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Declaration of confidentiality

1. Introduction

Date of last update: 21/02/2022

The purpose of this Privacy Policy is to inform any data subject whose personal data (the "Data") are processed by LEETCHI, on the characteristics of the processing carried out and on the rights available to him/her, in particular with regard to the amended Data Protection Act of 6 January 1978 and the European Regulation 2016/679 of 27 April 2016 on data protection, known as the "RGPD".

The data controller is LEETCHI SA ("LEETCHI"), a limited company under French law, with a capital of 1,134.309 euros, whose registered office is located at 4 rue de la Tour des Dames 75009 Paris, France and registered with the Paris Trade and Companies Registry under number 511361073. LEETCHI is also registered as an Intermediary in Participative Financing for donation operations with the ORIAS under the number 18000860.

LEETCHI has appointed a Data Protection Officer (DPO). For any information concerning this Privacy Policy and your rights, or to contact the DPO, you can write to us at the following address : rgpd@leetchi.com or in accordance with the procedures set out in section 9 of this policy.

2. Are you concerned by this privacy policy?

LEETCHI publishes the website www.leetchi.com which allows users to create money pots to collect and manage funds together (e.g. to organise a joint gift for a birthday, a farewell party, parties, but also to finance personal or associative projects, etc.).

This Privacy Policy applies to all data subjects who have subscribed to LEETCHI services by creating a Profile. This concerns the creators of the money pots, the participants, the beneficiaries of the money pot as well as the merchants affiliated to LEETCHI (or any natural person linked to a merchant, such as the corporate officers).

If you are browsing the internet www.leetchi.com website as an Internet user, you are also partly affected by this Policy. You can directly consult section 13 concerning cookies for more information on the processing that concerns you.

3. What Personal Data is processed by LEETCHI? How is it collected?

When you subscribe to LEETCHI's services, you accept that your Personal Data necessary for the provision of these services be processed by LEETCHI. This mainly concerns your identifiers (allowing you to access your profile), your identification data (in particular your surname, first name, address, date and place of birth, and, if applicable, your identity document as well as any supporting document that may be required to use the services), as well as the data generated by the use of the services (for example, the type of money pot). Your IP address is collected when you create your profile and when you use the services exclusively for browsing purposes (in particular to define the language in which the site is displayed, to enable you to search for solidarity money pots projects according to your geographical area, to filter the proposed spending partners according to the country of dispatch). Finally, geolocation data, which takes the form of GPS coordinates from the IP address, is collected at the time of the creation of the money pot and can be modified by the creator afterwards.

When you make a payment by card on the payment page, you have to enter certain personal data (surname, first name and card data). In order to guarantee the highest level of security in the processing of payment data, Leetchi does not have access to the card data in clear text, but only to the card alias and the expiry date. Only Payline, a product of the company Monext SAS (MANGOPAY service provider), has access to this Data in order to carry out the transaction. The Data is transmitted in an encrypted and secured manner in order to guarantee confidentiality. We inform you that Payline is a PCI-DSS compliant standard since 2008. The PCI-DSS standard serves as a reference for the technical and operational conditions for protecting the data of cardholders.

The Data that must be provided are prominently displayed on the site. If you refuse to provide the mandatory Data, you may be denied access to the services or the services may be suspended.

Using Facebook Connect to subscribe to LEETCHI services
You may choose to create your account on the LEETCHI website through your Facebook profile. When you use this option, Facebook transmits the following Personal Data to us: name, first name, email address, telephone number and date of birth. This data is integrated into your profile on LEETCHI, but you have the possibility to modify or rectify it at any time. Please note that the Facebook Connect feature does not allow us to access your Facebook profile or any other Personal Data held by Facebook.

4. For what purposes are your Personal Data processed?

Your Personal Data is processed in the context of the execution of the general terms and conditions of use ("Terms and conditions") concluded with LEETCHI or in order to take measures related to this contract. This includes the following purposes:

  • Subscribing to the services and managing your profile (including the intermediation services in participatory financing);
  • Creation and management of money pots, including sending notifications as a creator and/or as a participant (e.g. when the money pot is closed or in case of thanks, etc.);
  • Customer relationship management (handling your questions and possible complaints, collecting opinions on the quality of services, etc.);
  • In partnership with MANGOPAY, your Data is also collected for the purposes of providing payment services related to the money pot. For more information on these processing operations, we refer you to section 7.4 of the Privacy Policy.

LEETCHI also processes your Personal Data for legitimate interests, which are deemed necessary to ensure the quality of the services provided to you. This concerns the following purposes:

  • The detection of fraudulent money pot;
  • The preservation of the security of the LEETCHI website;
  • Content sharing services on social networks;
  • Improving navigation on the LEETCHI website and improving the services by means of audience measurement tools (for more information, you can consult section 13 concerning cookies);
  • Targeted advertising.

With regard to targeted advertising, we inform you that we may send users marketing emails. These emails are targeted according to your user profile, based on the following elements: the type of fund you have already created or participated in, the last date of use of our services and the number of times you have created or participated in funds. No other Personal Data is used in the context of the advertising targeting we carry out. You may object to this processing in the manner set out in section 8.5.

LEETCHI processes your Personal Data where required by law. This includes:

  • Compliance with the legal and regulatory obligations imposed on Leetchi in its capacity as an intermediary in participatory financing, and in particular in terms of the fight against fraud, money laundering and the financing of terrorism, in accordance with articles L.561-2 et seq. of the monetary and financial code;
  • Cooperation with the public authorities or any authority responsible for the application of the law, in the context of a control or an investigation.

Finally, some Data processing is only carried out if you have given your consent in a clear and express manner (for example by ticking a box dedicated to this purpose). This is the case for example:

  • For the deposit of certain cookies (cookies related to advertising-related operations; social network cookies generated by social network sharing buttons when they collect personal data without the consent of the persons concerned; as well as certain audience measurement cookies). For more information on cookies, please see section 13.
  • If you agree that LEETCHI may provide Data to third parties to enable them to provide you with information about products, programmes, services, communications and promotions that they believe may be of interest to you.

5. How long is your Personal Data kept?

LEETCHI keeps your Personal Data for the duration of the contractual relationship. Once you terminate the services, all of your Personal Data is permanently deleted, except for those that must be retained by LEETCHI under legal obligations or for legitimate reasons. Thus, the following specific retention periods will apply:

  • As part of its obligations to combat fraud, money laundering and the financing of terrorism, LEETCHI retains for five (5) years from the termination of services, documents and information relating to your identity as well as documents and information relating to transactions (Article L.561-12 of the Monetary and Financial Code);
  • The data necessary for the management of any disputes or litigation are also kept for a period of five (5) years, in accordance with the legal provisions in force (in particular, but not exclusively, those provided for by the Commercial Code, the Civil Code and the Consumer Code);
  • Contractual documents are kept for a period of five (5) years from the end of the contract;
  • Communications with the customer support may also be recorded. In this case, they will be kept for a period of five (5) years from the date of their receipt or recording;
  • The information allowing us to take into account your right to object to commercial prospecting is kept for three (3) years from the date of exercise of the right of objection.

6. Where are your Personal Data stored?

The servers used by LEETCHI to store your Personal Data are located in Luxembourg.

In addition, LEETCHI transmits some of your Data to its processors, who provide services necessary for the execution of the services. Some of these processors host your Data on servers located outside the territory of the European Union (in particular in the United States). In this case, LEETCHI shall ensure that the third country or entity in question has been the subject of a decision by the European Commission establishing an adequate level of protection for personal data. Failing this, LEETCHI implements appropriate safeguards to ensure the protection of your Data, such as the use of the standard contractual clauses adopted by the European Commission.

7. Who are the recipients of the Personal Data? Are they transmitted to third parties?

7.1. Authorised LEETCHI departments

Only specifically authorised LEETCHI employees may access your Personal Data, in the context of carrying out the tasks entrusted to them. Any LEETCHI employee who has access to your Data is subject to strict confidentiality obligations.

7.2. Competent authorities

LEETCHI may be required to transmit Personal Data to the competent authorities, such as the public authorities and administrative authorities, or bodies involved in the fight against money laundering and the financing of terrorism.

7.3. LEETCHI's processors

LEETCHI uses the services of processors for the purposes of providing the service you have requested (this concerns, for example, the hosting of the information system, data analysis, IT services, online ordering services, carrying out surveys, managing email and social networks, etc.). Processors process your Data only on the instructions of LEETCHI, and exclusively within the framework of the latter's activities. Unless you expressly agree, processors are not allowed to use your Personal Data for their own purposes.

LEETCHI contractually requires data processors to respect security and confidentiality obligations and to implement appropriate technical and organisational measures so that the processing carried out complies with all applicable regulations and guarantees the protection of your rights.

You may obtain a list of the categories of processors involved in the processing of your Data on request to LEETCHI.

7.4. Transmission of your Data to MANGOPAY

For the management of payments made through the website https://www.leetchi.com, LEETCHI uses the services of MANGOPAY, a payment service provider approved in Luxembourg and supervised by the Commission de Surveillance du Secteur Financier (https://www.cssf.lu). LEETCHI is designated by MANGOPAY as a payment agent. Thus, the Personal Data necessary for the provision of payment services are transmitted to MANGOPAY. This concerns Data related to the following purposes:

  • Subscription to the services and opening of your payment account;
  • Management of payment orders;
  • Customer relationship management (e.g. provision of transaction statements);
  • Handling your questions and any complaints you may have in relation to payment services;
  • Accessing your payment account (and managing any authentication procedures);
  • Executing card payments;
  • Compliance with legal and regulatory obligations in the fight against money laundering and terrorist financing.

Thus, MANGOPAY and LEETCHI assume joint responsibility for these Data processing operations. This system of joint responsibility is contractually defined between LEETCHI and MANGOPAY. For any request to exercise your rights or any complaint in connection with the above-mentioned processing, you may first contact LEETCHI in accordance with the procedures set out in section 9. LEETCHI and MANGOPAY cooperate to ensure the protection of your Personal Data. For more information on the processing carried out by MANGOPAY, you may consult its privacy policy accessible at the following address: www.mangopay.com

8. What are your rights regarding your Personal Data?

8.1. Right of access

You have the right to access the Data concerning you. If you exercise this right, LEETCHI will provide you with a copy of the characteristics of the processing carried out on your Data (the purposes of the processing, the categories of Data concerned, etc). This information will be provided to you on a commonly used electronic medium. You may, however, request that this information be provided to you in another form, provided that LEETCHI is technically able to provide the information in the requested format.
You are informed that LEETCHI may require payment of a fee based on the administrative costs generated by any additional copy request.

8.2. Right of rectification

If you find that the Data concerning you is inaccurate or incomplete, you have the possibility of requesting the rectification or updating of this Data. You can modify certain Identification Data directly from your LEETCHI profile.

8.3. Right to be forgotten

You may request the deletion of your Data in the following cases: when it is no longer necessary for the purposes for which it was collected or processed; when your Data has been processed unlawfully; or when it must be deleted to comply with a legal obligation under European Union law or French law.

However, you will not be able to obtain the deletion of your Data when the processing is necessary for the exercise of the right to freedom of expression and information, for the establishment, exercise or defence of legal claims, or to comply with a legal obligation imposed on LEETCHI.

8.4. Right to limit processing

You have the right to obtain the limitation of a processing operation in the following cases: if you contest the accuracy of your Personal Data; if the processing operation is unlawful and you wish to obtain the limitation of this processing operation instead of the erasure of your Personal Data; if LEETCHI no longer needs your Personal Data but it is still necessary for the establishment, exercise or defence of legal claims.

8.5. Right to object to processing

If you have a legitimate reason, you may object to your Data being processed. Once you object to the processing, your Data will no longer be processed for these purposes.
Moreover, when your personal Data (in particular your email address) are used for canvassing or commercial purposes, you may object at any time directly in your profile or by contacting LEETCHI, including in the event of possible profiling insofar as it is linked to said canvassing. If you object to the processing, your Data will no longer be processed for these purposes. We inform you that you can also unsubscribe from prospecting or commercial animation emails by means of the unsubscribe link available at the end of each of the said emails.

8.6. Right to Data portability

You have a right to the portability of the Data that you have transmitted. You can receive this Data in a structured, commonly used and machine-readable format. You also have the right to request that the Data be transferred to another controller, where technically possible.

9. How to exercise your rights?

You can exercise your rights by contacting LEETCHI at the following address:

For any request to exercise your rights, we may ask you to provide an official identity document in order to verify that you are the person concerned by the Data that is the subject of the request. Responses to your requests will be sent to you electronically, unless you explicitly request otherwise. In this case, you must accompany your request with the desired method of response.

We undertake to respond to all requests as soon as possible. You will receive a response within a maximum of one month of receipt of your request. However, we inform you that this period may be extended by two months if your request is particularly complex or given the number of requests. In this case, you will be informed of such an extension and the reasons for it within a maximum of one month of receiving your request.

If we are unable to comply with your request, you will be informed within one month of receipt of your request at the latest, stating the reasons. You will also have the opportunity to lodge a complaint with the relevant Supervisory Authority. If the Authority concerned is the Commission Nationale de l'Informatique et des Libertés (CNIL), here is the link to send your complaint: www.cnil.fr

You are informed that in the event of manifestly unfounded or excessive requests, in particular because of their repetitive nature, we may refuse to comply with your requests or require payment of a fee to take account of the administrative costs incurred in responding to your requests.

10. How is the security of your Personal Information ensured?

We implement all appropriate security measures to ensure the protection and confidentiality of your Data, including preventing the destruction, loss, alteration, unauthorised disclosure of, or access to, such Data. These security measures include the encryption of Data and the implementation of means to ensure the continued confidentiality, integrity, availability and resilience of processing systems and services. You will be notified as soon as possible of any breach of security affecting your Data and likely to result in a high risk to your rights and freedoms.

11. Changes to the Privacy Policy

Changes to the Privacy Policy are published on the LEETCHI website, with the date of the last update.

12. Voluntarily published content

The LEETCHI services allow the creators of a money pot to publish a description of their project as well as photographs. They can also add content to the money pot's news feed. Participants can post comments related to the fund. This information will either be made public or will only be available to users invited by the creator, depending on the privacy settings of the money pot determined by the creator.

When you voluntarily post content on the LEETCHI website, you acknowledge that you are fully responsible for any personal information you transmit (including any photographs or images). If you post content that includes Personal Information relating to third parties, you are solely responsible for obtaining the permission of those persons. You agree not to post any content that is potentially harmful or damaging to a person's reputation.

13. Cookie Policy

A cookie is a small file placed on your device when you browse a site. Cookies have a limited lifetime. They can only store text, which is always confidential and in most cases encrypted. These cookies therefore make it possible to identify you each time you visit and help improve your user experience by offering you services that are more appropriate to your needs.

By clicking on accept on this site, you consent to the use of cookies or similar techniques by Leetchi and its partners to store and access your personal data (such as your IP address). You can refuse or limit our cookies by setting your browser as specified on the site's cookie page.

The cookies used by LEETCHI may have different purposes, including :

  • Improving your browsing experience on the LEETCHI site by providing a user experience more tailored to your choices and providing services that you have expressly requested (e.g. saving your currency preferences, authenticating to your account, etc.). The use of these cookies also allows us to identify problems with the platform. These are so-called "functional" cookies;
  • Measuring the platform's audience in order to improve its performance, as well as its products and services. These are known as "analytical" cookies;
  • To carry out targeted advertising outside the site and to personalise the content presented to you. These are known as "retargeting" cookies;
  • Social network" sharing buttons and comments. These are so-called "social network" cookies.

These cookies are either implemented directly by LEETCHI, or offered through service providers (publishers of audience measurement solutions, advertising agencies and social networks in particular).

We specify that when cookies are deposited by third-party service providers, they are used exclusively on behalf of LEETCHI. LEETCHI does not authorise the issuers of cookies to use the Data collected on their own behalf. You can express or withdraw your consent to these tracers or oppose them by clicking on "set my cookie preferences".

You can also consult our cookie and tracker management policy for more information and to oppose the use of certain trackers.

Recommendations for using the facebook link (like button)

We have integrated an interface with the social network Facebook. The Facebook connection is as follows: https://developers.facebook.com/docs/plugins When you click on 'like' while logged into your Facebook account, you can add the content of our web pages to your profile, which allows Facebook to link your visit to our site to your profile on LEETCHI. Please note that as the provider of the website, we have no knowledge of the content of the data transmitted to Facebook or how Facebook uses it. For further information, please refer to the Facebook data protection guidelines at https://www.facebook.com/policies.
If you do not want Facebook to be able to link your visit to our site to your profile, please log out of your Facebook account before visiting our site.