DEFINITIONS

Capitalized terms refer to the following definitions:

"Digital programm" or "we" refers to the company EXCELLENCE EDITIONS, headquartered at 66 avenue des Champs-Élysées 75008 Paris, France, registered with the Registre du Commerce et des Sociétés under number 894 278 910, whose VAT number is FR72894278910.

The "Site" refers to the Internet site(s) accessible via the URL link

www.attraction-seduction.com and any sub-sites providing access to a content consultation area, an area reserved for customers, etc., which are provided by the Company.

"You" refers to the persons concerned by the Processing carried out on the Site (users, prospects, customers, etc.).

The "Policy" refers to this privacy policy.

Data" means any information about an identified or identifiable natural person (the "data subject"), directly or indirectly, in particular by reference to an identifier (name, identification number, location data, online identifier, etc.) or to one or more elements specific to his or her identity.

Processing" refers to any operation applied to Data (collection, recording, organization, storage, adaptation, communication by transmission, dissemination, deletion, etc.).

A "controller" is the person who, alone or jointly with others, determines the purposes and means of processing, and a "processor" is the person who processes Data on behalf of the controller. On the Site, unless otherwise stated, we are responsible for processing Data.

A "recipient" is the natural or legal person, public authority, department or any other body that receives communication of personal data, whether or not it is a third party.

The "Regulations" means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (''RGPD''); Law No. 78-17 of 6 January 1978 relating to information technology, files and freedoms; the rules applicable to commercial prospecting set out in the French Post and Telecommunications Code, and more generally the laws and regulations applicable to the Data Processing we carry out...

SHOWCASE SITE AND COMMERCIAL PROSPECTING

The Site presents our Company's activities and various forms (contact, newsletter subscription, etc.). By completing the forms and communicating with us via the Site, you transmit the following categories of information to us:

- Identity data: title/gender; surname; first name; and optionally, we may ask for your date of birth in order to propose birthday offers;

- Contact and correspondence data: e-mail address; postal address (address, zip code, town); telephone number; in the event of a customer service request, the nature and content of your request.

- Opinions and contributions: pseudonym, date of the opinion, content of the opinion, product or service concerned, profile photo attached to the opinion, if applicable; The Company may enrich its Site by collecting and republishing opinions and contributions expressed by its customers on other sites (in particular social networks) when these contributions are freely accessible to the public;

- Data required to carry out loyalty-building, prospecting, research, surveys, product testing and promotional activities;

- Data relating to the organization and processing of contests, lotteries and any promotional operation;

- Data collected through actions to exercise rights enshrined in the Regulations.

In accordance with our legitimate interests, and where necessary for the performance of pre-contractual measures taken at your request or of a contract, we process the above-mentioned Data for the following purposes:

- Presentation of the Company's products and services;

Management, processing and follow-up of requests and exchanges with the Company, via the Site (if necessary by offering you a chatbot, a call reservation tool, etc.);

- Management of relations with prospective customers;

- Management of people's opinions on the Company's products, services or content;

- Prospecting and/or sending of information, management of technical prospecting operations, selection of persons for loyalty actions,

Prospecting, surveys, product testing;

- Organization of contests, lotteries or any promotional operation on the Site.

Data used to manage commercial prospecting is kept for a maximum of three years from the date of the last active contact from the prospect or customer, and earlier if you withdraw your consent to receive messages from us. Notice and contribution data is kept for the duration of public access to the notice on the Site.

In accordance with our legal obligations, identity and contact data will also be processed for the following purposes:

Updating of its canvassing files by the organization in charge of managing the opposition list to telephone canvassing, in application of the provisions of the French Consumer Code.

Management of requests for access, rectification and opposition rights, and more generally of the rights described in the Policy.

ONLINE SALES

The Site allows you to make purchases, which leads us to Process the following Data:

- Identity and contact data

- Data relating to the contractual and commercial relationship: Details of order content; Pre-contractual and order-related exchanges (purpose, date...); Communications with the Company.

- Payment and transactional data: transaction date, amount, payment method, order number, billing data;

This information is necessary for the management of our customer-prospects file, and more specifically for the following purposes in accordance with our General Terms and Conditions accepted at the time of ordering on the Site and with our legal obligations:

- To carry out operations relating to the management of files concerning: contracts, including registrations; orders; delivery of the product or service; legal and commercial guarantees; invoices; accounting and follow-up of the commercial relationship (after-sales service), including opinions on the Company's offers;

- Preventing and combating fraud and payment fraud, in particular credit card fraud;

- Management of unpaid invoices and disputes, on condition that they do not concern offences and/or that they do not lead to the exclusion of a person from the benefit of a right, a service or a contract.

-Secure payment. All transactions carried out on our Site are secure. Credit card payments are handled by our payment service providers ("PSP"), as indicated in our general terms and conditions or on the order page for our products and services.

We use an SSL encryption system to protect your personal data and the means of payment used. At no time do we have direct access to your bank details through this process.

Retention periods. The personal data we process is kept for the periods shown in the table below.

CREATING AN ACCOUNT

Creating an account is optional in order to place an order on the Site.

On the Site, you may create an account, in which case the following information will be processed:

- Identity and contact data

- Account connection data: username, password; which may be automatically saved on the Site only if you give your consent via your browser settings;

- Account access and use data: IP address, connection time, connection duration, account settings, use of any account features.

Processing will be carried out for the purposes of managing authentication procedures, procedures for the loss of identifiers or passwords and for the needs of order execution in accordance with the purposes set out for online sales.

The identity and contact data entered when creating an account will be used with your consent to inform you about the Company's products and services.

The Company may provide tools for creating a profile by adding optional information to your account (identity, social networks, age, profile photo, profession, etc.).

SUPPLY OF DIGITAL CONTENT

The legal basis for Processing for the purpose of supplying digital content is contractual and, in the absence of any provision in the GTC, corresponds to our legitimate interest. For this purpose, we may process the following Data:

- Identity and contact data

- Content access data: Username and password, which may be automatically recorded on the Site only if you give your consent via your browser settings, and information about your connection to the access area (IP address, connection time, duration of connection, use of any tools available from this dedicated area, etc.).

- Content-related data: content consultation and tracking data: module consultation data, time spent on content; information concerning audio files downloaded and/or listened to.

- Tracking data: Progress indicators, statistics and progress tracking; any grades, surveys and quizzes taken, past evaluations.

- Publication data: Content of the publication of your contribution (comments, questions, publications, opinions...) date, time, response rate, information on the publication space concerned.

The Site from which content is accessible may include technical devices that enable Site use to be tracked (user account connected, IP address, type of application used, various logs of connection and use of the User account, etc.).

Data from these devices may be used in the fight against counterfeiting, and/or to identify and/or prevent any illicit or non-compliant use of the Site and/or violation of the applicable GTC.

SOCIAL NETWORKS AND THIRD-PARTY SITES

Exchanges on social networks. We may contact you or answer your questions via social networks, if you have first contacted us in this way. You are informed that the use of social networks entails the processing of personal data by the providers of these networks (see their privacy policy).

Public information. The information about you that you have transmitted to us may be enriched for commercial, prospecting, communication, solicitation or marketing purposes, by means of other sources of information such as social networks. This includes so-called "public" information, or information to which we may have access as administrator of a page or group. The legal basis for this processing is our legitimate interest as a commercial company.

Interconnection. In the event that your member area may connect to another service (e.g. a social network) for cross-mailing purposes, the third-party service may provide us with information that you have authorized to be disclosed. You are informed that publishers of third-party services may also collect information concerning your consultation and/or use of the Site, in accordance with their own personal data processing policies.

More information about registering on the Site using a third-party account, for :

Facebook: https://www.facebook.com/help/223184117694507 ; https://developers.facebook.com/docs/facebook-login/overview

Google: https://support.google.com/accounts/answer/112802?co=GENIE.Platform%3DDesktop&hl=fr

EXERCISING YOUR RIGHTS

To exercise any of the above rights, or for further information, please contact the Company at: contact@seduction-attraction.com or by post at the Company's registered office address shown at the top of this page.

In accordance with regulations, you have the following rights with regard to your Data:

- Right of access to your Data, including the right to request a copy, and to the information provided in this privacy policy (art. 15 RGPD). Where the legal basis for data processing is our legitimate interest, you have the right to request information relating to the balancing we have carried out between the interests of our customers those of the Company prior to such processing.

- Right to rectification (art. 16 RGPD) and updating of your data held by us.

- Right to erasure of your Data (art. 17 RGPD) when the data is no longer necessary for us, you have withdrawn your consent to its Processing (if it was based on our consent) or you object to Processing based on our legitimate interest or Processing carried out for canvassing purposes or for profiling purposes related to canvassing.

- Right to withdraw your consent at any time (art. 13-2c RGPD) for all data processing based on the legal basis of your consent. Furthermore, with regard to commercial prospecting, you have the option of unsubscribing from our mailing lists at any time by clicking on the unsubscribe link present in our communications or by contacting us to stop receiving solicitation messages.

- Right to the limitation of Processing, which, unless there is a compelling reason, can no longer be implemented without your consent (art.18 RGPD) when:

You dispute the accuracy of the data, for the time necessary to verify it,

If the data processing is unlawful but you object to the deletion of the data and opt instead for the limitation of processing,

If we no longer need the data but it is still necessary for the establishment, exercise or defense of your legal rights.

When you have objected to processing based on our legitimate interest, for the time necessary to balance our respective interests.

- Right to portability of Data directly provided by the data subject where they are subject to automated processing based on your consent or on a contract (art. 20 RGPD). This right means that you have the possibility of requesting the communication of this Data in a structured, commonly used and machine-readable format so that it can be communicated to another data controller.

- Right to object (art. 21 RGPD) to the Processing of your Data where such Processing has as its legal basis our legitimate interest.

- Right to define the fate of your Data after your death (art. 40-1 of Law 78-17 of January 6, 1978) and to possibly choose a trusted third party to whom the Company should entrust them.

You can also obtain more information on the CNIL website: https://www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles

In the event of a request, the Company reserves the right to ask you to specify your request and to provide proof of identity (which will be kept for one year in the event of exercising the right of access or rectification, and for three years in the event of exercising the right of opposition). If you are not completely satisfied with our response, you can always lodge a complaint with the authority responsible for controlling and protecting your personal data (in France, the CNIL).

RETENTION PERIODS

Commitments. Means for the effective deletion of Data are put in place as soon as the retention or archiving period necessary for the fulfillment of the determined or imposed purposes is reached, in particular after deletion of your account with our Company or at the end of your contract with our Company.

Minimization. In any event, Data subject to Processing is not kept beyond the time required to fulfill the obligations defined when the contract was concluded, or imposed by current legislation. Beyond that time, it may be anonymized and stored for statistical purposes, in particular in aggregate form.

Litigation. Likewise, we may archive information demonstrating the performance of our contractual obligations until the expiry of the prescription/forclosure periods applicable to legal actions, in order to defend our interests before the courts in the event of subsequent litigation. This applies in particular, but not exclusively, to the periods stipulated in the French Commercial Code, the French Civil Code and the French Consumer Code.

TO

Obligations. We undertake to ensure that any data recipient presents sufficient and appropriate contractual guarantees to respect your rights, so that the processing meets the requirements of the RGPD where this regulation applies (particularly with regard to subcontracting). On the basis of our legal obligations, your Data may be disclosed in application of a law, regulation or by virtue of a decision by a competent regulatory or judicial authority.

The information you give us is for internal use by authorized persons, is strictly confidential and may not be disclosed to third parties, except under the conditions provided for by the Regulations in the event of express agreement or if you have decided to make it public.

Subcontracting. Our external service providers (e.g. suppliers, carriers, etc.) may, in the context of the processing described above, receive personal data when this is necessary for the performance of their mission.

Transfers outside the EU. We undertake to ensure compliance with applicable regulations relating to the transfer of data to countries outside the European Union, in particular in the following ways:

We will transfer the data of visitors, prospects and customers to countries recognized as offering an adequate level of protection;

When the country of destination does not offer an adequate level of protection, we use transfer tools that comply with regulations (notably the European Commission's standard contractual clauses).

Aggregation of non-personal data. We may publish, disclose and use aggregated information (information relating to site users, prospects, customers, etc.) which we combine in such a way that no natural person is individually identifiable.

This processing is carried out in accordance with our legitimate interest for statistical purposes, sector and market analysis, presentation of our activities, promotional and advertising purposes and other commercial purposes.

COMPUTER SECURITY

Commitments. We undertake to implement appropriate technical and organizational measures using physical and logistical security measures to limit the risks of accidental, unauthorized or illegal access, disclosure, alteration, loss or destruction of your personal data.

Warning. We invite you to be careful about what you decide to make public on the Internet. This applies in particular to personal data, including data relating to your private or sensitive life, made public at your initiative or deduced from your contributions, comments and statements of any kind whatsoever on the Site, or on social networks in groups and/or conversations with other users of the Site.

Https protocol. The URL address of the Site is accompanied by a closed padlock or a key appears in the bottom right-hand corner of your browser, indicating the existence of the Https security protocol, applicable to data storage in particular. This means that you are in a secure browsing zone, particularly when you are asked for your credit card number.

Data breach. In the event of an event leading to the realization of risks of modification, disappearance or unauthorized access to Data, we undertake to:

Examine the causes of the incident;

Take the necessary measures to limit the negative effects and damage that may result from the incident;

Notify the competent authority and/or the persons concerned of the incident as soon as possible if this is required by law.

Under no circumstances may the undertakings set out above be assimilated to any admission of fault or responsibility for the occurrence of the incident.

GENERAL

Mandatory or optional. On the Site, you are informed of the compulsory nature of the answers by the presence of an asterisk or any other type of mention. In the event of an incomplete request (e.g.: on-line registration or order, request for information, etc.), the Company reserves the right to request additional information or to prevent the form concerned from being validated by any technical means.

Hypertext links. The Site may provide links to sites, applications and services other than its own, which may be operated by third-party companies. We are not responsible for the processing of personal data carried out by these third-party sites, or the sites linking to the Site, whose personal data protection policies the user is invited to consult for further information. The Policy applies solely to the Company's activities, and the Company shall not be held liable for any failure by a third party to comply with its obligations with regard to the protection of personal data.

Scope of application. The Policy is not exhaustive and we reserve the right to supplement it by any means.

Language. The Policy is written in French. In the event that it is translated into one or more languages, only the French text will be deemed authentic in the event of a dispute.

Non-waiver. The temporary or permanent non-application of one or more clauses of the present Policy shall not constitute a waiver of the other clauses of the present Policy, which shall continue to have full effect.

Modifications - Updates. We reserve the right to modify this privacy policy. The persons concerned will be notified when this is provided for by the applicable regulations. The date of update is indicated in the header and we invite you to consult it regularly.

INFORMATION ON COOKIES

Presentation: Cookies are connection cookies and, more generally, any file - deposited when a website or mobile application is consulted, or when software is installed or used on the user's terminal equipment - whose purpose is to read or write information on this equipment. Cookies enable us to collect Site consultation data (IP address, Internet service provider, hardware configuration, software configuration, browser type and language, etc.).

Cookies may be deposited by the Company or by third-party companies without your consent when they are strictly necessary for the operation of the site or to facilitate communication with the online public, for example when they are intended for authentication, to store the contents of a shopping cart, to generate traffic statistics, or to limit free access to a sample of content requested by users.

Duration: Cookies are kept for a maximum of 13 months after they are first deposited on your terminal, and this period is not extended with each visit.

Consent to cookies : With the exception of uses not subject to consent, cookies and tracers will only be deposited on your terminal with your express agreement. You may be asked periodically to reiterate your consent, to ensure that it is still valid.

Cookie settings : You always have the option of changing your preferences via your browser settings (Firefox with enhanced tracking protection; Firefox with cookie deletion; Chrome; Internet Explorer; Safari; Opera; Microsoft Edge). You can also configure your terminal's browser to activate the "Do Not Track" option, which indicates to websites, advertising agencies and applications that you do not wish to be "tracked". This feature is available for the following browsers in particular: Firefox; Chrome; Internet Explorer; Safari; Opera; Microsoft Edge.

If you refuse to accept cookies that are not essential to the Site's operation: Some Site functions, such as video players or interactive content, use services provided by third parties, and place cookies that enable them to identify your viewing of the content. If you refuse to accept these cookies, the personalization features will not function and the content offered to you (in particular suggested videos or advertisements) will still be present, but will not be linked to your centers of interest.

Types of cookies: In addition to cookies whose sole purpose is to enable or facilitate communication via our Site or cookies strictly necessary for the provision of the Site or Service to which you have subscribed, we use cookies and trackers for the following purposes:

Personalized advertising : The Company [and third-party companies] uses / use trackers in order to display personalized advertising based on your browsing and profile. These are the following third parties:

The Facebook pixel is an analysis tool that enables us to measure the effectiveness of our advertising by tracking the actions taken by Internet users on the Site (https://www.facebook.com/policies/cookies/).

The Google pixel is an analysis tool that enables us to measure the effectiveness of our advertising by tracking the actions taken by Internet users on the Site (https://policies.google.com/technologies/ads?hl=en-US).