Information on the processing of personal data in AFRIFF application,
pursuant to article 13 of EU 2016/679 Regulation
1. Data controller
The Data Controller is Summview SAS, 45 rue du Cardinal Lemoine, 75005 Paris, France, email: contact@summview.com
2. Data processing responsible
The Data processing responsible is AFRIFF, with headquarters in 9th Floor, CBC Towers, Olubunmi Owa Street, Lekki Phase 1.Lagos, Nigeria, Email: info@afriff.com
3. Purpose of application
The application AFRIFF allows the viewing of the program and contents of the Africa International Film Festival (AFRIFF).
4. Purpose of the data collection and processing
Users' personal data are collected and processed exclusively for the following purposes:
• Provision of the audiovisual content of AFRIFF.
• Marketing
The processing of personal data that is necessary for the pursuit of the aforementioned purposes can only be carried out on condition that the user has previously granted his /her specific consent.
5. Types of data processed
The data collected through the application are the user name, surname, and email. The provision of these data is mandatory to achieve the purposes and to perform the activities described in section 3 above.
Other data collected are the user birthdate, gender, and phone number. The provision of these data by the user is optional.
6. Consequences of the failure to communicate personal data
With regard to the mandatory personal data described in Section 4, for regulatory obligation (for example the obligations related to the keeping of accounting records and tax), the failure to communicate personal data prevents the establishment of the contractual relationship itself and does not allow the provision of the service described in section 3.
7. Legal basis of the processing
Summview SAS processes personal data lawfully, where the processing is:
• necessary for the execution of the contract of which user is a part;
• necessary to fulfill a legal obligation incumbent on the data controller;
• based on the express consent of the user.
8. Place and storage of data
In compliance with the principles indicated in art. 5, paragraph 1, of EU Regulation 2016/679, personal data, object of treatment for the above mentioned purposes, are kept for the whole duration of the use of the mobile application, and remain stored afterwards for 3 years unless the user requests to erase it.
9. Recipients of personal data
Personal data are communicated to the Data Processor (AFRIFF).
10. Data relating to the geographical location of the user
Access to geolocation tools by the application, unless otherwise specified, is exclusively aimed at enabling the optimization and / or provision of the requested service. The application is able to collect data related to the user's geographical location, in order to provide or increase the efficiency of services based on it.
The processing of such data, however, remains conditional to the acquisition of the specific consent of the data subject, which may at any time be revoked by the appropriate settings of the operating system in use.
11. Automated decision making and profiling
Summview SAS informs about the existence of an automated decision-making process, including the profiling referred to in Article 22, paragraphs 1 and 4, of the 2016/679 EU Regulation with the use of the logic of analyzing the choices of audiovisual content by users for the following purposes:
statistical analysis of user behavior in a generic and anonymous way, to allow Summview SAS to understand the way in which users use the application to improve services (eg Summview SAS can gather information on how many times a content is displayed).
massive analysis of data flows, their frequency and sometimes their contents for security reasons and to prevent fraud or abuse.
analysis of user behavior to allow Summview SAS to recommend audiovisual content and services that can be used by the application (eg: Summview SAS could suggest audiovisual content based on user interests based on their behavior).
12. System log
For the operation and maintenance of the application, Summview SAS could collect system logs, ie files that record user interactions, often containing personal data, such as the IP address used.
13. Particular categories of data
Summview SAS does not require or collect particular categories of data (such as information capable of revealing racial or ethnic origin, political, philosophical or religious beliefs, sexual habits or health data) through the application.
14. Processing methods
User personal data are processed by adopting the appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of personal data. All Summview SAS employees who have access to the databases connected to the application are duly designated as authorized parties and each of them can only process the data necessary for the performance of their job duties. Processing is carried out mainly through IT and / or telematic tools, with organizational and logical methods strictly related to the purposes indicated above.
15. Cross-border transfer of data
Personal data are not transferred outside Europe and Africa.
16. Users' rights
In accordance with article 13 of the 2016/679 EU Regulation, the user has the right:
to request from Summview SAS an access to personal data and information relating thereto; the correction of inaccurate data or the integration of incomplete data; the cancellation of personal data concerning the user (upon the occurrence of one of the conditions indicated in article 17, paragraph 1 of the GDPR and in compliance with the exceptions provided for in paragraph 3 of the same article); the limitation of the processing of personal data (to use one of the hypotheses indicated in Article 18, paragraph 1 of the GDPR)
to request from Summview SAS - in the cases in which the legal basis of the treatment is the contract or the consent, and the same is done by automated means - personal data in a structured and readable format by automatic device, also in order to communicate such data to another data controller (so-called right to the portability of personal data); at any time to the processing of personal data to the occurrence of particular situations that affect the user
revoke user consent at any time, limited to the cases in which the treatment is based on user consent for one or more specific purposes and concerns common personal data (for example date and place of birth or place of residence), or particular categories of data (for example data revealing user origin and racial, political opinions, religious beliefs, state of health, or user sex life). The treatment based on consent and prior to the revocation of the same retains, however, its lawfulness
to submit a complaint to a supervisory authority.
17. Changes to this privacy policy
The Owner reserves the right to make all the changes deemed appropriate or made mandatory by the regulations from time to time in force, informing the users.
Last update: June 2018