Singularity by Vaonis
VAONIS processes some of your personal data in order to provide you with the services you expect from our SINGULARITY application.
We also process some of your personal data in our legitimate interest.
In this context, our company VAONIS acts as a data controller within the meaning of EU Regulation n°2016/679 and the French Data Protection Act nᵒ 78-17 of 6 January 1978 as amended.
The data processing carried out by our company therefore requires us to comply with specific legal obligations arising from the Regulation on the protection of personal data. VAONIS is committed to complying with these obligations.
The purpose of this confidentiality policy is therefore to present our obligations and commitments to you in a transparent manner, in order to inform you as fully as possible about the processing of your personal data that we carry out in connection with your use of our SINGULARITY application.
Table des matières
2. VAONIS IS DATA CONTROLLER 2
3. HOW WE PROCESS PERSONAL DATA 2
3.1. Creating and managing our customer relationship 3
3.2 Creating personalised content and improving your user experience 5
3.4. Calendar functionality in the Application 10
3.5. Hosting photographs on our Cloud 10
4. NO AUTOMATED DECISION-MAKING OR PROFILING 11
5. RECIPIENTS OF YOUR PERSONAL DATA 12
5.1. Communication of your Data only to our Processors 12
5.2. List of our processors 12
6. TRANSFERS OF DATA ABROAD 13
7. SECURITY AND VIOLATION OF PERSONAL DATA 13
8. EXERCISING YOUR RIGHTS TO YOUR PERSONAL DATA 14
9. YOUR PERSONAL DATA CONTACT AT VAONIS 15
11. CHANGES TO THIS PRIVACY POLICY 15
DEFINITIONS
Application: refers to our SINGULARITY application, which is published and operated by our company VAONIS;
- Data Controller: means our company VAONIS, which determines the means and purposes of the Processing of your Personal Data described in Article 3 of this privacy policy;
- General terms of use: refers to the general terms of use of our SINGULARITY application, which accompany this privacy policy;
Personal Data: means any information relating to you as an identified or identifiable natural person, in accordance with the Personal Data Regulation;
- Personal Data Regulation: refers to EU Regulation n°2016/679, known as the ‘GDPR’, and the French Data Protection Act nᵒ 78-17 of 6 January 1978 as amended;
- Processing: means any operation or set of operations, whether or not performed by automated means, which is applied to your Personal Data within the meaning of the Regulation on personal data;
- Processor: means the persons who act under the authority of our company VAONIS and under our instructions for certain Processing of your Personal Data;
- VAONIS Telescope: means the new generation telescopes developed and marketed by our company VAONIS that work with our application SINGULARITY;
- Violation: means a breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of your Personal Data, or unauthorised access to such data;
VAONIS IS DATA CONTROLLER
The Processing of Personal Data identified in this privacy policy is carried out by our company VAONIS as the Data Controller.
We remind you that VAONIS is a French company whose registered office is located at Cap Alpha, 34830, Clapiers, France, with a share capital of €17133.80, registered with the Montpellier Trade and Companies Register under SIRET number 823 710 447.
HOW WE PROCESS PERSONAL DATA
We process the Personal Data that you enter on the SINGULARITY Application or that you provide to us through the use of our Application for the following purposes:
Creating and managing our customer relationship
3.1.1. Creation of the member account
To create your member account, you must enter:
- your electronic mail address (hereinafter referred to as ‘e-mail’),
- your surname,
- your first name(s),
- a username of your choice (Identifier),
- a password of your choice.
You can change and/or delete your username and/or password in your profile at any time in the ‘Settings’ / ‘Edit profile’ section.
If you wish to change your surname, first name and the e-mail address you gave when you registered, you may do so by sending a request to the following address: dpo@vaonis.com. If necessary, the Data Protection Officer may ask you for proof of identity to ensure that the request for modification really comes from you.
In the context of the General terms of use of the Application, you must maintain the accuracy of your identification data (surname, first name) throughout your use of the Application.
Regarding the password, it's up to you to create a strong password that cannot be guessed in relation to your private life (first names, surnames, dates, personal tastes, etc.), that is different from other passwords used on other applications (1 account - 1 password), that you never write down anywhere (paper/digital), etc. The longer and more complex your password, the lower the risk of your account being hacked.
Given the state of the art in password decryption, it is recommended that your password be at least 12 characters long, including upper and lower case letters, numbers and special characters. You can, for example, write a sentence with spaces in compliance with the above criteria.
In any event, you are responsible for the security and confidentiality of your password.
Please note that you must provide this information in order for us to create your member account.
Your Personal Data processed for the creation and management of your account is kept for the duration of your member account until it is deleted, and up to a maximum of 36 additional months. In the event of a dispute, this data may be kept until the dispute has been finally resolved.
Please note that if your member account is inactive for two uninterrupted years, your account and its content will be deleted. You will be notified in advance of this deletion and will be able to prevent it by reconnecting to your telescope within the allotted time.
3.1.2.Contacts, notifications and customer relations concerning use of the Application
Some of your Personal Data is used so that:
- you can contact us via the contact form on the website,
- you can receive notifications necessary for the provision of the services provided by the Application, and
- more generally, we could contact you for the purposes of any customer relations in connection with the use of the Application.
These processing purposes are therefore part of the performance of the contract for the use of our SINGULARITY Application.
Your Personal Data concerned by these processing purposes are:
-Your surname, first name,
-Your email address
We also use this data when we need to send you notifications necessary for the provision of services delivered by the Application.
Personalisation of the member account
As part of the personalisation of the member account, you can personalise your profile by adding a photograph. Your photograph can be imported from your library onto your terminal.
If you choose another photograph, make sure you have received permission from any other person who may appear in the photograph. If it is a photograph taken by a third party, make sure that you have the rights to use it, in accordance with the provisions set out in the General Terms of Use of the Application.
You may modify and/or delete it at any time in your profile.
3.1.4. Other communications related to the performance of the Contract for Use of the Application
With respect to other communications from VAONIS which, due to their nature related to the performance of the contract for use of the Application, could not be subject to unsubscription (in particular concerning a malfunction of the Application, a notification of data breach, an update of the General Terms of Use of the Application or of this privacy policy, a warning sent to you due to a breach of our General Terms of Use), the corresponding Personal Data may be used for the duration of your member account until it is deleted and for up to 36 additional months. In the event of a dispute, this data may be kept until the dispute has been finally resolved.
Summary of data processing carried out to create and manage our customer relationship:
Purposes
Personal data concerned
Whether collection is compulsory or not
Data retention period
Legal basis
Account creation / Management
Last Name, First Name, e-mail address
YES
For the duration of your account and for a maximum of 36 months after deletion of the account. In the event of a dispute, data retention may be extended until the dispute has been finally resolved.
Performance of the contract for use of the Application
Notifications necessary for the provision of services by the Application and customer relations
Last Name, First Name, e-mail address
YES
For the duration of your account and for a maximum of 36 months after deletion of the account. In the event of a dispute, data retention may be extended until the dispute has been finally resolved.
Performance of the contract for use of the Application
Personalisation of the profile
Photograph
NO
Deletion possible at any time. Deletion no later than 36 months after account deletion.
Your consent
Other communications relating to the performance of the contract for use of the Application
Last Name, First Name, e-mail address
YES
For the duration of your account and for a maximum of 36 months after deletion of the account. In the event of a dispute, data retention may be extended until the dispute has been finally resolved.
Performance of the contract for use of the Application
3.2 Creating personalised content and improving your user experience
We also collect some of your Personal Data in order to create personalised content on our Application according to your areas of interest (apart from any advertising content). We also collect data concerning your use of our SINGULARITY Application in order to improve it and your user experience.
3.2.1. Interests
When you create your member account, you are invited to enter your interests.
These interests are formulated in a generic manner, such as Art, Cinema, Literature, Physics, Geology, History, Image processing, Music, Computing, etc.
These areas of interest, if you choose to share them with us, are used solely to personalise the Application interface and any other communication channel to which you may have subscribed (Newsletter, etc.) with content related to your centres of interest.
The personalisation of your centres of interest is optional.
If you maintain your centres of interest in your profile, this data is kept for the duration of your member account until it is deleted.
3.2.2. Application usage data - Cookies
As part of the installation of the Application on your multimedia equipment (tablet, mobile phone, etc.) (hereinafter referred to as the ‘Terminal’), we deposit files on your Terminal allowing us to collect technical information and information about your use of the Application (hereinafter referred to as ‘Cookies’).
The Cookies installed by Vaonis on your Terminal are necessary to provide the services available on the Application or to establish communication, in particular between your Terminal and the Products you have purchased from Vaonis.
Cookies enable us to:
- Know your terminal type and screen size,
- Keep statistics on page loading times and the time spent on each page,
- Keep statistics on your actions as a user (clicks, selections) per page,
- Know the audience measurement per page.
The purpose of statistics / audience measurement is to enable our company VAONIS to measure the performance of its SINGULARITY Application, to detect navigation problems and to optimise its technical performance. This data is not ‘entered’ by you on the Application but is collected via audience measurement tracers installed in our Application.
Data relating to the use of our Application is processed on the basis of our legitimate interests, so that we can improve our Application and your user experience. We would like to point out that these audience trackers do not require consent within the meaning of the Regulation on personal data, as their purpose is strictly limited to measuring the audience for our Application and they only produce anonymous statistics.
We would also like to point out that the provision of this data, both the indication of your centres of interest and the provision of usage data (except in the case where you wish to benefit from our content personalisation service) is not compulsory. With regard to the latter, you can oppose their collection by deactivating the ‘Send usage data’ selection button available in the ‘Help’ section of our Application.
Data relating to the use of our application is kept for a maximum period of twenty-five months from the time it is collected by our trackers.
The Application allows you, if you wish, to share photographs or other content and information on third-party sites, in particular social networks. These sharing links enable you to use the functionalities of these networks.
When you activate this sharing, the Application may, with your consent, send information to the requested social network, which may then associate your actions with your profile.
Cookies from these third parties/social networks, which are not controlled by Vaonis, may then be deposited in your browser and/or Terminal. If you use these content sharing features on third-party applications (e.g. Facebook, Instagram, gmail, etc.), we invite you, before sharing your data with these publishers, to consult their privacy policy, in order to learn how your data collected by these third parties is processed, in particular the purposes and sharing with third parties. If you decide to share your data on applications / sites of these publishers through the Application, Vaonis no longer has control over your shared data, the authorizations you give or not, and cannot be responsible for the use made of your personal data by these other publishers.
Summary of processing carried out to create personalised content and improve your user experience:
Purposes
Personal Data concerned
Whether collection is compulsory or not
Data retention period
Legal Basis
Personalising content to your interests
Centers of interest
NO
Deletion when the account is deleted.
Consent
Cookies required to provide the services available on the Application or to establish communication
Technical information about the characteristics of your Terminal;
Personalisation of your interface
YES
twenty-five months after their collection by our trackers.
Legitimate interest
Cookies needed to produce anonymous statistics
- page loading time,
- time spent on each page
-actions (clicks, selections) per page,
- audience measurement per page
YES
twenty-five months after their collection by our trackers
Legitimate interest
3.2.3. Creation of personalised content using artificial intelligence
We offer you optional personalised services using artificial intelligence, which consist of obtaining answers, generated by artificial intelligence, to your written or oral questions.
These services may process personal data if the texts you enter contain such data. As these operations are carried out by artificial intelligence, you acknowledge that we are not able to identify which texts do or do not contain personal data, so we cannot process them specifically.
Personal data is also processed when you decide to ask your questions orally, rather than in writing, insofar as your voice constitutes personal data. Only the text may then be transmitted to third parties, the operators of artificial intelligence systems: voice data will be processed locally on the device and only the text resulting from voice recognition will be transmitted. Please note that your voice is not collected or stored by VAONIS.
Metadata is limited to the time and date of interactions and anonymised information on the use of functionalities (e.g. frequency of use, activation/deactivation status).
The processing of any personal data is justified by the performance of the contract, in order to offer you the optional services that you will choose to use. It is also justified, with the exception of personal data consisting of voice data, by the legitimate interest of the service providers, aimed at being able to analyse any feedback from you in order to improve the relevance of the prompts and responses. It is also justified by your consent insofar as you are the only one to decide what data you include in your questions and/or to decide to use voice recognition.
Such processing is purely optional insofar as you are under no obligation to use these services linked to artificial intelligence or to include personal data in your texts.
Vaonis will keep texts and any personal data contained therein for a maximum of two years.
3.3. Location data
3.3.1. Activating geolocation
We process your location data to enable you to observe the sky through your SINGULARITY telescope. This location data is essential for this service: without it, your SINGULARITY telescope connected to our Application will not be able to allow you to observe space.
You can provide us with your location data either manually, by entering these coordinates in our Application, or by geolocation, by activating your GPS when you use our SINGULARITY Application.
If you choose to activate your GPS when using the SINGULARITY Application, you will receive a ‘Push’ notification asking you to confirm your choice.
By confirming your choice, you agree to provide us with your location data using the GPS on your terminal, in order to set up your SINGULARITY telescope for sky observation.
We would also like to point out that if you have chosen to activate your GPS to provide your location data necessary for configuring your sky observation, your GPS will be deactivated automatically after each use of our Application. The SINGULARITY Application only uses location data when you use it to observe the sky.
Depending on your terminal, we also specify that your authorisation allowing our Application to access your GPS for sky observation may be predefined, or may be requested each time you use the SINGULARITY Application:
- On IOS, an authorisation request will be systematically sent by « Push » notification.
- On Android, you will be asked to authorise GPS activation ‘When you use the application’ or ‘Only this time’. You can change your choice at any time in the application settings on your terminal.
- Once you have given your authorisation to access your GPS, this authorisation will be set by default in your operating system, so that it will no longer be requested each time you use the application, depending on the choice you have made.
In all cases, you can set the access authorisations for your GPS directly in your terminal settings.
3.3.2. Creating Observation Points
The Application lets you create ‘Observation Points’. Each Observation Point corresponds to a piece of location data. You can give it a name such as ‘House’, ‘Country Residence’, etc.
Please note that the location data is only used for the duration of your sky observation, unless you choose to save this data in order to create an ‘observation point’ enabling you to observe the said observation point on a recurring basis.
You can manage the creation and deletion of these ‘observation points’ on the Application. Deleting an observation point also entails deleting the associated location data.
As your location data is processed in order to ensure the operation of your SINGULARITY telescope with the aim of enabling you to observe the stars at the location where you are, this data is therefore processed on the basis of the performance of a service contract between you and our company VAONIS within the meaning of the Regulation on personal data.
We remind you that the communication of this location data is necessary to operate your SINGULARITY telescope through our SINGULARITY Application.
The retention periods for your location data are as follows:
- Your location data is only processed for the duration of your session using our Application;
- At each new session of use of our Application, we will process the new location data that you have entered, or that your GPS will have provided to us if it is activated, when you have given us access authorisation;
- In the event of the recording of an observation point, the associated location data will be retained until the said point is deleted, or until your member account is deleted.
Processing intended to operate your SINGULARITY telescope using your location data
Purposes
Personal data concerned
Whether collection is compulsory or not
Data retention period
Legal basis
Geolocation of your location for the operation of the telescope and the Application
Geolocation points
Yes: necessary for the operation of the service
While you are connected to the Application
Performance of the contract
Creation of observation points to retain location points
Geolocation points associated with locations that you designate
Yes: necessary for the operation of the service
Until the said point is deleted, or until your member account is deleted
Performance of the contract
3.4. Calendar functionality in the Application
Our Application allows you to record events related to sky observation in the calendar integrated into the Application, depending on the model of your terminal, in accordance with Article 8.4 of our General Terms of Use.
The Personal Data recorded on the calendar integrated into your Application are processed on the legal basis of our contractual obligations, as this functionality is designed as a service of our company VAONIS.
The Personal Data concerned by this functionality are the Personal Data associated with the events recorded via the calendar integrated into the Application.
When the calendar is integrated into our Application, this data is kept until your member account is deleted or until the events are deleted from the Application.
Processing relating to the calendar functionality in the Application:
Purposes
Personal data concerned
Whether collection is compulsory or not
Data retention period
Legal basis
Creation of events in the Application calendar
Any Personal Data associated with this functionality
No personal data is mandatory
Until the deletion of your member account or until the deletion of said events from the Application
The performance of our services, thus the performance of a contract between you and VAONIS
3.5. Hosting photographs on our Cloud
We process the data derived from your photographs that you have hosted on our Cloud in accordance with article 8.5 of our General Terms of Use.
You are hereby informed that we may have access to the content hosted and the associated metadata, such as the date and time of these photographs, your identifier associated with your member account, as well as the content of your photographs.
However, we will only use this data for the purposes of hosting your content. We may also use this data if you notify us of a problem with hosting, in order to try to resolve the problems encountered.
Therefore, the legal basis for this processing under the Personal Data Regulation will be the performance of our contractual obligations to host your photographs, and the legal basis for Processing will be our legitimate reasons for accessing your photograph data for the purposes of maintaining the Application.
This data is collected automatically and is mandatory when you wish to have your photographs hosted on our Cloud.
This data is kept for the duration of the hosting of your photographs on our Cloud.
This data will then be destroyed if you choose to delete one or more of your contents from our Cloud, or if your member account is deleted.
Processing relating to the hosting of your data from your photographs and videos on our Cloud:
Purposes
Personal data concerned
Whether collection is compulsory or not
Data retention period
Legal basis
Hosting your photographs on our cloud
Data relating to photographs hosted on our Cloud (date and time, place where the photograph was taken, associated identifier, content)
Data collected automatically for hosting in the Cloud
The data is kept for the duration of the hosting of the content on our Cloud or until the deletion of your member account.
The performance of our hosting services, i.e. the performance of a contract between you and VAONIS.
Resolution of any problems concerning the hosting of your photographs on our Cloud
Idem
Idem
Idem
Our legitimate reasons, to enable us to respond to any maintenance requests concerning hosted content and to resolve any problems encountered with the Application
4. NO AUTOMATED DECISION-MAKING OR PROFILING
The Personal Data Regulation requires us to inform you of the existence of automated decision-making, including profiling, based on your Personal Data.
You are informed that VAONIS will never use your Personal Data to make such automated decisions against you, or to carry out profiling within the meaning of the Personal Data Regulation.
5. RECIPIENTS OF YOUR PERSONAL DATA
5.1. Communication of your Data only to our Processors
We do not communicate your Personal Data to third parties, except to our Processors for the purposes of the Service.
Our Processors may have access to certain categories of Personal Data as part of the services we delegate to them. Our processors are identified in Article 5.2 below.
VAONIS endeavours to use only Processors who provide sufficient guarantees that they have implemented the technical and organisational measures required by the Personal Data Regulation, depending on the nature of the Personal Data and the associated risks of Breach. Our Processors only have access to the Personal Data that is strictly necessary for them to provide the services that we entrust to them, and we ensure that the legal act provided for in Article 28 of Regulation no. 2016/679 (known as the ‘GDPR’) governs our relationship as Data Controller and Processors.
Still on the subject of the communication of your Personal Data to third parties, we would point out that when you specifically use a sharing functionality with a third-party service on our application in accordance with article 8.6 of our General Terms of Use, we are not acting as a Data Controller.
The Personal Data that you share with these third-party services already installed on your terminal is in fact done under your instructions and on your behalf. These data communications are therefore carried out under your control and responsibility.
5.2. List of our processors
Our company VAONIS keeps an updated list of Processors it uses for the functioning and operation of its SINGULARITY Application.
These Processors are as follows:
Identity of the processor
Functions
Heroku
San Francisco, California, USA
Hosting of our SINGULARITY application
Amazon Web Services, Inc. P.O. Box 81226 Seattle, WA 98108-1226 USA
Hosting of our Cloud and maintenance of the SINGULARITY application
Firebase Analytics
Published by par GOOGLE, Mountain View, California, USA
Analysis of data relating to use of our Application
OpenAI (ChatGPT)
Analysis of questions, which may contain personal data, to automatically generate answers.
VAONIS has taken appropriate measures to ensure and verify that these Processors benefit from sufficient guarantees regarding the implementation of technical and organisational measures required by the Personal Data Regulation, when they have access to some of your Personal Data.
This list of Processors is also available at any time on our website https://vaonis.com/.
6. TRANSFERS OF DATA ABROAD
Due to the identity of some of our Processors, your Personal Data may be transferred outside the European Union, and more specifically to the United States.
VAONIS has ensured that the transfer of such data to its Processors in the United States is accompanied by appropriate or adapted safeguards in accordance with the Personal Data Protection Regulations. These guarantees are:
- The choice of storing your Personal Data on servers located within the European Union whenever possible (Amazon Web Services);
- With regard to the United States, the choice of processors registered as certified bodies under the Data Privacy Framework;
- The standard contractual clauses in force (27 December 2022).
You can obtain a copy of the list of these guarantees by making your request to our Data Protection Officer, whose contact details are given in article 9.
7. SECURITY AND VIOLATION OF PERSONAL DATA
VAONIS makes every effort to ensure the security of your Personal Data.
We therefore implement several security measures adapted to the categories of Personal Data that we process:
- In particular, we ensure that only VAONIS personnel required for our Processing operations have access to the Personal Data concerned, and we ensure that such personnel are subject to an obligation of confidentiality;
- We limit access to Personal Data through physical and electronic authentication;
- We use encryption and pseudonymisation of data on the Application;
- We take care to implement measures to guarantee the confidentiality, integrity and availability of your Personal Data;
- We also implement tests to regularly assess the effectiveness of our technical and organisational measures.
These security measures are not exhaustive.
However, despite the protection measures that it implements, our company cannot guarantee their infallibility, particularly against the illegal actions of third parties.
Therefore, in the event of a Personal Data breach, we will ensure that we comply with the obligations set out in the Personal Data Regulation.
We will therefore notify the Commission Nationale Informatique et Libertés (CNIL) as the competent authority as soon as possible, and in principle within 72 hours of becoming aware of the Violation, unless the Violation in question is not likely to result in a risk to the rights and freedoms of the natural persons concerned.
If the Violation is likely to result in a high risk to your rights and freedoms as an individual, VAONIS will notify you as soon as possible, unless:
- If the Personal Data affected by the said Breach has been protected by appropriate safeguards so as to render the data incomprehensible to any person not authorised to have access to it;
- If we have taken subsequent steps to ensure that the high risk to your rights and freedoms is no longer likely to materialise;
- If such notification would require disproportionate effort. In this case, we will instead make a public announcement or take a similar measure.
VAONIS keeps an up-to-date inventory of the personal data breaches it has suffered, specifying in particular the manner in which they occurred, their effect and the measures taken to remedy them. We keep this inventory at the disposal of the CNIL.
8. EXERCISING YOUR RIGHTS TO YOUR PERSONAL DATA
In accordance with the regulations on the protection of personal data, you are hereby informed that you have the following rights in respect of the Personal Data we process:
- A right of access
- A right of rectification,
- A right of limitation,
- The right to object on legitimate grounds,
- A right to portability,
- A right to erasure,
- As well as the right to define directives concerning the fate of your Personal Data after your death.
You may exercise these rights by sending a written request to our Personal Data referent, whose contact details are given in article 9 below.
We emphasise that the aforementioned rights are exercised strictly within the limits set by the Personal Data Regulation.
You are also informed that exercising your rights to your Personal Data may influence the performance of the SINGULARITY Application and that of our services to you, as explained in article 3 of this privacy policy.
9. YOUR PERSONAL DATA CONTACT AT VAONIS
Our contact person in charge of issues relating to the protection of personal data within our company VAONIS is:
You may send him any questions you may have concerning the processing of your Personal Data.
Our representative will reply within one month of receiving your request.
However, this period may be extended by two months, depending on the complexity and number of requests received. In addition, you may be asked to provide proof of identity in order to respond to your request.
10. COMPLAINTS TO THE CNIL
You are informed that you always have the right to lodge a complaint with a supervisory authority if you believe that VAONIS has breached the regulations on the protection of personal data when processing your Personal Data.
In France, this authority is the Commission Nationale de l'Informatique et des Libertés (CNIL), located at 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07, Tel: 01 53 73 22 22, https://www.cnil.fr/fr/vous-souhaitezcontacter-la-cnil.
The CNIL has an online complaints service, available here: https://www.cnil.fr/fr/plaintes
11. CHANGES TO THIS PRIVACY POLICY
Our company VAONIS may be required to modify this privacy policy, in particular as a result of changes to the SINGULARITY Application and/or a change in personal data regulations.
In this case, these modifications will apply to Personal Data Processing carried out after the publication of our modified confidentiality policy.
You will also be informed of these changes at the email address associated with your member account in accordance with the provisions of Article 3 of this Confidentiality Policy.