Last updated December 20, 2023



Thank you for choosing to be part of our community at Antony Destras ("Company," "we," "us," or "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy policy or our practices with regard to your personal information, please contact us at tooolApp@gmail.com.


    This privacy policy describes how we might use your information if you:
  • Download and use our mobile application — TOOOL
  • Engage with us in other related ways ― including any sales, marketing, or events

    In this privacy policy, if we refer to:
  • "App," we are referring to any application of ours that references or links to this policy, including any listed above
  • "Services," we are referring to our App, and other related services, including any sales, marketing, or events

The purpose of this privacy policy is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Services immediately.



Please read this privacy policy carefully, as it will help you understand what we do with the information that we collect.



TABLE OF CONTENT






1. WHAT INFORMATION DO WE COLLECT ?


Personal information you disclose to us

In short: We collect personal information that you provide us.


We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and services or otherwise when you contact us.


The personal information that we collect depends on the context of your interactions with us and the App, the choices you make and the products and features you use. The personal information we collect may include the following: Name and Email address.


Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Google Play and Apple. You may find their privacy policy link(s) here: https://policies.google.com/privacy?hl=en-US and https://www.apple.com/legal/privacy/en-ww/.


All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.



Information automatically collected

In short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our App.


We automatically collect certain information when you visit, use or navigate the App. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our App and other technical information. This information is primarily needed to maintain the security and operation of our App, and for our internal analytics and reporting purposes.


    The information we collect includes:
  • Log and Usage Data. Log and usage data are service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our App and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the App (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).
  • Device Data. We collect device data such as information about your computer, phone, tablet or other devices you use to access the App. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.


Information collected through our App

In short: We collect information regarding your mobile device and may send push notifications when you use our App.


    If you use our App, we also collect the following information:
  • Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's storage, and other features. We need storage access for saving your music files locally on your device. If you wish to change our access or permissions, you may do so in your device's settings. Please Note: Denying or revoking storage permission may result in a bad user experience. Or, you may lose your music files.
  • Push Notifications. We may request to send you push notifications regarding certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.



2. HOW DO WE USE YOUR INFORMATION ?


In short: We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.


We use personal information collected via our App or contact form for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.


    We use the information we collect or receive:
  • To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our App, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS?" below).
  • For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and evaluating and improving our App, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end-users and does not include personal information.



3. WILL YOUR INFORMATION BE SHARED WITH ANYONE ?


In short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.


    We may process or share your data that we hold based on the following legal basis:
  • Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.


    More specifically, we may need to process your data or share your personal information in the following situations:
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the App, which will enable them to collect data on our behalf about how you interact with our App over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protecting the data they hold on our behalf and to retaining it for the period we instruct.



4. WHO WILL YOUR INFORMATION BE SHARED WITH ?


In short: We only share information with the following third parties.


We only share and disclose your information with the following third parties. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below titled "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?".


  • App Testing. TestFlight and Google Play Console.



5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY ?


In short: We may transfer, store, and process your information in countries other than your own.


If you are accessing our App from outside of the EU, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WILL YOUR INFORMATION BE SHARED WITH ANYONE?" above), in the United States, and other countries.


If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.


European Commission's Standard Contractual Clauses:


We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.




6. HOW LONG DO WE KEEP YOUR INFORMATION ?


In short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.


We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).


When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.




7. HOW DO WE KEEP YOUR INFORMATION SAFE ?


In short: We aim to protect your personal information through a system of organizational and technical security measures.


We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, the transmission of personal information to and from our App is at your own risk. You should only access the App within a secure environment.




8. WHAT ARE YOUR PRIVACY RIGHTS ?


In short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK) and Australia, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.


For EEA and UK Citizens:
In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.


If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.


If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.


If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.



For Australian Citizens:
If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may bring a complaint internally through our complaints process or you may decide to make a formal complaint with the Office of the Australian Information Commissioner (www.oaic.gov.au) (which is the regulator responsible for privacy in Australia).


We will deal with complaints as follows:


    Step 1: let us know
  • If you would like to make a complaint, you should let us know by contacting our Privacy Officer (see section 12 for contact details).

    Step 2: investigation of the complaint
  • Your complaint will be investigated by us.
  • A response to your complaint will be provided in writing within a reasonable period.

    Step 3: contact OAIC
  • We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also contact the Office of the Australian Information Commissioner as follows:
    Office of the Australian Information Commissioner (OAIC)
    Complaints must be made in writing.
    1300 363 992
    Director of Compliance
    Office of the Australian
    Information Commissioner
    GPO Box 5218
    Sydney NSW 2001

If you have questions or comments about your privacy rights, you may email us at:tooolApp@gmail.com




9. CONTROLS FOR DP-NOT-TRACK FEATURES


Some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.




10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS ?


In short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.


California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.


If you are under 18 years of age, reside in California, and have a registered account with the App, you have the right to request the removal of unwanted data that you publicly post on the App. To request the removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the App, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).


CCPA Privacy Notice


The California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose


All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.


What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:



Category Examples Collected
A. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name NO
B. Personal information categories listed in the California Customer Records statute Name, contact information, education, employment, employment history and financial information NO
C. Protected classification characteristics under California or federal law Gender and date of birth NO
D. Commercial information Transaction information, purchase history, financial details and payment information NO
E. Biometric information Fingerprints and voiceprints NO
F. Internet or other similar network activity Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements NO
G. Geolocation data Device location NO
H. Audio, electronic, visual, thermal, olfactory, or similar information Images and audio, video or call recordings created in connection with our business activities NO
I. Professional or employment-related information Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us NO
J. Education Information Student records and directory information NO
K. Inferences drawn from other personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics NO


    We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:
  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy policy.

You may contact us by email at tooolApp@gmail.com, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.


Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be the "selling" of your personal data.

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHO WILL YOUR INFORMATION BE SHARED WITH?".


Antony Destras has not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Antony Destras will not sell personal information in the future belonging to app users and other consumers.


Your rights with respect to your personal data

Right to request deletion of the data - Request to delete


You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

Right to be informed - Request to know


    Depending on the circumstances, you have a right to know:
  • whether we collect and use your personal information;
  • the categories of personal information that we collect;
  • the purposes for which the collected personal information is used;
  • whether we sell your personal information to third parties;
  • the categories of personal information that we sold or disclosed for a business purpose;
  • the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
  • the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights


We will not discriminate against you if you exercise your privacy rights.

Verification process


Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use the personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights


  • you may object to the processing of your personal data.
  • you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data.
  • you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
  • you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.

To exercise these rights, you can contact us by email at tooolApp@gmail.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.




11. DO WE MAKE UPDATES TO THIS NOTICE ?


In short: Yes, we will update this notice as necessary to stay compliant with relevant laws.


We may update this privacy policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.




12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE ?


If you have questions or comments about this notice, you may email us at tooolApp@gmail.com or by post to:


Antony Destras
37bis, Avenue Lenine
93230 Romainville
FRANCE




13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU ?


Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please email us at: tooolApp@gmail.com

Contact us

Got questions about Toool? Contact us for more information!

E-mail

tooolapp@gmail.com

Address

Paris, FRANCE

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