BRUT MOBILE APPLICATION AND WEBSITE PRIVACY POLICY

The Brut service. (hereinafter the "Brut Service") is published by the company Brut, a simplified joint stock company registered in the Paris Trade and Companies Register under number 829 162 395, whose registered office is at 17 rue de l'Arrivée, Paris (75015) and whose intra-community VAT identification number is FR88829162395 (hereinafter the "Brut SAS Company") and whose contact email is [email protected].

The Brut Service is accessible on the one hand, via a website accessible at the URL www.Brut.media (hereinafter the "Site") and on the other hand, in the form of a mobile application "Brut" (hereinafter the "Application") accessible and downloadable on mobile and tablet devices.

This Personal Data Protection Policy applies to personal data collected, processed, transmitted and stored in connection with your use of the Brut Service, whether on the Site or the Application.

Personal data is information relating to an identified or identifiable natural person (e.g. a surname, first name, email address, unique identifier, etc.).

BRUT undertakes to process the personal data of its users in accordance with the applicable law, and in particular with Law n°78-17 of 6 January 1978 relating to information technology, files and freedoms, known as "Informatique et Libertés" in its latest version in force, and with the European Data Protection Regulation n°2016/679 ("the applicable regulations on the protection of personal data").

1. Data controller’s contact details

The data controller of your personal data collected when you use the Application is BRUT, a French société par actions simplifiée (simplified joint stock company) registered with the Paris Trade and Companies Register under number 829 162 395 and having its registered office at 17 rue de l'Arrivée, 75015 Paris, [email protected]

2. Personal data collected by BRUT

The personal data to which BRUT has access are those that you provide us with when you create an account on the Application and when you use it. Therefore, BRUT collects in particular your e-mail address, login details, and information on your use of the Application (comments, likes, content viewed, etc.), in accordance with the conditions set forth in this Policy.

Unless otherwise stated, the information requested from you in the data collection forms available on the Application (e. g. account creation form) is mandatory. If you do not provide this information, you will not be able to validate the corresponding form. You are solely responsible for the accuracy of the data you provide to BRUT.

If you use the Facebook login feature, we will also collect the posts you have liked in order to provide you with relevant content from the moment you first log in.

3. Use of your personal data

We collect and process your personal data for the purposes and on the legal grounds described in the table below.

When you use the Application, we also collect information about your mobile device and how you use the Application, by means of trackers. For more information on these trackers, please refer to Article 6 hereunder.

Purpose of processing of the data	Legal ground
Management of user accounts and provision of the Application.	Performance of the general conditions of use of the Application.
Analysis of the preferences and areas of interest of the users of the Application.	BRUT’s legitimate interest in knowing its users’ preferences and areas of interest in order to improve its Application.
Analysis of areas of interest of the users of the Application connected via Facebook. BRUT’s legitimate interest in knowing its users’ preferences and areas of interest in order to improve its Application.	Display of personalized content to the users of the Application, in accordance with their preferences and areas of interest. BRUT’s legitimate interest in offering its users personalized content and an enhanced experience of the Application.
Management of requests from the users of the Application (notably requests to exercise rights in accordance with the conditions set forth in Article 8 hereunder).	BRUT’s legal obligation to respond to requests to exercise rights from persons whose personal data BRUT processes.
BRUT’s legitimate interest in responding to other questions and requests from users of its Application.	Management of pre-litigation and litigation. BRUT’s legitimate interest in asserting its rights in the context of pre-litigation or litigation.

4. Recipients and transfers of your personal data

Your personal data is collected, processed and stored by BRUT’s authorized personnel. We also transfer your personal data to the following recipients:

Your data will be pseudonymized and provided to our partner Crossing Minds Inc. to feed their content recommendation algorithms, which we will subsequently use to offer you the content most relevant to you.

Your non-pseudonymized personal data is not transferred outside the European Union.

5. Retention period of your personal data

Purpose/Data	Initial retention period	Archiving period
Management of user accounts and provision of the Application.	As long as your user account is active. A user account is considered “inactive” after 1 year with no log-ins. It is then automatically closed.	5 years after your user account is closed.
Analysis of the preferences and areas of interest of the users of the Application.	As long as your user account is active.	5 years after your user account is closed.
Display of personalized content to the users of the Application, in accordance with their preferences and areas of interest.	As long as your user account is active.	5 years after your user account is closed.
Management of requests from the users of the Application (notably requests to exercise rights in accordance with the conditions set forth in Article 8 hereunder).	Until your request is closed.	5 years after your request is closed.
Management of pre-litigation and litigation.	Until the definitive amicable resolution of a pre-litigation or until all legal recourse has been exhausted.	Settlement agreements and court decisions are definitely archived when they are of historical interest to BRUT.

The retention period for the cookies used on the Application is indicated in Article 6 hereunder.

6. Cookies

We use various cookies on the website to improve the interactivity of the Application.

A cookie (or other tracking device) is a small file placed on the hard drive of the user’s computer or mobile device when the user first visits the website. It allows us for example to see how many times a page is visited and to recognize a user who has already accessed the website. This can help us to personalize services and make navigation easier.

You will find hereunder a list of the cookies used on the Application, their purpose and how to disable them. With the exception of the cookies needed for the Application to function, which you cannot disable, these cookies can be disabled at any time, individually or all together. However, if you disable all or any of the cookies shown below, certain elements and functionalities will not be offered to you.

Name of cookie	Purpose	Period of storage
Google Analytics	Statistics related to website and application usage	13 months
Google Ads	Assessment of advertising campaign effectiveness	13 months
Facebook Pixel	Statistics related to redirection from Facebook to our website and application	13 months
Snapchat	Improvement of Snapchat advertising campaigns	13 months
Tiktok	Statistics related to redirection from Tiktok to our website and application	13 months

7. Security of your personal data

We undertake to protect the personal data that we collect. To this end, BRUT takes all necessary physical, technical and organizational measures to prevent any unauthorized or unlawful processing, as well as any accidental loss, destruction or destruction of your personal data.

8. Your rights to of your personal data

You have the right to access your personal data and obtain a copy of them, to object to the processing of these data, and to have them rectified or erased. You also have the right to restriction of processing of your data and to data portability. Finally, you have the right to specify what happens to your data in the event of your death.

As regards the right of objection, we draw your attention in particular to the fact that you can object at any time to the processing of your personal data based on the pursuit of our legitimate interests (for example, processing aimed at analyzing your preferences and areas of interest and offering you personalized content).

To learn more about your rights, you can visit the CNIL website https://www.cnil.fr/en/rights-and-obligations

To exercise your rights, please contact us at [email protected].

If you consider that your rights have not been respected, you can lodge a complaint with the CNIL.

9. Amendments to the Privacy Policy

This Privacy Policy may be updated. You will be informed by e-mail of any significant amendment to the Privacy Policy.

Date of last update January 3, 2019