This privacy notice for SACLIC STUDIO (“we,” “us,” or “our”) describes how and why we may collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:
• Download and use our mobile application (HoldX, or any other application of ours that links to this privacy notice).
• Engage with us in other related ways, including any sales, marketing, or events.
By accessing or using HoldX, you consent to the practices described below. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at
[email protected].
SUMMARY OF KEY POINTS
• What personal information do we process? We collect personal information that you voluntarily provide to us. This can include name, email address, and payment data for subscriptions.
• Do we process any sensitive personal information? No, we do not process sensitive personal information.
• Do we receive information from third parties? We do not receive any personal information from third parties.
• How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, and for security and fraud prevention.
• With whom do we share your personal information? We may share information in specific situations (e.g., payment processing) or with trusted service providers.
• How do we keep your information safe? We have industry-standard security measures in place but cannot guarantee 100% security.
• What are your rights? Depending on where you live, you may have certain rights to review, change, or terminate the personal information we collect from you.
• How can you exercise your rights? The easiest way is by contacting us at
[email protected].
For a detailed explanation, please continue reading the full privacy notice.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
13. CONVERSATION DATA COLLECTION AND USAGE
14. COLLECTION AND USE OF FACIAL DATA
15. DO WE MAKE UPDATES TO THIS NOTICE?
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal Information You Disclose to Us
We collect personal information that you voluntarily provide to us, such as:
• Names
• Age
• Gender
You may also choose to provide additional personal details when interacting with our Services (e.g., birthdate, personal relationships, etc.). All personal information must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information Automatically Collected
We automatically collect certain information when you use the Services, including:
• IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, and location.
• Mobile device data, such as device ID, model, manufacturer, operating system/version, and application usage.
This information is primarily needed to maintain the security and operation of our Services and for our internal analytics and reporting purposes.
2. HOW DO WE PROCESS YOUR INFORMATION?
We process your personal information for a variety of reasons, including to:
• Provide, improve, and administer our Services.
• Communicate with you (e.g., sending updates, support messages).
• Ensure security and fraud prevention.
• Comply with legal obligations.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
EU/UK Users
If you are located in the European Union or the United Kingdom, we rely on applicable legal bases, including your consent (where relevant), to process your personal information under the General Data Protection Regulation (GDPR) and other applicable data protection laws.
Other Locations
In other jurisdictions, we only process your information when we have a valid legal reason to do so, such as your consent or as otherwise permitted by local laws.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
We do not sell or rent your personal information. However, we may share your data with:
• Service Providers: Trusted third parties that assist with payment processing, analytics, and hosting.
• Legal Compliance: When required to comply with legal obligations or protect the rights, safety, and property of SACLIC STUDIO, its users, or others.
• Business Transfers: In the event of a merger, acquisition, or sale of assets.
5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
Our servers may be located in the United States or other countries. If you access our Services from outside these regions, your information may be transferred to and processed in countries where data protection laws may differ from those in your jurisdiction. We take measures to ensure your personal information remains protected.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
We retain personal information for as long as necessary to fulfill the purposes outlined in this notice, or as otherwise required by law. Once we no longer need your information, we will delete or anonymize it in accordance with our data retention policies.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
We employ organizational and technical measures to protect the personal information we process. However, no method of transmission or storage is 100% secure. We cannot guarantee total security, and you use the Services at your own risk.
8. DO WE COLLECT INFORMATION FROM MINORS?
We do not knowingly collect or market to individuals under the age of 18. If we discover that we have inadvertently collected data from a minor, we will delete it as soon as reasonably possible.
9. WHAT ARE YOUR PRIVACY RIGHTS?
Depending on where you live, you may have the right to:
• Access: Request a copy of the personal data we hold about you.
• Rectification: Correct inaccurate or incomplete information.
• Erasure: Request deletion of your personal data.
• Restriction: Limit the processing of your personal data.
• Objection: Object to certain types of processing.
• Withdrawal of Consent: Withdraw any consent you have given us.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature. We do not respond to DNT browser signals.
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
If you are a resident of states with specific data protection laws (e.g., California, Colorado, Connecticut, Utah, or Virginia), you may have additional rights regarding your personal information. We have not sold or shared personal information in the last 12 months.
12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
Residents of Australia, New Zealand, and the Republic of South Africa may have additional rights regarding personal information. Please contact us if you believe such laws apply to you.
13. CONVERSATION DATA COLLECTION AND USAGE
We may collect and analyze conversation data to improve functionality, while respecting user privacy. Any such data is handled securely, and used solely for the purpose of enhancing user experience.
14. COLLECTION AND USE OF FACIAL DATA
If our Services require collecting facial data (for example, selfies or images for certain analyses), it is used only for the specific feature and is not stored permanently. Any analysis happens in real time, and data is deleted thereafter.
15. DO WE MAKE UPDATES TO THIS NOTICE?
Yes, we may update this notice as required by law or business practices. We will notify you of significant changes and encourage you to review this notice regularly.
16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at
[email protected] or write to us at:
SACLIC STUDIO
60 RUE FRANCOIS IER
75008 PARIS, FRANCE
SIREN: 935200071
17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
To request to review, update, or delete your personal information, please email us at
[email protected]. We will consider and act upon any request in accordance with applicable data protection laws.
For any further inquiries, please reach out to us at
[email protected].