Privacy Policy – LUCKYSIT
Updated version as of 23/05/2024

This Privacy Policy aims to inform you about the characteristics of the processing operations implemented by LUCKYSIT with regard to your personal data when you use and access the Luckysit platform or our website www.luckysit.com, when you participate in a contest or lottery organized by LUCKYSIT, and/or when you interact with our teams.
The Privacy Policy also provides information about the rights you have with regard to your personal data and how you can exercise them with us.
Transparency being a fundamental value for LUCKYSIT, we attach the utmost importance to the respect of the privacy of our users and comply in this respect with the provisions of the French Data Protection Act (Loi Informatique et Libertés) No. 78-17 of January 6, 1978 in its current version and of Regulation (EU) No. 2016/679 of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

Who are we?
The processing operations described in this Privacy Policy are implemented by LUCKYSIT SAS, a simplified joint-stock company (société par actions simplifiée) registered with the Trade and Companies Register of Lyon under number 912 645 017, and whose head office is located at 24 rue Laure Diebold, 69009 Lyon, (hereinafter: “LUCKYSIT”).

What categories of personal data do we collect?
We collect your personal data directly from you in the following cases:
– you use and/or create a user account on the Luckysit web platform,
– you participate and/or win a prize in a contest or lottery organized by LUCKYSIT,
– you browse our website,
– you subscribe to our newsletter,
– you send us a request or question via the contact form accessible from our website,
– you exercise your rights concerning the processing of your personal data by LUCKYSIT.

The categories of personal data collected by LUCKYSIT include:
– Identification data (surname, first name)
– Contact details (email address, postal address, telephone number)
– Your exchanges with your interlocutors at LUCKYSIT (content of requests and exchanges addressed to LUCKYSIT),
– Your usage data and browsing history on the Luckysit site and/or platform.

Please note that the collection of your personal data is required in order to be able to register on the Luckysit web platform and/or participate in an event organized by LUCKYSIT.

How do we use your personal data?
The information contained in this section is intended to help you better understand the purposes pursued by the processing operations we implement, the grounds on which the implementation of these processing operations is based, and the length of time your personal data is retained.

Ensure the creation and management of your user account
▸ Legal basis: performance of pre-contractual measures at your request and performance of the contract
▸ Categories of personal data: identification data (surname, first name), contact details (email address), authentication method (password), usage history (list of events)
▸ Retention period: for the entire duration of validity of the user account, until its deletion initiated by the user or upon the expiration of a period of 2 years from the last action carried out by the latter.

Establish usage statistics for our services
▸ Legal basis: consent
▸ Categories of personal data: IP addresses, unique identifiers (generated via cookies or trackers)
▸ Retention period: 26 months

Measure the effectiveness of advertising campaigns
▸ Legal basis: consent
▸ Categories of personal data: IP addresses, unique identifiers (generated via cookies or trackers)
▸ Retention period: 13 months.

Manage your participation in a contest or lottery
▸ Legal basis: performance of pre-contractual measures at your request and performance of the contract
▸ Categories of personal data: identification data (surname, first name), contact details (email address, postal address)
▸ Retention period: for the duration of the event, then archiving in an intermediate database for a period of 5 years for evidentiary purposes in case of a dispute.

Manage the sending of commercial communications by LUCKYSIT
▸ Legal basis: consent
▸ Categories of personal data: contact details (email address)
▸ Retention period: 3 years from the collection of the contact details or the last contact with the recipient of the communications (e.g.: click on a link in an email).

Manage the sending of our newsletter
▸ Legal basis: consent
▸ Categories of personal data: contact details (email address)
▸ Retention period: 3 years from the collection of the contact details or the last contact with the recipient of the newsletter (e.g.: click on a link in an email).

Respond to your requests and questions sent from the site
▸ Legal basis: legitimate interest of LUCKYSIT to provide information and answers to its prospects and users
▸ Categories of personal data: identification data (surname, first name), contact details (email address, telephone number), content and nature of the request
▸ Retention period: 12 months from the sending of the response by LUCKYSIT.

Respond to your requests to exercise your rights
▸ Legal basis: legal obligation incumbent upon LUCKYSIT
▸ Categories of personal data: identification data (identity, email address), content and nature of the request, copies of identity documents
▸ Retention period: deletion upon the processing of the request (copy of identity document), for 5 years from the date of the processing of the request or 6 years for requests to exercise the right of opposition.

How do we share your personal data?
Your personal data is transferred to our subcontracting partners, to whom LUCKYSIT entrusts in whole or in part the implementation of the processing operations described in the Privacy Policy. Our subcontracting partners include in particular our partners in charge of the hosting or maintenance of the Luckysit site or platform, the sending of our newsletter and our commercial communications, the establishment of usage statistics.
When you expressly consent to it, your personal data is also transferred to our partners, so that they can contact you and obtain your consent to the sending of commercial communications relating to their products and services. Our partners who receive your personal data include in particular the sponsor of the event proposed by LUCKYSIT, and, where applicable, any other partner mentioned in the description of the event in which you participate.
In any event, and regardless of the purpose of the processing operation implemented with regard to your personal data, we may be required to disclose your personal data:
– in all cases where the law, a regulation in force, a court order or a regulation requires or authorizes it, or if this disclosure is necessary as part of an investigation, or a procedure, on the national territory or abroad,
– to our advisors, auxiliary officers of justice, ministerial officers, administrations, courts or administrative authorities when this is necessary for the establishment, exercise or defense of the rights of LUCKYSIT.

Transfers of your personal data outside the European Union
The personal data we collect is not transferred outside the European Union.

Security of your personal data
We adopt appropriate technical and organizational measures to protect your data as completely as possible. In addition to our employees’ commitment to respect confidentiality, a rigorous selection and a careful control of our service providers, who are required to comply with high security standards regarding the protection of your personal data, we also secure our operational environment in an adequate manner.

What are your rights and how can you exercise them?
In accordance with the regulations on the protection of personal data, you have the following rights with regard to your personal data and the processing operations we implement:
– The right to obtain information about the characteristics of the processing operations implemented with regard to your personal data,
– The right to access your personal data that is subject to processing,
– The right to rectify your personal data when it is incomplete or inaccurate,
– The right to obtain the erasure of your personal data,
– When we implement a processing operation based on your consent, the right to withdraw your consent at any time,
– The right to object to the processing of your data and/or to obtain the limitation of the processing of your data,
– The right to request the portability of the personal data that you have provided to us, when it is subject to automated processing operations based on your consent or the performance of a contract,
– The right to define advance directives regarding the fate of your personal data after your death, in particular to require its erasure or its transmission to a third party.

You can exercise your rights at any time by sending a request by email to the following address: dpo@luckysit.com or by mail to the following address: 24 rue Laure Diebold, 69009 Lyon.
In order to enable LUCKYSIT to respond to you quickly, we thank you for indicating your surname, first name, email and address in your request to exercise your rights. For reasons of confidentiality and protection of your personal data, we will have to identify you in order to respond to your request. For this purpose, in case of reasonable doubts about your identity, you may be asked to provide a copy of an official identity document, such as an identity card or a passport, in support of your request.
In accordance with the regulations, and except in special cases, a response to your request will be sent to you within a period of one month from the receipt of your request.
If you no longer wish to receive commercial solicitations by electronic means (email, SMS) from us, you can also unsubscribe via the unsubscribe links provided in the emails or SMS that are sent to you.
In any event, you have the right to lodge a complaint with the competent supervisory authority, namely for France the Commission Nationale de l’Informatique et des Libertés (CNIL) (3 Place de Fontenoy TSA 80715 75334 PARIS CEDEX 07 – +33 (0)1 53 73 22 22 – https://www.cnil.fr/)

Contact us – Update of the Privacy Policy
For any remarks or questions relating to the content of the Privacy Policy, you can write to us by email at the following address: dpo@luckysit.com.
Luckysit may modify this Privacy Policy periodically, in connection with the evolution of the processing operations implemented from the Platform or as part of the services provided by LUCKYSIT, and/or the changes made to the applicable regulations. Therefore, we invite you to consult this Privacy Policy regularly.
The current version of this Privacy Policy is accessible at any time from the website www.luckysit.com.