Privacy Policy

1. Data Controller and Data Protection Officer

Data Controller

Data Protection Officer (DPO)

In accordance with Article 37 of the GDPR, Shabon has appointed a Data Protection Officer.

DPO Contact:

2. Personal Data Collected

2.1. Account levels

Bulle offers several account levels depending on the data you choose to provide and verify. Each level unlocks additional features and modifies usage restrictions. To view the features and restrictions of each level, see Section 4 of the Terms of Use.

Standard Account (mandatory)

Minimum data required upon registration:

• Identity: Username
• Contact details: Email address
• Authentication: Password (hashed and salted)
• Age: Date of birth (self-declared for protection of minors)
• Settings: Language, country

Important: Standard-level users are automatically subject to the strictest restrictions (content filtered for under-15s, usage limitations).

Verified Account (phone verification)

In addition to Standard Account data, you provide:

• Phone number: Verified via SMS code

This level unlocks access to 15+ content for users who have declared they are over 15, and additional features (reactions, content filtering).

Certified Account (full identity verification)

If you are over 16, you can certify your account through one of the two following methods, at your choice:

Option 1 — Stripe Identity (all countries): you present an official identity document (national identity card, passport, or driving licence) along with a selfie. These documents are processed exclusively by our certified provider Stripe Inc. and never transit through Bulle in clear form.

Option 2 — France Identité (French electronic national identity card): you authenticate via the official France Identité application, a public service operated by the ANTS, which securely reads your identity card. Bulle is connected to this service under a service agreement signed with the ANTS. We have chosen to request only the strict minimum: your date of birth (to verify the minimum age of 16) and an anonymous identifier specific to Bulle, which cannot be correlated with any other service.

We do not request or receive your name, given name, place or country of birth, address, email, photo, nationality, gender, or any information about your identity document.

Purposes: identity verification ensures your actual age, adjusts accessible content accordingly, and prevents the creation of multiple accounts with the same identity (protection against impersonation and ban circumvention).

Regardless of the method chosen, Bulle does not retain any civil identity data. No document, selfie, biometric data, name, given name, or place of birth is stored in our databases. Only a technical encrypted identifier, which reveals no personal information, is kept to confirm that the verification took place and to prevent the same person from opening multiple accounts.

Bulle Avenir Account (semi-professional creator)

Reserved for Certified users aged 16 or over who have been approved by the Editorial Committee as part of the Bulle Avenir Programme. Full conditions are set out in the Terms of Sale.

In addition to Certified Account data, we collect:

• Application data: Description of the editorial project, topic, motivations
• Billing data: Information related to the one-time registration fee payment (9.99 EUR), processed via distribution platforms (Apple, Google)
• Content statistics: Views, engagement, audience data

Professional Account

Reserved for invited creators and media selected by Shabon, or Bulle Avenir Creators who have progressed. Adults (verified 18 years minimum) holding a Certified Account. Remuneration requires 1,000 subscribers, of which 500 must be Certified.

In addition to Certified Account data, we collect:

• Remuneration data: Banking information (IBAN), tax data (only if eligible for remuneration)
• Content statistics: Views, engagement, audience data

Advertiser Profile (Ad Service)

Available to Certified and adult users (18 years minimum) wishing to broadcast a promotional video. Full conditions are set out in the Terms of Sale.

In addition to Certified Account data, we collect:

• Ad data: Submitted video, description, desired targeting criteria (age range, approximate geographic area, interests)
• Billing data: Information related to payment (9.99 EUR / 1,000 credits)
• Distribution statistics: Number of impressions consumed, aggregated breakdown by age range and geographic area (anonymised data)

2.2. Profile data (optional for all)

Regardless of your account level, you may enrich your profile with:

• Public profile: Profile picture, biography, interests
• Preferences: Privacy settings, notifications, theme, language

Note: This data is entirely optional and may be modified or deleted at any time from your settings.

2.3. Automatically collected data

• Technical: IP address, device type, operating system, app version, unique identifier
• Connection: Date, time, session duration, pages viewed
• Location: Approximate only, based on IP address (30 to 100 km precision depending on the geographic area). No GPS location or exact address is collected

2.4. Data generated by your use

• Content: Posts, photos, videos, comments, messages
• Interactions: Subscriptions, followers, likes, shares
• Private messages: Encrypted (see section 9.1)
• Reports: Reported content or users

3. Purposes and Legal Bases for Processing

4. Ads, Advertising, and Personalised Recommendations

4.1. General principle

Bulle may display ads and advertising to fund the free Service. Ads appear in your video feed, filtered according to the same criteria as organic videos. Users who have subscribed to the Premium Subscription do not see any advertising or ads.

4.2. The Ad Service

The Ad Service allows Certified and adult Users to broadcast promotional videos to the Bulle community, using an impression credits system. The full conditions of the Ad Service are set out in the Terms of Sale.

4.3. How content and ad filtering works

Bulle uses a system of filtering by interests and declared criteria:

• You select your interests (cooking, sport, technology, etc.)
• You may declare an area of interest independent of your actual location (for example, you may be based in Lyon but interested in news from Toulouse)
• These preferences create a unique filter that applies to all content in your feed
• Organic videos and ads are filtered in the same way
• Advertisers may set targeting criteria (age range, approximate location, certification level, interests)

4.4. Managing your preferences

You may at any time:

• Modify your interests: Settings > Privacy > Interests
• Add or remove categories
• Refine the type of content you wish to see
• Subscribe to the Premium Subscription (3.99 EUR/month) to remove all advertising and ads

4.5. Data used and not used for filtering

4.6. GDPR compliance

4.7. How it works in practice

Example: You select "cooking" and "sport" as interests.

• Your feed: You will see videos and ads related to cooking and sport
• What we do NOT do: Analyse your behaviour to guess your hidden interests, sell your profile to advertisers, track your activities outside of Bulle, or create a detailed psychological profile.

Example for an Advertiser: A local artisan submits an ad via the Ad Service and targets "cooking" + "Paris area" + "18-35 years old".

• What the Advertiser sees: "Your ad generated 847 impressions out of 1,000 credits purchased. Breakdown: 62% 18-25 years, 38% 25-35 years."
• What the Advertiser does NOT see: No names, no profiles, no addresses, no individual data of any User.

4.8. For minors and unverified users

• Filtering by declared interests only
• Age-appropriate content (strict filtering of inappropriate ads and videos)
• No behavioural profiling or tracking, ads are random
• Prohibition of regulated products (alcohol, gambling, etc.) in ads shown to minors

5. Specific Protection of Minors

5.1. Age collection and verification

• Standard Account: Self-declared date of birth (unverified). The strictest restrictions are automatically applied.
• Verified Account: Declared date of birth, phone verification only (age remains unverified)
• Certified Account: Age verified via official identity document (Stripe Identity or France Identité). The exact age is extracted and retained to filter appropriate content. Bulle does not retain any identity document, only a unique verification identifier is stored to prevent the creation of multiple accounts.

5.2. Purposes of age processing

We use your age (declared or verified) to:

• Apply appropriate daily usage restrictions (1h30 or 3h depending on age)
• Activate appropriate curfews (11pm-7am for under-15s, midnight-6am for 15-17 year-olds, none for over-18s)
• Filter accessible content (under-15 content, 15+ content, 18+ content)
• Filter accessible ads (prohibition of regulated products for minors)
• Restrict features according to age and account level
• Verify eligibility for the Bulle Avenir Programme (minimum age 16)
• Comply with our legal obligations for the protection of minors

Legal basis: Legal obligation (protection of minors) and legitimate interest (user safety).

For full details of restrictions by age and account level, see Section 4 of the Terms of Use.

5.3. Parental consent (ages 13-14)

Minors aged 13 to 14 must obtain the consent of their parents or legal guardians. We collect:

• Parent/guardian email
• Confirmation of consent (timestamped)
• Ability for the parent to revoke consent at any time via

Retention: Parental consent is retained while the minor is aged 13 to 14, then automatically deactivated.

5.4. Usage time monitoring and curfews

To enforce the daily usage limitations and curfews described in the Terms of Use, we automatically collect:

• Timestamps of logins and logouts
• Cumulative usage duration per rolling 24-hour period

Legal basis: Legal obligation and legitimate interest (protection of minors, addiction prevention)

Retention: This data is retained for 30 days then aggregated anonymously for global statistics.

5.5. Identity verification for Certified accounts

When a user wishes to upgrade to Certified level, we use Stripe Identity and/or France Identité (French government service) for identity verification. These providers:

• Analyse the identity document (national ID card, passport, driving licence)
• Verify the document's authenticity (forgery detection)
• Compare the selfie to the identity document photo (biometric verification) or use the document's NFC chip (France Identité)
• Transmit only the verification result and date of birth to us

5.6. Enhanced protections for minors

In addition to usage restrictions, we apply:

• Priority moderation: Processing within 24 hours for reports involving minors
• Strict content filtering: Automatic blocking of sensitive, violent, or sexual content
• Limited interactions: Social features limited according to age and account level
• No behavioural profiling: Recommendation algorithms are general-purpose and identical for all users. No individual usage data is used to personalise content.
• Random advertising: Minors are not subject to any advertising profiling. Ads shown to them are random, filtered only by their declared interests, and exclude all regulated products or services (alcohol, gambling, etc.)

5.7. Specific rights of minors and their parents

• Minors aged 13-14: Parents/guardians may exercise all GDPR rights on behalf of the minor (access, rectification, erasure, objection, etc.)
• Minors aged 15-17: Parents/guardians may exercise all GDPR rights on behalf of the minor, but minors may also exercise their rights directly.

Contact for parents:

5.8. Reporting inappropriate content or suspicious behaviour

Minors, their parents, or any user may report:

• Content inappropriate for minors
• Suspicious or predatory behaviour
• Attempts to circumvent age restrictions
• Harassment or cyberbullying

Priority email:
Processing within 24 hours maximum.

6. Data Recipients

6.1. Internal (Shabon)

Access limited to authorised personnel:

• Technical teams (maintenance, development)
• Customer service and support
• Moderation team and Editorial Committee
• Legal and compliance department
• Management

6.2. Other users

According to your privacy settings:

• Public: Username, photo, biography, public posts
• Your followers: Content shared with them
• Private interactions: Messages, comments

6.3. Service providers (GDPR sub-processors)

Partners subject to strict contractual obligations:

• Hosting: OVH (servers in France, ISO 27001 certified, GDPR compliant)
• Cloud services: Supabase on AWS Europe infrastructure (GDPR compliant)
• Identity: Stripe Identity (ISO 27001 certified, PCI-DSS, GDPR compliant) and France Identité (French government service). No identity documents are retained by Bulle.
• Payment: RevenueCat (PCI-DSS compliant)
• Phone verification: Twilio (ISO 27001 certified, GDPR compliant)

6.4. Public authorities

Only upon lawful request:

• Judicial or administrative requisition
• Protection of rights and safety
• Combating illegal content

6.5. Advertisers

7. Data Transfers Outside the European Union

We prioritise storage and processing within Europe. Certain service providers may be located outside the EU with appropriate safeguards.

7.1. Safeguards implemented

• Adequacy decision of the European Commission
• Certifications (Privacy Shield successor, ISO 27001, etc.)

7.2. Current transfers

• AWS (Supabase infrastructure): Europe region
• Stripe (payments): PCI-DSS certified
• Twilio (phone): ISO 27001 certified

8. Data Retention Period

Upon expiry, your data is permanently deleted or irreversibly anonymised.

9. Data Security

9.1. Technical measures

• Encryption: SSL/TLS for communications
• Private messages: Encrypted using an asymmetric encryption system (RSA-OAEP + AES-256-GCM). Messages are encrypted directly on the user's device before transmission and storage. They are stored in encrypted form in our databases and cannot be read in plaintext by Shabon's teams, nor processed by any algorithm. In accordance with applicable law, decryption may only occur pursuant to a judicial or administrative order issued by a competent authority, under the conditions provided by law.
• Passwords: Hashing and salting
• Testing: Regular audits, penetration tests
• Monitoring: 24/7

9.2. Organisational measures

• Regular staff training
• Principle of least privilege
• Incident management procedures
• Confidentiality clauses
• Data Protection Impact Assessments (DPIAs)

9.3. Breach notification

In accordance with Article 33 of the GDPR, in the event of a data breach likely to pose a risk to your rights:

• Notification to the CNIL within 72 hours
• Information to affected users if high risk
• Protection recommendations

10. Your Rights Regarding Your Personal Data

In accordance with the GDPR, you have the following rights:

10.1. Right of access (Art. 15 GDPR)

Obtain confirmation of processing, a copy of your data, and information about the processing operations.

10.2. Right to rectification (Art. 16 GDPR)

Correct your inaccurate or incomplete data. Directly accessible in My profile > Settings.

10.3. Right to erasure / "Right to be forgotten" (Art. 17 GDPR)

Request the deletion of your data if it is no longer necessary, you withdraw your consent, you object to the processing, the processing is unlawful, or to comply with a legal obligation.

10.4. Right to restriction (Art. 18 GDPR)

Request a temporary freeze of processing in certain cases.

10.5. Right to data portability (Art. 20 GDPR)

Receive your data in a structured, readable, and interoperable format (JSON).

Available via: Settings > Privacy with us > Export my data

Timeframe: Your request will be processed within 30 days maximum. A confirmation email is sent immediately. A 24-hour security delay is applied before processing, to protect you in case of a fraudulent request (if it wasn't you, contact us within 24 hours).

10.6. Right to object and withdrawal of consent (Art. 21 & Art. 7.3 GDPR)

You may at any time object to processing or withdraw your consent, directly from the application:

• Switch to chronological mode (disables algorithmic recommendations)
• Disable geolocation (Settings > Privacy with us)
• Modify your interests and area of interest
• Manage your notification preferences

10.7. Exercising your rights

10.8. Right to lodge a complaint

If you believe that your rights are not being respected, you may lodge a complaint with the CNIL:

11. Amendments to the Privacy Policy

We may amend this Policy at any time, in particular to comply with any regulatory, case law, or technical developments.

Notification of amendments

In the event of a substantial amendment, you will be notified by:

• Notification within the Application
• Email to the registered address

Amendments take effect 7 days after notification. Continued use constitutes acceptance. If you disagree, you may delete your account before the amendments take effect.

Version history: Available upon request to the DPO.

12. Contact and Exercise of Your Rights