Privacy Policy

1. General

Thot, acting as data controller, undertakes to protect and respect your privacy. The purpose of this notice is to inform you of our practices regarding the collection, use and disclosure of information you may provide through our mobile application.

This Privacy Policy sets out the basis on which any personal data we collect from you or that you provide to us will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

2. What information do we collect from you and for how long?

We may collect and process the following data about you:

2.1 Information you give us

You may provide us with information, including personally identifiable information ("Personal Data"), when you use our Platform, by filling in forms on the Platforms (such as the registration form), when you participate in one of our contests, promotions or surveys, when you correspond with us by phone, email or otherwise, and when you report a problem with the use of our Platform

The information you provide to us may include:

  • Required information required to register for the service we provide on our Platform or to access other services we provide, including your name, email address, date of birth and, when you create an account, a password. All of these fields are required. Thot will not be able to provide you with the services offered on our Platforms if the required information is not provided or, if applicable, you will not be able to create a user account on our Platform;
  • A profile picture;
  • A postal address;
  • Your telephone number;
  • Details of your knowledge and knowledge ;
  • Your mini-biography, your gender when you agree to provide this information;
  • A record of any correspondence between you and Thot ; we may record and/or listen to telephone calls between you and Thot (e.g. with our Community Relations officers). We give you the opportunity to object to this processing at the beginning of the call;
  • A record of all bookings you have made or application-related advertisements you have placed with or through our Platform;
  • Details of accounting or financial transactions, including transactions made through our Platform or otherwise. This may include information such as your payment card or bank account details, details of services or steps you have booked or offered through our Platform;
  • Details of your visits to our Platform and the resources you access;
  • Your answers to any surveys or questionnaires, such as your opinions on exchanges made via our Platform. This information may be used for user analysis and understanding purposes;
  • Information we may ask you for when you report a problem with our Platform or service, such as the subject of your support request;
  • Location information where you have given your consent to the collection and processing of this data so that we can respond to your search for trips near you; and
  • A copy of identity card and other similar documents that you have agreed to provide to us.

2.2 Information We Collect Automatically

  • If you register via authentication methods on social networks, Thot will access certain personal data (e.g. first name, last name, photo and email) in your social media account in accordance with the applicable terms and conditions of these social media platforms. We may also collect some of your personal data when you interact with third-party social media features, such as "Like" features.
  • With respect to each of your visits to our Platform, we may collect, in accordance with applicable laws and where applicable with your consent, information relating to thedevices you use and the networks to which you are connected when using our services. This may include the following information: your IP address, login information, browser type and version, browser plug-in types and versions, operating system and platform, information about your visit, including URL clickstream to different pages of our platform, content you viewed or searched for, search terms used, download errors, length of visits to certain pages, your device's advertising ID, interaction with the page, and any phone number used to contact us. We collect this information through the use of various technologies, including cookies.
  • We also collect aggregated information about your activity on our Platform (such as the number of bookings offered, your response rate to messages, etc.).

2.3 Data retention

With the exception of the categories of Personal Data mentioned in clauses 2.3.2 and 2.3.3 below, your Personal Data will be archived after the following retention periods:

  • 5 years after your last use of our Platform, if you have not closed your account;
  • 30 days after the closure of your account, unless you have received a negative rating or report, in which case your data is kept for 2 years after the closure of your account.

The following categories of Personal Data may be kept for different periods of time:

  • Financial data (payments, refunds, etc.) are kept for the duration required by applicable tax and accounting laws (e.g. accounting records are kept for up to 10 years);
  • All user-generated content (e.g. comments, reactions and ratings) is anonymized for the periods mentioned in section 2.3.1 but remains available on our Platform;
  • Log data is kept for up to 12 months from the date of collection;
  • Phone calls with our Community Relations department are kept for up to 1 month and analysis documents (such as the time and duration of the call) are kept for up to 1 year.

In case of suspension or blocking of your account, we will keep your data for a period of 2 or 10 years depending on the severity of the breach in order to avoid you circumventing the rules applicable to our Platforms.

We may archive some of your Personal Data for a period not exceeding five (5) years in order to comply with our legal obligations and to manage any disputes.

3. How do we use the information we collect from you?

We will use the information we collect:

OBJECTIVES LEGAL BASIS

3.1. To perform our obligations arising from any contract entered into between you and us or between you and our business partners and to provide you with the information and services you have requested;

This processing is necessary for the performance of our mutual contractual obligations.

3.2. To send you service-related information by email and/or SMS and/or any other means of communication (e.g. your booking confirmation);

This processing is necessary for the performance of our mutual obligations or carried out with your consent.

3.3. To collect payments from you or to transfer payments to you that we collect on your behalf;

This processing is necessary for the performance of our mutual contractual obligations.

3.4.To allow you to personalize your user profile This processing is carried out with your consent.

This processing is carried out with your consent.

3.5.To allow you to communicate and interact with other members spread over the Platform about our services or about the reservation(s) you have/will make and/or arrange;

This processing is necessary for the performance of our mutual contractual obligations or carried out with your consent.

3.6. To provide you with access and to enable you to communicate with our Community Relations department;

This processing is (i) necessary for the performance of our mutual contractual obligations, (ii) carried out with your consent or (iii) necessary for the establishment, exercise or defence of legal claims.

3.7. To improve our Community Relations service and train our customer agents by recording your telephone conversations with us;

This processing is based on our legitimate interest (to provide you with high-quality customer support/to improve our customer support).

3.8.To ensure compliance with applicable laws, our Terms and Conditions, and our Privacy Policy. Certain breaches that we consider inappropriate may result in the suspension of your account on our Platform. For these purposes, we may use technologies to automatically analyze your use of the Platform, including the content of your posts, to detect behavior that may constitute a violation by you;

This processing is necessary for the performance of our mutual contractual obligations, is based on your consent or for the establishment, exercise or defence of legal claims.

3.9. To send you, in accordance with applicable laws and where applicable, with your consent, marketing materials and information necessary to facilitate the service or booking process and to make suggestions and recommendations to you about goods or services related to our services that may be of interest to you. We also use your data to target you to serve our ads on social media platforms or third-party sites. You can learn more about how these features work and what data we obtain about you by visiting the relevant sections of third-party social media platforms or sites;

This processing is based on your consent where required by law or on our legitimate interest (i.e. to provide you with meaningful advertising).

3.10. To notify you about changes to our services;

This processing is necessary for the performance of our mutual contractual obligations, compliance with our legal obligations or the establishment, exercise or defence of legal claims.

3.11. To verify the information contained in your Passport, ID Card and other identification documents that may be collected from you at the time of registration or at any other time during your use of our Platform;

This processing is based on your consent, carried out for the establishment, exercise or defence of legal claims or for compliance with our legal obligations.

3.12. To administer our Platforms and for internal operations, including troubleshooting, data analysis, testing, research, analysis and investigations;

This processing is based on our legitimate interest (i.e. to ensure the security of our Platform and improve its functionality).

3.13.To improve our platform to ensure that content is presented in the most effective manner for you and your device;

This processing is based on our legitimate interest (i.e. to provide you with relevant content).

3.14. To allow you to participate in interactive features of our Service, when you choose, such as searching for knowledge and individuals around you based on your location;

This processing is necessary for the performance of our mutual contractual obligations or on the basis of your consent, where required by law.

3.15. As part of our efforts to ensure the security of our Platform; and

This processing is based on our legitimate interest (ensuring the security of our Platform), carried out for the establishment, exercise or defense of legal claims or for compliance with our legal obligations.

3.16. To measure or understand the effectiveness of the advertising we serve and to provide relevant advertising to our users.

This processing is based on our legitimate interest (i.e. measuring and optimising the effectiveness of our advertising campaigns) or your consent where required by law.

4. Who are the recipients of the Information we collect from you and for what purposes?

4.1.When you use our services, certain information about you is shared with members of our communities or with operators on our Platform, either on your public profile or during the booking process.

4.2.We may receive and send information about you, including your personal data, to other entities and affiliates of Thot, for the purposes described in this Privacy Policy.

4.3. We also work closely with third parties who may be recipients of your Personal Data such as:

  • Our business partners who are social media platforms and who may provide you with login services, such as connecting your Thot profile information, from their social media platforms to our Platform;
  • Our business partners who may advertise their services on our Platforms and to whom you may choose to register;
  • Our business partners who may advertise our services on their websites;
  • Our subcontractors, including in technical, payment, identity verification and delivery services, or analytics providers.

4.4. We only share your personal data with one of these third parties mentioned in section 4.3 in the following cases:

  • When we use a third party service provider, for the performance of any contract we enter into with you to facilitate or extend our services (for example in connection with payments made on our Platform);
  • As part of the booking process and in order to provide the requested services, information such as your name, photograph, mobile phone number and/or e-mail address, may be displayed on the Platform and/or transmitted to another member;
  • As part of our rating system, the reviews you write will be published on the Platform. Reviews including your short name and photograph are visible to all visitors to the Platform;
  • We use analytics and search engine providers to help us improve and optimize our Platforms;
  • It is explicitly requested by you (for example when using social media authentication methods, subscribing to a service offered by one of our partners, requesting participation in an offer or a good plan of one of our partners);
  • We may distribute portions of our Platforms (including bookings you have posted) for display on our business partners' websites via APIs or widgets. In these cases, certain information from your public profile may be displayed on these sites;
  • If required by law or in good faith, we believe it is reasonably necessary to respond to claims made against Thot, comply with legal process, enforce any agreements with our users such as our Terms and Conditions and Privacy Policy, in the event of an emergency involving danger to public health, death or bodily harm to a person in connection with an investigation or to protect rights, the property or personal safety of Thot, its members or others;
  • In the event that we sell or buy a business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and
  • If Thot or all or part of its assets are acquired by a third party, in which case the Personal Data held by it on its members will be part of the assets transferred.

4.5. In accordance with applicable laws and where required with your consent, we may combine information about you, including your personal data and cookie information, that we send to and receive from our business partners. We may use this information and the combined information for the purposes set out above.

4.6. We draw your attention to the fact that if you decide to share your information, including Personal Data, with us through the matchmaking services of our business partners, the privacy policies and/or notices of our business partners may also apply to you, in addition to this privacy policy. We do not control the collection and/or processing of your information that may be carried out by our business partners on their own platforms.

5. How do we use and moderate your messages?

5.1.We may read messages you exchange with other members of our community through our Platform for the purposes of fraud prevention, service improvement, customer support, performance of contracts with our members (such as our Terms and Conditions). For example, in order to prevent circumvention of our online booking system, we may scan and analyze messages sent through our Platform to ensure that they do not contain contact details or references to other websites and, where appropriate, messages may be blocked, or totally or partially filtered.

5.2. We never scan or analyze your messages with other members of our community for commercial and advertising purposes. We may use automated methods to moderate these messages, but no automated individual decision-making is made in this regard.

6. Targeted ads and our email and/or SMS communications

In accordance with applicable laws and where required with your consent, we may use the information you provide to us on our Platform for electronic direct marketing purposes (e.g. receiving our newsletters, receiving invitations to our events or other communications that we may be of interest to you or providing you with targeted advertisements on social media platforms or third party websites based on your profile). and your interests.

For electronic marketing communications :You may withdraw your consent at any time by unchecking the relevant box in your member account, clicking on the unsubscribe link we provide in each communication addressed to you or contacting us using the contact details provided.

For targeted ads and content :

  • On social networks (e.g. Facebook): you can object at any time by configuring your advertising settings directly via your social network account or by contacting us;:
  • On third-party sites: please refer to our cookie policy to find out how to object.

7. Is your information transferred, how and where?

In principle, we store the personal data we hold about you in the European Union ("EU"). However, as some of our service providers are based in countries outside the European Union ("third countries"), we also transfer some of your data to third countries. This may include third countries for which the European Commission has not decided that that third country ensures an adequate level of protection. In this case, we ensure that the transfer is carried out in accordance with the applicable legislation and that appropriate safeguards have been put in place (including standard contractual clauses as enacted by the European Commission) to ensure a sufficient level of protection for individuals. privacy and fundamental rights.

8. What are your rights regarding your personal data?

8.1.You have the right to receive a copy of your personal data in our possession (your right to access the data).

8.2. You may request the deletion of personal data or the correction of inaccurate personal data (your right to erasure and rectification). Please note that we may retain certain information about you, as required by law, or where we have a legal basis to do so. For example, if we believe you've committed fraud or violated our Terms and Conditions and we want to prevent you from circumventing our community guidelines

8.3.You have the right to object at any time to the processing of your personal data for direct marketing purposes, or to any other processing of your personal data based on our legitimate interest (your right to object to processing).

8.4. You have the right to restrict the processing of your personal data (your right to restriction of processing). Please note that this only applies if you have contested the accuracy of your personal data and we verify the accuracy of the personal data, you have exercised your right to object and we are still considering, as provided by applicable law, whether the legitimate grounds we pursue prevail over yours; or your personal data has been processed by us unlawfully and you request a restriction of its processing rather than erasure; or we no longer need the personal data for the purposes of processing, but they are still necessary to establish, exercise or defend legal claims.

8.5.You have the right to data portability, i.e. the right to receive the Personal Data you have provided to us, in a structured, commonly used and machine-readable format and the right to transmit such data to another controller (your right to data portability)

8.6. You also have the right to lodge a complaint with the competent data protection supervisory authority or to seek a remedy before the courts if you believe that your rights have been violated.

8.7.To exercise your rights, please contact the Group's Data Protection Officer using the contact details provided.

9. Cookies and similar technologies

For more information, please see our Cookie Policy

10. Confidentiality of your password

Where you have chosen a password that allows you to access your account on our Platform, you are responsible for maintaining the confidentiality of that password. We ask that you do not share a password with anyone

11. Links to Other Websites and Social Media

Our Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy practices and that we do not accept any responsibility or liability for these policies. Please check these policies before submitting any personal data to these websites.

12. Changes to our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page. If so, we will inform you or ask for your consent. Please check back frequently for updates or changes to our Privacy Policy.

13. Responsible for contacts and data protection

If you have any questions about this privacy policy or if you have any requests regarding your personal data, you can contact us with our data protection officer.