Privacy Policy

 

1. Preamble

This Privacy Policy governs the collection and management of digital data collected by LOOPING APP FZCO, trading as Phenix Blanc, a company registered in the Free Zone in Dubai (United Arab Emirates), hereinafter referred to as "the Provider."

The Provider acts as the data controller for all data collected in connection with its services.

2. Data Collected

We only collect the data necessary to provide the Services.

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2.1 Data provided directly by the User

• First and last name,

• Email address,

• Phone number (if provided),

• Billing, payment, and purchase information,

• Postal address (if required),

• Login credentials (email + password),

• Messages sent via form or customer support.

2.2 Data collected automatically

• IP address,

• Connection logs,

• Pages viewed,

• Technical data (browser, device),

• Functional or analytical cookies.

2.3 Optional data

• Notes taken in the member area,

• Participation in the private community,

• User preferences,

No sensitive data is collected (health, religion, biometrics, etc.).

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3. Purposes of Processing

The data is used to:

• Provide access to programs and training,

• Manage account creation and authentication,

• Provide customer support,

• Issue invoices and process payments,

• Improve the user experience,

• Send information related to purchased services,

• Prevent abuse and fraudulent use,

• Comply with our legal and accounting obligations,

No processing is carried out for purposes incompatible with the above purposes.

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4. Applicable Legal Basis

Depending on the User's location:

4.1 For Users located outside the European Union

Processing is based on:

• The performance of the contract or agreement (provision of services),

• Legitimate interest (security, service improvement).

4.2 For Users located within the European Union (GDPR)

Data is processed in accordance with the GDPR (EU 2016/679), the legal bases for which are:

• Article 6(1)(b): performance of the contract,

• Article 6(1)(c): legal obligations (accounting),

• Article 6(1)(f): legitimate interest (fraud prevention, security),

• Article 6(1)(a): consent for marketing communications.

5. Data Security and Responsibilities of External Providers

The Provider implements all reasonable security measures to protect User data, including through platforms secure.

Data may be stored, processed, or hosted via third-party tools such as, but not limited to:

• Stripe (payments),

• Google Workspace or equivalent (storage and documents),

• WhatsApp, Telegram, or Discord (communities),

• Wix (web hosting).

 

The User acknowledges that these providers have their own privacy and security policies.

The Provider cannot be held liable for:

• A breakdown, failure, interruption, or hacking originating from any of these external services,

• A data leak attributable to an external third party,

• A security breach affecting a tool or provider over which it has no control.

In the event of an incident affecting an external provider, the Provider will take reasonable steps to restore service but does not guarantee any timeframe.

These providers act as data processors and may not use the data for any other purpose. No data is:

• Sold,

• Exchanged,

• Shared with unauthorized third parties.

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6. International Data Transfer

Data may be hosted or transferred outside the European Union. For users located in the EU, where applicable:

• Appropriate safeguards are in place (SCC/technical measures),

• Transfer is limited to essential service providers.

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7. Data Retention Period

Data is retained only for as long as necessary:

• User account: as long as the account is active,

• Contractual and billing data: 7 years (legal obligations),

• Emails and correspondence: up to 3 years after the last contact,

• Immediate deletion upon valid request (excluding legal obligations).

Inactive accounts may be deleted after 24 months of inactivity.

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8. Data Security

The Provider implements reasonable measures to protect data against:

• Unauthorized access,

• Loss,

• Alteration,

• Unwanted disclosure.

Since no method is completely secure, the User acknowledges transmitting their data at their own risk.

9. User Rights

In accordance with the GDPR for users located in the EU, the User has the following rights:

• Right of access,

• Right to rectification,

• Right to erasure,

• Right to restriction of processing,

• Right to object,

• Right to data portability,

• Right to withdraw consent to any moment.

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10. Cookies and Trackers

The Provider uses cookies and trackers on its platform and in the member area to ensure the proper functioning of the service, improve the user experience, and compile browsing statistics.

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10.1 Types of Cookies Used

Strictly necessary cookies are essential for the operation of the website and the member area. They enable, in particular:

• User authentication,

• Session management,

• Securing connections,

• Access to protected content.

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They cannot be disabled because without them, access to the service would be impossible.

Functional cookies improve user experience (language preferences, device memory, etc.).

Analytical and performance cookies measure audience, analyze browsing, and improve the platform (via Google Analytics or equivalent).

Marketing cookies, if used, allow us to display personalized content or relevant advertisements based on user activity.

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10.2 Managing and Disabling Cookies

Users can, at any time:

• Accept all cookies,

• Reject non-essential cookies,

• Configure their browser to block certain trackers.

However, disabling necessary cookies may make access to the service impossible or severely degraded.

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10.3 Consent

Upon their first login, users are informed about the use of cookies.
Continuing to browse constitutes acceptance of non-essential cookies, unless otherwise configured.

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10.4 Maintenance and Liability

The Provider cannot be held liable for:

• Temporary interruptions related to maintenance or updates,

• Slowdowns or malfunctions attributable to external service providers (hosting providers, servers, internet service providers),

The Provider shall not be liable for any data loss resulting from technical intervention, except in cases of proven negligence on the part of the Provider.

11. External Links

The website may contain links to third-party platforms or websites.

The Provider is not responsible for their privacy policies and encourages Users to review them separately.

12. Changes to this Policy

The Provider may modify this Policy at any time.
The applicable version is the one in effect on the date of consultation.

In the event of a major change, the User will be notified by email or via the platform.

13. Contact

For any questions or to exercise your rights:

• LOOPING APP FZCO – Phenix Blanc

• Email: contact@phenixblanc.com

• DSO-IFZA, DSO-IFZA Properties, Dubai Silicon Oasis, Dubai, United Arab Emirates.

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Proof of identity may be requested.