When registering, the Member expressly consents to his/her data being transmitted to Blind Me’s service providers and subcontractors outside the European Union, to let Blind Me run statistical studies, support members, and if need be, host data processed by the Web app.
Blind Me guarantees that the transfers are made under conditions ensuring the confidentiality and security of the data and providing an adequate level of protection in compliance with regulations (notably the examples of contractual clauses provided by the European Commission).
- By filling the contact form on Blind Me’s website ( www.blind-me.com/en/contact ) or directly on the Web app.
- By sending an email to : [email protected]
- By sending a letter to : BLIND 18 rue du chant du merle, 31400 Toulouse FRANCE