This page is a translation provided for information purposes only. In the event of any discrepancy, the French version shall prevail.
This policy describes the processing of personal data carried out in connection with bridge-training.com, its subdomains, interfaces and associated applications (the “Site”). It supplements the Terms and Conditions of Use and, for paid services, the Terms and Conditions of Sale.
1. Data controller and data protection contact
Bridge for Good SAS
61 rue Youri Gagarine, Building B, 7th floor, apartment 707, 94800 Villejuif, France
Créteil Trade and Companies Register (RCS) 929 281 012 — SIRET 929 281 012 00021
Email: contact@bridge-training.com — Telephone: +33 (0)9 53 57 10 37
Data protection contact: Jean-Pierre DESMOULINS — contact@bridge-training.com
Contact by email should be preferred.
2. Bridge for Good’s role according to the processing activity
Bridge for Good acts as data controller for the data required to manage the Site, Accounts, subscriptions, billing, security, support, usage measurement and, where applicable, advertising and trackers.
Where a teacher, club, federation, company or other Account Holder enters data relating to its students, players, members, employees or contacts in order to use the Site’s features, that Account Holder will in principle determine the purposes of the processing and act as data controller. Bridge for Good will then process that data on its behalf as a data processor, within the scope of the requested service. The corresponding obligations are set out in the GDPR appendix to the Terms of Sale.
Bridge for Good may also process certain data as controller where justified by a legal obligation, Site security, prevention of abuse or the defence of its rights. Statistics that have been irreversibly anonymised are no longer personal data.
3. Data that may be processed
- Account data: surname, first name, email address, language preferences and information required to manage the Account.
- Billing and subscription data: identity or company name, billing address and country, VAT number where applicable, Offer subscribed to, due dates, invoices, payment references and payment status.
- Connection and security data: IP address, access logs, technical identifiers, browser, device, timestamps and security events.
- Usage and educational data: content created or viewed, deals played, relevant URLs, dates and frequency of use, attempts, results, stars, errors, playing time and other indicators made available by the features used.
- Data entered by Account Holders about third parties: in particular surname, first name, email address, telephone number, group or class, assigned content and progress data where such information is voluntarily recorded in the service.
- Content and files: deals, collections, texts, comments, visuals, imported files, settings and other items supplied to the Site.
- Communications with Bridge for Good: support requests, complaints and correspondence.
- Cookies and trackers: identifiers and information associated with technical, audience measurement or advertising cookies, according to the choices expressed through the consent management platform (CMP).
- Payment data: card or bank account data required for payment is processed directly by Stripe or the payment provider used; Bridge for Good does not intend to retain full payment-card numbers.
The Site is not designed to receive special categories of personal data under Article 9 GDPR (for example health data, political opinions, religion or biometric data), or data relating to criminal convictions and offences. Users are asked not to enter such data unless a feature expressly provides for it and specific safeguards have been put in place.
4. Purposes and lawful bases
Where processing is based on legitimate interests, the interests pursued are primarily the security and integrity of the service, improvement of the service, prevention of abuse and defence of Bridge for Good’s rights, subject to the rights and freedoms of the persons concerned.
5. Mandatory or optional nature of data
Fields marked as mandatory are required to create an Account, subscribe to a service or provide the relevant feature. Failure to provide them may prevent Account creation, payment or use of the requested service. Other information is optional unless a specific legal obligation applies.
6. Data relating to students, players or other third parties
An Account Holder who enters data relating to third parties remains responsible for the lawfulness of its collection, determining the lawful basis, data minimisation and informing the persons concerned where required by law. Where minors are concerned, the Account Holder is in particular responsible for complying with the information, authorisation or representation requirements applicable in its circumstances.
For data processed on behalf of the Client, Bridge for Good does not use the data for purposes incompatible with the service. Requests to exercise data protection rights should in principle be addressed to the controller that entered the data; Bridge for Good assists that controller in accordance with the GDPR appendix to the Terms of Sale.
7. Recipients and service providers
Data is accessible only to authorised persons at Bridge for Good and to service providers required for operation of the service, within the scope of their respective tasks. Depending on the features used, these may include hosting and infrastructure providers, payment providers, messaging providers, support providers, audience measurement services, consent-management services and advertising providers.
Services currently used include, in particular, OVH for hosting, Stripe for payments, Matomo for audience measurement and, for advertising, Ezoic and/or the relevant Google services. The current list of tracker partners is shown in the CMP and may change as the Site’s features evolve.
Depending on the processing activity, Stripe may act as Bridge for Good’s processor or as an independent controller, in particular for certain obligations specific to the payments sector, fraud prevention and regulatory compliance.
Data may also be disclosed to authorities, courts, advisers or authorised professionals where required by law or where necessary to defend Bridge for Good’s rights. Bridge for Good does not sell its users’ personal data.
8. Transfers outside the European Economic Area
Some service providers may process data from countries outside the European Economic Area. Where a transfer is subject to the GDPR, it is based on a mechanism recognised by applicable law, such as an adequacy decision, Standard Contractual Clauses approved by the European Commission, or another appropriate safeguard. Further information on the applicable safeguards may be requested at contact@bridge-training.com.
9. Retention periods
- Account data and data required for the service: for as long as the Account is in use; after closure or inactivity, data required to manage a potential dispute may be placed in restricted archives for the applicable limitation period and then deleted or anonymised.
- Billing data, invoices and accounting records: ten years from the end of the relevant financial year, in accordance with applicable accounting obligations.
- Payment data: Bridge for Good retains the references and statuses required to manage the transaction; full banking details are retained by the payment provider in accordance with its own obligations.
- Technical and security logs: in principle for up to twelve months, unless a longer period is required in connection with an incident, fraud, a legal obligation or litigation.
- Support communications and complaints: for the time required to handle them and then, where necessary, in restricted archives for as long as useful to establish or evidence rights and obligations.
- Data processed on behalf of a Client: for as long as necessary to provide the service and in accordance with the Client’s instructions, the export and retention mechanisms provided by the Site and the GDPR appendix to the Terms of Sale.
- Cookies and trackers: for the period applicable to each tracker as stated in the CMP; consent or refusal choices are retained for an appropriate period and may be changed at any time.
Data may be retained for longer where required by a legal obligation, a request from an authority, or the establishment, exercise or defence of legal claims. Data that has been irreversibly anonymised may be retained without any GDPR-related time limit.
10. Cookies and trackers
Cookies strictly necessary for operation of the Site may be placed without consent where permitted by law. Trackers requiring consent are placed only after the user has made a choice in the CMP. It must be as easy for the user to accept as to refuse, and the user must be able to change their choice at any time through the cookie-management tool available on the Site.
The CMP provides the current list of partners, purposes and retention periods associated with the relevant trackers. If there is any discrepancy concerning the technical list of trackers actually active, the information displayed in the CMP at the time the user makes their choice shall prevail for that operational list.
11. Security
Bridge for Good implements technical and organisational measures proportionate to the risks, including access controls, secure communications, permission management, backups, logging and security maintenance. As no information system can guarantee absolute security, these measures are intended reasonably to reduce the risks of unauthorised access, alteration, loss or disclosure.
12. Rights of individuals
Depending on the processing activity and its lawful basis, any person concerned may exercise rights of access, rectification, erasure, restriction, objection and, where the relevant conditions are met, data portability. Where processing is based on consent, consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.
Requests may be sent to the data protection contact at contact@bridge-training.com. Bridge for Good may request such information as is reasonably necessary to verify the requester’s identity and prevent disclosure of data to an unauthorised third party.
Where a request concerns data processed exclusively on behalf of a teacher, club, federation or other Client, Bridge for Good may forward the request to that controller or invite the person to contact the controller directly.
Any person also has the right to lodge a complaint with the French Data Protection Authority (Commission nationale de l’informatique et des libertés — CNIL), www.cnil.fr.
13. Automated decision-making and future AI features
As at the date of this policy, Bridge for Good does not use the data covered by this policy to make decisions based solely on automated processing that produce legal effects concerning a person or similarly significantly affect them. If future features, including artificial intelligence features, involve new processing requiring additional information to be provided, that information will be supplied at the appropriate time, in particular when the feature is activated.
14. Changes to this policy
Bridge for Good may update this policy to reflect changes to the Site, processing activities, service providers or applicable law. Material changes will be brought to the attention of the persons concerned by an appropriate means. The version published on the Site states its date of update.