Privacy Policy - Fair-eZone

Valid as of 17 September 2019

The purpose of this data protection policy ("Policy") is to inform you about how Fair-eZone collects and processes your personal data when you use:
  • Our websites mypocket.io and www.fair-ezone.com (the "Site"),
  • The MyPocket mobile application available on Android and iOS (the "Mobile Application"),
  • Any services accessible via the Site or the Mobile Application (the "MyPocket Services").

The purpose of this Policy is also to inform you of your rights regarding your personal data. It is therefore important that you familiarise yourself with it, as well as any other specific information that we may communicate to you from time to time, when we collect or process personal data about you.

1. The data controller

The data controller of your personal data is Fair-eZone, a simplified joint stock company, registered with the Nanterre Trade and Companies Register under number 800 845 323, having its registered office at 20 bis Rue Louis-Philippe 92200 Neuilly-sur-Seine, France.

In this Policy, the terms "we", "us", "our" refer to the Fair-eZone company.

2. The personal data we collect

In the course of providing its services, Fair-eZone may collect and process the following categories of personal data about you:

When you subscribe to our MyPocket Services:

  • Identifying data, such as your title, identity, date of birth, nationality, country and place of birth, identity document, selfie, proof of address, professional occupation.
  • Contact data, such as your email and postal addresses and mobile phone number.
  • Financial and banking data, such as monthly income level, expected loading level, expected spending level.

When you use our MyPocket Services to make a transaction:

  • Transactional data, such as amount, currency, card number, bank account number, account balance, merchant, supplier or beneficiary name.
  • Profile data, such as your MyPocket Services usage preferences and direct marketing preferences.
  • MyPocket Services usage data, for incident resolution as part of customer support.

When you browse the Site or use the Mobile Application:

  • Technical data, such as the model of your terminal, your browser, your IP address, your browsing in the Mobile Application or on the Site...
  • If you expressly authorise us to do so, your geolocation data, your telephone contacts, status data from your phone (phone ID, language, ...) and, during the identification document collection phase, images from your phone's camera, in order to scan your identification documents. You may withdraw your consent at any time by deactivating the authorisation given for the MyPocket application in your device settings.

This data is collected and processed for the purposes described below, depending on whether you use the Site, the Mobile Application or our MyPocket Services.

Where we need to collect personal data about you (under a legal obligation or a contract we have entered into with you, or intend to enter into with you) and you do not provide such personal data when requested, we may not be able to provide you with the services you require. The mandatory nature of this data is indicated to you at the time of collection.

3. Why we process your personal data

The table below tells you why your personal data is collected and the legal basis on which Fair-eZone processes your data in compliance with applicable laws and regulations.

Activity / Purpose of processingLegal basisLegitimate interest pursued
(where applicable)
Providing the MyPocket Services

Our contract

Our legitimate interest

Our legal obligations

Our commercial interest in providing you with a quality service
Fighting fraudOur contract
Our legal obligations
Facilitating the marketing of the MyPocket Services that interest you and those of our partners

Our legitimate interest

Your consent

Our commercial interest in facilitating the marketing of the MyPocket Services and promoting those of our partners

Our commercial interest in improving our knowledge of the types of customers using our MyPocket Services

Maintaining the MyPocket Services in operational condition and developing new services

Our contract

Our legitimate interest

Our legal obligations

Our business interest in providing you with an efficient service and support

Our business interest in providing you with new services

Please note that we may process your personal data on the basis of several legal bases, depending on the specific purpose for which we use your personal data. For more details on this subject, please do not hesitate to contact us (our contact details are available below, in point 9).

Fair-eZone does not make decisions based solely on the automated processing of data that would produce legal effects with regard to you.

4. Our use of "cookies"

When using our Sites or our mobile application, information relating to the browsing of the terminal (computer, tablet, smartphone, etc.), may be recorded in "cookie" files deposited on the terminal, subject to the choices expressed concerning cookies and which may be modified at any time.

3 types of cookies are deposited by Fair-eZone:

  • Internal cookies necessary for the Site to function

These cookies enable the Site to function optimally. They include, for example, cookies that allow you to connect to secure areas of our Site.

  • Audience measurement cookies

With a view to tailoring our MyPocket Services to the requests of visitors to the Site, we measure the number of visits, the number of pages viewed as well as visitor activity and frequency of return. We use Google Analytics cookies. Google Analytics collects information anonymously. It reports trends on the Site without identifying individual visitors. You can deactivate Google Analytics without affecting the way you visit the site. For more information about Google Analytics, click here.

  • Third-party cookies designed to improve the interactivity of the site

The Site relies on certain services offered by third-party sites. These include videos broadcast on the Site (Youtube). These features use third-party cookies deposited directly by these services. When you first visit the Site, a banner informs you of the presence of these cookies.

You block cookies by activating the setting on your browser that allows you to refuse the installation of all or some of the cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or part of our Site.

5. Recipients of your personal data

We do not rent, sell or disclose any personal data to third parties for their own marketing use. Your personal data is only shared with third parties in the following circumstances.

We share some of your personal data with partners who provide us with certain specialist services or who cooperate with us on projects. These partners act as separate data controllers and are therefore responsible for their own personal data protection compliance. These include Prepaid Financial Services, the issuer of the MyPocket card, whose data protection policy can be found here.

Your personal data may also be transferred to service providers selected by
Fair-eZone, to provide certain services on behalf of Fair-eZone and in accordance with instructions provided by
Fair-eZone. These service providers ("sub-contractors" within the meaning of the Regulation) are subject to an obligation of confidentiality, and have access to your personal data only to the extent necessary to provide their service and are therefore not authorised to use your data for any other purpose. These include, in particular, our anti-fraud service providers and some of our IT service providers (hosting, audience analysis...).

We may also communicate your personal data (i) if we are required to do so by a legal obligation (ii) to enforce our rights and protect the security of our services and (iii) as part of company mergers or acquisitions.

6. International transfers and security of your personal data

Your personal data that we collect is transferred and stored within the European Economic Area (EEA). As we provide an international service, your data may be processed outside the EEA in order for us to perform our contract with you to provide the MyPocket Services. We will need to process your personal data in order, for example, to comply with a request from you to make an international money transfer, to process your payment information and to comply with our anti-fraud obligations. We will take all necessary steps to ensure that your personal data is processed securely and in accordance with this Policy.

7. How long we keep your personal data

Your personal data is kept by Fair-eZone for as long as is necessary to fulfil the purposes for which it was collected.

In determining the appropriate retention period for your personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk arising from unauthorised use or disclosure of the personal data, the purposes for which we process your personal data as well as our legal obligations.

8. Your rights

Depending on your personal situation, you have the rights listed below in application of personal data protection regulations. We will honour your requests as required by the applicable regulations, but please bear in mind that these rights are not absolute: they do not always apply and may be subject to exceptions.

Right of access: You have the right to access the personal data we hold about you. This gives you the right to receive a copy of your personal data and certain information relating to the processing of your personal data.

Right to rectification:You have the right to ask us to correct your personal data if it is inaccurate or out of date. If you have created a user account, you can correct some of your information by visiting your account.

Right to erasure:In certain circumstances, you have the right to request the erasure of your personal data. Please note that your personal data may only be erased when it is no longer necessary for the purposes for which it was collected and we have no other legal basis for processing it.

Right to object:Where we process your personal data on the basis of a legitimate interest, you may object to this processing where your particular circumstances justify it. In some cases, we may not comply with your request if we demonstrate that the legitimate interest we are pursuing prevails. You also have the right to object to the processing of your personal data for direct marketing purposes at any time and without justification.

Right of limitation:You may request the limitation of the use of your personal data in certain circumstances, in particular where the data is not or is no longer necessary, or, if you have disputed its accuracy, while we can verify its accuracy.

Right to portability:We will provide you, or a third party chosen by you, with your personal data in a structured, commonly used and machine-readable format. Note that this right only applies to your personal data that we process in an automated way, (i) with your consent or (ii) as part of the performance of a contract entered into with you.

Fate of data after death:You may formulate directives relating to the retention, erasure and communication of your personal data after your death.

In addition, if the processing of your personal data is based on your consent, you also have the right to withdraw your consent at any time.

You will not be charged a fee to access your personal data or to exercise any of the other rights mentioned above. However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive. Alternatively, we may refuse to respond to your request in these circumstances.

We may ask you for specific information to help us confirm your identity so that we can respond to your request. We try to respond to all legitimate requests within one month.

9. Contacting us

If you have a question about how we use your personal data or would like to exercise any of the above rights, you can contact us by email or registered post:

  • legal@fair-ezone.com
  • Fair-eZone (Personal Data), 20 Bis, rue Louis-Philippe 92200 Neuilly sur Seine, France.

You also have the possibility of lodging a complaint regarding the processing of your personal data with the Commission nationale de l'informatique et des libertés (CNIL).

10. Updates to the Policy

We may revise this Policy from time to time. We ensure that the most recent version is published on the Site. When material changes are made to the Policy, we will notify you by posting a notice online and/or sending you an email.

The Policy was last updated on 17 September 2019.

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