Details of versioning and variations

v1 published on 03/05/2021


In the following, we present the Privacy Policy of the website


Privacy Policy


This Privacy Policy (“Policy”) describes and governs the information collection, use, and sharing practices of LightOn SAS, 2 rue de la Bourse, 75002, Paris, France, (also referred to as “LightOn” “we,” “us,” or “our”) and you or the entity you represent (“you” or “your”) with respect to the PAGnol Website (“Website”) accessible through the web address

This Agreement takes effect when you click on the “ACCEPT” button or checkbox presented with these terms or if earlier when you use the Website (the “Effective Date”). You represent to us that you are lawfully able to enter into contracts (e.g. you are not a minor).

Before you submit any information on or through this website, please carefully review this Policy to understand our views and practices regarding your information and how we will treat it.

Please note that this Policy applies only to information collected through this Website and not to information you may provide to any third-party sites to which the Website may link, except as expressly provided herein.

This Policy applies regardless of the device used to access the Website (e.g., personal computer, mobile device, consumer electronics device, or any other technology or software known today or developed in the future). Some online services offered by or affiliated with LightOn may be governed by a separate privacy policy. In those instances, the product-specific privacy policy shall apply to that online service.

For the purpose of data protection laws applicable from time to time to you in the location that you provide your information (“Applicable Law”), LightOn SAS will be a “data controller” (or such equivalent or replacement terminology as appropriate) for the information you provide through the Website.



We collect information in multiple ways, including when you provide information directly to us, and when we passively collect information from you, such as from your browser or device.


Information that is Passively or Automatically Collected

We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the Website. We may collect and analyze information such as (a) IP addresses, geolocation information, unique device identifiers, IMEI and TCP/IP address, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, the state or country from which you accessed the Website; and (b) information related to the ways in which you interact with the Website, such as: the input you provide in forms and text boxes, referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the Website, the amount of time spent on particular pages, the date and time you used the Website, the frequency of your use of the Website, error logs, and other similar information.


Information You Provide Directly to Us

We may collect information from you during your use of or access to the Website, such as when you:

  • Fill in forms;
  • Communicate with us by e-mail or otherwise;

You do not have a statutory or contractual obligation to provide us with your information; however, if you do not provide us with your information, we may not be able to provide you with the services you have requested or you may be limited in your use of our Website (e.g., if you do not provide us with your email address, we will not be able to communicate with you for either transactional or).



We may use your information for the following purposes:

  • To keep our Website safe and secure;
  • To use IP addresses to identify the location of users, to block disruptive use, to establish the number of visits from different countries and to determine the jurisdiction in which you are accessing the Website;
  • To administer and troubleshoot the Website;
  • To provide the features and services available through the Website;
  • For internal research and reporting;
  • To analyze and improve the content and features of the Website; and
  • To enforce the legal terms that govern your use of the Website;



LightOn SAS may disclose and/or share your information to or with any non-affiliated third parties under the following circumstances:

Consent: We may disclose your information to any third parties based on your consent to do so.

Protection of LightOn SAS and others: By using the Website, you acknowledge, consent and agree that we may access, preserve and disclose your information, including, but not limited to, any user content, if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to (a) comply with legal process; (b) enforce this Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of LightOn SAS, its agents and affiliates, and/or the public. This includes exchanging information with other companies and organisations for fraud protection, and spam/malware prevention, and similar purposes.

Business Transfers: As we continue to develop our business, we may buy, merge or partner with other companies. In such transactions, (including in contemplation of such transactions, e.g., due diligence) user information may be among the transferred assets. If a portion or all of LightOn assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets.



Our legal grounds for processing your personal data are as follows:

Legitimate Interests: In many cases, we handle personal data on the grounds that it furthers our legitimate interests in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:

  • Customer service
  • Marketing
  • Protecting our customers, personnel, and property
  • Analyzing and improving our business
  • Managing legal issues

Legal Compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.

Consent: Where required by law, and in some other cases, we handle personal data on the basis of consent. Where we handle your personal data on the basis of consent, you have the right to withdraw your consent at any time. Such withdrawal will not affect the lawfulness of processing performed before you withdraw your consent.



If you have provided contact information through the Website and decide that you do not want LightOn to use that information in accordance with this Policy, you can opt-out of future use at any time by contacting us as described below.

Individuals in the European Economic Area (“EEA”) and many other jurisdictions have certain legal rights to obtain confirmation of whether we hold personal data about them, to access personal data we hold about them, and to obtain its correction, update, amendment, or deletion in appropriate circumstances. You may also have rights to object to our handling of your personal data, restrict our processing of your personal data, and to withdraw any consent you have provided. You also have the right to give directives on the processing of your data after your death and to data portability, which allows you to obtain your personal data for your own purposes or to ask the transfer of your personal data to another organization. To exercise these rights, please contact us, as described below, with the nature of your request. Our security procedures mean that we may request proof of identity before we reveal information. This proof of identity will typically take the form of your e-mail address and any password submitted upon registration. While we strongly encourage you to first raise any questions or concerns about your personal data with us, you also have a right to contact the relevant supervisory authority.

Many of the rights described here are subject to significant limitations and exceptions under applicable law (e.g., objections to the processing of personal data, and withdrawals of consent, typically will not have retroactive effect).



We will keep your information only for as long as is reasonably necessary for the purpose that it has been processed, taking into account any legal requirements under Applicable Law. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Information may persist in copies made for backup and business continuity purposes for additional time.



We may transfer your information outside the European Economic Area (EEA) or to an international organisation in the unlikely event that we are required to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.



The Website may contain links to third-party websites, applications, and other services. Please be aware that we are not responsible for the privacy practices of such other sites and services. We encourage our users to be aware when they leave our Website and to read the privacy statements of each and every site they visit that collects their information. Some partners may use cookies to understand your use of the Website.

The Website may also include widgets and social media features, which are interactive mini-programs that provide specific services from another company (e.g., displaying the news, opinions, music, etc.). Information such as your email address may be collected through these features. These features may collect your IP address and set cookies to enable them to function properly. We are not responsible for nor do we endorse the privacy practices or the content of such third party services. Any information you provide via those services is subject to their applicable privacy policies and is not covered by this Policy.



The Website is not directed to children under the age of 15 and such children are not permitted to use the Website. If we discover we have received any “personal information” from a child under the age of 15 in violation of this Policy, we will take reasonable steps to delete that information as quickly as possible. If you believe we have any information from or about anyone under the age of 15, please contact us as described below.



We reserve the right to change this Policy at any time to reflect changes in the law, our data collection, and use practices, the features of our Website, or advances in technology. Please check this page periodically for changes. Your continued use of the Website following the posting of changes to this Policy will mean you accept those changes.



If you have any questions about our Policy, to exercise any of your rights, or for any other privacy-related inquiries, you can contact us through contact[at]