The Privacy Policy

IPAOO.COM is very concerned about the privacy of its visitors and users. It is fully committed to protecting their personal information and making appropriate use of it under data privacy laws. This policy describes how we collect and use personal information, as well as the related rights and choices available to our visitors and users. You should read this policy and make sure you fully understand its terms before accessing or using any of our services.

This Privacy Policy complements our other commitments outlined in our Conditions of Sale and Use.

1. Presentation of our Privacy Policy

This Privacy Policy ("Privacy Policy") of IPAOO.COM describes how we (IPAOO.COM Trademark of FIGURES LIBRES SARL "IPAOO. FR" or "we"/”us”) collect and use information about each of our non-registered visitors and registered users including premium users (each (respectively) a "Visitor" or "User" or "you"), in connection with the nature of their access to, and use of, IPAOO.FR's websites (including IPAOO.COM and each of its subdomains, the "Website"), web applications, mobile applications, and related services.

The purpose of this Privacy Policy is to provide you with a clear explanation of when, why, and how we collect and use your personal information, as well as an explanation of your rights.

This Privacy Policy is not intended to abrogate the terms of any contract you may have with us, or any rights you may have under applicable data privacy legislation.

Please make sure you understand our practices regarding your personal information before accessing or using any of our Services. If you read and fully understand this Privacy Policy, but remain opposed to our practices, you should immediately leave this site, application or service, and avoid or discontinue all use of any of our Services. If you have any questions or concerns regarding this policy, please contact us at support [AT] ipaoo [DOT] com

By accessing and using our Services, you acknowledge that you have read and agree to this Privacy Policy

2. What information do we collect?

2.1. Visitor and User Information

We collect two types of information about our Visitors and Users:

1. Non-identifiable information about a Visitor, or a User who has not identified himself, that may be made available to us or collected automatically as a result of his use of the Services ("Impersonal Information"). This Impersonal Information does not allow us to identify the Visitor or User from whom it was collected. The Impersonal Information we collect is primarily technical and usage aggregation information, such as browsing activity and click stream on the Services, session and scrolling statistics, as well as non-identifying information about the device, operating systems, browsers, screen resolutions, language, and keyboard settings, access providers, referring/exit pages, timestamp data, etc., used by the Visitor or User.
2. Individually Identifiable Information, therefore, information that identifies an individual or is likely, by reasonable means, to identify an individual, or may be of a private or sensitive nature ("Personal Information"). The Personal Information we collect is primarily relational (e.g. email address or № phone number), accounting (name, billing address, payment method, and transaction details) that are exclusively collected from Users with Paid Services, relating to a viewing or usage session IP address, geolocation and/or unique device identifier), regarding related third party accounts (such as email or username pertaining to a PayPal account, Google or Facebook account), scanned identification documents provided to us (such as identification cards, driver's licenses, passports or official company registration documents), correspondence (including correspondence made through or sent to our Services) and any other Personal Information provided to us by Visitors and/or Users accessing and/or using our Services. For the avoidance of doubt, any Impersonal Information that relates to or is linked to Personal Information (for example, in order to improve the Services we offer) is considered, and treated by us, as Personal Information, for as long as that relationship or link exists

2.2. User's User Information

We may also collect similar information about visitors to and users of our User's websites or services ("Users of Users") solely for, and on behalf of, our Users (as described in Section 6 below).

2.3. Information relating to applicants for employment with IPAOO.COM

We also collect information provided to us by applicants for jobs offered by IPAOO ("Applicants"), when they apply for any of the job positions via email or otherwise (as described in Chapter 7 below).

3. How do we collect this information?

We use two main methods to do this:

1. We collect information from your use of the Services. When you visit or use our Services, including when you visit the Website or any User Website, sign up for a User Account, modify your User Website, transfer information and content, this usually results in the assembly, collection, and recording of such uses, sessions and related information, both independently and through third party services as detailed in Section 8 below, including through the use of cookies and other tracking technologies as detailed in Section 9 below.
2. We collect information that you voluntarily provide to us. For example, we collect Personal Information that you provide to us when you register for our Services; when you connect to our Services through third party services such as Facebook or Google; when you make purchases and/or register domain names; when you submit or transmit such Personal Information in connection with your use of any of our Services; and/or when you contact us directly, through any communication channel (e.g., support ticket, emails to IPAOO)
3. We also collect information from third-party sources as described in Chapter 8 below

When you visit or use our services - you may also provide us with certain information (automatically through the process of using the Service, or by submitting it manually).

4. Why do we collect this information?

We collect this information, both Personal and Impersonal, for the following purposes:

1. To provide and operate the Services;
2. To develop, customize and improve our Services, based on the common and personal preferences, experiences, and challenges of Visitors and Users;
3. To provide our Users with an ongoing customer and technical support;
4. To have the ability to contact our Visitors and Users with general or personalized service-related notifications and promotional messages (as detailed in Chapter 10 below);
5. To facilitate, sponsor and offer certain contests, events, and promotions, determine the eligibility of entrants, monitor fulfillment, contact winners, award prizes, and incentives;
6. To create aggregated statistical data and other aggregated and/or inferential Impersonal Information, which we, or our business partners, may use to provide and improve our respective services;
7. To improve our data security and fraud prevention techniques;
8. To review an application for employment with IPAOO (as detailed in Chapter 7 below);
9. To comply with any applicable laws and regulations.

We use your Personal Information only for the purposes set out in Chapter 4 where we believe that:

1. Our use of your Personal Information is necessary to perform a contract or to take steps to enter into a contract with you (e.g., to provide you with site design, customer assistance, or technical support), or
2. Our use of your Personal Information is necessary to comply with relevant legal or regulatory obligations of ours, or
3. Our use of your Personal Information is necessary to support legitimate interests we have as a business (e.g. to maintain and improve our Services by identifying user trends and the effectiveness of IPAOO campaigns and to identify technical problems), so long as it is implemented proportionately, and which respects your privacy rights.

Our Services are not intended for children under the age of 18. No one under the age of 18 is likely to provide Personal Information through our Services. We do not knowingly collect Personal Information from children under the age of 18. Parents and guardians must supervise their children's activities at all times.

5. Storage of your information?

Personal Information of IPAOO Visitors, IPAOO Users, and User's Users may be preserved, processed, and stored by IPAOO and our authorized affiliates and service providers in the United States of America, Europe as necessary for the proper delivery of our Services and/or as required by law (as explained below). Information relating to an Applicant for employment with IPAOO will be preserved, processed, and stored in France, at the location(s) of the employment in question, and, if necessary, in secure cloud storage provided by Third Party Services.

IPAOO.FR, a registered trademark of SARL FIGURES LIBRES, is established in France, which the European Commission considers to be a country offering an adequate level of protection for the Personal Information of residents of EU member states.

IPAOO's affiliates and service providers who store or process your Personal Information on IPAOO's behalf have all contractually agreed to protect and secure it following industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

Upon request, IPAOO will provide you with information on the possible holding of your Personal Information. You can access and correct your Personal Information directly from the administration of your site. You can proceed or request the deletion of your Personal Information by following the instructions provided in the articles of the tutorial site: "GDPR: Recovering Your IPAOO Account Data" or "GDPR: Definitive deletion of Your IPAOO Account". We will respond to your request within the timeframe imposed by local law or within a reasonable timeframe.

Note that permanently deleting your IPAOO account will delete all your information from IPAOO's databases. Once this process has been completed, you will no longer be able to use any of your IPAOO Services, your User Account and all their data will be permanently deleted, and in the future IPAOO will not be able to restore your account or recover your data. If in the future you contact IPAOO Support, the system will not recognize your account and the Support agents will not be able to locate the deleted account.

IPAOO's data storage service providers are contractually committed to protecting and securing your data.

Data Localization Obligations: If you reside in a jurisdiction that mandates "data localization" or "data residency" (i.e., requires that Personal Information of its residents be maintained within the territorial limits of that jurisdiction), and this fact is brought to our attention, we may maintain your Personal Information within those territorial limits, if we are legally obligated to.

You acknowledge that while doing so, we may continue to collect, store and use your Personal Information elsewhere, including in the United States of America as explained above.

6. User's Users Informations

IPAOO may collect, store and process certain Impersonal and Personal Information of Users ("User Information"), solely on behalf of and as directed by our Users. For example, each of our Users may import their email contacts from a third-party service such as Gmail, or otherwise collect and manage contacts via their User Website. These contacts are then stored with IPAOO on behalf of the User.

In this regard, IPAOO is a provider and shall be deemed to be performing "Processing" and not "Control" (as those two capitalized terms are defined in the European Union General Data Protection Regulation) over such User Information. Users controlling and operating these User Websites shall be deemed to be in "Control" of such User Information and are therefore required to comply with all laws and regulations that may apply to the collection and control of such User Information, including all privacy and data protection laws, from all relevant jurisdictions.

You are responsible for the security, integrity, and authorized use of your Users' Personal Information, and for obtaining consents, authorizations, and providing any fair processing notices necessary for the collection and use of such information.

IPAOO cannot provide legal advice to Users or their Users of Users, however, we recommend that all Users post and maintain clear and comprehensive privacy policies on their User Websites, that these comply with applicable laws and regulations, and that all Users of Users carefully read and ensure that they fully consent to them. For more information on how IPAOO manages User Information (which may be relevant to the specific notice you provide to, and/or consent you obtain from, your User Users), see Chapters 8, 12, and 13 below.

Whether you are a visitor, user, or customer of any of our Users, we invite you to read the following: IPAOO has no direct relationship by name with the Users of Users whose Personal Information it processes. Whether you are a visitor, user, or customer of any of our Users, and have any request or inquiry regarding your Personal Information, we invite you to contact that, or those, Users directly. For example, if you wish to access, correct, rectify or delete inaccurate information processed by IPAOO on behalf of its Users, address your request directly to the relevant User (who is the "Controller" of that data). If we are requested to delete any Personal Information of Users, we will respond within thirty (30) days. Unless otherwise instructed by our User, we retain their User's Personal Information for the period defined in Section 12 below.

7. Apply for a job at IPAOO

When you apply for an internship or a job at iPaoo, by sending us your contact information and resume through a form, an email, or any other means, we know that confidentiality and discretion are essential. We are therefore committed to preserving the confidentiality of Applicants' Information and to using it only for internal recruitment purposes.

IPAOO may retain Applicant Information submitted to it for up to two years after the position has been filled or eliminated. This is in order to be able to reconsider the application for other positions and/or opportunities so that we can use the Applicants' Information as a reference for future applications they submit; and if the Applicant is hired, for other professional and business purposes related to their work at IPAOO. As with the management of data submitted in connection with the creation of a website at iPaoo, if you wish to access, update or have your data deleted, please contact us at support [AT] ipaoo [DOT] com.

8. Sharing Personal Information with Third Parties

IPAOO does not share your Personal Information with, or allow access to, third parties except in the following circumstances:

8.1. Third-Party Services:

IPAOO has established partnerships with various service providers, which complement, facilitate and enhance its own. These include server hosting and co-location services, content delivery networks (CDNs), computer and data security services, billing and payment processing, domain name registrars, fraud detection and prevention services, web analytics, email distribution, and monitoring, session logging, and remote access, data optimization and marketing performance measurement, content delivery, and our legal and financial advisors (collectively, the "Third Party Services").

These Third Party Services may receive, or otherwise, have access to, Personal Information of our Visitors and Users and/or Users of Users, in whole or in part - depending on each of their particular roles and purposes in facilitating and improving our Services and business, and they may use it only for those purposes.

Please note that while our Services may include links to other websites or services, we are not responsible for the privacy practices of those websites or services. We encourage you to keep this in mind when you leave our Services and to read the privacy statements of every website and service you visit before providing any Personal Information. The Privacy Policy binding on us does not apply to such linked third-party websites and services.

IPAOO is accountable for the Personal Information it receives under the Privacy Policy and subsequently transfers to a third party as described in the Privacy Policy Principles. In particular, IPAOO remains liable under the Privacy Policy Principles for any third-party agents that it engages to process Personal Information on its behalf in a manner contrary to the Principles unless IPAOO proves that it is not responsible for the events giving rise to the damage.

8.2. Law enforcement, requests, and legal obligations:

Where permitted by local data protection laws, IPAOO may disclose, or otherwise permit others to access, your Personal Information in response to a legal request, such as a subpoena, court proceeding, search warrant or court order, or in accordance with applicable law, if we believe in good faith that the law requires us to do so, with or without notice to you.

8.3. Protection of rights and security:

IPAOO may share your Personal Information with others if we believe in good faith that doing so helps protect the rights, property, and personal safety of IPAOO, any of its Users, and any User of Users, or any person in general, with or without notice to you.

8.4. Social media features and framed pages:

Our Services include certain features, widgets, and connections to Social Media, such as the "Facebook Application" features, the "Facebook Like" and "Share this" buttons, or other interactive mini-programs ("Social Media Features"). These Social Media Features may collect information such as your IP address or the page you visit on our Website and may set a cookie to enable their operation. Social Media Features are hosted either by a third party or on our Services. Your interactions with these third-party Social Media Features are governed by their own policies, not ours.

In addition, our Services may allow you to share your Personal Information directly with third parties, for example, through in-page windowing techniques that deliver content to or from Third Party Services or others, while maintaining the look and feel of our Website and Services ("Windows"). Please be aware that if you choose to interact or share any Personal Information through these Windows, you are in fact providing it to those third parties and not to us, and such interactions and sharing are governed by the policies of those third parties and not by ours.

8.5. IPAOO Branches and Affiliates:

We may share Personal Information internally within our group companies or offices for the purposes described in this Privacy Policy. In addition, if IPAOO, or any of its affiliates, were to undergo any change in control, including by way of merger, acquisition, or purchase of a substantial portion of its assets, your Personal Information may be shared with the parties involved in that transaction. If we believe in good faith that such a change in control would materially affect your Personal Information held by us at that time, we will notify you of this transaction and of certain choices you may make regarding your Personal Information, by email and/or by means of a prominent notice on our Website.

9. Use of cookies and other tracking technologies

IPAOO, in conjunction with its business, analytical, and technology partners, uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags, and scripts). These technologies are used to preserve, provide and improve our Services and provide a better experience for our Visitors, Users, and Users of Users. With these technologies, we can, among other things, preserve and track the authenticated preferences and sessions of our Visitors and Users, to better secure our Services, detect technical problems, usage trends, and campaign effectiveness, and analyze and improve the overall performance of our Services.

Note that Third Party Services that place cookies or use other tracking technologies through our Services may have their policies regarding how they collect and store information. These practices are not covered by our Privacy Policy and are beyond our control.

Cookies: To function properly, some of these technologies require that a small data file ("cookie") be downloaded and stored on your device. By default, we use several persistent cookies for the purposes of the session and user authentication, security, maintaining user preferences (e.g., language and default settings), connection stability (e.g., for media playback, use of e-Commerce functionality, etc.), monitoring the effectiveness of our services and marketing campaigns, and generally delivering and improving our Services. If you wish to delete or block any of these cookies, please refer to the help and support area of your web browser for instructions on how to locate the file or directory in which it is stored. Information on deleting or controlling cookies is also available on the CNIL website: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser (note that this website is not provided by IPAOO, and we cannot guarantee its accuracy, completeness, or availability). We draw your attention to the fact that deleting, disabling cookies, or tracking technologies, may prevent you from accessing certain areas or features of our Services, or affect you in different ways, your user experience.

Transparent GIFs: IPAOO and certain Third Party Services may employ a software technology called clear gifs (or web beacons/invisible pixels), which allow us to improve our Services by measuring their effectiveness and performance. Clear gifs are small graphical elements with a unique identifier that work similarly to cookies and are not stored on your device but are embedded within our Services.

Flash and HTML5: IPAOO and some Third Party Services may also use certain tracking technologies known as "Flash" and "HTML5" cookies, especially for advertising purposes. Different browsers may offer their own management tools for the removal and blocking of these technologies. For more information on managing Flash cookies go to: http://www.macromedia.com/support/documentation/fr/flashplayer/help/settings_manager07.html (note that this website is not provided by IPAOO, and we cannot guarantee its accuracy, completeness, or availability).

Targeting/Behavioral Retargeting: Certain Third Party Services and ad networks may display ads on our Website or on IPAOO's applications and/or mobile applications, or manage our advertising on other sites. These partners may use certain tracking technologies to collect certain information about your activities on the Services and various Third Party Services, to provide you with targeted advertisements based on your interests and preferences. You can opt-out of receiving targeted advertisements from certain advertisers and networks by clicking here and if you are located in the European Union, click here (provided by YourChoicesOnline.eu).

Note that this does not offer you the choice to opt-out of receiving all advertisements and only allows you to opt-out of receiving the specific advertisement. You will continue to receive advertising that you have not opted out of.

Additional User Data: We may receive data about you from other sources, including publicly available databases or from third parties from whom we have purchased data, and combine that data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers and offer products and services that may be of interest to you. When we obtain your Personal Information from third parties, we ensure that these third parties are contractually bound to inform you that your Personal Information is being shared with us and we take steps to ensure the accuracy of your Personal Information before using it. If you provide us with Personal Information about other people, or if other people give us your information, we will only use that information for the specific purpose for which it was provided to us.

10. Communications from IPAOO

10.1. Promotional messages:

We may use your Personal Information to send promotional content and messages via email, text messages, direct messaging, commercial calls, and similar forms of communication from IPAOO or through our partners (acting on behalf of IPAOO).

If you do not wish to receive these promotional messages or calls, you may, at any time, notify IPAOO or follow the "unsubscribe" or "opt-out" instructions contained in the promotional communications you receive.

We take steps to limit the promotional content we send you to a reasonable and proportionate level and to send you information that may be of interest or relevance to you, based on your information.

10.2. Service and billing messages:

IPAOO may also contact you with important information regarding our Services or your use of them.

For example, we may send you a notification (by any of the means available to us) if a certain Service is temporarily suspended for maintenance; respond to your support request ticket or email; send you reminders or warnings about impending or late payment for your current or future subscriptions; relay abuse complaints related to your User Website, or notify you of important changes in our Services.

You must be always able to receive these messages. For this reason, you cannot opt-out of receiving these Service and Billing Messages, unless you are no longer a Visitor or User of IPAOO (which can be done by deleting your account).

11. Your rights regarding your personal information

You must have control over your Personal Information. That is why IPAOO takes steps to allow you to access, receive copies of, update, modify, delete, and limit the use of your Personal Information.

Before disclosing the required Personal Information, we may ask you for additional information to confirm your identity or for security reasons. We reserve the right to charge a fee where permitted by law (e.g., if your request is unfounded or excessive).

You have the right to file a complaint with your local data protection supervisory authority (but we recommend that you contact us first).

If you are a Visitor or User of IPAOO, and you would like to receive a copy of, access to, and/or ask us to make corrections to, the Personal Information you have stored with us (both yours and those of the User's Users), or request details of the Personal Information (if any) about you that we have disclosed to third parties for direct marketing purposes, please send your request by post to IPAOO - BP40307 - 06906 Sophia Antipolis Cedex. We will use reasonable efforts to comply with your request (unless we need additional information to comply with your request), within the legal time frame, subject to legal and other permissions.

You may also correct, update or remove portions of this Personal Information, either by yourself or through your User Account or User Website settings.

Note that permanently deleting your IPAOO account will delete all of your information from IPAOO's databases. Once this process is complete, you will no longer be able to use any of your IPAOO Services, your account and all of its data will be permanently deleted, and in the future, IPAOO will not be able to reinstate your account or recover your data. If in the future you contact IPAOO Support, the system will not recognize your account and the Support agents will not be able to locate the deleted account.

12. Data retention

We may retain your Personal Information (as well as User's User Information) for as long as your User Account is active, as set forth in this Privacy Policy, or as otherwise necessary to provide you with our Services.

We may continue to retain such Personal Information even after your User Account is deactivated and/or you cease using any particular Service, to the extent reasonably necessary to comply with our legal obligations, resolve disputes regarding our Users or their User's Users, prevent fraud and abuse, enforce our contracts, and/or protect our legitimate interests.

13. Security

IPAOO has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic, and procedural measures. Among other things, we provide secure HTTPS access to most areas of our Services; the transmission of sensitive payment-related information (such as credit card №) through our dedicated purchase forms is handled by a banking provider over an industry-standard SSL/TLS encrypted connection. At the same time, we regularly monitor our systems for potential vulnerabilities and attacks and regularly seek new ways and Third-Party Services to increase the security of our Services and the protection of our Visitors and Users.

Despite the measures and efforts undertaken by IPAOO - we cannot and do not guarantee absolute protection and security of your Personal Information, User Information, or any other User Content that you upload, post, or otherwise share with IPAOO, or with anyone else.

Therefore, we encourage you to create strong passwords for your User Account and User Website and to avoid providing us or anyone else with any sensitive information whose disclosure could cause you significant or even irreparable harm.

In addition, because some areas of our Services are less secure than others (for example, if you set your support forum ticket as "Public" rather than "Private", or if you visit a non-SSL page), and because email and instant messaging are not recognized as secure means of communication, we ask and encourage you not to share your Personal Information in any of these areas, or through any of these means. If you have any questions about the security of our Services, please contact us at support [AT] ipaoo [DOT] com

14. Public forums and user content

Our Services offer freely accessible blogs, communities, and support forums. Please keep in mind that any information you provide in any of these areas can be read, collected, and used by others who have access to them. To request removal of your Personal Information from our blogs, communities, or forums, please contact us at support [AT] ipaoo [DOT] en. In some cases, we may not be able to remove your Personal Information from these areas. For example, if you use a third-party application to post a comment (e.g., via Facebook's social plugin) while logged into your profile associated with that third party, you will need to log in to that application or contact its provider, to remove the Personal Information you have posted on that platform.

In any case, we do not recommend that you send any information (or use any means of sending information) that you do not wish to post on these platforms.

If you send any User Content to your User Account or post it on your User Website and otherwise offer it as part of the use of any Service, you do so at your own risk.

We have implemented adequate security measures to protect your Personal Information. However, it is not our responsibility to control the actions of other Users or members of the public who may access your User Content and we are not responsible for any circumvention of the privacy settings or security measures you or we have placed on your User Website (including, for example, password-protected areas on your User Website). You understand and acknowledge that even after removal by you or us, copies of User Content may remain visible in caches, or archived pages, or if a third party (including any of your User's Users) has copied or stored such User Content.

Simply put, we strongly discourage you from posting or sending any information that you do not wish to make public.

15. Updates and interpretation

We may update this Privacy Policy as required by applicable law, and as our information collection, use, and storage practices change. If we make any change that we consider to be "material" (in our good faith discretion), we will notify you (using one of the notification methods outlined in the Terms of Use) before the change takes effect. We encourage you to periodically visit this page for the most current information about our privacy practices. Unless otherwise stated, our most current Privacy Policy applies to all information we have about you and your Users concerning our Website, Apps, Mobile Apps, and other Services.

Any headings, captions, or chapter headings contained herein are provided for convenience only and do not in any way define or explain the chapters or provisions hereof and are not legally binding on either of us in any way.

This Privacy Policy is written in French and English and may, for your convenience, be translated into other languages. You can access and view versions in other languages by changing the language settings on the IPAOO Website. If a translated (non-French) version of this Privacy Policy conflicts with the French version, the provisions of the French version shall prevail.

16. Contact us

If you have any questions about this Privacy Policy or wish to exercise any of your rights described above, contact the Data Protection Officer at support [AT] ipaoo [DOT] com

We will attempt to resolve any disputes regarding the use of your Personal Information in accordance with this Privacy Policy. You can also contact us by letter at the following address IPAOO - BP 40307 - 06906 Sophia Antipolis Cedex - France