Welcome to the Services Privacy Notice.
Reading Devices and the Service respect your privacy and we are committed to protecting your personal data. This Privacy Notice will inform you as to how we look after your personal data when you use your Reading Device when it is connected to Wi-Fi and tell you about your privacy rights and how the law protects you.
This Privacy Notice is provided in a layered format so you can click through to the specific areas set out below.
This Privacy Notice shall be read in connection with the License Agreement available at
This Privacy Notice aims to give you information on how we collect and process your personaldatathrough your use of the Service, including any data you may provide through Reading Device or byusing other services of our partners.
The Services are not intended for children under 16 and we do not knowingly collect datarelating tochildren. Users must be at least 16 years old to register for a Services Account to use theServices. If a parent or guardian believes that we have in our database the personal informationofa child under the age of 16, please contact us using the contact details as provided in Section 10, and we will use our best efforts to remove theinformation from our records.
It is important that you read this Privacy Notice together with any other privacy notice or fairprocessing notice we may provide on specific occasions when we are collecting or processingpersonaldata about you so that you are fully aware of how and why we are using your data. This PrivacyNotice supplements the other notices and is not intended to override them.
If you do not agree with this policy, do not access or use our Services or interact with anyotheraspect of our business.
Vivlio, société par actions simplifiée, registered at the Lyon company registry under number 532570 397, whose registered office is located at 26 rue Berjon 69009 Lyon - France, is thecontrollerand responsible for your personal data (referred to as “we”, “us” or “our” in this PrivacyNotice).
If you have any questions about this Privacy Notice, including any requests to exercise yourlegalrights under the GDPR, please contact us using the contact details as provided in Section 10.
By this Privacy Notice we want to ensure you that we are working on our Services to make themcompliant with the requirements of the GDPR.
We may revise the provisions of this Privacy Notice as necessary. The latest version of thePrivacyNotice will govern the terms of use of your personal data by us and it will remain published athttps://my.vivlio.com/privacy-policy.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where an individual can no longer be identified directly or indirectly (anonymous data).
When you connect to Wi-Fi from your Reading Device or from any Supported Device we can collect such non-identifying information concerning the Services:
| Cookie issuer | Cookie name | Cookie purpose |
|---|---|---|
| _ga | Google Analytics | |
| Vivlio | PHPSESSID | Authentication |
Reading Device itself does not collect any personal data. Only in case you login through it to our other Services listed in Section 2 The data we collect about you Services will collect your personal data.
PURPOSES FOR WHICH WE WILL USE YOUR DATA
We have set out below, in a table format, a description of all the ways we plan to use data we collect from your Reading Device, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
NOTE that we do not collect any personal data if you use only Reading Device without use of any from our Services.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To use data analytics and statistics to improve our Services and make your reading experiences better | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Services updated and relevant, to develop our business) |
| To make you book recommendations | Usage | Necessary for us to make you your personalized recommendation for your book preferences. |
| To personalize the Digital Contents and the Services (eg. language) | Location | Necessary for us to make you your personalized recommendation for your book preferences or Services preferences. |
| To enable authentication to our Services. Newsletter | E-mail address | Necessary for the performance of the Services (authentication to the Services) Your consent for the sending of newsletter |
We do not collect person-identifying data via Reading Device that’s why we do not disclose it to anyone.
We may share your personal data with third-party business partners, providers, vendors or contractors acting on our behalf and under our instructions, whether located inside and outside of the European Union (“EU”) or the Economic Area (“EEA”), for the purposes of operating the Services, sending marketing and other communications related to our business, and for other legitimate purposes permitted by applicable law or otherwise, and when needed, with your consent.
Therefore, we may share your personal data in the following ways:
By using Services, you authorize us to transfer and store your information outside the European Union, for the purposes described in this policy.
We take additional measures when personal data is transferred outside of the European Economic Area (EEA). This includes having standard clauses approved by the European Commission in our contracts with parties that receive information outside the EEA. We also rely on European Commission adequacy decisions about certain countries, as applicable, for data transfers to countries outside the EEA.
We have put in place appropriate security measures to prevent your data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your data to the employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your data, the purposes for which we process your data and whether we can achieve those purposes through other means, and the French legal requirements and statute of limitation.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. As a user of our Services you have such rights:
Access, free of charge, obtain a paper or electronic copy, review, correct and update all your personal data stored by us, notably to confirm its accuracy.
Subject to any relevant legal requirements and exemptions, limit the processing of your personal data or request that certain of your personal data be deleted from our files.
If you reside within the EU, you may also exercise you right to portability of your personal data where the lawful basis for the processing is (i) (a) a contract or (b) your consent and (ii) by automated means. Please note that such a request could be limited to the sole personal data you provided us with or that we hold at that given time and subject to any relevant legal requirements and exemptions, including identity verification procedures.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Subject to your choices, we may also send you marketing communications via email. In addition to the “unsubscribe” link contained in each of our e-mail marketing communications, you may opt-out freely and at any time of receiving our newsletters or other e-mail marketing communications from us by contacting us using the contact details provided in Section 10.
We may send you service communications relating to the products or services we provide you via email (e.g. to inform you about changes to the product or service you requested from us, revisions of our terms and conditions or this Policy). As such service communications are necessary for the purposes of providing you with our products or services or complying with our legal obligations, you will not be able to opt-out from receiving them.
If you wish to exercise any of the rights set out above, please contact us by using the contact details as provided in Section 10.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
For any request or in the event of a dispute between you and us, related to the processing of your personal data, you may address your request or complaint to Vivlio by following our process available at https://my.vivlio.com/contact or by contacting us at the e-mail address privacy@vivlio.com or at the postal address 26 rue Berjon 69009 Lyon – France.
We will endeavor to find a satisfactory solution to ensure compliance with the applicable privacy regulation.
If we do not respond or if the dispute persists despite our proposal, you may file a complaint with the Commission nationale de l’informatique et des libertés (“CNIL”) or the supervisory authority of the European Union Member State in which you are located.