PRIVACY POLICY BLACKPILLS_V1 applicable to all residents in the world except US residents:
Updated on 24th May 2018.

Information collected
Purpose of the processing
Recepients
Transfer of the data
Plug-ins
Cookies and analog technologies
Broadcast of Advertisements
Data Storage
Users’ Rights
Data Security
Modification of the Privacy Policy

Welcome to the Privacy Policy for Blackpills SAS, a French simplified joint stock company, (“Blackpills”).  This policy sets forth Blackpills’ handling of data and other information provided by an individual residing anywhere in the world except in the United States, in connection with his or her accessing www.blackpills.com (the “Website”) or the Blackpills’ on-demand video service (the “Service”). Blackpills respects the privacy of each such individual accessing the Website or the Service (“User”) and wants the User to understand how his data and other information is being handled by Blackpills.

This Privacy Policy’s purpose is to define the engagements of Blackpills regarding data protection, confidentiality and security of their personal data with the strict respect of the applicable rules and regulations and the General Data Protection Regulation and as well as the CNIL’s recommendations.

It equally seeks to inform the User of the Service and Site about Blackpills’ commitment regarding personal data protection, that are voluntarily communicated by the User or automatically collected.

The data processing is conducted in conformity to the applicable data protection regulation and in particular the French Act 78-17 of 6th January 1978 on Data Processing, Data Files and Individual Liberties as amended by the European regulation on the personal data protection of 14th April 2016 (hereafter “the personal data protection regulation”).

Information collected

In order to use the Service, the User is invited to sign in and communicate to Blackpills certain information, notably personal data.

This data can be collected and handled by Blackpills in its capacity as designated data processor according to the applicable regulation on personal data.

Blackpills does not collect any personal data without (i) having obtained collecting the explicit consent of the user (ii) having informed of the type of collected data, the purpose of the processing, the identity of the recipient and the rights the User can exercise regarding his data.

Only the necessary and relevant data in respect of Blackpills legitimate purposes are collected.

Furthermore, personal data shall not be stored for longer than is necessary for the purposes for which the personal data are processed by Blackpills.

Information communicated by the User

Upon registration to the Service, Blackpills requests from the User and collects the following personal data: username, valid telephone number and a date of birth (“Mandatory Data”).

Information the User voluntarily provides to Blackpills

The User is free to provide additional information, while it is not an obligation in order to use the Service, in order to create his “user profile”. This additional information is the following: preferred language relative to the audio and subtitles, the opportunity to be notified of any new content/episode (“Optional Data”).

Information collected automatically

During the use of the Service and the Website, Blackpills automatically collects certain information, including personal data, regarding the material used and in which way.  

This information concerns technical data (such as IP address used by mobile devices, operating system, navigator, etc.) and relative information in regards to the User's consultation and the utilization of the Service and the Website's functionalities. (“Information Collected Automatically”)

Purpose of the processing

User’s data, including personal data are collected and processed for the purposes of the legitimate interests pursued by Blackpills.

2.1 Accessing and using the Service and the Website

Blackpills collects and processes Mandatory Data in order for the User to register, access and benefit from the Service’s functionality and potentially from the Website if this function is available.

 2.2 Optimizing the User’s experience

Mandatory Data and Optional Data voluntarily transmitted by the User allows for a better user experience in regards to the use of the Service and the Website. Mandatory Data and Optional Data permit to personalize, adapt and improve the use of the Service and the Website. Blackpills could also use Mandatory Data and Optional Data to target offered advertisements while using the Service and the Website.

2.3 Optimizing and development of the Service and the Website

Data processing as detailed in articles 1.2 and 1.3 seen above, permit to analyze and compile statistics regarding the consultation and the use of the Service and the Website. These studies will enable Blackpills to send notifications including Blackpills’ newsletters provided on the Service. If the User no longer wishes to receive such notifications, he can unsubscribe at any moment by adjusting his settings within his general account.

2.4 Security

In order to create and maintain a trustworthy environment, personal data are stored for security reasons to identify or verify the identity information transmitted by the User and control the respect of the General Terms and Conditions of Sales.
They are also stored in order to fulfill the legal and regulation to which Blackpills must comply.

Recipients

Blackpills proceeds to process data of the User to ensure the functionality of the Service and the Website.

In this context, Blackpills could be required to transfer certain user data to technical or functional processors for the functionality of the Service and the Website, excluding any other use (notably advertising or commercial).

Such processors have a limited access to the data within the execution of their tasks for Blackpills’ account and have contractual obligations of confidentiality and protection of the Users’ data for which they were initially provided.

Transfer of the Data

The collected personal data by Blackpills are neither licensed or exchanged to third parties, at the exception of its partners and affiliates, unless it has been clearly specified during the collection of the data in question and after having been obtained prior User consent. The partners and affiliates of Blackpills only have access to the necessary personal data for the execution of the services and in conformity of the applicable general data protection regulation and are not authorized to exploit them for any other purpose.

The User is informed that this data can be transferred within the Blackpills Group in another country than the country of residence of the User and notably outside the European Union (to the United States of America). The User therefore authorizes the transfer, storage, and processing of this information to the United States of America, and eventually to other countries. Applicable laws in these countries can differ from the applicable laws of the country of residence of the User. Blackpills transfers this data in respect to the French Act 78-17 of 6th January 1978 on Data Processing, Data Files and Individual Liberties, and notably Articles 68 and 69 of this Act.

The User is equally informed that during the data processing, data can be transferred by Blackpills to Blackpills servers, some of which can be located abroad.

Blackpills may be required to disclose personal data without prior User consent in cases where Blackpills would have reasons to believe that this is necessary to identify, contact or engage proceedings against someone who could potentially cause injury or interfere with the rights or ownership of Blackpills or alongside someone who could be affected by these actions. Blackpills could also be required to reveal this personal data in the event Blackpills is brought to believe, in good faith, that this is required by law.
Blackpills could also transfer User information if Blackpills acquires a company or is acquired by another company, in case of a merger or a reorganization of any nature.

Plug-ins

The Website may include social plug-ins. These allow the User to interact with his contacts on the related social medias. The User can, for example, recommend to his contacts some content he has watched on the Website. These Plug-ins are entirely anonymized. No personal data are stored and no user profile is merged with personal data of the User.

Utilization of “Cookies” and analog technologies

Blackpills uses “cookies” and other analog technologies during the consultation of the Website and the use of the Service.  

These tools allow Blackpills to automatically collect certain data concerning the User and his material during the use of the Service and the Website. For example, Blackpills collects the IP address, the name of the web navigator, the data and hour of the last connection and the web browser data, the shared content and for what purpose. Blackpills can equally be required to collect information on the online activity of the User, such as the viewed series.

These technologies allow to compile statistics and information on traffic, to facilitate navigation and improve the Blackpills services for the benefit of the User, who has the possibility to delete the “cookies” stored on his web browser in order to definitively delete the information contained within it. Users may prevent the use of these cookies by configuring his web browser accordingly. User may also prevent the recording of these “cookies” in general or only certain of them, the functions of the Website can be limited.

Broadcast of Advertisements
The Service and/or the Website can expose the User to advertisement and videos of commercial partners of Blackpills. Blackpills cannot in any way be held responsible for the content of the advertisements, sponsorships or videos of commercial partners
This type of advertisement is entirely anonymized. No personal data are stored and no user profile is merged with the personal data of the User.

Data Storage

The data are stored at the host identified in the legal notices (www.iguanesolutions.com) and are kept for the appropriate length of time for the purposes of the processing indicated herein.

The host has a restricted access to the data, such access is limited to the performance of its duties on behalf of Blackpills and has a contractual obligation of confidentiality and to protect the data in order to use them solely for the purposes for which they were disclosed.

User’s rights

In respect to applicable rules and regulations and the General Data Protection Regulation and in particularly to the French Act 78-17 of 6th January 1978 on Data Processing, Data Files and Individual Liberties, the User has the right to control the destination, the reach and scope of its personal data. In that respect the rights of access, rectification, blocking, erasure, restriction of processing, objection and data portability may be exercised by the User by sending a request by e-mail to the controller Blackpills at the following address: contact@blackpills.com.
 
The User is informed that in the event that he requests the erasure of his personal data, Blackpills may nevertheless retain certain personal data necessary for legitimate commercial interests, such as the detection of anomalies and the improvement of security; retain and use the data to the extent necessary to comply with its legal and regulatory obligations; retain residual copies of data on backup systems for a limited period of time.

 Data Security

Blackpills is concerned with the protection of the User’s personal data and implements to this effect all technical and organizational measures reasonably appropriate in order to limit the risk of loss, deterioration, non-authorized access or wrongful use of such data.

Some of these measures used to protect the data are network firewalls, encryption etc. as well as controlled access to information, notably through the implementation of a clearance policy to access documents including personal data.

 Modification of the Privacy Policy

Blackpills can be required, in the future, to update its Privacy Policy, notably if it provides new services and/or in order to comply with new laws and regulations. It shall inform the User of any substantial amendment by sending a notification through the Service or by any other appropriate mean. The User is also invited to consult from time to time the Privacy Policy on the Service or the Website.