The purpose of this Privacy Policy is to define how Bigben Interactive (hereinafter referred to as “Bigben”) and its affiliates (“Bigben”, “Games.fr”, “Nacon”) collect, use, disclose, process and protect any information you transmit to us when you use the « Aromasound » product or service. Any information that we may ask you to provide for your identification during the use of the “Aromasound” product or service will be used in accordance with this Privacy Policy.

We recommend that you take time to carefully read this Privacy Policy, which is designed for you, so that you have a thorough understanding of our practices in the collection and use of personal information in order to establish mutual trust in our relationships.

The term “personal information” refers to any information that might be used for a person’s identification based solely on such information, or based on such information combined with other information to which Bigben has access regarding that person. Personal information is not limited to information that you provide or download; it may also include information regarding the apparatus, etc.

In using the “Aromasound” product or service, you are deemed to have read, acknowledged and agreed to all of the provisions set forth in the Privacy Policy, including changes we may make therein from time to time.

For any questions related to this Privacy Policy, we recommend that you contact the dedicated department at this address: privacy@bigben.fr

Information collected

We will ask you to provide personal information that is necessary for us to render our services. We cannot provide you with our products and/or services if we do not have your personal information.

We will collect only information that is necessary to serve specific purposes, which will subsequently be processed only in a way that is compatible therewith. Collected information, whether or not personal, may be categorized as follows:

Information that you provide or which we download to create an account and participate in the Bigben platforms: In that regard, we may collect personal information such as the email address, the details of the Bigben account (e.g. user’s name).

Information regarding the location (only for particular services/ functionalities): We may collect your local information when you use the “Aromasound” application, and, in particular, we may collect your IP addresses, your country code or city code.

Use of personal data

Personal data are collected to provide you with services and/or products. In consenting to this collection, you agree that we process and disclose personal information to our affiliates or Third Party Service Suppliers (defined hereinafter) for the purposes set forth in this Privacy Policy.

Generally, we may use your personal information to:

Provide, process, maintain, improve and develop our products and/or services, including after-sale service and customer assistance, as well as services on your apparatus or our Websites.

Communicate with you regarding your apparatus, service, or any general question, such as updates, assistance at the customer’s request, or information regarding our events and notifications.

Analyze and develop statistical information regarding the use of our products and services in order to improve them.

Optimize performance of your apparatus.

Save and retain information for our sales activities or our legal requirements.

Provide local services without communicating with our servers.

In practice, we use your personal data for the following operations and services:

Configuration of your Aromasound account. The personal information collected for the creation of an Aromasound account via our mobile apparatuses is used to create your Aromasound personal account and your profile page for the user.

Use for commercial purposes

We may use your email address and your Aromasound account to provide you with marketing documents regarding the products and services of the Bigben companies and our commercial partners. We will use your personal data only after receipt of your explicit authorization beforehand. You have the right to retract your authorization to use your personal data for direct marketing. If you no longer wish to receive certain communications by email, you may unsubscribe by sending an email to privacy@bigben.fr. We will not transfer your personal data to our commercial partners for a use via our commercial partners in direct marketing.

Sharing of Personal information with our Group and third party service suppliers

We do not sell any personal information to third parties.

We may occasionally disclose your personal information to third parties (as described below) to provide you with the products and services you have requested.

Personal information may be disclosed to the Bigben group’s Third Party Service Suppliers and affiliates. The fact that you give Bigben your consent thereto will commit the subcontractors with respect to the processing of your personal information. It is important for you to know that, when Bigben shares your personal information with Third Party Service Suppliers in any of the circumstances described in this section, Bigben will specify that the Third Party is subject to the practices and obligations required for compliance with the laws and regulations applicable to data protection.

In order for us to properly carry out your commercial operations by providing you with all of the functionalities of our products and services, we may occasionally disclose your personal information to other companies affiliated with Bigben or to our Third Party Service Suppliers, such as our shipment companies, our delivery services, telecommunications companies, data centres, data storage facilities, users’ service suppliers, suppliers of advertising and marketing services, and representatives of Bigben.These Third Party Service Suppliers may process your personal information in the name of Bigben or for one or more reasons set forth hereinabove. If you no longer wish to share this information, please contact us at the following address: privacy@bigben.fr.

Other sharing of Personal information

Bigben may disclose your Personal information without your consent when the information is required by the applicable law.

Bigben may collect, use or disclose your personal information without your consent only if such is explicitly authorized by the local laws applicable to data protection. Such disclosure may be required to protect our rights, guarantee your security and that of others, or comply with the local government’s requirements to facilitate enquiries regarding illegal activities.

Security measures

Regarding Bigben:

We commit to assure the security of your Personal information. To prevent any unauthorized access, any disclosure or other similar risk, we have implemented reasonable physical, electronic and management procedures to save and secure the information we collect when you use Aromasound products and services. We extend every reasonable effort to protect your Personal information.

All of your personal information is saved in secured and protected servers in controlled facilities. We classify your data according to their importance and sensitivity, and ensure that your personal information is given the highest level of security. We ensure that our employees and Third Party Service Suppliers that have access to your information to assist you in our products and services are subject to very strict contractual obligations of security, and may be disciplined or dismissed if they fail to comply therewith. We also have special access controls for data storage in cloud. In short, we regularly examine our collection of information, our practices in the storage and processing of information, including physical security measures, by preventing any unauthorized access and use.

We take any possible measures to protect your personal information.However, you must be mindful of the fact that use of the internet is not entirely secured and that, therefore, we cannot guarantee the security or integrity of personal information transferred from you or to you via the internet.

Regarding your role in preserving your data:

You can play a role in the protection of your personal information by refraining from disclosing your password or your account data to anyone, unless that person is duly authorized by you. When you connect as a user of the Aromasound account, in particular on the APP or apparatus of another person on public internet terminals, you must always disconnect at the end of your session.

Bigben cannot be held liable for security failures caused by third parties’ access to your personal information following your inability to preserve the confidentiality of your personal information. Notwithstanding the foregoing, you must immediately inform us of any unauthorized use of your account by another internet user or any other violation of security.

Your assistance will help us protect the confidentiality of your personal information.

Retention of Personal information

Personal information will be retained for as long as necessary with respect to the particular purpose for which it was collected, or for as long as required or allowed by the applicable laws. We will no longer retain your personal information -- or will delete the means by which it may be associated with particular individuals -- insofar as it is reasonable to assume that collection of your Personal information no longer serves the purpose thereof. If a subsequent processing of data is for the purpose of archiving them in the public’s interest, for scientific or historical research, or for statistical purposes in accordance with the applicable law, Bigben may retain the data even if the subsequent processing thereof is unrelated to the initial objectives.

You may control your information

If you have previously agreed to our use of your Personal Data for the aforesaid purposes, you may nevertheless change your mind at any time by writing to us or sending us an email at this address: privacy@bigben.fr.

Protection of minors’ personal data

We deem it to be the parents’ responsibility to monitor their children’s use of our products and services.

Bigben does not seek or intend to seek personal information of minors. If a parent or guardian has reason to believe that a minor provided personal information to Bigben without its prior consent, please contact us to ensure that the personal information involved is deleted and that the minor is unsubscribed from Aromasound services.

Updating of the Privacy Policy

We regularly comply with our Privacy Policy and we may update it to reflect changes in our practices regarding information. If we make significant changes in our Privacy Policy, we will inform you by email (sent to the email address indicated in your account), or we will publish the changes on all of the Bigben websites or via our software, so that you are aware of the information we collect and the way in which we use it. Any changes in our Privacy Policy apply as of the effective date specified in the notice or the website. We encourage you to regularly review that page to obtain the latest information regarding our practices pertaining to confidentiality. Your continued use of products and services on the internet, cellular phones and/or any other apparatuses will be deemed to be your acceptance of the updated Privacy Policy. We will ask again for your consent before collecting other personal information, or ask if you want to use or disclose your personal information for new purposes.

Your rights and your withdrawal of consent

You have the right, at any time, to cancel the authorization you gave Bigben to use your personal data with respect to our mailing list or for other marketing purposes.You may do so by clicking on the unsubscribing option at the bottom of each email, or by sending us a request at this address: privacy@bigben.fr

You also have the right to request a review of your personal data processed by Bigben, to oppose or restrict the processing thereof, and to request a deletion or correction thereof, by sending us a request via our portal dedicated to requests for access to data at this address: privacy@bigben.fr.

Please note that, if you request a deletion or restriction of all or any part of your personal data, we may be unable to execute our contractual obligations to you, or adequately respond to your requests to the customer department.

Moreover, you have the statutory right to file a complaint with the National Commission for Computerized Data Processing and Individual Rights, the French data protection authority, (known in France as CNIL).

Transfer outside of the European Economic Space

All transfers of personal data to third parties located outside of the European Economic Space (i.e. all of the EU countries, Iceland, Liechtenstein and Norway) are bound to the EU standard contractual Clauses.

Bigben may use facilities abroad to process or save your personal information. Currently, Bigben has data centres in France. This country may, or may not, have established data protection laws that are substantially similar to those of your country of origin.

To contact us

If you have comments or questions regarding this Privacy Policy or questions related to Bigben’s collection, use or disclosure of your personal information, please contact us at the address below in reference to the “Privacy Policy”:

Bigben Interactive (Aromasound.eu) – CRT2 Fretin – CS90414 – 396, rue de la voyette – 59814 Lesquin Cedex – France

Email : privacy@bigben.fr.

Changes in confidentiality policy

Bigben may at any time make changes in this confidentiality policy at its discretion. The date of such changes will appear at the bottom of this page. For Users to be aware of the changes made herein and be kept up-to-date with the way in which Bigben protects personal information that it collects, we encourage them to frequently review it.

In the event of a dispute

In the event of a lack of response or an unsatisfactory response, the person involved may refer the matter to the French data protection authority (CNIL).

This document was most recently updated on 20/09/2019.