Date of last modification: 03/06/2023
The French company DAZZ (“Dazz” or “we”), an asimplified joint stock company located at 11 rue du chalet 25620 Tarcenay, France, has designed and developed the Hoop application (“Hoop” or our “Services”). Hoop is intended to enable any registered user (“you”) to establish contact with other users around the world. We attach great importance to the protection and respect of your privacy. This privacy policy aims to inform you about how we use your personal data and the ways you can maintain control over it.
If you have any questions about our privacy policy, you can contact us by email at: hello@hoop.photo or by letter to the address mentioned above. For any legal or administrative requisition, you can contact us by e-mail at hello@hoop.photo
The privacy policy is divided into two parts: a first part which provides you with essential information on the processing of your personal data and a second part which explains more exhaustively how we and our partners use your personal data.
Part 1. Overview of the processing of your personal data
We have personal data about you collected from you or by our Partners
| Purposes | Legal basis | Data processed by Hoop | Source of data | The duration of the conversation | Recipients | Transfer outside the EU | |
|---|---|---|---|---|---|---|---|
| Registration and authentication on Hoop | Execution of measures pre-contractual | User identification: Google account email address; Apple account email address; name on Hoop; date of birth; country; External ID | User-provided | As long as the user does not delete their account | The information disseminated at the user's initiative are likely to be accessible to any other user from all over the world. | ||
| Management of registration on Hoop | Customization of profile | Consent | Snapchat username; TikTok profile link; gender; search criteria (M/F; country/world); photography; photography decorations | User-provided | As long as the user does not delete their account or modify it | Depending on their respective needs: Dazz staff; service provider staff | Data storage may take place outside the EU in accordance with the Privacy Shield, Clauses Contractual Types of European Commission (“CCT”) or any other appropriate guarantee |
| Information from holder of authority parental | Legal obligation | Email address of the holder parental authority ; opposition from the holder of parental authority | Provided by the user and owner of authority parental | Thirty (30) days | Depending on their respective needs: Dazz staff | No | |
| Proposal for connecting Hoop users | Consent | Name on Hoop; country ; age ; photograph(s); username Snapchat; TikTok profile link; blocked users; Hoop usage level | Provided by the user or established by Dazz | As long as the user does not express achoice (accept/refuse/report) or delete their account | Depending on their respective needs: Dazz staff; service provider staff | The information disseminated at the user's initiativeare likely to be accessible to others users from all over the world. Data storage may take place outside the EU in accordance with the Privacy Shield, CCT or any other appropriate guarantee. |
|
| User Notifications | Consent | Friend requests received; acceptance of a friend request; information relating to rewards; notification date sent/accessed | Provided by users | Seven (7) days after opening | Depending on their respective needs: Dazz staff; service provider staff | Data storage may take place outside the EU in accordance with the Privacy Shield, CCT or any other appropriate guarantee. | |
| Dazz is the originator of the transmission of the identifier advertising, the cookie identifier, the country entered on Hoop and data relating to consent to advertising or personalized advertising. | Provided by the user or its terminal. | No conservation by Hoop of the transmitted data | Transmission to third-party partners (Google AdMob, IronSource, Unity and TapJoy) | ||||
| Display of personalized or non-personalized advertisements on Hoop to obtain rewards | Consent | Dazz is the recipient of the data techniques relating to viewing and granting a reward as well as performance statistics of advertising campaigns | Provided by the Partner (Google AdMob, IronSource, Unity and TapJoy) | Conservation by Hoop of the total rewards available until the user deletes the account | Depending on their respective needs: Dazz staff; service provider staff | Data storage may take place outside the EU in accordance with the Privacy Shield, CCT or any other appropriate guarantee. | |
| Dazz is the originator of the transmission of the advertising ID and the cookie ID. | Provided by the user or its terminal. | No retention by Hoop of transmitted data | Transmission to supplier partner Pollfish | The partners recipients are likely to process data outside the EU. | |||
| Displaying surveys from Hoop to obtain rewards | Consent | Dazz is the recipient of the data viewing and reward techniques and survey campaign performance statistics | Provided by the Partner (Pollfish) | Conservation by Hoop of the total rewards available until the user deletes the account | Depending on their respective needs: Dazz staff; service provider staf | ||
| Displaying actions to perform on Hoop for obtaining rewards | Consent | Technical data relating to shares | Provided by the user or their recipients | Conservation by Hoop of the total rewards available until the user deletes the account | Depending on their respective needs: Dazz staff; service provider staff | ||
| Dazz is the originator of the transmission of the identifier advertising and cookie identifier. | Provided by the user or its terminal. | No conservation by Hoop of the transmitted data. | Transmission to partner (TapJoy) | ||||
| Display of actions to be carried out from Hoop for rewards | Consent | Dazz is the recipient of the data techniques relating to viewing and granting a reward. | Provided by the Partner (TapJoy) | Conservation by Hoop of the total rewards available until the user deletes the account | Depending on their respective needs: Dazz staff; service provider staff | Data storage may take place outside the EU in accordance with the Privacy Shield, CCT or any other appropriate guarantee. | |
| Rewards management | Legitimate interest | Technical data relating to the value of the reward and its use | Provided by the Partners | Conservation by Hoop of the total rewards available | Depending on their respective needs: Dazz staff; service provider staff | ||
| Followed by the interruption of Services and maintenance | Session logs (timestamp; Hoop version), terminal logs (brand, model, orientation, RAM space, disk size, terminal operating system) | Provided by the user or his terminal | Crash reports are kept as long as as needed by Dazz | ||||
| Administration technique of Hoop | Content analysis for abuse detection and prevention | Legitimate interest | Text data; photographs | User-provided | The time required to content analysis | Depending on their respective needs: Dazz staff; service provider staff | |
| Production of Hoop audience and usage statistics | Consent | Aggregated statistical data: age; gender; country; city; language; terminal operating system; terminal brand; engagement statistics; performance statistics from advertising or survey campaigns for performance monitoring purposes; date of last activity. | Provided by the user, their terminal or Partners | Aggregated statistical reports are retained as necessary by Dazz | Depending on their respective needs: Dazz staff; service provider staff; Partners | Data storage may take place outside the EU in accordance with the Privacy Shield, CCT or any other appropriate guarantee. The partners recipients are likely to process data outside the EU |
|
| Request information on using Hoop | Consent | Contact information; version of Hoop and SDK, terminal model, External ID; user request | The time required to demand management | One-off data transfer when the request comes from a user outside the EU. | |||
| Reporting users or contents | Legal obligation | Session logs; terminal log; ID external | The time required to content analysis | Data storage may take place outside the EU in accordance with the Privacy Shield, CCT or any other appropriate guarantee. | |||
| Management of requests relative to Hoop | Suite management data to requests | Legitimate interest; legal obligation | Depending on the response given | Provided by the user or their terminal | The duration necessary to manage the request then possible archiving | Dazz staff based on their respective needs; requesting authorities. | Data storage may take place outside the EU in accordance with the Privacy Shield, CCT or any other appropriate guarantee. Transfers may be necessary within the limits of the obligations of international cooperation. |
| Elaboration of statistics | Legitimate interest | Aggregated statistical data | Aggregated statistical reports are retained as long as needed by Dazz | Data storage may take place outside the EU in accordance with the Privacy Shield or CCT. | |||
Part 2. Description of the processing of your personal data
1. Data controller
Dazz acts as the data controller of your personal data collected when using Hoop.
Depending on the case, Dazz also acts as a data controller jointly with its Partners (as listed below) to offer you features or reward you (the “rewards”) and level up. As such and provided you agree, Dazz may transmit or receive personal data concerning you.
2. Purposes of processing
When downloading and then using Hoop, Dazz uses your personal data for the following reasons:
2.1. Your registration on Hoop
Your registration on Hoop first requires you to have a Google account or an Apple account. To create an account and log in to Hoop, Dazz uses your Snapchat username, and your link to your TikTok account.
as well as your age the country where you are located and assigns you an external identifier.
This data is used to create your account when you first use Hoop and then to identify you during your subsequent connections.
2.2. Your profile on Hoop
You can choose to personalize your profile on Hoop by providing information about yourself (such as photographs) that will be accessible to other users. This information can be modified at any time from your account.
You can also configure your search criteria (gender and country) to find friends. Your search criteria can be modified at any time and are not shared with other users or our Partners.
2.3. Parental control of your use of Hoop
In accordance with current legal obligations, when you are not of legal age to consent alone to the processing of your personal data, you must provide us with the email address of one of your parents so that we can inform them of your using Hoop. Depending on the case, your parent may review the information you have chosen to disclose on Hoop or request deletion of your account on Hoop to terminate your use.
2.4. Connecting with other users
Hoop allows you to find other users with whom you can become friends based on your selection criteria based on gender (male/female) and geographic location (same country/whole world) as well as your age. To do this, Hoop uses mathematical formulas (algorithms) to combine your data with those of other registered users and offer you profiles as well as offer your profile to other users.
Only the information you have decided to share is published on Hoop (name on Hoop, gender and, where applicable, age, photographs, Snapchat username and TikTok profile link).
You can decide to accept a profile or request a profile as friends to add it on Snapchat and/or TikTok. If your request is accepted, the Snapchat username of the selected profile and/or the link to their TikTok profile will be communicated to you and you will be able to add them as a friend on Snapchat and/or on TikTok. You will not be informed if your request is refused.
You can also choose to refuse a profile that has been offered to you
Other users can also select your profile, then you will receive friend requests from them go. You can accept the request, ignore the request, or block the user. If the profile is blocked, the user will not be able to send you new requests. You can unblock a user from your account at any time.
For security reasons, users under the age of 18 are not offered adult user profiles
2.5. Your notifications
When you choose to enable notifications on your device, Dazz may notify you of the following events: friend requests received, friend requests accepted, rewards information.
You can change your settings at any time to turn off notifications.
Notifications regarding friend requests are also accessible from your account.
2.6. You reward through viewing advertisements (personalized or not), participating in surveys or carrying out actions
Some Hoop features require the use of photographs, friend requests, and viewing previously viewed profiles. These include decorations for your viewing previously viewed profiles
You can accumulate rewards for free in several ways and without any obligation to purchase: by viewing personalized or non-personalized advertisements, by participating in surveys, by carrying out actions on Hoop or on Partner services. The reward is awarded to you upon completion of the action.
2.6.1. Display of advertisements
Hoop uses Partner modules, which allow the deposit and reading of cookies containing information about your terminal and other personal data. These cookies are used for different technical operations such as displaying advertising, avoiding repetition of the same advertisement, fighting fraud, establishing invoicing for the advertising display service, and measuring the audience to enable advertisers to understand the effectiveness or otherwise of advertising.
Dazz uses Google (Google Mobile Ads SDK) as a technical partner and IronSource, Unity and TapJoy as advertising partners (advertising networks).
You have the right at any time to revoke your consent to the display of personalized advertisements or change your advertising display settings.
Advertising is displayed when you choose to click on the “watch a video” tab and the reward is awarded upon completion of full viewing.
a) Personalized advertising
Dazz and its Partners use your personal data collected from Hoop and your device to display personalized advertising based on your profile. Your profile is determined by the Partners based on your interests established on the basis of the information transmitted by Hoop and its combination with your activity on other sites and applications that you may have consulted.
b) Non-personalized advertising
Dazz and its Partners use your personal data collected from Hoop and your device to display advertising without profiling you.
2.6.2. Participation in surveys
To obtain rewards you can choose to complete a survey from Hoop.
Dazz uses Pollfish as a Technology Partner, which offers surveys on behalf of its clients advertisers.
Dazz and its Partner use your personal data collected from Hoop and your terminal to offer you the survey service.
Dazz is in no way the recipient of the data provided to Pollfish (whether data provided to verify your eligibility to participate in surveys or your responses to surveys). Dazz has access to aggregated statistical data to track billing for displaying surveys and technical data relating to participation in a survey to grant you rewards.
Survey Serving Technology
This app uses Pollfish SDK. Pollfish is an online survey platform, through which, anyone can conduct surveys. Pollfish collaborates with Publishers of applications for smartphones in order to have access to users of such applications and address survey questionnaires to them. When a user connects to this app, a specific set of user's device data (including Advertising ID, Device ID, other available electronic identifiers and further response meta-data is automatically sent, via our app, to Pollfish servers, in order for Pollfish to discern whether the user is eligible for a survey. For a full list of data received by Pollfish through this app, please read carefully the Pollfish respondent terms located at https://www.pollfish.com/terms/respondent. These data will be associated with your answers to the questionnaires whenever Pollfish sends such questionnaires to eligible users. Pollfish may share such data with third parties, clients and business partners, for commercial purposes. By downloading the application, you accept this privacy policy document and you hereby give your consent for the processing by Pollfish of the aforementioned data. Furthermore, you are informed that you may disable Pollfish operation at any time by visiting the following link https://www.pollfish.com/ respondent/opt-out. We once more invite you to check the Pollfish respondent's terms of use, if you wish to have more detailed view of the way Pollfish works and with whom Pollfish may further share your data.
2.6.3. Other actions
a) Actions proposed by Dazz
Dazz uses your personal data to measure your interactions on Hoop and grant you rewards.
You can get rewards when:
- you introduce Hoop to your friends by sharing a link inviting them to download the application. The reward is acquired when five (5) separate people have clicked on the link;
- you add twenty (20) profiles on Snapchat or TikTok using Hoop;
- you claim your daily reward.
b) Actions proposed by Partners
To earn rewards you can choose to complete download actions from Hoop through our Technology Partner TapJoy.
Dazz and its Partner use your personal data collected from Hoop and your terminal to display you the offer of services.
Dazz is in no way the recipient of the data provided to TapJoy (whether the data provided or the download data). Dazz has access to aggregated statistical data allowing monitoring of billing for the display of services and technical data relating to the performance of actions to grant you rewards.
2.7. Technically administer Hoop
2.7.1. Monitoring of malfunctions and maintenance of Hoop
Dazz ensures that Hoop functions properly and corrects interruptions or errors that may affect its use. For this purpose, we use technical data to optimize the display of Hoop (such as terminal operating system, and orientation), for reporting operational interruptions (time stamp, application version, identifier, RAM size and disk space) and correct it during updates or new versions of the application.
2.7.2.Detection and prevention of abuse on Hoop
We are committed to ensuring that Hoop remains user-friendly, we therefore ensure that the legality of the content is respected and that it does not harm users. Hoop incorporates technologies that allow content (photographs you provide) to be automatically analyzed to detect abuse or content that could harm users. Where applicable, we reserve the right to delete data that violates Hoop's terms of use and security policies.
2.8. Measure audience and usage of Hoop
Hoop uses Partner tools (Google Analytics) which allow the deposit and reading of cookies containing information about your terminal and other personal data. These cookies are used to establish aggregated statistics to allow Hoop to understand how users access Hoop, the journeys taken and the features most used.
This data is used to evaluate performance to optimize the design of Hoop and develop new services or features.
2.9. Managing requests relating to Hoop
2.9.1. Request for information on using Hoop
When you contact us with a question about using Hoop, Dazz uses your personal data (such (e.g. contact email address, Hoop and SDK version, device model, external ID, content of your request) to process and respond to the request.
2.9.2. Reporting inappropriate users or content
In accordance with current legal provisions, Hoop includes a content or user reporting tool. The data collected helps ensure the security of users and protect them against abusive or harmful behavior. If applicable, we may be required to sanction violations of Hoop's terms of use and security rules.
2.9.3. Management of the follow-up given to requests
Requests for information or reports may justify the retention of your data for evidentiary purposes or the transmission of it to the competent authorities or persons to enable Dazz to comply with its obligations or to preserve rights.
In any case, we respond to legal or administrative requisitions and injunctions while ensuring compliance with the legal provisions in force.
2.9.4. Elaboration of statistics
For internal or external transparency purposes, we may be required to produce statistics on the management of requests relating to Hoop.
3. Legal bases
Depending on the case, Dazz processes your personal data in the execution of pre-contractual or contractual measures, on the basis of your consent, its legitimate interest or in execution of legal obligations.
- Contract: When you create an account on Hoop, you enter into a contract with Dazz for the provision of Services.
- Consent: When you decide to take an action on Hoop (for example, creating your profile, requesting friends, displaying an advertisement, participating in a survey, redeeming a reward, etc.) you materialize your consent by clicking on the relevant tab.
- Legitimate interest: In certain cases, Dazz uses your personal data in its interest, provided that the data used does not excessively invade your privacy. This is the case for technical data, navigation data and statistical data used for internal purposes to ensure the security and reliability of Hoop and enable its constant improvement.
- Legal obligation: Dazz may be required to use your data to comply with legal, regulatory, judicial or administrative obligations.
4. Recipients
Your personal data is kept with care, it is only made accessible under strict conditions to the following people only:
- Dazz staff members, according to an internal authorization policy and provided that these people need access;
- members of the staff of service providers retained by Dazz (host);
- the partners.
As of the effective date of the privacy policy, Dazz Partners are:
| Google Ads | Advertisement | ||
| Google Analytics | Measure audience | https:// policies.google.com/ privacy?fg=1 | |
| Unity | Advertisement | https://unity3d.com/legal/privacy-policy | |
| Iron Source | Advertisement | http://www.ironsrc.com/wp-content/uploads/2019/03/ironSource-Privacy-Policy.pdf | |
| TapJoy | Advertisement | https://www.tapjoy.com/legal/players/privacy-policy/ | |
| Pollfish | Survey | https://www.pollfish.com/terms/respondent | |
5. Subsequent treatments
When our Partners are recipients of your data, they may use them under the conditions they have determined and as indicated in their confidentiality policy referred to above or any other document.
complementary. It is your responsibility to review these conditions. Dazz is not responsible for the subsequent use made by Partners of your personal data.
You can exercise your rights directly with these Partners.
6. Transfers of your data
6.1. Transfers by Hoop
Hoop is intended for users located around the world. Depending on your privacy and search settings, the data you choose to make public may be accessible outside the European Union.
Dazz uses Firebase as its cloud hosting provider and benchmarking service provider. As such, transfers are carried out in compliance with the Privacy Shield when they take place to the United States of America and in compliance with the Standard Contractual Clauses (CCT) of the European Commission or under any other appropriate guarantee. when they take place towards a state which is not the subject of an adequacy decision.
When Dazz responds to requests from users established outside the European Union, one-off transfers may occur.
Finally, transfers may be necessary in compliance with international cooperation obligations.
6.2. Transfers to Partners
the Standard Contractual Clauses (CCT) or any other appropriate guarantee.Dazz Partners may be established outside the European Union, transfers may be made in compliance with the Privacy Shield, in compliance with the Standard Contractual Clauses (CCT) or any other appropriate guarantee.
7. Duration of retention of your data
Depending on the nature of your data, it is kept by Dazz:
- temporarily (such as the address provided for your parent), •until they are used (such as the number available),
- until they are modified or deleted at your initiative (profile information), •until the date your account is deleted, or
- within the limits authorized by the limitation rules when this is necessary to preserve rights by Dazz.
You can modify or delete your data at any time according to the terms provided below “Your rights”.
8. Your rights
You can exercise your rights from your user account or by contacting Dazz: hello@hoop.photo
8.1. Access your data
You have the right at any time to know if Dazz has information about you and, if so, to request access to it.
8.2. Correct your data
You have the right at any time to rectify or request the rectification of data concerning you which is inaccurate or incomplete.
8.3. Erase your data (right to be forgotten)
You have the right at any time to delete your user account or request the deletion of your account from Dazz.
Your data is deleted automatically at your initiative or as soon as possible following your request to Dazz.
The deletion is permanent, except in cases where processing of your data is necessary to comply with a legal obligation or for the establishment, exercise or defense of legal rights.
8.4. Limit the processing of your data
You can modify your profile at any time to delete all or part of your information (photographs, etc.) or modify the confidentiality settings in order to limit their processing.
8.5. Extract your data
You can request to receive data concerning you in a structured format for portability purposes. This right only applies where the processing is based on your consent, on a contract or when such processing is carried out by automated means.
Dazz reserves the right to carry out reasonable identity verifications before responding to a data portability request
8.6. Object to processing
Where we process data about you based on legitimate interest, you can object to the processing at any time. This is not an absolute right and we may for legal or legitimate reasons refuse your request.
8.7. Submit a complaint
If you believe that Dazz is not complying with the Privacy Policy, you can lodge a complaint with the competent supervisory authority.
8.8. Guidelines regarding the fate of your data
You can give us your instructions regarding the fate of your data after your death and the use of it
9. Automated decision making and profiling
Dazz uses technological tools allowing the automatic analysis of data and their combination for the execution of the Services (connection proposal).
For security reasons, Dazz also uses technological data analysis tools to detect abuse or illegal content. Any automatic analysis is subject to additional control by Dazz staff to decide what action to take.
10. Changes to our privacy policy
To satisfy you even more, our Services are constantly improving and evolving.
Dazz may occasionally modify the confidentiality policy, in particular in order to comply with any regulatory, jurisprudential, editorial or technical developments. In such a case, we will inform you by any means of this modification and the date appearing at the top of the document will be modified. We invite you to regularly refer to this page to check your personal data.