Singularity by Vaonis
Introduction
VAONIS processes your personal data to provide services through the SINGULARITY application and ensure legitimate interests. As a data controller, VAONIS complies with the EU General Data Protection Regulation (GDPR) and French Data Protection Act (Loi Informatique et Libertés). This policy explains how your personal data is processed when you use the SINGULARITY application.
1. Definitions
• Personal Data: Any information relating to an identifiable person.
• Processing: Operations performed on personal data (e.g., collection, storage, use).
• Controller: VAONIS, determining the purpose and means of data processing.
• Processor: Entities acting under VAONIS’s authority to process data.
• Breach: A security incident affecting data confidentiality, integrity, or availability.
• Application: The SINGULARITY application published by VAONIS.
• VAONIS Telescope: New-generation telescopes compatible with the SINGULARITY application.
2. VAONIS as the Controller
VAONIS, a French company headquartered at Cap Alpha, 34830, Clapiers, is responsible for all personal data processing as described in this policy.
3. Personal Data Processing Purposes
3.1 Customer Relationship Management
Personal data is used for account creation, contact requests, newsletters, and communication.
Data Processed:
• Name, surname, email, optional photo.
Legal Basis: Contractual obligation and legitimate interest.
Retention Period:
• Member account: Up to 36 months after deletion.
• Contact requests: 36 months.
• Newsletter: Until unsubscribed or account inactivity for 3 years.
3.2 Personalization and User Experience Improvement
Data is collected to provide personalized content (excluding ads) and enhance user experience.
Data Processed:
• Interests indicated during account creation.
• Application usage data (e.g., device type, browser, session statistics).
Legal Basis: Legitimate interest and contractual performance.
Retention Period:
• Interests: Until account deletion.
• Usage data: 25 months.
3.3 Telescope Operation Using Location Data
Location data is used to enable telescope functionality and resolve operational issues.
Data Processed:
• Manually entered or GPS-provided location data.
Legal Basis: Contractual necessity.
Retention Period:
• For the session duration, unless saved as an “observatory point”.
• Maintenance data: Until no longer required.
3.4 Calendar Functionality
Sky observation events can be recorded in your device’s calendar.
Data Processed: Event-related data.
Legal Basis: Contractual performance.
Retention Period: Only during event transmission; not stored by VAONIS.
3.5 Cloud Hosting for Photographs
Photos and metadata (e.g., timestamp, location) hosted on the VAONIS cloud.
Legal Basis: Contractual obligation and legitimate interest.
Retention Period: Until content or account deletion.
4. Automated Decision-Making and Profiling
VAONIS does not perform automated decision-making or profiling based on personal data.
5. Data Recipients
VAONIS does not share personal data with third parties, except for processors acting under strict agreements to provide services. Examples include hosting and customer support providers.
6. Processors List
• Heroku (USA): Application hosting.
• Digital Ocean (USA): Application hosting.
• Amazon Web Services (EU/USA): Cloud hosting.
• Kibana – Elastic Cie (USA): Application maintenance.
• Firebase Analytics (USA): Usage data analysis.
• SupportYourApp (USA): Outsourced customer service.
7. Data Transfers to Third Countries
Data may be transferred outside the EU, particularly to the USA, with safeguards including:
• Storing data on EU-based servers when possible.
• Using Standard Contractual Clauses (SCCs).
8. Security and Breach Management
VAONIS implements strong technical and organizational security measures (e.g., encryption, access control). In case of a breach, VAONIS will notify relevant authorities (e.g., CNIL) and affected individuals if the risk is significant.
9. Your Rights
You have the right to:
• Access, rectify, or erase your data.
• Restrict or object to processing.
• Port data to another provider.
• Define directives for posthumous data handling.
To exercise these rights, contact dpo@vaonis.com. Proof of identity may be required.
10. Data Protection Contact
For privacy-related inquiries, email dpo@vaonis.com. Responses are typically provided within one month, extendable by two months for complex cases.
11. Supervisory Authority Complaint
You may lodge a complaint with the CNIL (Commission Nationale de l’Informatique et des Libertés):
• Address: 3 Place de Fontenoy, TSA 80715, 75334 PARIS CEDEX 07, France.
• Phone: 01 53 73 22 22.
• Online: CNIL Complaints.
12. Policy Updates
This policy may be updated to reflect changes in the application or legal requirements. Changes apply to future processing and will be communicated via email.