LivinFrance Privacy Policy

LivinFrance Privacy Policy

The French version prevails over the English version

1. General

The Eden Initiative company (Operator of the LivinFrance service), in its capacity as data controller, attaches the greatest importance to the respect and protection of your personal data.

The purpose of this privacy policy is to inform you about the purposes and methods of processing the data that you may provide to us through our web application https://university.livin-france.com. (hereinafter "the App"), accessible from the website https://www.livin-France.com or https://university.livin-france.com/nomdelecoleu/register (hereinafter "the Site"), or through our "Call centre".

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a URL customisation that we offer to our partner schools and universities

This document also sets out your rights in relation to the data we hold about you. If you have any queries, please contact our Data Protection Officer, whose details are set out below.

Eden Initiative will hereafter be referred to as "LivinFrance", "we" or "us".

1.1 Identity of the Data Controller and Data Protection Officer

The person in charge of processing users' personal data collected via the above-mentioned Site and App is: Eden Initiative, a simplified joint stock company (SAS), with a capital of 4,200 euros, whose registered office is located at 185 BD Vauban in Lille, 59000, SIREN number (812904928), represented by Mr Antoine Trannoy, Data Protection Officer (or "DPO"), email: Antoinel@LivinFrance.com

1.2. Competent supervisory authorities

The competent supervisory authority is, as appropriate :

France :

1.3. Contact us

For any information relating to your personal data, you can contact the Data Controller or the DPO at the postal address indicated above, or by email at the following address

2. Data collected

What personal data do we collect?

2.1. When do we collect your personal data?

Personal data (also known as personal data) refers to any information relating to a natural person from which that person can be identified, directly or indirectly, such as his or her first and last name, e-mail address or telephone number.

In the course of our business, we may collect your personal data when :

We may also receive information from third parties, in this case our partners, when you enter into a contract with one of them through us (for example, to confirm that the contract has been taken into account and validated).

The collection of your data by our services is a prerequisite for the conclusion of contracts with our partners (energy, telephone and internet suppliers, insurers, other service providers). You have the right to refuse to provide the information requested. However, this may compromise the processing of your requests relating to the services offered by the Data Controller.

Where certain information is required to access specific features of the Site or App, the form will indicate the mandatory nature of the information at the time of entry.

2.2. Data that you transmit directly to us

The personal data we collect is essentially the information you provide directly to us when you initiate a subscription (or termination) process on our App or by phone via our Call centre. This data includes:

Please note that our telephone experts, duly authorised for this purpose, may collect, on a complementary basis, certain personal data concerning you, other than those expressly provided for in the fields of the forms of the various courses, by taking notes in a free field of our CRM provided for this purpose, only when this is strictly necessary for the processing of your requests. The content of this field is automatically and irreversibly destroyed 3 months after it is entered. You have the right to specifically object to this processing and can contact our Data Protection Officer at the above-mentioned addresses.

2.3. Data that you transmit to us indirectly

When you enter into a contract with one of our partners (e.g. energy supplier, internet box provider, insurance company, etc.) through us, that partner may share information about the contract with us.

2.4. The data we collect automatically

In addition to the information you provide directly, we collect a certain amount of data relating to your connection, your navigation and your interaction with our services.

2.5 Telephone records

In order to improve the quality of the user experience delivered by our call centre, to optimise the training of our operators in this respect, and to evaluate them, your calls may be recorded. This recording is not systematic. The recordings are kept for a period that cannot exceed six months. You may, if you wish, object to this processing by contacting our DPO at the above address.

3. Purpose of the processing

How do we use the data we collect?

We only process your personal data where we have a relevant legal basis for doing so. Depending on the purpose of the processing, we may process personal data in accordance with the following

The data we collect and process are strictly necessary for the purposes specified below:


Category of data processed

Purposes of the processing

Legal basis

Shelf life

Identification data, data necessary for the qualification of your needs and the subscription to the various offers

Allow you to access our services and present you with offers (those of our partners) personalised to your needs and profile;

Provide you with access to the various features of the App;

To contact you, where necessary in connection with our services, to retrieve information necessary for the conclusion/validation of the contract to which you have subscribed (e.g. your Delivery Point for the subscription of an energy contract);

Performance of a contract / pre-contractual measure

Our legitimate interest

3 years from your last activity (subscription, connection to the App, incoming call, click in an email) or from the closing of your user account (+5 years in archive)

Data necessary for the subscription of contracts with our partners

To enable us to tell you whether you are eligible for a particular contract with a particular supplier and to tell you the exact price;

Allow us to subscribe to our partners' contracts on your behalf;

To enable us to make payment on your behalf for the contract you wish to take out through us;

Performance of a contract

3 years from your last activity (+5 years in the archive)

Connection and navigation data on the Site and/or App

To measure the number of visitors to our Site and App;

To measure the interest and improve the efficiency and quality of the services we offer you;

Personalise the ergonomics and user experience according to your profile, for example by pushing the most relevant offers to you;

To enable our Customer Service to help you as efficiently as possible if you have any questions or complaints;

To carry out user analysis, selection and segmentation statistics to improve our services and to serve our marketing strategy;

Your consent

13 months from the date of deposit of the cookies

Contact data (email address, telephone)

To communicate with you in general, in particular to: Keep you informed of the progress of your contracts (for example by sending you confirmation by email of the validation of a contract to which you have subscribed online or by telephone)

To collect your opinion / satisfaction on our services and/or contracts;

Inform you of any changes to our privacy policy;

Answer your questions when you ask us by email or via our chat for example;

Help you finalise the subscription of a contract initiated on our App or via our Call centre, but not validated;

To provide you with offers similar to those you have already subscribed to with us and which may be of interest to you

Our legitimate interest

Performance of a contract / pre-contractual measure

3 years from your last activity (+5 years in the archive)

You can unsubscribe from our emails at any time by clicking on the unsubscribe link at the bottom of each email

Data obtained from our partners necessary for the conclusion of a contract

To enable us to monitor and inform you of the correct processing and validation of your contract by our partner with whom you have taken out a contract through us

Allow us to contact you if any information is missing to proceed with the actual contracting on the supplier side (meter reading, PDL number, etc.)

Performance of a contract

Our legitimate interest

3 years from your last activity (+5 years in the archive)

Telephone conversations via our call centre

To enable us to record our telephone exchanges in order to improve the quality of the user experience delivered by our call centre, to optimise the training of our telephone operators in this respect and to evaluate them

Our legitimate interest

6 months from collection

Proof of identity

To enable us to verify your identity in the event of a request from you for access, rectification, deletion, restriction or portability of your data

Your consent

12 months (article 9 of the code of criminal procedure, CNIL, deliberation n°2016-264 of 21 July 2016 known as NS4

Other personal documents (VISA and CAF route)

To enable us to tell you whether you are eligible for such and such procedures, with such and such administrations; To enable us to compile your complete file for such and such procedures. No commercial use will be made of these documents.

Your consent

12 months (article 9 of the code of criminal procedure, CNIL, deliberation n°2016-264 of 21 July 2016 known as NS4


4. Recipients of the data

Who are the recipients of the data we collect? Why do we give them this information?

We strive to treat your personal data as private and confidential.

The data collected or processed during the use of our services are intended for the entities of LivinFrance, more precisely for the persons authorized and authorized internally to have knowledge of them for the purposes of the above-mentioned processing.

This data may also be used for :

Apart from the cases listed above, your personal data may only be disclosed in accordance with a law, regulation or decision of a competent regulatory or judicial authority or, if necessary, for the purposes of the Data Controller to protect your rights and interests.

5. How long we keep your data
How long do we keep your personal data?

Your data is kept in an active database for a period of 3 years from the date of your last activity on the App (subscription to a contract, connection) or via our Call centre (incoming call), or from the closing of your user account.

We may retain certain personal data for a longer period of time, including after your account has been closed, to fulfil our legal retention obligations or those of our partners and to defend or enforce our rights. After the expiry of the 3-year period mentioned above, your data may be archived for 5 years in a dedicated archive, with restricted access. This data, which is kept as evidence, is kept in its entirety, taking into account the purposes for which it was collected.

The transfer to the intermediate storage base is irreversible and the data stored there can no longer be re-entered into the active base.

This data is concomitantly transferred to our Big Data platform for statistical purposes. This data, which is 100% anonymised, in an irreversible manner, at the end of the 3-year period mentioned above, is useful to us for drawing up statistics on the development and performance of our activity.

Some personal data are subject to a shorter retention period, which may not exceed :

6. Data security

What security measures are applied to your data?

The security of your personal data is important to us. Because we want you to use our services with confidence, we are committed to ensuring the protection of the data you entrust to us. We have put in place physical, technical and organisational measures to ensure that your personal data is protected against unauthorised access, accidental loss, destruction or damage.

We use firewalls to prevent unauthorised access to your information.

For enhanced security, our server operates in HTTPS (encryption of data using an algorithm that only the recipient can read), basic passwords are encrypted with a sha256 algorithm. Routes are protected so that they only respond to the user who has made the request (and verified rights, if necessary) and calls are protected via CSRF. Personal files are stored on an amazon S3 server, managing a policy of time-limited access rights and rights verification. In addition, access to the production databases is controlled and secured (IP filtering, access management policy) and the access keys to the computer servers are themselves encrypted and their access is logged.

Concerning payment data: we do not store any credit card data. We delegate the secure processing of this data to Stripe, a certified payment intermediary.

Several specific procedures have been put in place within our internal organisation to optimise the security of your data and minimise the risk of disclosure:

7. Your rights

What are your rights regarding your personal data?

In accordance with the provisions of Articles 38 to 40 of Law No. 78-17 of 6 January 1978, as amended, relating to information technology, files and freedoms, and Articles 15 to 22 of Regulation No. 2016/679/EU of the European Parliament and of the Council of 27 April 2016, on the General Data Protection Regulation (GDPR), you have a number of rights concerning the personal data we hold about you.

In order to exercise these rights, we invite you to contact the Data Controller or the Data Protection Officer directly, by post or by email, at the above addresses.

For security reasons and to avoid fraudulent applications, this application must be accompanied by proof of identity. Once the application has been processed, this proof of identity will be destroyed.

7.1. The right to be informed

You have the right to be informed in a clear, transparent and understandable way about how we collect and process your personal data and about your rights regarding this data. That is the purpose of this privacy policy!

7.2. The right of access and communication of data

You have the right to access your personal data that is processed by us. If you wish to access the information we hold about you, please contact the Data Controller or the Data Protection Officer at the above addresses. For any request made electronically, we will provide you with a copy of the data in a commonly used electronic form, unless you request otherwise. The Controller is entitled to charge a reasonable fee to cover administrative costs for any additional copies and/or to object to requests which are manifestly unreasonable in number, repetition or systematicity. To help you in your approach, the National Commission for Information Technology and Civil Liberties (CNIL) provides you with a model letter at the following address: https//www.cnil.fr/fr/modele/courrier/exercer-son-droit-dacces

7.3. The right of rectification

You have the right to obtain the rectification and/or updating of personal data concerning you that we hold if such data is inaccurate, incomplete, ambiguous or out of date.

To help you in your approach, the Commission nationale de l'informatique et des libertés (CNIL) provides you with a model letter at the following address: https://www.cnil.fr/fr/modele/courrier/rectifier-des-donnees-inexactes-obsoletes-ou-perimees

7.4. The right of deletion

Also known as the "right to be forgotten". You have the right to ask us to delete the personal information we hold about you. To help you in your request, the French National Commission for Information Technology and Civil Liberties (CNIL) provides you with a model letter at the following address: https://www.cnil.fr/fr/modele/courrier/supprimer-des-informations-vous-concernant-dun-site-internet

7.5. The right to restrict processing

You have the right to obtain a restriction on the processing of your personal data in the following situations:

  1. you challenge the accuracy of your Personal Data for the period of time necessary for us to verify the accuracy of your Personal Data; and/or
  2. in the event of unlawful processing by us and you request a restriction on their use rather than erasure; and/or
  3. we no longer need the personal data for the purposes of the processing, but they are still necessary for the establishment, exercise or defence of legal claims; and/or
  4. if you exercise your right to object during the period of verification as to whether the legitimate reasons we are pursuing override yours.

Where the processing of your personal data is subject to restriction, the Controller may, with the exception of storage, process your personal data only with your consent or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or on important Union or Member State public interest grounds.

7.6. The right to object to the processing

You have the right to object, on legitimate grounds relating to your particular situation, to the processing of your personal data, unless we can demonstrate that such processing is justified by compelling legitimate grounds which override your grounds.

In particular, you have the right to object, free of charge, to the use of your data for canvassing purposes, in particular commercial canvassing by us or by a third party.

7.7. The right to data portability

You have the right to obtain the personal data you have provided to us in a structured, commonly used and machine-readable format, so that you can re-use it for your own purposes by passing it on to another data controller yourself.

7.8. The right to withdraw consent

Where processing is based on your consent, you have the right to withdraw your consent at any time, without prejudice to the lawfulness of the processing based on consent carried out prior to the withdrawal of consent. To do so, simply contact us at the above address.

7.9. The right to object to telephone solicitation

We may contact you by telephone to finalise a contract you have entered into with us, either by telephone or directly on our website, or to offer you a service similar to the one(s) you have already entered into with us (provided you have given us your telephone number).

You have the right to object to your personal data being processed by telephone.

Since 1 June 2016, the government has set up a free telephone opposition list for consumers, which can be accessed at www.bloctel.gouv.fr

7.10. The right to determine instructions concerning the processing of your data after your death

You have the right to determine instructions regarding the retention, deletion and communication of your personal data after your death. In order to define these instructions, we invite you to contact our Data Protection Officer at the above address.

7.11. The right to lodge a complaint with the competent supervisory authority

You have the right to lodge a complaint about the way we handle or process your data with the relevant national supervisory authority (see 1.2).

7.12. Time limits for processing rights and notification

We undertake to respond to your requests within a reasonable period of time, which shall not exceed 1 month from the receipt of your request, and to notify you of any operations carried out by our services in accordance with your requests.

7.13. Closing your user account

If you close your user account, we will in principle keep your personal data for a period which may not exceed 3 years. However, you have the right to object to this processing by exercising your right to erasure in the manner described above.

8. Cookies, what is our cookie policy?

8.1. What is a cookie?

Cookies are small text files that are automatically placed on your computer, smartphone or tablet when you visit websites. They are stored by your browser.

The vast majority of sites use these cookies to collect basic information relating to your browsing, to recognise you from one browsing to another, and thus to optimise and personalise their operation and ergonomics and offer you the most successful browsing experience possible.

For example, we use cookies on our web application to remember your login details so that you do not have to re-enter them each time you visit. We also use other cookies to analyse traffic on our site and to better understand how our visitors use it so that we can continually improve the service we offer.

Cookies are not malicious. They are neither programs nor viruses that could damage your terminal.

For more information on cookies in general, you can visit www.allaboutcookies.org and http://youronlinechoices.com/fr

8.2. What types of cookies do we use?

We use "essential" cookies: these cookies are absolutely essential for the proper functioning of our Site and App. They facilitate your access, help you navigate smoothly and access all the features built into our service offering. Without them, our Site and our App would not function properly and your navigation would not be as smooth as we would like. For example, they allow us to identify your browser when you return to us and to store your login information so that you do not have to re-enter it each time you visit.

This allows us to identify the content/features that our users are most interested in, so that we can develop our service in the right direction. For example, by ensuring that you can easily find what you are looking for on our App.

Advertising cookies are only used to measure the performance of the campaigns we activate on social networks, i.e. to identify the proportion of our traffic attributable to this acquisition lever. No advertising is displayed on our Site or App and none of your data is marketed to third party partners.

8.3. How long are cookies kept?

Cookies have a limited lifetime of 13 months after their first deposit on your browser.

8.4. What to do if you wish to object to cookies?

  1. 8.4.1. Revoking your consent to the use of cookies via your browser
    The storage of a cookie on your terminal is subject to your wishes, which you can express and modify at any time through the settings offered by the browser you use to access our Site or our App
    If you have accepted in your browser the deposit of cookies on your terminal, the cookies integrated in the pages you have consulted may be stored temporarily in a dedicated space on your terminal. Only the sender can read them.
    If you wish to delete the cookies already stored on your terminal and set your browser to refuse any new cookies, you can go directly to the cookie settings of the browser you use to access our Site or App.
    Please note, however, that disabling cookies may affect the functionality of our App. Some features of the site may no longer be accessible for which we cannot be held responsible.
    In order to exercise your choice, you can consult the following pages, depending on the browser you are using:
    Internet Explorer: http:
    //windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies Safari: https://support.apple.com/fr-fr/safari Chrome: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647 Firefox: http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies Opera: http://help.opera.com/Windows/10.20/fr/cookies.htmlCette
    configuration differs on mobile or tablet devices: For iOS:
    https:
    //support.apple.com/fr-fr/HT201265 For Android: http://global.blackberry.com/fr/legal/privacy-policy.html#types-info-d For Blackberry: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies





  2. 8.4.2. For more information on cookies
    If you would like more information on cookies and how to control them, you can consult the CNIL website which provides a comprehensive guide
    https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser or the following website: http://www.youronlinechoices.com/fr/ where you will find simple instructions on how to manage cookies depending on the browser you use.

9. Updating the privacy policy

We may change this privacy policy from time to time. The date on which the latest revisions were made will appear in this article. All changes will be effective upon posting.

We will be sure to let you know if we do so, either by email to the email address you have provided, or by posting a notification directly on our Site and Application.

We invite you to consult this document regularly in order to be aware of the most recent version.

This privacy policy was last updated on 31 March 2021.

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