Privacy policy

Last updated: 16 May 2019

The purpose of this Privacy Policy (the "Charter") is to formalize our commitment to respect the privacy of users of the WinLAB Application operated by WINSTATE SAS. The Charter is governed by the General Conditions of Use of the Application. All capitalized terms not defined in this Policy are defined in the Terms and Conditions. For more information on the Terms of Use, please read these Terms and Conditions carefully on the Site.

Personal data means any information that directly or indirectly identifies a natural person ("Personal Data"). We collect and process Personal Data as part of the publishing of general software used for business purposes for domestic purposes distributed on physical media or download, operating websites that use search engines to produce and maintain large databases containing addresses and content on the Internet, in an easily searchable format, access to a virtual space allowing users to exchange and document on proposed topics, participation in all economic operations, legal, industrial, commercial, civil, financial, movable or immovable property directly or indirectly related to the aforementioned activities or any similar, related or complementary objects or likely to promote its extension or development and this exclusively, in strict accordance with the law "computer and freedoms "No. 78-17 of 6 January 1978 as amended. The data collected is essential for these treatments. You will never be asked to fill in so-called "sensitive" Personal Data, such as your racial or ethnic origins, your political, philosophical or religious opinions.

By registering with the Application, you authorize us to process your Personal Data in accordance with the Charter. If you refuse the terms of this Charter, please refrain from using the Application.

1 - In which cases do we collect your Personal Data?

We may collect and store your Personal Data, including when you use in any way the features of the Application such as features for example:

  • Login to the Application;
  • Send feedback;
  • Use the paid features of the Application

1.1 - Navigation on the Site

Connection data. Whenever you connect to our Site, we passively collect information such as, but not limited to, your IP address and your computer's MAC address, the date and time of connection, and information about your browser. Navigation data. We also collect information to identify how you access the App, what features are used, viewed, and for how long. We may use the use of Cookies as specified below. Data related to your contact list. We also collect information from your contacts list on your phone that identifies other people with whom you can trade through the app.

1.2 - Creation of an Account

Access to the Application requires the prior creation of an Account. In accordance with the Terms and Conditions, you will be asked to enter a number of Personal Data when creating your Account your phone number and a nickname.

1.3 - Payment

You agree that we may use external service providers who will collect your Personal Data for the purpose of enabling the proper functioning of the credit card processing services and, where applicable, the delivery of goods or services.

To pay for your purchase, you must provide your last name, first name, phone number you want to credit, your postal address, email address, country and your payment details, ie the number of your credit card , the name of the cardholder, the validity date and the security codes, in order to process your payment.

We keep the details of your payments, as well as the details of the purchases you make. The details of the transactions are kept either in our systems or at the external service provider. This retention is for internal purposes, including accounting, compliance and legal purposes, in accordance with paragraph 5 of this Policy.

1.4 - Joining our Newsletter (named WinLetter)

When browsing our site, you can provide your email address to receive newsletters about new products, services and promotions. The unsubscription is done simply by sending an unsubscription request email to the following email address:

1.5 - Contacts

In order to respond to requests that you may make to our Customer Service and to confirm information about you, we will use your surname, first name, email address and your telephone number.

2 - How do we protect your Personal Data?

We have put in place technical and organizational security measures to ensure the security, integrity and confidentiality of all your Personal Data, to prevent it from being distorted, damaged or unauthorized third parties. have access. We provide a level of security tailored to the risks of the processing and the nature of the data to be protected, given the level of technology and the cost of implementation.

However no method of data transmission via the Internet or electronic storage is able to guarantee 100% security. As a result, we are unfortunately unable to guarantee absolute security of your Personal Data.

In addition, it is your responsibility to ensure the confidentiality of the password allowing you to access your Account on our website. Do not share this information with anyone. If you share your computer, be sure to sign out before leaving a Service.

3 - How do we use your Personal Data?

We use your Personal Data to enable the implementation and management of the Application's services and to respond to your specific requests. We also use your Personal Data in order to improve our approach and our Application. This information is used only by us and allows us to better adapt to your expectations. If you have decided to receive e-mails and mini-messages from us when creating your Account on our site, you will receive e-mail and alphanumeric messages about our products and promotions. We will then use the Personal Data you provided when you registered. You can unsubscribe from this service at any time by sending an unsubscription request email to the following address:

4 - In which case do we share your Personal Data?

We undertake not to divulge your Personal Data to a third party without obtaining your express and prior authorization. No transfer of Personal Data is made outside the European Union. NB: The company WINSTATE agrees not to sell the data of its users and has no source of revenue related to the use of data.

4.1 Sharing your Personal Data with third-party companies

When browsing the Application, your Personal Data may be transmitted to external service providers. These third parties provide service on our behalf and on our behalf to enable the proper functioning of credit card and other payments. Except in the case where a third party asks you to accept a confidentiality charter and conditions of use that are specific to it, the third companies that have received your Personal Data will only share this data with us. We will never share, without your prior consent, Personal Data with third-party companies for marketing and / or commercial purposes.

4.2 Sharing with the authorities

We may disclose Personal Data to administrative or judicial authorities where disclosure is necessary for the identification, prosecution or prosecution of any individual who may prejudice our rights, or the rights of any other user or a third party. We can finally be legally obliged to disclose Personal Data and can not in this case oppose it.

5 - How long do we keep your Personal Data?

We will keep your Personal Data only for the time of your registration on the Site to ensure your identification during your connection and, where appropriate, the supply of products or services. Except where the laws and regulations impose a different shelf life, we will retain your Personal Data for a period strictly necessary in accordance with the uses set forth in this Policy.

If you unsubscribe from the Application, your Personal Data will be erased and only retained as an archive for the purpose of establishing proof of a right or contract that may be archived in accordance with the provisions of the Code. of business relating to the shelf life of books and documents created during commercial activities and the code of consumption relating to the preservation of contracts concluded electronically.

6 - What are your rights?

In accordance with articles 38, 39 and 40 of the amended Law No. 78-17 of 6 January 1978 relating to computers, files and liberties, you have the right to query and access the Personal Data you concerning the right of rectification and deletion of such data as well as the right to object on legitimate grounds for their use.

You can also object to the processing of your Personal Data for prospecting purposes. You may contact our Customer Service to enforce your right to oppose, query, access, rectify or remove data at the following email address: or at the mailing address following: WINSTATE SAS, 11, Place des Carmes 31000 Toulouse by joining at your request a copy of an identity document.

In addition, you can unsubscribe from our newsletter at any time by sending a message to the following address: It is specified that the databases formed with your Personal Data have been the subject of a declaration with the CNIL under the receipt number [4EI2339163x].

7 - Can we amend the Charter?

We reserve the right to modify the Charter at any time. It is therefore recommended that you consult it regularly. In the event of a change, we will post such changes on this page and at the places we deem appropriate for you to know what information we collect, how we use it, under what circumstances, and if so, how we disclose it.

If we make material changes, we will notify you by means of an email and a warning on the Application before the change is implemented. Your use after any modification means that you accept these changes. If you do not agree to any substantial changes to this Policy, you must stop using the Application.

8 - How to contact us ?

For any question relating to this charter or if you wish to delete your Account, please contact us at the following address: