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Privacy Policy

Introduction

This privacy policy (the “Policy”) explains which personal data we process, why, for how long, with whom we share it and which rights you can exercise.

It applies to the OnYuu mobile application (the “Application”), to the website https://on-yuu.com (the “Site”) and to the area reserved for Partner Venues accessible from the Site.

The Policy constitutes the information required by Articles 12 to 14 of Regulation (EU) 2016/679 (the “GDPR”) and by the amended French Law No. 78-17 of 6 January 1978, known as the “Informatique et Libertés” Act (the French Data Protection Act). It supplements the Terms of Use (Conditions Générales d’Utilisation, the “Terms of Use”) and, for Partner Venues, the Terms of Sale, without replacing them. Capitalised terms that are not defined here have the meaning given to them in the Terms of Use.

Personal data means any information relating to an identified or identifiable natural person. We only collect data that is adequate, relevant and limited to what is necessary for the purposes described below.

We do not ask you to provide so-called “sensitive” data within the meaning of Article 9 of the GDPR — racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health data, sex life or sexual orientation — and we do not use your data to infer such information. We would nevertheless draw your attention to one point: a profile photograph, the content of a written or voice message, a story or your presence at a particular place may, depending on the circumstances, indirectly reveal such information to other Users. Bear this in mind before publishing content or activating Mode ON, and avoid sharing sensitive information about yourself or about third parties in Ephemeral Discussions.

1. Who is responsible for your data?

The data controller is TS TESSIER, a French single-shareholder simplified joint-stock company (société par actions simplifiée unipersonnelle) with a share capital of 1,000 euros, registered with the Paris Trade and Companies Register (R.C.S.) under number 993 469 048, whose registered office is at 11 rue Marguerite de Rochechouart, 75009 Paris, France, operating the Service under the trade name “OnYuu” and represented by its President, Mr Sorel Tessier (“OnYuu”, “we”, “us”).

You can contact us by email at support@on-yuu.com or by post at TS TESSIER — OnYuu, 11 rue Marguerite de Rochechouart, 75009 Paris, France. This email address is also the point of contact provided for by Regulation (EU) 2022/2065 on digital services (Digital Services Act).

We have not appointed a data protection officer: such an appointment is not mandatory in view of our current activities. We review this question at regular intervals, in particular as the number of Users and the scope of processing evolve. Requests relating to your data are handled by the point of contact indicated above.

2. Who and what does this Policy apply to?

The Service is accessible via the Application. The Site presents the Service, makes our contractual documents available and hosts the area reserved for Partner Venues. The Service is reserved for natural persons aged eighteen (18) or over and, at present, for Users located in France.

The Policy concerns three categories of people: Users of the Application, visitors to the Site, and natural persons representing a Partner Venue.

3. What data do we process, for what purposes and on what legal basis?

We collect data when you create an Account, use the Application, activate Mode ON, interact with other Users, use an Offer, take out a Subscription, visit the Site or contact us.

Some data is not provided to us directly by you. It comes from your device (technical and connection data), from the download platforms (the status of your Subscription), or from other Users and third parties (reports of content or behaviour). These cases are indicated below.

3.1 Creating and managing your Account

Creating an Account is necessary to access the Service. For this purpose we collect your first name, your email address, your date of birth, your authentication data (password, in encrypted form), your username and, if you wish, a profile photograph or an avatar chosen from those we offer, other photographs, a short introduction (“bio”) and the other profile information offered by the Application.

Your date of birth allows us to check that you meet the age requirement set by the Terms of Use. Photographs that you add to your profile or send in a room or a private conversation can be cropped in the Application: this cropping is carried out on your device, before sending.

What other Users see. Not all elements of your profile are visible to the same people:

• any logged-in User sees your first name, your username, your age (calculated from your date of birth, which is not displayed), your profile photograph or avatar, your bio if you have written one, as well as the other identity information you have provided (for example gender or city), your badges and the number of your followers, people you follow and contacts;
• Users who follow you additionally see your current vibe (“Mood”), your interests and all of your photographs. Following a User does not require their agreement: anyone who chooses to follow you has access to these elements. Following does not allow them to write to you;
• your contacts (Users with whom a contact request has been accepted, or with whom you follow each other, under the conditions of Article 3.3 ter) additionally see the personality sections of your profile, and can write to you in a private conversation.

A person you have blocked, or who has blocked you, sees no element of your profile. Your email address and date of birth are never visible to other Users.

We use this data to create and manage your Account, authenticate you, send you the messages necessary for the operation of the Service (confirmation of registration, password reset via a secure (https) single-use link valid for one hour, information about a change to the Service or to our contractual documents) and respond to your requests.

The Terms of Use restrict access to the Service to certain conditions, in particular the absence of any final criminal conviction for sexual offences or violent offences. Compliance with these conditions relies on your declaration at registration: we do not ask you for any document relating to your criminal record, we have no access to any judicial records and we do not record any data relating to convictions or offences. We only act if precise and legitimate information reaches us — a final and public court decision, a substantiated report, a notification from a competent authority — and solely for the purposes of the measure to be taken.

Legal basis: the performance of the contract you enter into with us by accepting the Terms of Use (Article 6(1)(b) of the GDPR). Checking your eligibility for the Service is also based on our legitimate interest in protecting Users and the integrity of the Service (Article 6(1)(f)).

3.2 Mode ON, geolocation and the Map

Mode ON is an optional feature that you activate yourself, for a limited period, in order to signal your presence at a place and to be visible on the Map to other Users nearby.

What we process

• the location of your device, provided by your operating system, for the duration of the activation;
• the timestamp of activation and deactivation;
• your presence at a place (“check-in”): the place, the time of arrival and the time of departure;
• where your presence is linked to a Partner Venue or to a vibe (“Mood”), that information.

Why

To make you visible on the Map to Users located nearby, to link your presence to a place or to a vibe, to display how busy places are, to give you access to Ephemeral Discussions and Offers, and to ensure the security and reliability of the Service.

What other Users see

Users within a restricted geographical area see an approximate presence at a place, and not your exact address, together with the elements of your profile that are visible in the Service. They see neither your past activations nor your movements. Please note: a story you publish is linked to a venue and reveals, for as long as it is visible, that you were there (see Article 3.3 bis).

Your consent

This processing is based on your consent (Article 6(1)(a) of the GDPR), obtained in the Application at the time of activation, separately from your acceptance of the Terms of Use. This consent is also required under Article 82 of the French Data Protection Act for reading the location information stored on your device. The permission granted to the Application in your phone’s settings does not, on its own, constitute consent: you are asked for each of them separately.

You can withdraw your consent at any time, as easily as you gave it, by deactivating Mode ON in the Application. The collection of your location then stops immediately and your presence disappears from the Map. If you do not deactivate it manually, Mode ON switches off automatically at the end of the period indicated in the Application. Withdrawing your consent does not affect the lawfulness of processing already carried out.

What declining Mode ON means. You can use the Service without ever activating Mode ON: view the Map, Partner Venues, vibes and stories, save or follow places, chat in your private conversations and manage your Account. However, the features that rely on presence at a place — visibility to Users nearby, rooms (Ephemeral Discussions), publishing stories and Offers — are only available when Mode ON is activated. Your choice remains free: it is made activation by activation and is never final.

Scope and limits of the collection

• No background collection. Your location is only processed while Mode ON is activated. We do not collect your location when Mode ON is deactivated, nor when the Application is not in use.
• No continuous tracking. In its current design, Mode ON is neither a continuous geolocation system nor a means of tracking your movements. We do not keep a history of your GPS positions. Your presences at places are, however, recorded: for each presence, we keep the place, the time of arrival and the time of departure for thirty (30) days after you leave. During that period, the list of these presences constitutes a history of the places you have been to.
• Limited retention. Your current location is deleted no later than twenty-four (24) hours after its last update. Each presence at a place (place, time of arrival and time of departure) is deleted thirty (30) days after you leave; a presence that is still ongoing is not deleted. Thereafter, all that remains, for each place and each day, is a total number of presences that contains no data about you. By way of exception, where a story published during a presence is reported, that presence is kept for as long as the story is kept for moderation purposes (Article 3.8).
• Restricted internal access. Access to location data is limited to authorised persons who need it for the operation, security or support of the Service.
• No reuse for other purposes. Your location data is not used for advertising purposes and is not passed on to Partner Venues in a form that would allow you to be identified.

Should we introduce a different location feature in the future, in particular one operating in the background, this Policy would be updated and your consent obtained again before any new collection.

Fair use of Mode ON

The Terms of Use ask you not to activate Mode ON at a place where you are not present. In the event of serious doubt as to the genuineness of an activation, or following a report, we may carry out a one-off check based on the data of the activation concerned, in order to prevent fraudulent use. Such checks are examined on a case-by-case basis; any measure likely to significantly affect you involves human intervention. This processing is based on our legitimate interest in ensuring the reliability and security of the Service (Article 6(1)(f) of the GDPR).

3.3 Interactions, rooms and private conversations

When you interact with other Users, we process the content of your exchanges — written messages, photographs, voice messages, reactions and replies — as well as the associated metadata: participants, timestamp, place or room concerned.

Rooms (Ephemeral Discussions)

A room is a group discussion linked to a place. You can only access it when Mode ON is activated and you are on site. Its messages, photographs, voice messages and reactions are visible to the members of the room. They are deleted when the room ends, that is to say when it is closed or when its duration, shown in the Application, expires.

Where a room is an official room opened by a Partner Venue, the members of that venue’s team can read, without being able to write in it, the usernames of the participants and the text of the messages, for as long as the room is open.

Private conversations

A private conversation opens between two Users when they become contacts (Article 3.3 ter). Its messages (text, photograph, voice message) are only visible to its two participants. If one of them removes the other from their contacts, or in the event of blocking, the conversation remains readable by both participants, in read-only mode: no new message can be sent in it.

• Retention period: each message is deleted twelve (12) months after it was sent, together with the files and thumbnails that accompany it.
• Ephemeral mode: either participant can switch a conversation’s ephemeral mode on or off. The setting applies to both participants, and each change is announced in the conversation by an automatic message. Messages sent while ephemeral mode is on are deleted twenty-four (24) hours after they were sent. The change only applies to messages sent after it: earlier messages keep their retention period.

Photographs and voice messages

Photographs and voice messages exchanged in a room or a private conversation are first uploaded to a staging area of our storage space. When they are sent, we check the file (size, format and, for a voice message, duration), we strip photographs of their metadata (EXIF data, including GPS location, as well as XMP and IPTC data) before any distribution, and we then save the file to its final location; files that are uploaded but never sent are erased automatically. Photographs in HEIC format are not accepted in rooms and private conversations, because their metadata cannot be removed; the Application converts your photographs into an accepted format before sending. The files are then delivered only to the participants by means of temporary links. The Service does not accept links to media hosted by third parties.

Other photographs (profile, gallery, stories) — both the original and the thumbnails we generate — are rewritten without their metadata (EXIF data, including GPS location, as well as XMP, IPTC and ICC data) shortly after upload. Limitation: a photograph in HEIC format uploaded other than through the Application (for example from the Partner Venues web area) cannot be processed and keeps its metadata.

Voice messages. When you record a voice message, the Application records your voice using your device’s microphone, only during the recording that you trigger, up to a limit of sixty (60) seconds per message. The recording of your voice is personal data. It is only stored and delivered to the participants: it is not transcribed or subjected to any processing intended to identify you by your voice. It follows the retention period of the room or conversation in which it was sent. Access to the microphone requires your permission in your device’s settings.

Reactions and replies

You can react with an emoji to messages from other participants (but not to your own) and reply to a message by quoting it. Your reactions and the quoted message are visible to the participants and are deleted along with the message to which they relate.

Caveats

Two caveats, one technical and the other legal, must be brought to your attention:

• copies may temporarily remain in our security backups until they are overwritten by the normal rotation cycle of those backups;
• where content is the subject of a report or a moderation procedure, it is exempt from automatic deletion and is kept under the conditions described in Article 3.8.

Furthermore, we cannot technically prevent a participant from taking a screenshot or a recording of an exchange. The ephemeral nature relates to the availability of the content within the Service.

Legal basis: the performance of the contract (Article 6(1)(b) of the GDPR). Keeping reported content is based on our legitimate interest in ensuring moderation and, where the regulations so require, on a legal obligation (Articles 6(1)(f) and 6(1)(c)).

3.3 bis Stories

A story is a photograph or a short video (fifteen (15) seconds at most, sound included), optionally accompanied by a caption, that you publish from the Application. It is linked to a venue and can only be published when you are on site, with Mode ON activated.

• Who sees it: all logged-in Users, except people you have blocked or who have blocked you. Your story is only displayed while your Mode ON is activated. It is accompanied by your username and the name of the venue, and therefore reveals that you were there.
• For how long: you choose the visibility period when publishing — two (2), six (6), twelve (12) or twenty-four (24) hours, twelve (12) hours by default. At the end of that period, the story is no longer visible to other Users; its file is deleted within the following twenty-four (24) hours, during which you can still view the list of people who have seen it.
• Views and reactions: when you open another User’s story or react to it, its author sees your username, the time you viewed it and any reaction.

Legal basis: the performance of the contract (Article 6(1)(b) of the GDPR).

3.3 ter Following and contacts

The Service distinguishes between two relationships between Users: following a User allows you to see their activity (current vibe, interests and photographs, in accordance with the rules of Article 3.1) without being able to write to them; being contacts allows you to write to each other in a private conversation.

• Following: following a User does not require their agreement. The person followed receives a “New follower” notification, no more than once per twenty-four (24) hour period for the same follower.
• Becoming contacts: two Users become contacts when one accepts the other’s contact request, or when they follow each other. In the latter case, they become contacts automatically, a private conversation is opened between them and each receives the notification “You are now contacts”. This automatic contact never takes place if either of them has previously declined a request from the other, removed the other from their contacts or blocked the other. Subsequently unfollowing the person does not remove the contact. A request that remains unanswered for fourteen (14) days expires; this is not a refusal.
• Declining a request: the request disappears. The person whose request is declined receives no notification of it and the Application does not tell them that their request has been declined. They can only send a new request to the same person after a period of thirty (30) days; before then, the Application simply tells them that a request has already been sent recently. Only the person who declined can reopen the contact, at any time, by sending a request themselves or by accepting a new request.
• Removing a contact: when you remove a User from your contacts, they are not notified. You can no longer write to each other, but the private conversation remains readable by both of you, in read-only mode; its messages remain subject to the retention periods of Article 3.3 (twelve (12) months, or twenty-four (24) hours for messages sent in ephemeral mode). If the contact is reopened by the person who removed it, the same conversation becomes active again.
• Blocking: blocking takes precedence over everything else: neither User can see the other’s profile any more, any following between them is removed and an existing conversation becomes read-only. Unblocking does not restore any following; if you were contacts before the block, the contact is restored, otherwise no contact is created automatically afterwards, even if you follow each other.
• Meeting place: a place is only displayed as a meeting place for a contact if both Users were present there at the same time, according to their recorded presences (Article 3.2). Otherwise, no place is displayed.

Record of refusals. To prevent a contact from being recreated automatically against the wishes of either User, we keep a record of the fact that a refusal, a removal or a block has occurred between two Users: who decided it, towards whom, its nature and the date of the most recent decision. For this purpose we keep neither the reason, nor the place, nor any content. This information is kept for as long as both Accounts exist and is erased when either Account is deleted.

Legal basis: the performance of the contract (Article 6(1)(b) of the GDPR) for following, contacts and the associated notifications. [Legal basis for the record of refusals: to be completed following legal advice.]

3.4 Partner Venues and Offers

When you use an Offer, we record the Partner Venue concerned, the Offer used and the date and time of its use. This data allows us to operate the feature, to check compliance with the conditions set by the Partner Venue and to prevent fraudulent use.

An Offer is validated within the Application, with the Partner Venue. We do not disclose any individual data about you to Partner Venues: neither your first name, nor your email address, nor your date of birth, nor your location, nor the history of your Mode ON activations or of your Offers. The only exception: in an official room opened by a Partner Venue, its team can read the usernames of the participants and the text of their messages while the room is open (Article 3.3).

Saving and following a place. You can “Save” a place so that you can find it again in your profile: this action does not trigger any notification. You can also “Follow” a place: by following it, you agree to be informed of its offers, outings and events, in particular through the alerts described in Article 3.9. A followed place is also saved; unfollowing it leaves it saved. You can unfollow a place at any time from its page.

We make usage statistics available to Partner Venues — footfall, attendance trends, Offer redemption rates. These statistics are exclusively aggregated: they relate to groups of Users and are designed so that the behaviour of any specific person cannot be singled out. They contain no identifier, no profile data and no individual location.

A useful reminder: the Partner Venue sees you physically on its premises when you use an Offer, like any business receiving a customer. That information does not come from us.

Legal basis: the performance of the contract, for the operation of Offers (Article 6(1)(b) of the GDPR); our legitimate interest in measuring the use of the Service and reporting on it to our partners, for the production of aggregated statistics (Article 6(1)(f)).

3.5 Subscription and payment

The Subscription giving access to the Premium Features is taken out from the Application and processed entirely by the download platform through which the Application is distributed, namely Apple’s App Store or Google Play.

You never give us your bank details and we have no access to them. They are collected and processed by Apple or Google, which act in this respect as separate data controllers, in accordance with their own privacy policies and terms of use.

We receive from these platforms only the information necessary to grant and maintain your entitlements: a technical transaction or subscription identifier, the status of your Subscription (active, expired, cancelled, disputed) and the corresponding dates. Your Subscription is managed, changed and cancelled from the account you hold with the platform concerned.

We also draw up and keep the accounting records that the regulations require us to keep.

Legal basis: the performance of the contract (Article 6(1)(b) of the GDPR) and compliance with our accounting and tax obligations (Article 6(1)(c)).

3.6 Area reserved for Partner Venues

When a Partner Venue enters into a relationship with us, we process the data of the natural persons who represent it: surname and first name of the contact person, job title, business email address and telephone number, login credentials for the partner area, content submitted for publication, orders, invoices and correspondence exchanged in the course of the business relationship.

This data comes from the person concerned or from the Partner Venue. When we contact a venue for business prospecting purposes, it may also come from publicly accessible professional sources.

Payment for orders placed on the Site is processed by our payment service provider, Mollie. Bank details are entered in that provider’s secure environment: they do not pass through the Site and are not stored by us. We only have access to the information necessary to manage the contractual relationship: payment status, invoices and billing history.

Legal basis: the performance of the contract or pre-contractual measures (Article 6(1)(b) of the GDPR); our legitimate interest in making the Service known to professional establishments (Article 6(1)(f)); our accounting and tax obligations (Article 6(1)(c)).

3.7 Featured content, vibes and no profiling

The content you see in the Application — Partner Venues displayed on the Map, vibes, available Offers — is selected on the basis of your location when Mode ON is activated, the vibe you choose and the filters you yourself apply in the Service.

We do not build an advertising profile about you and we do not take any decision based solely on automated processing which produces legal effects concerning you or similarly significantly affects you within the meaning of Article 22 of the GDPR.

Should we introduce personalisation based on your usage history, we would inform you in the Application before implementing it, indicating the main criteria used, and this Policy would be updated.

3.8 Security, moderation and reports

We process technical data — IP address, technical session and device identifiers, connection and event logs — in order to ensure the security of the Service and to detect and prevent fraud, abuse and unauthorised access.

Where content or behaviour is reported, we process the content concerned, the identification data of the reported User and of the person who made the report, as well as the contextual elements necessary to examine the report and the measure taken. The identity of the person who made a report is not disclosed to the reported User, except where the law requires us to do so.

Context sheet. To examine a report, OnYuu administrators consult a sheet limited to the reported content. It includes: the reported content; where it is a message, no more than three (3) messages preceding it and three (3) following it in the same private conversation or room (a message already deleted at the end of its retention period only appears if it is kept under the conditions below); the history of reports received and sanctions imposed on the reported User; for each person who made a report, the number of reports they have made and their outcome, as well as their relationship with the reported User (contact, pending request, block, shared conversation or room). It contains no email address, telephone number, date of birth or shared location. Each consultation of a sheet is recorded in an audit log (administrator, date and time, content consulted, designated by technical identifiers), kept for three (3) years.

Retention of reported content. When a message in a room or private conversation (text, photograph or voice message) is reported, we keep a copy of it with the report. The reported content and that copy are exempt from the automatic deletion described in Article 3.3: once the date on which the content should have been deleted has passed (end of the room, expiry of the private message), it is only visible to the people responsible for moderation. This retention lasts:

• for as long as the report has not been dealt with;
• once the report has been dealt with, whatever the decision — a measure (removal of the content, closure of the room, restriction or suspension of the Account) or dismissal of the report —, for one hundred and eighty-three (183) days after the decision, in order to allow the internal complaint-handling procedure provided for by Regulation (EU) 2022/2065 to be used: the User subject to a measure can contest it, and the person who made the report can contest a dismissal, from the “Contest a decision” screen in the Application;
• for as long as a complaint against the decision is being examined.

They are then deleted. The other elements of the report (reason, status, decision, dates) are kept under the conditions set out in Article 4.

We may use tools based on artificial intelligence technologies to identify content or behaviour likely to breach the Terms of Use. These tools are used to support our teams: any individual decision likely to significantly affect you — in particular the restriction, suspension or deletion of your Account — involves human intervention. You are informed of the measure taken, the reasons for it and the means of challenge available to you, in accordance with Regulation (EU) 2022/2065, except where the law prohibits this or where overriding reasons of security or the prevention of a criminal offence justify it.

When we become aware of information giving rise to a suspicion that a criminal offence involving a threat to the life or safety of a person has taken place, is taking place or is likely to take place, we inform the competent authorities without delay.

Legal basis: our legitimate interest in ensuring the security of the Service and protecting Users (Article 6(1)(f) of the GDPR); compliance with our legal obligations as a provider of hosting services and of an online platform (Article 6(1)(c)).

3.9 Notifications

If you agree to receive notifications, we process the technical notification identifier assigned to your device by Apple or Google, in order to send you messages relating to the operation of the Service and to your Interactions. Promotional notifications are only sent to you with your consent. You can change your choices at any time in the settings of the Application or of your device.

Delivery of notifications. Notifications sent by our servers are delivered by Apple’s notification service (Apple Push Notification service) on iPhone and by Firebase Cloud Messaging, a Google service, on Android. These providers therefore receive your device’s notification identifier and the text of the notification. Message notifications do not contain the content of the message: they only show the sender’s username (for example “Username sent you a message”) and technical identifiers allowing the right conversation to be opened. The notification identifier is linked to your device’s login session: it is deleted when you log out, when your sessions are revoked (for example after resetting your password), when your Account is suspended and when your Account is deleted.

Flash offer alerts. When a Partner Venue publishes a flash offer, the Application may alert you through a notification generated on your device itself (local notification), without going through Apple’s or Google’s notification services. Two settings are offered in the Application:

• “Places I follow”: alerts for offers from places you follow. This setting is on by default, since following a place amounts to a request to be informed of its offers;
• “Offers within 250 m”: alerts for offers published less than 250 metres from you. This setting is off by default. When you switch it on, the distance is calculated on your device from its last known location: your location is not sent to OnYuu for this calculation.

These alerts are not issued when the Application has been closed. You can switch off each of these settings at any time.

Legal basis: the performance of the contract for notifications relating to the operation of the Service (Article 6(1)(b) of the GDPR); your consent for promotional notifications (Article 6(1)(a)).

3.9 bis Inviting your contacts

You can invite someone you know to join the Service. The Application then opens your device’s contact picker: you yourself choose the contact to invite. Only the number of the contact you have chosen is passed to the Application, which uses it solely to open your SMS app with a pre-filled message containing the link https://on-yuu.com/lancement; you can also share this link through the app of your choice. The Application does not request access to your contacts. Your address book is neither read by nor sent to OnYuu, and the chosen number is not sent to our servers.

3.10 Browsing the Site

When you visit the Site, we process your IP address, the date and time of connection, the pages viewed and technical information about your browser, your operating system and your device. This data is used to provide and secure the Site and to measure its audience.

The placing and reading of cookies and other trackers are described in Article 9 and in our cookie policy (in French).

Legal basis: our legitimate interest in ensuring the operation and security of the Site (Article 6(1)(f) of the GDPR); your consent for trackers that are not strictly necessary (Article 82 of the French Data Protection Act).

3.11 Contact, support and communications

When you write to us or call us, we process your first name, your email address, your telephone number if you give it to us, as well as the content of your request and any documents you attach to it, in order to respond to it and follow it up. Legal basis: the performance of the contract or our legitimate interest in handling requests sent to us.

If you subscribe to our newsletter, we process your email address and first name in order to send it to you, on the basis of your consent. You can unsubscribe at any time using the link included in each mailing.

4. Summary: purposes, legal bases and retention periods

The sheets below summarise, for each processing operation, its legal basis, its recipients and the applicable retention period.

Where processing is based on our legitimate interest, we balance that interest against your rights and freedoms before carrying it out. You can obtain information about this assessment by writing to us, and you have a right to object under the conditions set out in Article 10.

5. Who do we share your data with?

5.1 Other Users

The elements of your profile are visible to other Users in accordance with the rules described in Article 3.1: your first name, your username, your age, your profile photograph or avatar and your bio are visible to any logged-in User, except to people with whom a block is in place; other elements are reserved for Users who follow you or for your contacts (Article 3.3 ter). When Mode ON is activated, your approximate presence is visible to Users located nearby. Content you publish in a room is visible to its members, content in a private conversation to its other participant, and your stories to all logged-in Users during their visibility period.

5.2 Our service providers

We use service providers that process data on our behalf, as processors within the meaning of Article 28 of the GDPR: hosting, sending emails, delivering notifications, mapping service, audience measurement, moderation tools and support. They act only on our documented instructions, are bound by confidentiality and must implement appropriate security measures. The categories of recipients are listed in the appendix.

5.3 Partner Venues

Partner Venues only receive from us aggregated statistics, which do not allow you to be identified, subject to the reading of the official rooms they open, as described in Article 3.3. They are responsible for the processing they carry out on their own behalf in the course of their business.

5.4 The download platforms and our payment service provider

Apple and Google process payment and subscription data on their own behalf, as separate data controllers. The same applies to our payment service provider for orders placed by Partner Venues. Their privacy policies are their own.

5.5 Authorities and authorised third parties

We may be required to disclose data to the competent administrative or judicial authorities, where required by law or in response to a well-founded request. We may also disclose data to our advisers where this is necessary for the establishment, exercise or defence of legal claims. In the event of a transaction affecting our share capital or a transfer of business, data could be passed on to the acquirer, in compliance with the applicable regulations.

5.6 What we do not do

We do not sell your personal data and we do not pass it on to third parties for their own marketing purposes.

6. Transfers outside the European Union

We favour service providers that process data within the European Union: this is notably the case for the Site’s hosting provider and our payment service provider.

Some processing does, however, involve parties established outside the European Union, in particular in the United States. This is the case for the Apple and Google download platforms, including for the delivery of notifications, as well as for certain third-party services present on the Site. It is also possible that a service provider uses its own sub-processors located outside the European Union.

These transfers are subject to the safeguards provided for in Chapter V of the GDPR: an adequacy decision of the European Commission for countries that benefit from one, or standard contractual clauses adopted by the European Commission, supplemented, where necessary, by additional measures.

You can obtain information about these transfers, the list of recipients concerned and a copy of the safeguards in place by writing to us at support@on-yuu.com.

7. How long do we keep your data?

We only keep your data for as long as necessary for the purposes pursued. The applicable periods are set out in the sheets in Article 4.

7.1 Inactive Account

After thirty-six (36) months without use of your Account, we send a message to your email address. If you do not reply within one month, your Account and the associated data are deleted or anonymised.

7.2 Deleting your Account

You can request the deletion of your Account at any time, using the contact form available in the Application and on the Site, or by email to support@on-yuu.com. We will do so without undue delay and, at the latest, within one month of your request.

Deleting your Account removes your profile and your presence from the Map and erases your data from our active systems. It does not cancel a Subscription taken out with a download platform: that cancellation is made from the account you hold with that platform.

Some data is kept beyond deletion:

• accounting records, for ten (10) years, pursuant to Article L. 123-22 of the French Commercial Code;
• identification data that the regulations applicable to online public communication services require us to keep, for the period they prescribe;
• elements relating to a report or a moderation measure, under the conditions set out in Article 4;
• data necessary for the establishment, exercise or defence of legal claims, in the form of a restricted-access archive, until the applicable limitation period expires;
• copies present in our security backups, until they are overwritten by the normal rotation cycle of those backups.

Data kept in archives is no longer used to provide the Service and access to it is reserved for people who specifically need it.

8. How do we protect your data?

We implement technical and organisational measures designed to ensure a level of security appropriate to the risk, in accordance with Article 32 of the GDPR, in particular:

• encryption of communications between your device and our servers;
• storage of passwords in a non-reversible encrypted form, and password reset via a secure (https) single-use link valid for one hour;
• uploading photographs and voice messages to a staging area of our storage space, checking them before any distribution, delivering them only to authorised recipients by means of temporary links, and removing metadata (EXIF, including GPS location, XMP, IPTC, ICC) from original photographs and their thumbnails; the HEIC format is refused in rooms and private conversations, and a HEIC photograph uploaded outside the Application to another part of the Service keeps its metadata;
• deletion of a device’s notification identifier at the end of the login session to which it is linked;
• recording administrators’ actions in an audit log kept for three (3) years, including each consultation of a moderation context sheet;
• limiting internal access to authorised persons only, on a need-to-know basis, with a particular restriction for location data;
• selecting service providers offering sufficient guarantees and governing them by a contract compliant with Article 28 of the GDPR.

As no system is infallible, we cannot guarantee absolute security. In the event of a personal data breach likely to result in a high risk to your rights and freedoms, we will inform you under the conditions provided for in Article 34 of the GDPR.

It is your responsibility to keep your login credentials confidential and not to share them with anyone. Let us know without delay of any unauthorised use of your Account.

9. Cookies and trackers

9.1 On the Site

A cookie is a file placed on your device when you use an online service, which allows its issuer to recognise that device during its period of validity.

On your first visit, a banner allows you to accept or refuse, purpose by purpose, the placing of trackers that are not strictly necessary for the operation of the Site. Refusing is as easy as accepting, and no non-essential tracker is placed before your consent has been obtained. Strictly necessary trackers are placed without consent, in accordance with Article 82 of the French Data Protection Act.

You can change your choices at any time from the cookie management module available on the Site. The list of trackers used, their issuer, their purpose and their duration is set out in our cookie policy (in French).

9.2 In the Application

The Application uses technical identifiers necessary for its operation, for your authentication and for the security of the Service. It may also incorporate software development kits (SDKs) provided by third parties, in particular for displaying the Map, delivering notifications and audience measurement.

Trackers that are not strictly necessary for the operation of the Application are only activated after your consent has been obtained, in accordance with Article 82 of the French Data Protection Act and the CNIL recommendation on mobile applications. You can change your choices at any time in the Application settings. This consent is separate from the permissions you grant to the Application in your device’s settings.

10. What are your rights?

You have the following rights, under the conditions provided for by the GDPR:

• Access (Article 15): to find out whether we process data about you and obtain a copy of it.
• Rectification (Article 16): to have inaccurate or incomplete data corrected.
• Erasure (Article 17): to request the deletion of your data, subject to our legal retention obligations.
• Restriction (Article 18): to request that the use of your data be temporarily frozen.
• Portability (Article 20): to receive, in a structured, machine-readable format, the data you have provided to us and which is processed on the basis of your consent or of the contract.
• Withdrawal of consent (Article 7(3)): to withdraw your consent at any time, in particular by deactivating Mode ON, changing your tracker or notification preferences, unfollowing a place or switching off flash offer alerts, or unsubscribing from our newsletter. Withdrawal does not affect the lawfulness of prior processing.
• Post-mortem instructions (Article 85 of the French Data Protection Act): to determine what happens to your data after your death.

Right to object (Article 21 of the GDPR). We draw your particular attention to this right: you can object, at any time and on grounds relating to your particular situation, to processing that we base on our legitimate interest — in particular the production of aggregated statistics, business prospecting and security processing that is not required of us by law. You can also object at any time, without having to give reasons, to any direct marketing.

10.1 How to exercise your rights

You can exercise your rights:

• from the Application, to change your profile information, manage your consents and request the deletion of your Account;
• by email to support@on-yuu.com;
• by post to TS TESSIER — OnYuu, 11 rue Marguerite de Rochechouart, 75009 Paris, France, marked “Protection des données” (Data Protection).

We respond within one month of receiving your request. This period may be extended by two months owing to the complexity or number of requests; in that case we will inform you within one month of your request, giving the reasons for the extension, in accordance with Article 12(3) of the GDPR.

We may ask you for additional information if we have reasonable doubts about your identity. This information is limited to what is necessary and is not kept beyond the handling of your request.

11. Changes to this Policy

We may amend this Policy, in particular to take account of changes to the Service or to the regulations. The version date appears at the top of the document and earlier versions can be obtained on request.

In the event of a substantial change, we will inform you by appropriate means — for example by email or by a notice displayed in the Application — before it takes effect. Where processing is based on your consent, no new use of your data is implemented without that consent having been obtained again.

12. Contact — Data protection

For any question relating to this Policy or to the processing of your data: support@on-yuu.com, or TS TESSIER — OnYuu, 11 rue Marguerite de Rochechouart, 75009 Paris, France, marked “Protection des données” (Data Protection).

13. Complaint to the CNIL

You can lodge a complaint at any time with the French data protection authority, the Commission Nationale de l’Informatique et des Libertés (CNIL), on its website www.cnil.fr or by post: CNIL, 3 place de Fontenoy — TSA 80715, 75334 Paris Cedex 07, France. If you wish, we invite you to contact us first so that we can answer your questions, but this is not a mandatory prerequisite.

Appendix 1 — Categories of recipients

The table below sets out the categories of recipients we use. The up-to-date list of the service providers concerned, by name, together with their country of processing, can be obtained simply by requesting it at support@on-yuu.com.

Appendix 2 — Reference texts

• Regulation (EU) 2016/679 of 27 April 2016 (GDPR)
• Amended French Law No. 78-17 of 6 January 1978, known as the “Informatique et Libertés” Act, in particular Articles 82 and 85
• Regulation (EU) 2022/2065 of 19 October 2022 on a Single Market for Digital Services (Digital Services Act)
• CNIL — Recommendation on mobile applications (deliberation No. 2024-061 of 18 July 2024, as amended by deliberation No. 2025-024 of 27 March 2025)
• CNIL — Guidelines and recommendation on “cookies and other trackers”
• Article L. 123-22 of the French Commercial Code

→ Cookie policy (EU, in French)

→ Version française