Data protection :
We take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the legal provisions on data protection as well as this Privacy Policy.
This Privacy Policy applies to the processing of personal data that we carry out on our website as well as when using our applications. They are intended to explain the nature, purpose and extent of data processing in the context of our applications.
We draw your attention to the fact that data transmission over the Internet may have security gaps. It is not possible to guarantee infallible data protection against access by third parties.
Data controller :
"Controller" is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
The Data Controller for the provision of the website and applications is :
Virtual-Concept.NET
80b, allée des Saphirs
97400 Saint-Denis de La Réunion (France)
Website :
http://www.virtual-concept.net
General information on data processing :
Scope of personal data processing > The collection and use of our users' personal data regularly takes place upon explicit action by the user only ("Contact Us" page of the website). The data collected within the framework of the mobile applications are only kept on the user's device, and this within the framework of the use of the mobile application.
Legal basis for the processing of personal data > If we obtain the consent of data subjects for processing personal data, Art. 6, para. 1 letter a of the EU General Data Protection Regulation (GDPR) serves as the legal basis for the processing of personal data.
In the event of the processing of personal data necessary for the performance of a contract of which one of the parties to the contract is the data subject, Art. 6, para. 1, letter b of the GDPR serves as the legal basis. The same applies in the case of processing processes necessary to carry out pre-contractual measures.
If the processing of personal data is necessary to fulfill a legal obligation to which our company is subject, Art. 6, para. 1, letter c of the GDPR serves as the legal basis.
In the event that vital interests of the data subject or another natural person make it necessary to process personal data, Art. 6, para. 1, letter d of the GDPR serves as the legal basis.
If processing is necessary to pursue a legitimate interest of our company or a third party and if the interests and fundamental rights and freedoms of the data subject do not outweigh our legitimate interest, Art. 6, para. 1, letter f of the GDPR serves as the legal basis for the processing.
Erasure of data and duration of storage > The personal data of the data subject are deleted or blocked as soon as the purpose for their storage no longer applies. Storage may also take place if the European or national legislator has provided for it in regulations, laws or other legal Community provisions to which the controller is subject. A blocking or deletion of the data also takes place when a storage period imposed by the aforementioned standards expires, unless it is necessary to continue storing the data for the conclusion or fulfillment of a contract.
Contact and data processing policy :
You can contact us through our contact form on our website or by mail. When you contact us, the data from your inquiry, including the contact details you provided there, are stored with us exclusively for the purpose of processing the inquiry and in the event of follow-up questions. No data is transmitted to third parties in this context.
The legal basis for data processing is Art. 6, para. 1, letter f of the GDPR. Our interest in responding to your request prevails over yours; since you are writing to us, it is also in your interest to obtain a response and you are aware that we have to process your data to respond to your request.
If the purpose of contacting by e-mail is to conclude a contract, the legal basis for the processing is Art. 6, para. 1, letter b GDPR.
The data is erased as soon as it is no longer necessary to achieve the purpose for which it was collected. This is the case when the conversation with the user is over. The conversation is over when it appears from the circumstances that the facts concerned have been definitively clarified.
Links to social networks :
We maintain online presences on social networks and platforms in order to communicate with customers, interested persons and users who are active on these networks and to be able to inform customers, interested persons and users about our services.
If you access the aforementioned platforms or networks, the terms and conditions and privacy policies of the company operating such networks or platforms apply. Unless otherwise provided in our privacy policy, we process user data when they communicate with us through social networks or platforms, for example when they send us messages.
Mobile apps :
Personal data is processed when using our mobile applications. In addition to the processing processes already described above for mobile applications, below we explain the other features and services used for this purpose.
Platform services and hosting > Our mobile applications are offered for free or for purchase through Google's platforms, the Google Play Store. The data necessary for the provision are processed by the respective platform operators as controllers within the scope of data protection law. Their terms of use and privacy policies apply.
The Google Play Store Privacy Policy is available at :
https://policies.google.com/privacy.
Payments > We offer to make payments for purchases made online in the Apps through the Platforms' payment service providers. These service providers process billing data such as card data, payment information, payment addresses and other information required by law as controllers. No provider gives us access to sensitive information such as your full credit card number or your account number. We only receive the payment confirmation with the attribution to the user (order ID), country, payment amount and product as well as the date of payment execution.
We have a legitimate interest in cooperating with payment service providers and referring you to them as part of the payment process, as they enable us to facilitate payment processing and make our services accessible to a wider audience using such payment services, but also because they facilitate the payment process for you as a user of such a payment service provider. The legal basis for passing on to such payment service providers is our legitimate interest pursuant to Art. 6, para. 1, letter f of the GDPR.
The data that we process for the confirmation of payments are deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. This is the case as soon as the verification of the corresponding payment process is completed and it has been verified that the corresponding payment has been made lawfully. The legal basis for this processing is Art. 6, para. 1, letter b GDPR.
If, in the context of a payment, we are obliged to retain or store data due to provisions of tax, commercial or other law, their deletion will only take place after expiry of the retention period or corresponding registration (see III. point 2). The legal basis for this registration is Art. 6, para. 1, letter c of the GDPR.
Payment in Google Play: When paying in Google Play, we transmit your payment data as part of the payment process to Google Ireland Ltd. (hereinafter “Google”). All the data necessary for the payment process are transmitted securely using the “SSL” procedure. If you use Google for Payments, you agree to Google's Terms of Service. Further information on data protection law can be found in the Google Privacy Policy at :
https://policies.google.com/privacy.
Since payment service providers, as well as suppliers and providers of so-called payment processing portals, have their own data protection provisions with regard to data and information which we have to make available for processing, we recommend that you take note of the data protection information of the respective service provider or supplier.
User Support Request > Vous pouvez nous envoyer des requêtes d’assistance par l'intermédiaire de notre formulaire de contact. Lorsque vous nous contactez, les données issues de votre requête d’assistance, y compris les coordonnées que vous y avez indiquées, sont enregistrées chez nous exclusivement dans le but de traiter la requête d’assistance et en cas de question de suivi. Aucune donnée n’est transmise à des tiers dans ce cadre.
The legal basis for data processing is Art. 6, para. 1, letter f of the GDPR. Our interest in responding to your request prevails over yours; since you are writing to us, it is also in your interest to obtain a response and you are aware that we have to process your data to respond to your request.
If the purpose of contacting by e-mail is to conclude a contract, the legal basis for the processing is Art. 6, para. 1, letter b GDPR.
The data is erased as soon as it is no longer necessary to achieve the purpose for which it was collected. This is the case when the conversation with the user is over. The conversation is over when it appears from the circumstances that the facts concerned have been definitively clarified.
External links > Our mobile applications may contain links to external websites or third party services. We have no influence on their content, the data protection they operate and the security standards applied on these sites. Therefore, we invite you to consult the websites or services of the relevant providers to find out about the data protection provisions therein.
The linked pages were checked at the time of linking for possible legal infringements. At the time of their linking, no illegal content could be identified. If we become aware of a violation of rights, we will immediately remove the corresponding links.
These external links are provided solely for the convenience of the proper functioning of the application and it is not absolutely necessary to visit the corresponding websites or services in order to complete the use of the applications.
Rights :
If personal data relating to you is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:
Permission to access > You can ask the controller to give you confirmation that personal data concerning you is being processed by us.
If such processing does take place, you can require the controller to access the following information :
(1) the purposes for which the personal data is processed;
(2) the categories of personal data processed;
(3) the recipients or categories of recipients to whom the personal data concerning you have been disclosed or are still being disclosed;
(4) the planned storage period for the personal data concerning you or, if no concrete information is available on this subject, the criteria for determining the storage period;
(5) the existence of a right to rectify or erase personal data concerning you, a right to limit processing by the controller or a right to oppose this processing;
(6) the existence of a right of complaint to a supervisory authority;
(7) all available information on the origin of the data, when the personal data was not collected from the data subject;
(8) the existence of automated decision-making including profiling in accordance with Art. 22, para. 1 and 4 GDPR and – at least in these cases – relevant information on the logic involved as well as the scope and intended effects of such processing for the data subject.
You are entitled to know whether the personal data concerning you have been transmitted to a third country or to an international organization. In this context, you can demand to be informed about the appropriate guarantees taken in accordance with Art. 46 GDPR in the context of transmission.
Right of rectification > You have a right of rectification and/or completion vis-à-vis the controller insofar as the personal data processed concerning you is inaccurate or incomplete. The controller must immediately make the rectification.
Right to restriction of processing > You can request the restriction of the processing of personal data concerning you under the following conditions :
(1) when you dispute the accuracy of the personal data concerning you for a period, allowing the controller to verify the accuracy of the personal data;
(2) when the processing is unlawful and you refuse the erasure of the personal data and request instead a restriction of the use of the personal data;
(3) when the controller no longer needs the personal data for the purposes of the processing, but still needs them for the assertion, exercise or defense of legal claims, or
(4) when you have objected to the processing pursuant to Art. 21, para. 1 GDPR and it has not yet been determined whether the legitimate interests of the controller override your interests.
If the processing of personal data concerning you is restricted, these data may only be processed – with the exception of their storage – with your consent or to establish, exercise or defend legal claims or to protect the rights of another natural or legal person or for a reason of important public interest of the European Union or of a Member State.
If the restriction of processing has been restricted in accordance with the aforementioned conditions, the controller will inform you before lifting the restriction.
Right to erasure > You can demand from the controller that personal data relating to you be erased immediately and the controller will be obliged to erase such data immediately insofar as one of the following grounds applies:
(a) The personal data concerning you are no longer necessary to achieve the purposes for which they were collected or otherwise processed.
(b) You have revoked your consent on which the processing was based pursuant to Art. 6, para. 1 letter a or art. 9, para. 2 letter a GDPR and there is no other legal basis for the processing.
(c) You object to the processing pursuant to Art. 21, para. 1 GDPR and there is no overriding legitimate interest in the processing or you object to the processing pursuant to Art. 21, para. 2 GDPR.
(d) The personal data concerning you have been processed unlawfully.
(e) The erasure of personal data concerning you is necessary to fulfill a legal obligation under Community law or the law of the Member States to which the controller is subject.
(f) The personal data concerning you was collected in connection with information society services in accordance with Art. 8, para. 1 GDPR.
If the controller has made the personal data concerning you public and if he is, in accordance with Art. 17, para. 1 of the GDPR, required to erase them, he must take appropriate measures, including technical ones, taking into account the technologies available and the costs of implementation, to inform the persons responsible for processing personal data of the fact that you as a data subject have requested the erasure of all links to such personal data or copies and duplicates of such personal data.
The right to erasure cannot be exercised if the processing is necessary
(a) the exercise of the right to freedom of expression and information;
(b) for the satisfaction of a legal obligation imposing processing under Community law or of the Member States to which the controller is subject or for the performance of a task in the public interest or relating to the exercise of authority public authority vested in the controller;
(c) for reasons of public interest in the field of public health pursuant to Art. 9, para. 2, letters h and i as well as in accordance with art. 9, para. 3 GDPR;
(d) for archival purposes in the public interest, for scientific or historical research purposes or for statistical purposes in accordance with Art. 89, para. 1 of the GDPR, insofar as the right referred to in point a) is likely to render impossible or seriously impair the achievement of the objectives of this processing, or
(e) to establish, exercise or defend legal claims.
Right to information > If you have asserted your right to rectification, erasure or restriction of processing vis-à-vis the controller, the latter is obliged to communicate this rectification or erasure of data or restriction of processing to all recipients to whom the personal data concerning you have been disclosed, unless this proves impossible or involves a disproportionate effort.
You have the right to obtain from the controller information about the recipients of your personal data.
Right to data portability > You have the right to obtain the personal data concerning you which you have made available to the controller in a structured, common and machine-readable format. On the other hand, you have the right to have this data transmitted to another controller, without the controller to whom the personal data has been communicated being able to prevent this, insofar as
(1) the processing is based on consent in accordance with Art. 6, para. 1 letter a GDPR or Art. 9, para. 2 letter a GDPR or on a contract pursuant to Art. 6, para. 1, letter b GDPR and
(2) the processing was carried out by means of an automated procedure.
By exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically possible. In doing so, the rights and freedoms of other persons must not be infringed.
The right to data portability does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority vested in the controller.
Right of opposition > You have the right to object at any time, for reasons relating to your particular situation, to the processing of personal data concerning you based on Art. 6, para. 1 letter e or f GDPR; the same applies in the event of profiling based on these provisions.
The controller no longer processes the personal data concerning you, unless he can demonstrate that there are compelling legitimate grounds for the processing which override your interests, rights and freedoms, or that the processing serves to establish, exercise or defend legal rights.
If personal data concerning you is processed for direct advertising purposes, you have the right to object at any time to the processing of personal data concerning you for such advertising purposes; the same applies in the case of profiling insofar as it is related to such direct advertising.
If you object to the processing for direct advertising purposes, the personal data concerning you will no longer be used for these purposes.
In the context of the use of information society services, you have the possibility, notwithstanding Directive 2002/58/EC, to exercise your right of opposition by means of automated procedures involving technical specifications.
Right to revoke a data protection declaration of consent > You have the right to revoke your data protection declaration of consent at any time. The revocation of your consent does not affect the lawfulness of the processing already carried out under your consent until its revocation.
Automated decision-making on a case-by-case basis, including profiling > You have the right not to be subject to a decision based solely on automated processing, including profiling, producing legal effects concerning you or significantly impacting you in a similar way.
This does not apply when the decision
(1) is necessary for entering into or performance of a contract between you and the controller,
(2) is authorized by the legal provisions of the European Union or of the Member States to which the controller is subject and when these legal provisions contain appropriate measures to safeguard your rights and freedoms as well as your legitimate interests or
(3) is made with your explicit consent.
However, these decisions must not be based on special categories of personal data pursuant to Art. 9, para. 1 GDPR, insofar as Art. 9, para. 2, letter a or g is applicable and where appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests.
With regard to the cases referred to in points (1) and (3), the controller shall take appropriate measures to safeguard the rights and freedoms as well as your legitimate interests, which includes at least the right to obtain the intervention of a person representing the controller, to express his personal point of view and contest the decision.
Right of complaint to a supervisory authority > Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your place of residence, your place of work or the place of alleged breach, if you believe that the processing of personal data concerning you infringes the GDPR.
The supervisory authority with which the complaint has been lodged will inform the claimant of the progress and results of the complaint, including the possibility of a legal remedy in accordance with Art. 78 GDPR.
March 2022
