This Privacy Policy concerns the processing of personal data (hereinafter « Personal Data ») while you are using the smartphone or tablet application « Pulssy » (hereinafter the « Application ») as published by Krystal, a French “société par actions simplifiée” registered under the number 512988643 at the Nanterre “Registre du Commerce et des Sociétés”, with headquarters located at 33 rue Anna Jacquin 92100 Boulogne-Billancourt and represented by its President, Jerome Olivet (hereinafter « Krystal »).
The Personal Data collected are processed by Krystal, or on its behalf, under the conditions set out below. As a Data Controller, Krystal undertakes to implement adequate measures to ensure the protection, confidentiality, and security of your Personal Data and to process and use such data in compliance with all applicable laws and regulations, in particular the European Union Regulation 2016/679 of 27 April 2016 (hereinafter the « GDPR ») and French law n° 78-17 of 6 January 1978 known as the « Loi informatique et libertés », and any other law or regulation that may be added to it or take its place.
The purpose of this Privacy Policy is to inform you of the way Krystal processes the Personal Data that you provide, and that Krystal collects, while you are using the Application. It applies to all use of the Application by individuals signed up to use the Application (hereinafter the « Users »). For any services provided and operated by third parties, please refer to the privacy policies of those service providers.
1. What Personal Data is processed by Krystal?
Personal Data means any information relating to an identified or identifiable natural person (“Data Subject”) who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. Krystal collects and processes your Personal Data when you use the Application, including:
– Information that you provide directly to Krystal.
– Information that Krystal collects automatically from you.
– Information that Krystal collects from third parties.
When you sign up to the Application by SMS, the following Personal Data are mandatory:
– Your phone number, when you register using that phone number.
– Your first name.
– Your date of birth.
– Your gender.
– Your search preferences relating to the type of meeting that you seek (with men, women, or both), your expectations in terms of relationship and your current state of mind. You can change this information at any time in the Application settings.
– At least one profile picture.
Some of this information identifies you. Once communicated, the following information will be visible to other Users and made public on the Application:
– Your photos.
– Your first name.
– Your age (derived from your date of birth).
– Your gender.
– Your biography, if you have filled it in.
– Your geographic proximity with other Users.
Additional data such as geolocation and content of text messages sent on the Application are required to provide services and functionalities according to the Terms and Conditions of Use of Krystal.
Data that Krystal Collects from Third Parties
When you sign up to the Application via third-party services:
– Google Account: By clicking on the « connect with Google » button, Krystal collects from Google your first and last name, your date of birth, your email address, and your gender.
– Apple Account: By clicking on the « connect with Apple » button, Krystal has access to your name and your email address.
Data that Krystal Collects Automatically
Krystal automatically collects the following data when you use the Application:
– Activity Data: This includes the date you signed up, your connection history, « connected » or « disconnected » status, interactions with other users, number of transactions, and actions such as scrolling, clicking, and adding items to a cart.
– Technical Data: IP address, application version, device version and model, mobile or device identifier, connection history, the country you are located in, language used, application crashes, and browser used.
– Advertising Identifiers: Such as IDFA for Apple and GAID for Google, along with the identification number of the iOS or Android operating system used.
– Bank Transaction Data: No banking data is collected or processed directly by Krystal. These data are exclusively collected and processed by the App Store or Play Store. Krystal only keeps the transaction numbers for validation, along with your purchase and subscription history.
Legal Bases for Processing Your Personal Data
– Contractual Necessity: Krystal processes data necessary for the performance of its contract with you, including managing your account, delivering services you have requested, and managing customer service interactions.
– Legitimate Interests: Krystal processes data based on legitimate interests, such as enhancing user experience, improving and customizing service offerings, and for safety and security purposes.
– Consent: For certain types of processing, Krystal relies on your consent, such as for sending marketing communications or for non-essential cookies and similar technologies on the Application.
Sensitive Data Handling
Krystal understands the importance of additional protections required for sensitive data under the GDPR. This includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, or data about a person’s sex life or sexual orientation. Such data is processed only when strictly necessary or with your explicit consent.
Profile Verification and Security Measures
To enhance security and user trust, Krystal implements measures such as:
– Account Verification: This may involve sending a code to your phone or asking you to perform actions that confirm control of your account.
– Photo Verification: Users may voluntarily participate in photo verification to receive a ‘verified’ badge. This process involves scanning submitted photos using facial recognition technology to compare with profile photos to ensure authenticity. Verification photos are not used in the profile and are stored securely for future comparisons.
Krystal is committed to maintaining the highest standards of data privacy and security. If you have any questions about how your personal data is handled or wish to exercise any of your rights, you can contact Krystal at any time via the contact information provided on the application or through their website. Additionally, if you have concerns or complaints, you are encouraged to reach out directly before contacting regulatory authorities.
Personal Data Collection from Third Parties
When you sign up to the Application via third-party services such as Google or Apple:
– Google account: By clicking on the « connect with Google » button, Krystal collects from Google your first and last name, your date of birth, your email address, and your gender.
– Apple account: By clicking on the « connect with Apple » button, Krystal has access to your name and your email address.
1.2. Data that Krystal Collects Automatically
When you use the Application, Krystal automatically collects the following data:
– Data related to your activity on the Application, such as the date you signed up, your connection history, your « connected » or « disconnected » status, your interactions with other Users, your number of transactions, notifications received, and your actions such as scrolling, clicking, adding to cart, etc.
– IP address, application version, device version and model, mobile or device identifier, connection history, the country in which you are located, language used, application crashes, browser used, advertising identifiers such as IDFA for Apple and GAID for Google, and the identification number of the iOS or Android operating system used.
– Bank transaction data: No banking data is collected or processed by Krystal directly. These data are exclusively collected and processed by the App Store or Play Store. Only the transaction numbers, for their validation, and your purchase and subscription history are kept by Krystal.
2. Why Does Krystal Process Your Personal Data and What Is the Legal Basis for the Processing?
2.1. To Comply with Krystal’s Terms and Conditions of Use
– Creation and management of your User account, to verify your compliance with the Code of Conduct and to validate your signing up to the Application.
– Management and storage of communications exchanged between Users, in particular « likes » and « dislikes », to determine whether there is a match and, if not, to avoid displaying the same profile twice.
– Management of subscriptions and paid services as subscribed.
– Sending of notifications relating to use of the Application.
– The legal basis for this processing is the performance of a contract to which you are a party.
2.2. To Suggest Profiles to You
– Krystal uses indications based on users’ profiles to recommend the most relevant profiles to maximize everyone’s chances of finding meaningful connections.
– The matching algorithms are based on a range of factors and use machine learning to rank profiles to maximize your chance of finding compatible matches.
– Data used include your profile information (age, distance, gender), how you interact with the app, and your device coordinates to understand your proximity to other members.
– The legal basis for this processing is the performance of a contract to which you are a party.
2.3. To Ensure the Security of Your Personal Data and Respond to User Requests
– Monitoring or preventing security breaches and identifying and analyzing fraudulent activity to ensure that the Application may be used in good technical and operational conditions.
– The legal basis for this processing is the legitimate interest of Krystal to ensure the security of your Personal Data.
2.4. To Manage Krystal’s Marketing Operations
– Conducting marketing campaigns and allowing selected partners to conduct campaigns on behalf of Krystal.
– Partners may use cookies which require your consent, which can be managed at sign-up via the cookie management banner.
– You can withdraw your consent at any time, modify your preferences in the Application’s settings, or object to the processing by contacting (mailto:contact@pulssy.com).
– The legal basis for the processing described above is your consent.
2.5. To Detect or Prevent Fraudulent Activities
– Automated analysis of profile data and activity on the Application to ensure the quality of User profiles and to detect false profiles and fraudulent behavior.
– The legal basis for this processing is the legitimate interest of Krystal to prevent fraudulent activity.
3. How Long Does Krystal Keep Your Data?
Krystal retains your Personal Data as long as necessary for the purposes for which they were collected and processed and as long as your Application account exists. Details of data retention include:
– Duration of the User’s use of his or her User account plus one (1) additional year.
– Data of banned accounts are kept for one (1) year in Krystal’s active database and are archived for a further year before being permanently deleted.
– Users’ Personal Data may be kept for a longer period in intermediate archiving, in accordance with legal or regulatory obligations or for the purposes of the establishment, exercise, or defense of legal rights.
4. Personal Data of Children
The use of the Application is reserved exclusively for adults. Krystal reserves the right to verify that the User is over 18 years old.
5. To Whom is Your Personal Data Intended and How Is It Shared?
Krystal’s authorized managers process Users’ Personal Data for the purposes described above and only process such data that are necessary for the execution of their assignments such as providing assistance to Users or tracking their reports and requests.
The Application’s main functionality being the development of relationships with other Users, your data is shared with those other Users.
Krystal also shares some of your data with authenticated and trusted service providers and partners in compliance with the Privacy Policy and who guarantee the security and confidentiality of Users’ Personal Data.
In particular with:
– Social Networks: Connection via Google ([Google Privacy Policy](https://policies.google.com/privacy?hl=en-US)) and connection with Apple ([Apple Privacy](https://www.apple.com/privacy//))
– Subcontractors for App Hosting and Maintenance: Google ([Google Privacy Policy](https://policies.google.com/privacy?hl=en-US))
Krystal may also share your information with third parties:
– To comply with legal obligations and to enforce its rights;
– If Krystal is involved in, without this list being exhaustive, restructuring, change of control, merger, acquisition, disposal, dissolution…
6. Is Your Personal Data Transferred Outside the European Union?
Users’ Personal Data may be transferred to entities such as Google in the United States for data hosting services. These transfers of Personal Data are secured by standard contractual clauses, validated by the European Commission and approved certifications or other relevant security measures allowing data transfers from the EU to other countries.
7. What Are Your Rights and How to Exercise Them?
In accordance with the GDPR and French law n° 78-17 of 6 January 1978, known as the « Loi informatique et libertés », you have the right:
– To access your Personal Data under the conditions set out in Article 15 of the GDPR;
– To rectify your Personal Data that are incomplete, inaccurate, out-of-date, or deleted in accordance with Article 16 of the GDPR. You have the right to modify and rectify certain data directly from the Application;
– To the portability of the Personal Data you have provided, in a structured, commonly used, and machine-readable format and to have such Personal Data transmitted directly to another Data Controller, when technically possible (Article 20 of the GDPR). Krystal reserves the right to verify the identity of the applicant. Proof of identity may be requested and will not be transmitted or transferred to third parties;
– To object at any time, for reasons related to your particular situation, to the processing of Personal Data for prospecting purposes. Krystal will no longer process such data, unless it can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the Data Subject, or for the establishment, exercise, or defense of legal claims;
– To request Krystal to erase your data within the limits of the rights based on Article 17 of the GDPR. You also have the possibility to delete your User account directly on the Application, in the « Settings » tab. Krystal, as host, has the legal obligation to keep your Personal Data for one (1) year under Article 6-II) of French Law N° 2004-575 of 21 June 2004 “Loi pour la confiance dans l’économie numérique”. The data will be kept in a separate archive solely for the purpose of responding to a judicial requisition and will be permanently deleted at the end of the aforementioned one-year period;
– To restrict some of your data under the conditions of Article 18 of the GDPR;
– To define the directives relating to the conservation, deletion, and communication of your Personal Data after your death in accordance with Article 85 of the ”Loi informatique et liberté”.
Krystal undertakes, within its capabilities, to respect the protection of your Personal Data and to process your requests as soon as possible. Please note that data communicated to Krystal via third-party platforms like Google or Apple cannot be rectified without their cooperation.
You can exercise these rights by sending an email to: (mailto:contact@pulssy.com), directly from the Application, or by sending a letter to the following postal address: Krystal, 33 rue Anna Jacquin 92100 Boulogne-Billancourt.
In case of doubt about the identity of the applicant, proof of identity may be requested.
For any additional information or complaint, you can contact the Commission Nationale de l’Informatique et des Libertés (CNIL) or any other competent supervisory authority. Please contact Krystal prior to lodging a complaint.
8.How to Contact Krystal?
For any questions relating to this Privacy Policy or for any request relating to your Personal Data, you can contact Krystal:
– By email, directly from the Application at our contact email address: (mailto:contact@pulssy.com);
– By mail at the following postal address: Krystal, 33 rue Anna Jacquin 92100 Boulogne-Billancourt.
Last update: 17 April 2024