Personal data protection policy

Don't worry! The Holy Owly app, is committed to privacy.

Update date: September 2020

KidsMBA is concerned about the rights of individuals, particularly with regard to automated processing, and in a desire for transparency with its customers, has put in place a policy listing all such processing, the purposes pursued by the latter as well as the means of action available to individuals so that they can best exercise their rights. For any further information on the protection of personal data, you can consult the CNIL website: https://www.cnil.fr/

If you have any questions at all, please don't hesitate to contact us

1. Person responsible for the processing of personal data

The company KidsMBA SAS owner of the Holy Owly brand domiciled at 7 Place Saint Jacques in Besançon, with a capital of €13,810 and registered in the Besançon Trade and Companies Register, represented by Stéphanie Bourgeois, in her capacity as President

2. The purposes of processing personal data

The processing of personal data is implemented for the following purposes:

.....

Purpose of data processing	What are the justifications?
Customer account and order management;	Execution of the contract made on the basis of the general sales conditions
Management of payment transactions;
Management of customer relations (telephone/email), order tracking, after-sales service and refunds;
Statistical operations, analysis, selection and segmentation of customers in order to improve customer knowledge;	Legitimate interest to better know its customers
Collection of data from minors under the age of 16	Consent of the holder of parental authority
Transmission of data to commercial partners	Legitimate interest of Kids MBA Customer consent if it concerns data concerning minors under 16 or email addresses used for prospecting purposes by the partner

3. Personal data collected by Holy Owly

a. Origin of data collected by Holy Owly

We collect information when you log in and register in our app and on our site.

We may collect personal data from our partner companies who wish to provide Kids MBA services to their customers.

b. Origin of the data collected by Holy Owly

Holy Owly applies the principles of data minimization. Thus, we only collect data that is useful for the operation of the services you choose on Holy Owly.

The data collected by the company is as follows:

Last name; first name;
Email
Child's first name and nickname
Child's class
Smartphone ID
IP address
Bank details for payment

In the course of providing the service, learning data will be generated and processed by the Company. This is the following data:

the scores achieved by the child
the learning path based on their results (missions completed, bonus outfits obtained during the weekly bonus and illustrations unlocked during the monthly challenges).

4. What are your rights?

Any natural person using the service has the right to exercise his or her rights of access, rectification, opposition and deletion to the processing of his or her data in accordance with articles 38 to 40 of the law of 6 January 1978.

In application of Regulation 2016/679 of 27 April 2016, the natural person may exercise his or her right to the limitation of processing, to the erasure of his or her data to portability and may object to profiling from 25 May 2018.

Any User may also formulate directives relating to the conservation, deletion and communication of his/her personal data after his/her death in accordance with Article 85 of Law 78-17 of 6 January 1978. These directives may be general or specific

a. How to exercise them?

These rights may be exercised with the KidsMBA company that collected the personal data in the following manner:

By post, by writing to us at the following address: Village by CA, 7 place Saint Jacques 25000 Besançon
Electronically, by writing to contact@HolyOwly.fr

KidsMBA shall send a reply within 1 month after the exercise of the right. In certain cases, related to the complexity of the request or the number of requests, this period may be extended by 2 months.

b. What are the consequences of exercising certain rights?

In case of exercising a right to object to marketing profiling, the user is informed that he/she will continue to receive commercial solicitations but these will be less relevant and will no longer be targeted according to the person's interests.

c. What to do next?

In the event of a non-response or unsatisfactory response, the person concerned has the option of referring the matter to the competent supervisory authority, the CNIL at the following address: https://www.cnil.fr/.

5. Data retention

Data is kept for a period that does not exceed the time necessary for the purposes for which it was collected.

For the management of your newsletter subscription: we automatically delete the data after 3 years of inactivity. If you unsubscribe, the sending of newsletters is not automatically deactivated. You can request this by contacting us at contact@HolyOwly.fr in order to proceed with the effective removal of your address from our database.

For data collected as a result of subscription, it is retained for the purpose of performing our service, and then we delete it 3 years after the end of our contractual relationship.

6. Who are the recipients of the data?

Your personal data is intended for the Kids MBA company owning the Holy Owly brand:

Your data is passed on to partners of Kids MBA who may process the data on their behalf (these are recipients) or solely on behalf of and according to the instructions of Kids MBA (these are subcontractors).

The recipients of the data are:

Legally empowered judicial authorities
Kids MBA's commercial partner companies, a list of which is available here:
- The company TAPE A L'OEIL
  Société par Actions Simplifiée à capital variable, registered with the RCS of LILLE METROPOLE under the number 389 632 639, whose registered office is located at 24 Avenue du Grand Cottignies (59290) WASQUEHAL, represented by Mr Edouard BLANCHON, President of the company SDAE, Société D'Aménagement et de Développement de magasins de vêtements pour Enfants, Société par Actions simplifiée au capital de 18.146.390 euros, whose registered office is located at 24 Avenue du Grand Cottignies (59290) Wasquehal, itself President of the company TAPE A L'ŒIL

Kids MBA also uses subcontractors for the following operations:

The secure payment on the site
The hosting of data
The realization of distance learning courses
The realization of technical maintenance and development operations of the website, internal applications and the information system
The sending of commercial prospecting emails

7. Is the data sent outside the European Union?

For certain operations, personal data may be transferred to companies located in countries outside the European Union. Prior to the transfer outside the European Union, and in accordance with the regulations in force, KIDS MBA ensures the security of these data transfers.

Please note that the transfer of personal data to companies outside the European Union is not permitted.

More information on data transfers outside the European Union can be provided upon request to the Data Protection Officer.

8. How to adjust my cookie preferences.

In accordance with Directive 2002/58/EC of 12 July 2002, KIDS MBA collects your prior consent to the deposit of advertising, audience measurement and sharing cookies to social networks.

You may choose at any time to express and modify your wishes regarding cookies, by the means described below.

a. Setting your browser software

You can configure your browser software so that cookies are stored in your terminal or, on the contrary, that they are rejected, either systematically or according to their sender. You can also configure your browser software so that you are offered the option of accepting or rejecting cookies from time to time, before a cookie is likely to be stored on your terminal.

How to exercise your choices

How to exercise your choices, depending on the browser you use.

In managing cookies and your choices, each browser has a different configuration. It is described in your browser's help menu, which will tell you how to change your cookie wishes.

b. Setting cookies with a tool offered by KIDS MBA

In order to comply with the regulation, KIDS MBA uses a tool allowing the Internet user to set the deposit of cookies when connecting to the website or to the mobile application.

To access the list of cookies deposited and to configure their deposit click here for the details of cookies

c. Opt-out list to manage the deposit of cookies

You also have the option of objecting to the deposit of cookies by accessing the website https://www.youronlinechoices.com/fr/controler-ses-cookies/ .

d. Third party publisher link

KIDS MBA uses sharing cookies to social networks whose data protection policy the user can consult to set the cookies:

KIDS MBA uses the Google Analytics audience measurement cookie that can be set at https://tools.google.com/dlpage/gaoptout?hl=fr.

You have the ability to adjust your cookie preferences by clicking on the link below:

Adjust your cookie preferences

9. How to contact the data protection officer

KIDS MBA has appointed a data protection officer who can be contacted at stephanie@holywoly.fr