1.     DEFINITION AND NATURE OF PERSONAL DATA

When using the websites www.zplintr.com, www.optionizr.com and their subdomains (hereinafter referred to as the “Website”), through which you can access an options’ service allowing you to benefit from a ‘time to think’ period before completing a reservation on the online seller platform offering our services and through which you have access to these services, and to process these services, you may be required to communicate your personal data.

“Personal data” shall mean any information relating to the identification of a person, such as surname, first name, alias, photograph, postal address and e-mail, phone numbers, date of birth, data relating to your transactions on the website, details of your purchases and subscriptions, credit card numbers, and any other information you choose to share with us.

2.     PURPOSE OF THE CHARTER

We inform you that we collect and process your data exclusively as required by the online seller, as a subcontractor within the meaning of the GDPR. We do not use your personal data for our own purposes.

The purpose of the charter is to inform you about the means used to collect your personal data, with the strictest respect for your rights, as required by the online seller.

Regarding the collection and processing of your data, we inform you that we comply with Data Protection Act n° 78-17 of January 6th, 1978 (loi n° 78-17 du 6 janvier 1978 relative à l'informatique, aux fichiers et aux libertés) in its current version, as well as the provisions of the European General Data Protection Regulation n°2016/679 (hereinafter referred to as the "GDPR").

3.     IDENTITY OF THE PERSON IN CHARGE OF DATA COLLECTION

The person in charge of collecting and processing your personal data is the online seller offering our services on his platform, and whose contact details may be found on the platform, in the section “terms and conditions”.

As part of our mission assigned by the online seller, we inform you that your personal data are collected in his name and on his behalf by Optionizr, a société par actions simplifiée, registered with the Trade and Companies Register of Nanterre (Registre du Commerce et des Sociétés de Nanterre) under the number 810 583 260, with its registered office at 9 Allée Claude Monet, 92300 Levallois, France (hereinafter referred to as “we”, “us” or “our”).

4.     PERSONAL DATA COLLECTION

The collection of your personal data has several purposes:

(i)           Manage your access and the use of the services available on the Website to which you have subscribed,

(ii)         Process client management operations relating to contracts, orders, invoices, loyalty programs, customer relations monitoring,

(iii)        Create a file of registered members, users, customers and prospects,

(iv)        Send newsletters, solicitations and promotional messages. If you don’t want it, you can express your refusal when collecting your data,

(v)         Produce commercial and attendance statistics,

(vi)        Organize games and contests, lottery and other promotional activities excluding gambling which are submitted for approval to the French Online Gambling Regulatory Authority (Autorité de Régulation des Jeux en ligne),

(vii)      Manage user reviews and opinions on products, services or contents,

(viii)     Handle unpaid debts and potential lawsuits relating to the use of our products and services,

(ix)        Comply with our legal and regulatory obligations.

When we collect your personal data, we inform you which data are mandatory or optional. We also inform you of the consequences of a failure to answer.

We inform you that your personal data may be indirectly collected from the booking websites that have subscribed to our services and giving you access to our services, including your employer and / or any person on whose behalf you access these services.

5.     USE OF PERSONAL DATA

Our staff, the services in charge of the control (including auditors) and our subcontractors could have access to your personal data.

We also communicate your personal data to the online seller whose one or more options apply to one or more of his products or services offered for sale. They may use them for the purposes and under the conditions referred to in this charter, unless otherwise agreed between you and the seller. For your information, the seller is solely responsible for the respect of his legal obligations relating to your personal data processing, made by itself with its own means and for its only needs. We are only responsible for our use of your personal data, excluding any other use by the online seller.

Your personal data may also be communicated to public institutions, judicial officers, ministerial officers and debt collection agencies, but only to meet our legal obligations.

6.     TRANSFER OF PERSONAL DATA

Your personal data shall not be sold, rented or exchanged directly by Optionizr for the benefit of third parties, except to the online seller on whose behalf you use the services and to whom we communicate your personal data, relating to your use of the services.

7.     HOW LONG WE KEEP YOUR PERSONAL DATA

(i)      Data relating to client and prospects management:

Your personal data shall not be kept beyond the time strictly necessary to manage the business relationship between the online seller and you. However, the data establishing the proof of a right or a contract that have to be kept to meet a legal obligation, shall be kept for the duration provided for by applicable law.

Regarding potential prospecting operations for customers, their data may be kept for a period of three years from the end of the business relationship.

Personal data relating to a non-client prospect may be kept for a period of three years from the date of their collection or the date of the last contact from the prospect.

At the end of this three-year period, the online seller may contact you to know whether or not you wish to receive commercial solicitations.

(ii)     Data relating to identity documents:

When an individual exercises his right of access or correction, the data relating to identity documents may be kept for the period provided for in Article 9 of the Criminal Procedure Code (Code de procedure pénale), i.e. one year. When an individual exercises his right of opposition, these data may be archived during the limitation period provided for in Article 8 of the Criminal Procedure Code (Code de procedure pénale), i.e. three years.

(iii)    Data relating to bank information:

A payment service provider is responsible for the financial transactions relating to the payment for purchases and fees via the Website. He ensures the smooth running and security.

For the purposes of the services, this payment service provider may be required to receive your personal data relating to your account number (RIB key), which it collects and keeps in our name and on our behalf.

We do not have access to these data, nor the online seller.

To enable you to make regular purchases or pay related fees on the Website, your data relating to your bank details are kept during the time of your registration on the Website and at least until you make your last transaction.

By checking the box expressly provided for this purpose on the Website, you give us your express consent for this conservation.

If you refuse that your personal data relating to your account number (RIB key) are kept under the conditions specified above, we will not keep this data beyond the time required to complete the transaction.

In any case, the data relating to these may be kept, for a proof purpose in case of contest of the transaction, in intermediate archives, for the duration provided for in Article L 133-24 of the monetary and financial Code (Code monétaire et financier), i.e. 13 months after the debit date.

(iv)   Management of rights of opposition from prospecting:

Data relating to your right of opposition are kept at least three years from the date of exercise of the right of opposition.

(v)     Audience measurement statistics:

Data stored in the user terminal or any other element used to identify users and allowing their traceability or attendance will not be kept beyond 6 months.

8.     SECURITY

We undertake to take all the necessary precautions, organizational and technical measures to preserve the safety, the integrity and the confidentiality of your personal data, and in particular to prevent distortion, damage and unauthorized third parties from accessing such data. We may also use secure payment systems that comply with the state of the art and applicable regulations.

We respect the security measures provided by our hosting providers:

• OVH, which measures are available on the website

https ://www.ovh.com/fr/apropos/certifications.xml.

• Amazon Web Services, which measures are available on the website

https://aws.amazon.com/fr/security/.

9.     HOSTING

We inform you that your data are kept and stored for the duration of their conservation on the servers of OVH, located in France in the European Union, or on the servers of Amazon Web Services, located in Ireland, in the European Union.

Your data will not be transferred outside the European Union regarding the use of the services we offer.

10.  COOKIES

Cookies are text files, often encrypted, stored in your browser. Cookies are created when a user's browser loads a particular website: the website sends information to the browser which then creates a text file. Every time the user goes back to the same website, the browser retrieves and sends this file to the website's server.

We can define the three following categories, with different purposes: technical cookies, social network cookies and advertising cookies:

Ø   Technical cookies are used during your browsing to facilitate and perform certain functions. For example, a technical cookie may be used to memorize the answers filled in a form or the user's preferences regarding the language or the display of a website, when such options are available.

Ø   Social network cookies are created by social platforms to allow web designers to share the content of their site. These cookies may be used by social platforms to trace the browsing of Internet users on websites, whether or not they use these cookies.

Ø   Advertising cookies may be created not only by the website on which the user is browsing, but also by other websites displaying advertisements, ads, widgets or other items on the displayed page. These cookies may be used for targeted advertising, i.e. advertising based on the browsing of the user.

We use technical cookies. They are stored in your browser for a period that cannot exceed thirteen months.

We do not use social network cookies. However, if we had to use social network cookies in the future, we would inform you in advance. We already inform you that these cookies would only be deposited with your agreement. You could be informed about their nature, accept them or refuse them.

We do not use advertising cookies. However, if we had to use advertising cookies in the future, we would inform you in advance and you will be able to deactivate these cookies.

We use or may use Google Analytics, an audience analysis tool that generates a cookie to measure the number of visits on the Website, the number of pages viewed per visitor and the activity of visitors. Your IP address is also collected to define your city of connection. The conservation of this cookie is mentioned in article 7 (v) of this charter.

We remind you that you can oppose the deposit of cookies by setting up your browser. Such a refusal could however prevent the proper functioning of the Website.

11.  SOCIAL NETWORK

The Website uses social networking modules, including but not limited to, Facebook and Twitter (hereinafter collectively referred to as the Social Networks and individually a Social Network).

If you interact through these modules to pre-fill information or by clicking on the sharing button, the information related to your browsing on the Website and your membership of these networks will be transmitted and kept on the server of the company operating the Social Network and shared according to your user account settings, under the terms of use of the Social Network.

If you do not want a Social Network to link the information collected to the relevant Social Network's user account through the Website, you shall disconnect from the Social Network before visiting the Website. In any case, the use of these modules is operated by the Social Networks and is exclusively governed by their conditions.

12.  CONSENT

When you choose to communicate your personal data for the execution of the services we offer, you expressly consent to the collection and use of the data in accordance with the terms of this charter and to the legislation in force.

13.  ACCESS TO YOUR PERSONAL DATA

In accordance with Data Protection Act n°78-17 of January 6, 1978 (loi n° 78-17 du 6 janvier 1978 relative à l'informatique, aux fichiers et aux libertés) relating to data processing, files and freedoms, as well as the GDPR, you have the right to obtain the communication and the rectification or the suppression of your personal data by contacting:

-              e-mail address: contact@optionizr.com

-              postal address: 9 Allée Claude Monet - 92300 Levallois-Perret, France

We remind you that any person may, for legitimate reasons, ask for the limitation of the processing or refuse the processing of his personal data.

14.  PORTABILITY OF YOUR PERSONAL DATA

You have a right to portability of the personal data you have provided. Your personal data mean the data that you have actively and consciously declared in connection with the access and use of services, as well as data generated by your activity as part of the use of the services. We remind you that this right does not relate to data collected and processed on any other legal basis than the consent or performance of the contract binding us.

This right may be exercised for free, at any time, in order to recover and keep your personal data.

We will send your personal data, by any means, in a standard open format commonly used and machine-readable, in accordance with the state of the art.

15.  LODGING A COMPLAINT WITH A SUPERVISORY AUTHORITY

You are also informed that you have the right to lodge a complaint with a competent supervisory authority (the French National Commission for Data Protection and Liberties), in the Member State where you are habitually resident, where you work or where the violation of your rights would have been committed, if you consider that the processing of your personal data constitutes a violation of the applicable texts.

This complaint may be exercised without prejudice to any other complaint before an administrative or judicial court. You also have access to administrative or judicial proceedings if you consider that the processing of your personal data constitutes a violation of the applicable texts.

16.  TERMINATION OF THE BUSINESS RELATIONSHIP BETWEEN THE ONLINE SELLER AND OPTIONIZR

We inform you that in case of termination of the business relationship with the online seller, all your personal data will be fully transferred to the online seller and destroyed from our servers.

In such a case, you shall exercise your rights of access, rectification, deletion, limitation, opposition or portability directly with the online seller. We will keep you informed in case of exercise of your rights.

17.  MODIFICATIONS

We reserve the right, at our discretion and as required by the online seller, to modify the charter at any time, in whole or in part. These modifications will become effective from the day of the publication of the new charter. Your use of the Website following the entry into force of these modifications, which will be notified to you in advance, shall constitute recognition and acceptance of the new charter. Failing that, and if you don’t agree with the new charter, you will no longer have access to the Website.

18.  ENTRY INTO FORCE

This charter became effective on April 30, 2015 and has been last amended on May 21, 2018. The last version is available online.