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PRIVACY POLICY & LEGAL NOTICE

This Privacy Policy explains how Spirtix collects, uses, and protects your personal data in connection with the website www.spirtix.app and the Spirtix application (the "App"). We are committed to protecting your privacy in full compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and applicable French data protection law.

By registering or using Spirtix, you acknowledge that you have read and understood this Privacy Policy.

1. Data Controller

The Data Controller responsible for processing your personal data is the individual identified in the Legal Notice above. For any privacy-related request, you may contact us at: spirtixteam@gmail.com.

2. Data We Collect

Spirtix collects only the data necessary to provide its service. The following categories of personal data may be processed:

Category	Data Collected	Purpose
Registration Data	Name, email address, password (encrypted), age/date of birth, ski/snowboard skill level	Create and manage your user account
Profile Data	Username, avatar, preferred disciplines, experience level	Display your public profile to other users
Location Data	Geographic area or ski resort selected manually by the user from a list; no GPS or device location permission is ever requested	Match users and display proposals in a given area
Session Proposals	Date, time, location, discipline, description of the proposed session	Publish and display proposals to other users
Technical Data	IP address, browser type, operating system, device type, session data	Security, service operation, abuse prevention, and usage analytics
Communication Data	Emails sent to our support address. Contact with other users (e.g. via WhatsApp) takes place entirely outside the App; SPIRTIX does not operate an internal messaging system and has no visibility into those conversations	User support and moderation

We do not collect sensitive personal data (e.g. health data, racial or ethnic origin, political opinions) and we do not use automated profiling or decision-making systems.

3. Legal Basis for Processing

We process your personal data on the following legal bases under Article 6 GDPR:

• Performance of a contract (Art. 6.1.b): Processing necessary to provide the service you registered for (account creation, session proposals, user matching).
• Legitimate interest (Art. 6.1.f): Ensuring the security and proper functioning of the service, preventing abuse and illegal activity.
• Consent (Art. 6.1.a): When you provide consent for optional analytics cookies via our cookie consent banner.
• Legal obligation (Art. 6.1.c): When required to comply with French or EU law, or to respond to lawful requests from competent authorities.

4. Location Data — Special Notice

Spirtix uses location data solely to display session proposals in the geographic area chosen by the user.

• The location is a text value you select manually from a list (e.g. a ski resort name); it is never obtained from your device's GPS or any other location-sensing technology.
• Neither the App nor the Website ever requests access to your device's precise location or GPS.
• The location you select is displayed publicly as part of your session proposals, in the same way as the rest of your session details.

5. How We Use Your Data

Your personal data is used exclusively for the following purposes:

• Creating and managing your Spirtix user account.
• Displaying your profile and session proposals to other registered users.
• Matching users who wish to practice snow sports together in the same area.
• Ensuring the security of the service and preventing fraud, abuse, or illegal activity.
• Responding to your support requests or communications.
• Complying with legal or regulatory obligations.

We do not sell, rent, or share your personal data with third parties for commercial or marketing purposes.

6. Data Visibility — What Other Users Can See

By registering and creating a profile on Spirtix, you acknowledge that certain information will be visible to other registered users of the platform, including:

• Your username and avatar.
• Your skill level and preferred disciplines.
• Session proposals you publish (date, area, discipline, description).

Your email address, password, and technical data are never visible to other users.

7. Data Retention

Your personal data is retained for as long as your account is active. Upon account deletion:

• Your profile and session proposals are permanently deleted from the platform within 30 days.
• Technical and security logs may be retained for up to 12 months as required by French law.
• Data exchanged with support (emails) is retained for up to 3 years for legal purposes.

During the current beta testing phase, data may be reset or deleted without prior notice as part of technical maintenance or platform updates.

8. Data Storage and Security

All personal data is stored on secure servers located within the European Economic Area (EEA). We implement appropriate technical and organizational measures to protect your data against unauthorized access, loss, alteration, or disclosure, including:

• Encryption of passwords and sensitive data at rest.
• HTTPS encryption for all data in transit.
• Access controls limiting data access to authorized personnel only.

No data transmission over the internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

9. Third-Party Services and Data Transfers

Spirtix may rely on third-party providers for hosting and technical infrastructure. Such providers act as data processors under a Data Processing Agreement (DPA) and are bound to process data only on our instructions. No personal data is transferred outside the EEA without appropriate safeguards in place (e.g. Standard Contractual Clauses).

We use Firebase Analytics (provided by Google Ireland Limited) to collect anonymised usage statistics that help us understand how the App and Website are used (e.g. page views, feature usage). Firebase Analytics acts as our data processor under a Data Processing Agreement, in the same manner as our hosting and infrastructure providers described above, and does not sell or share your personal data with third parties for advertising purposes. We do not integrate third-party advertising networks or social login systems.

10. Cookies and Local Storage

Spirtix may use cookies, browser local storage, or similar technologies (including those used by Firebase Analytics) for technical, functional, and basic usage-analytics purposes (e.g. keeping you logged in, storing session preferences, understanding how the App is used). We do not use advertising cookies or third-party tracking for marketing purposes. You may clear cookies or local storage at any time through your browser settings, though this may affect the functionality of the App.

11. Your Rights (GDPR)

Under the GDPR, you have the following rights with respect to your personal data:

• Right of Access (Art. 15): Request a copy of all personal data we hold about you.
• Right to Rectification (Art. 16): Request correction of inaccurate or incomplete data.
• Right to Erasure (Art. 17): Request deletion of your data ("Right to be forgotten"), subject to legal retention obligations.
• Right to Restriction (Art. 18): Request that we limit the processing of your data in certain circumstances.
• Right to Data Portability (Art. 20): Receive your data in a structured, machine-readable format.
• Right to Object (Art. 21): Object to processing based on legitimate interest.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please send a written request to: spirtixteam@gmail.com. We will respond within 30 days as required by the GDPR. We may ask you to verify your identity before processing your request.

12. Age Restriction

SPIRTIX is intended solely for adults aged 18 or over. We do not knowingly collect personal data from anyone under the age of 18. If we become aware that a person under 18 has created an account or provided personal data, we will delete the account and associated data without undue delay.

13. External Links

The App or Website may contain links to third-party websites. We are not responsible for the privacy practices or content of such third-party sites, which are governed by their own privacy policies. We encourage you to review the privacy policy of any third-party website you visit. Accessing third-party links is entirely at your own risk.

14. Supervisory Authority

If you believe your personal data has been processed in violation of the GDPR, you have the right to lodge a complaint with the French supervisory authority:

15. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. Users will be informed of material changes through the App or Website. The date of the latest revision is indicated at the top of this document. Continued use of the service after any modification constitutes acceptance of the updated policy.