Privacy Policy

PRIVACY POLICY • PSITT
Version in effect as of February 4, 2026

Aware of the importance of protecting privacy and individual freedoms, EKD CONNEXION (hereinafter, « PSITT » or « We ») is committed to ensuring their protection in compliance with applicable law and, in particular, Regulation (EU) 2016/679 of April 27, 2016, as well as Law No. 78-17 of January 6, 1978 as amended (hereinafter, collectively referred to as the « Applicable Regulations »).

This document aims to inform you of the principles governing the way we process your personal data in the context of your use of our social platform (hereinafter, the « Service »), as well as the rights you have over your personal data.

Who is the controller of my personal data?

The data controller is EKD CONNEXION, a simplified joint-stock company registered with the Trade and Companies Registry of STRASBOURG under number 943 306 886, with its registered office at 25 Avenue de la Forêt-Noire, STRASBOURG (67000), France.

For any questions regarding the processing of your personal data, you may contact us:

By post, at the address: EKD CONNEXION (PSITT), 25 Avenue de la Forêt-Noire, 67000 STRASBOURG;
By email, at the address: info@psitt.eu.

What personal data does PSITT collect and process?

In accordance with the principle of «data minimisation», we strive to collect and use only the data that is relevant and strictly necessary in relation to the purposes of the processing.

In the context of your use of the Service, PSITT is notably led to collect and process the following information:

Identification and access data: username, last name and first name (only if this information appears in your pseudonym – optional), phone number…;
Profile data: photograph (optional), personal description (optional), interests (optional), list of friends on the Service…;
Location data: places where you voluntarily report your presence, places where you indicate you will be present in the future (date, location and time, where applicable), «verified position» status, history of your past presences, geolocation (only if you activate and use the Psitt Live feature)…;
Data from your interactions: messages, photographs, content published or shared with other users, profiles visited, as well as associated metadata (e.g. date and time of sending or viewing)…;
Data related to the purpose of your presence: option selected when you report your presence at a location (optional – for example, chat, network, meet, move together, discover)…;
Technical and connection data: device identifier, device type, operating system, application version, IP address, connection and activity logs…;
Moderation data: reports made or received, reasons for reporting, any attachments, measures and decisions taken by PSITT…;
Privacy settings: your preferences regarding the sharing of your position on the map, the display of your presence at a location, and the ability to be contacted by other users;
Data related to your Subscription (only if you have taken out a Subscription): plan subscribed to (monthly/annual), Subscription status (active/inactive), subscription, expiry and renewal dates, transaction or order identifiers, as well as associated information provided by the download platform used (for example, purchase confirmation and, where applicable, account holder identification information for the platform used, etc.)…

Depending on the information shared in the context of using the Service, PSITT may also be led to collect and process so-called «sensitive» data.

Why does PSITT need this personal data and on what legal bases does it process my data?

In the context of your use of the Service, we may process your personal data for the following purposes and on the basis of the following legal grounds:

Purposes	Legal bases
Enabling you to create and manage your user account	Performance of a contract (our Terms and Conditions of Use)
Enabling you to use our Service	Performance of a contract (our Terms and Conditions of Use)
Displaying information essential to your profile and the operation of the Service	Performance of a contract (our Terms and Conditions of Use)
Managing your interactions with other users, in particular through messaging	Performance of a contract (our Terms and Conditions of Use)
Sharing your position on the map, according to your visibility preferences	Your consent
Sharing your position with people at the same location, according to your visibility preferences	Your consent
Verifying your presence at a location («verified position» badge) Note: if you decide to verify your presence at a location, we may access your geolocation until you leave that location in order to update your status.	Your consent
Allowing other users to contact you	PSITT's legitimate interest in making it easy for users to communicate via the Service
Ensuring moderation of the Service and managing user reports	PSITT's legitimate interest in ensuring moderation of the Service and handling reports in order to enforce the rules of use of the Service and, thus, contribute to a safe and respectful environment for all
Preventing, detecting and addressing abusive, fraudulent or rule-violating behaviour	PSITT's legitimate interest in preventing, detecting and addressing abusive, fraudulent or rule-violating behaviour and, thus, ensuring the security of the Service and the protection of its users
Complying with legal obligations incumbent on PSITT, including those relating to the security of the Service, combating offences, cooperating with competent authorities and handling GDPR rights requests	Legal obligations
Informing you of actions or interactions that concern you within the Service (for example, messages received, reminders related to your presences, etc.)	Performance of a contract (our Terms and Conditions of Use)
Sending you push notifications, when you have enabled them in your device settings	Your consent
Managing the subscription, performance, renewal and termination of your Subscription, as well as access to the associated Premium Features	Performance of a contract (our Terms and Conditions of Use)
Ensuring compliance with our legal and regulatory obligations, particularly in accounting and tax matters, in the context of Subscription management	Legal obligations
Preventing, detecting and addressing abusive or fraudulent behaviour or disputes related to the subscription, performance or payment of Subscriptions	PSITT's legitimate interest in ensuring the secure management of Subscriptions, preventing and detecting abusive or fraudulent use, and handling disputes or payment incidents
Informing you of events related to your Subscription and Premium Features	Performance of a contract (our Terms and Conditions of Use)
Improving the Service and developing new features	PSITT's legitimate interest in continuously improving the Service by enhancing existing features and developing new ones
Providing the necessary assistance and support to answer your questions or requests relating to the Service and/or your Subscription	Performance of a contract (our Terms and Conditions of Use)
Producing anonymised or aggregated statistics relating to the use of the Service	PSITT's legitimate interest in producing statistics to better understand the use of the Service
Conducting satisfaction surveys and gathering your feedback on the Service	PSITT's legitimate interest in assessing the quality of the Service and measuring user satisfaction
Managing pre-litigation and litigation involving PSITT	PSITT's legitimate interest in defending its rights and interests in the event of a dispute or legal proceedings

Who is my personal data shared with?

• PSITT. Within PSITT, only those persons authorised by virtue of their duties or functions may access the personal data processed, and solely within the strict limits of their respective responsibilities and the performance of those duties and functions.

• Other users. Given the nature of the Service, certain information about you (for example, your username and your presence at a location) may be visible to other users, in strict compliance with the visibility and privacy settings you have defined.

• Our subcontractors. Your personal data may be shared with our subcontractors, strictly in consideration of the purposes sought and only where necessary for the subcontractor to fulfil their duties.

Indeed, PSITT uses third-party service providers, such as OVH, Supabase and AWS, who act on its behalf, particularly in the context of hosting, maintenance and technical and/or operational management of the Service.

These subcontractors are not authorised to share the information that may be communicated to them, nor to use it for any other purpose. PSITT has ensured that its relationships with them are governed by contractual arrangements to guarantee an adequate level of security for your data.

• Competent authorities. In exceptional cases, your personal data may be transmitted to legally authorised administrative or judicial authorities, in strict compliance with applicable regulations.

Note: In the context of Subscription management, certain information relating to transactions and Subscription-related events is transmitted to us by the download platform through which the Application is distributed (in particular the App Store or Google Play). These platforms act, in their own regard, as data controllers, in accordance with their own terms and conditions and privacy policies, over which PSITT has no control.

Is my personal data transferred to countries outside the European Union?

Your data may be transferred to a country located outside the European Union. In such a case, we systematically take all appropriate measures to ensure that the recipients of the data maintain an adequate level of protection equivalent to French and European regulations, in particular through the signing of standard contractual clauses adopted by the European Commission.

How long is my personal data retained?

Your personal data is retained in a form that allows your identification for a period not exceeding that which is necessary in relation to the purposes for which it is processed.

Subject to any legal or regulatory obligations requiring a longer retention period, your personal data will be retained for a period of three (3) months from the closure of your user account.

If your user account remains inactive for an extended period, we may occasionally send you a message to confirm that you wish to keep it. In the absence of account closure, PSITT will proceed to delete it, along with all associated data, upon expiry of a period of twenty-four (24) months from your last login to the Service.

By way of exception to the above:

Unless you delete it in advance, the history of your presences at locations is retained for a period of thirty (30) days, then anonymised or deleted;
Data necessary for the management of a report, fraudulent behaviour or a moderation procedure may be retained for a maximum period of twelve (12) months from the closure of the relevant case, where necessary to ensure the security of the Service, protect users and/or prevent the recurrence of harmful behaviour;
Certain data concerning you may be retained for a longer period in order to comply with our legal data retention obligations. Thus, in accordance with applicable regulations, your phone number will be retained for a period of five (5) years. Your username (pseudonym), technical data and traffic data will be retained for a maximum period of one (1) year;
If you have taken out a Subscription, certain data related to your Subscription may be archived for the period necessary to comply with our legal and regulatory obligations, particularly in accounting and tax matters, as well as, where applicable, for the duration of applicable limitation and/or forfeiture periods, to allow for the management of any disputes, payment incidents or the defence of PSITT's rights;
Finally, certain data may also be retained beyond the periods indicated above where their retention is necessary for the establishment, exercise or defence of legal claims. In such cases, the data concerned will be retained for the period strictly necessary for the resolution of the dispute, within the limits of applicable limitation and/or forfeiture periods.

Is my personal data secure?

We are committed to preserving the confidentiality, integrity, availability and security of your personal data. In accordance with applicable regulations, we strive to implement appropriate technical and organisational measures to guarantee the most suitable level of security given the risks involved in processing your personal data. We also put in place means to prevent, as far as possible, any loss, accidental destruction, alteration and unauthorised access to your personal data.

What rights do I have over my personal data?

In accordance with applicable regulations, you have:

A right of access to and rectification of your personal data;
A right to object to the processing of your personal data on legitimate grounds;
In the cases provided for by law, the right to request the restriction of processing of your personal data and/or its erasure;
A right to request the portability of your personal data, for your personal use or to transfer it to a third party of your choice;
The right to withdraw, at any time, your consent, where consent forms the legal basis for the processing of your personal data.

You also have the right to lodge a complaint with a supervisory authority, such as the French National Commission for Information Technology and Civil Liberties (CNIL).

To learn more about your rights, you may visit the CNIL website.

For any questions regarding the processing of your personal data and/or to exercise your rights over it, you may contact our data protection officer:

By post, at the address: EKD CONNEXION (PSITT), 25 Avenue de la Forêt-Noire, 67000 STRASBOURG;
By email, at the address: info@psitt.eu.

In order to protect your privacy, we may take reasonable steps to verify your identity before fulfilling your request.

Version current as of February 4, 2026

This notice is subject to change, depending in particular on the legal and regulatory context, as well as the positions taken by supervisory authorities on the protection of personal data (particularly those issued by the French National Commission for Information Technology and Civil Liberties). Accordingly, we invite you to refer to it regularly in order to stay informed of any updates.