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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, profile photo (if provided), preferred disciplines, experience level	Display your public profile to other users
Location Data	Geographic area or ski resort selected by the user; approximate GPS position (only if permission is granted)	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, and abuse prevention
Communication Data	Messages exchanged via the App (if applicable), emails sent to our support address	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 voluntarily provide optional data (e.g. profile photo) or grant permission for precise GPS location access.
• 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. Regarding GPS/precise location:

• Precise GPS access is requested only if you grant explicit permission via your device settings.
• You may alternatively select your area manually without enabling GPS.
• Precise GPS coordinates are never shared with other users; only an approximate area or resort name is displayed publicly.
• You may revoke GPS permission at any time through your device settings.

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 profile photo (if provided).
• Your skill level and preferred disciplines.
• Session proposals you publish (date, area, discipline, description).

Your email address, password, precise location, 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 do not integrate third-party advertising networks, social login systems, or analytics platforms that would share your data with external parties.

10. Cookies and Local Storage

Spirtix may use cookies or browser local storage exclusively for technical and functional purposes (e.g. keeping you logged in, storing session preferences). No advertising or tracking cookies are used. You may clear cookies 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. Minors

Spirtix is not directed at children under the age of 16. We do not knowingly collect personal data from individuals under 16. If we become aware that a minor has registered without parental consent, we will delete their account and associated data without 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.