Terms and Conditions of Use

1. Preamble and Definitions

1.1. Overview

These Terms and Conditions of Use (hereinafter referred to as the "Terms") govern the use of the mobile and web application "Bulle" (hereinafter referred to as the "Application" or the "Service"), published by SHABON, a simplified joint-stock company (société par actions simplifiée) with a share capital of 19,191 euros, registered with the Paris Trade and Companies Register under number 993 549 971, with its registered office located at 10 rue de la Paix, 75002 Paris, France.

1.2. Definitions

The following terms shall have the meanings set forth below in these Terms:

• "User": any natural or legal person using the Application
• "Creator": a User authorized to publish content on the Application. This term refers indiscriminately to Invited Creators, Media Outlets, and Bulle Avenir Creators.
• "Invited Creator": a professional or media outlet selected and directly invited by Shabon to publish content on the Application
• "Media Outlet": a press organization or news media invited by Shabon to publish content
• "Bulle Avenir Creator": a semi-professional creator who has applied and been approved through the Bulle Avenir Program, having paid the one-time registration fee, and authorized to publish video content. The conditions of the Bulle Avenir Program are governed by the GTC.
• "Advertiser": a Certified and adult User who has subscribed to the Advertising Service to broadcast a promotional video. The conditions of the Advertising Service are governed by the GTC.
• "Content": any element published by a User (text, image, video, comment, etc.)
• "Advertisement": a promotional video submitted by an Advertiser through the Advertising Service and broadcast after approval
• "Account": the User's personal space on the Application
• "Standard Level": account with email verification only
• "Verified Level": account with phone number verification
• "Certified Level": account with identity verification through official document and biometrics
• "Professional Level": Certified account with access to video content creation and monetization features, reserved for Invited Creators and Media Outlets
• "Bulle Avenir Level": Certified account with access to video publishing through the Bulle Avenir Program, without access to monetization
• "Editorial Committee": Shabon's internal body responsible for evaluating applications and validating content
• "Moderation": content review by Shabon or its service providers

1.3. Purpose of the Application

Bulle is a European social media platform enabling Users to view, share, and interact with verified, quality content, in accordance with the values of authenticity, rigor, and transparency.

1.4. Creator Selection and Editorial Policy

2. Acceptance of the Terms

2.1. Conditions of Acceptance

By creating an account or using the Application, you represent and warrant that:

• You have read, understood, and accepted these Terms in their entirety
• You have read and accepted our Privacy Policy
• You have read and accepted our Code of Ethics
• You have read and accepted our General Terms and Conditions of Sale if you subscribe to a paid offer
• You are at least 13 years old (with mandatory parental consent if under 15 years old)
• You have the legal capacity to enter into a contract
• You are not a person prohibited from using the Service

2.2. Minors and Protection

For more information on the collection and processing of data related to age and identity verification, please refer to our Privacy Policy.

2.3. User Warranties

By using the Application, you represent and warrant that:

• All content you publish does not violate any law or any third-party right (intellectual property, privacy, right of publicity, etc.)
• You have obtained all necessary authorizations from individuals appearing in your content (right of publicity, consent, parental authorization where applicable)
• Your content will not cause any harm to any third party or to Shabon
• You are not subject to any international sanctions, embargo, or prohibition from accessing the Service under any applicable regulation
• All information you provide is truthful, accurate, and not misleading

3. Account Creation and Management

3.1. Account Creation

You agree to:

• Provide accurate, complete, and up-to-date information
• Create only one personal account
• Not impersonate any other person or entity
• Not sell, assign, or transfer your account
• Keep your information up to date

3.2. Account Security

You are solely responsible for the confidentiality of your credentials and for all activities conducted through your account. You must:

• Use a strong and unique password
• Never share your credentials
• Notify us immediately of any unauthorized use
• Log out after each session on a shared device

Shabon shall not be held liable for any loss or damage resulting from your failure to protect your credentials.

3.3. Identity Verification

Shabon reserves the right to request identity verification for any account, particularly to combat identity theft, protect minors, or investigate violations of these Terms. The different verification levels and their implications are detailed in Section 4.

4. Account Levels and Usage Restrictions

4.1. Measures Applicable to All Users

• Default content filtering: Standard accounts have their content filtered according to the most restrictive settings (equivalent to under 15 years old)

4.2. "Standard" Level (email verification only)

This level applies by default to all new accounts.

4.3. "Verified" Level (phone verification)

Accessible after phone number verification via SMS code.

4.4. "Certified" Level (full identity verification)

Accessible after verification of an official identity document via Stripe Identity and/or France Identité (French government service). This level guarantees the user's actual age. No identity document is stored by Shabon, only a unique identifier confirming the verification is retained.

4.5. "Bulle Avenir" Level (Semi-Professional Creator)

Accessible to Certified users aged 16 and over who have been approved by the Editorial Committee as part of the Bulle Avenir Program.

4.6. Professional Level

Accessible only to Invited Creators and Media Outlets selected by Shabon, or to Bulle Avenir Creators who have progressed after approval. Reserved for Certified users aged 18 and over.

4.7. Changing Account Level

You may at any time request to upgrade the verification level of your account through the Application's Settings. The verification process and data collected for each level are detailed in our Privacy Policy.

Important: Once a verification level has been achieved, reverting to a lower level will result in the loss of all privileges associated with intermediate levels.

4.8. Circumvention of Restrictions

4.9. Disclaimer of Liability

Shabon disclaims all liability in the event of circumvention of protections by the User or by a third party. Usage restrictions are provided as protective measures but shall in no way substitute for parental supervision or the User's personal responsibility.

5. Rules of Use and Ethics

The User agrees to comply with Bulle's Code of Ethics as well as the following rules.

5.1. Prohibited Content

5.2. Content Subject to Special Restrictions

5.3. Prohibited Behavior

The following is prohibited:

• Harassing, intimidating, or threatening other users
• Creating fake accounts or manipulating the Application
• Using unauthorized bots or automated systems
• Manipulating engagement metrics (likes, views, subscribers, shares), including by paying or incentivizing individuals, using click farms or third-party boosting services, coordinating groups to artificially inflate engagement, or buying or selling accounts with followers
• Circumventing security or moderation measures
• Extracting data (scraping, crawling) or exporting any content or data from the Application through automated means, including robots, bots, and scripts, without prior written authorization from Shabon
• Using the Application for commercial purposes without authorization or without going through the Advertising Service
• Impersonating another person, Creator, brand, or entity, or providing inaccurate information about your affiliation
• Using the Application for market research, benchmarking, competitive analysis, or any form of business intelligence without written authorization from Shabon

5.4. Respect for Intellectual Property

You must only publish content for which you hold the rights or for which you have obtained the necessary authorizations. Any reproduction or sharing of protected content without authorization is strictly prohibited. Only brief quotation is permitted, provided it is justified, proportionate, and clearly attributed.

5.5. Platform Integrity and Anti-Circumvention

5.6. Content Redistribution

5.7. Advertisements and Promotional Content

All promotional or commercial activity on Bulle must be conducted exclusively through the Advertising Service defined in the GTC. Disguised promotion, undeclared advertising, and any form of unauthorized commercial communication are strictly prohibited and subject to sanctions.

The following is also prohibited:

• Selling, reselling, or commercializing access to the Service, its content, or its data
• Selling advertising, sponsorships, or promotions placed on, within, or around content on the Application, outside the Advertising Service
• Using the Application for unauthorized recruitment, solicitation, or commercial prospecting

6. Limitation of Liability

6.2. Exclusions of Liability

Shabon shall under no circumstances be held liable for:

• Content published by Creators: Shabon does not control, validate, approve, or endorse published content. Each Creator is solely responsible for their publications.
• Advertisements broadcast via the Advertising Service: each Advertiser is solely responsible for the content of their Advertisements and the products or services promoted. Approval by the Editorial Committee does not constitute an endorsement or guarantee of the content or products promoted.
• Interactions between Users: private messages, comments, discussions, meetings, transactions, etc.
• Acts of harassment, threats, or violence committed by Users against other Users
• Theft, loss, or alteration of data resulting from force majeure, a cyberattack, a technical failure, or an act of a third party
• Interruptions or malfunctions of the Service, regardless of the cause
• Moderation or Editorial Committee decisions made in good faith, even if erroneous
• Accuracy, truthfulness, or legality of content published by Users or Advertisers
• Indirect, incidental, special, or punitive damages including loss of profits, clientele, opportunity, reputation, or any moral harm
• Links to third-party websites: Shabon is not responsible for the content and practices of external sites

6.3. Service Provided "As Is"

6.4. Limitation of Damages

UNDER NO CIRCUMSTANCES SHALL SHABON'S TOTAL LIABILITY, FOR ALL DAMAGES COMBINED, EXCEED:

• The total amount paid by the User to Shabon during the 12 months preceding the event giving rise to liability.

This limitation applies even if Shabon has been informed of the possibility of such damages and regardless of the nature of the liability (contractual, tortious, or otherwise).

6.5. Force Majeure

Shabon shall not be held liable for any delay or failure to perform its obligations resulting from an event of force majeure, including but not limited to:

• Natural disasters (fires, floods, earthquakes, etc.)
• Wars, riots, acts of terrorism, sabotage
• General power, internet, or telecommunications outages
• Cyberattacks, DDoS attacks, large-scale hacking
• Failures of our technical service providers (hosting providers, ISPs, cloud services)
• Legislative or regulatory changes making it impossible to perform the Service
• General strikes, major social conflicts
• Epidemics, pandemics

6.6. Service Interruptions

Shabon reserves the right to interrupt, suspend, or limit access to the Service at any time, for any reason whatsoever, including for maintenance, updates, bug fixes, technical issues, commercial or strategic decisions, without prior notice and without incurring liability.

6.7. Right to Modify the Service

Shabon reserves the right, at any time and without prior notice, to:

• Modify, update, add, or remove features, content, or elements of the Service
• Modify the algorithms for recommendation, ranking, moderation, or any other algorithm used by the Application
• Modify access conditions for the various account levels, verification thresholds, and eligibility criteria
• Temporarily or permanently discontinue all or part of the Service, subject to reasonable notice in the event of permanent cessation

Such modifications shall give rise to no compensation or indemnity for the User.

6.8. Experimental Features

Shabon may offer features in beta, experimental, or early access versions. These features are provided "as is", without any warranty of availability, stability, or permanence. Shabon reserves the right to modify or withdraw them at any time, without notice or compensation. Use of these features is at the User's own risk.

7. Indemnification by the User

• Your content: any content that you publish, share, or transmit via the Application
• Your Advertisements: any promotional content broadcast via the Advertising Service, including the products or services promoted
• Your use of the Service: any use you make of the Application, whether or not in compliance with the Terms and GTC
• Violation of the Terms or GTC: any breach of your contractual obligations
• Violation of third-party rights: infringement of intellectual property rights, privacy, image, reputation, or any other right of a third party
• Violation of laws or regulations: any breach of applicable French, European, or international laws
• Fraud or illegal activity: any fraudulent, deceptive, or illegal activity conducted through your account
• Third-party claims: any complaint, claim, or legal action brought by another User or a third party concerning your actions on the platform

This indemnification obligation survives the termination or deletion of your account and extends to any judicial or administrative proceedings.

8. Intellectual Property

8.1. Ownership of the Application

The Application, its source code, design, structure, databases, algorithms, brand, and all elements comprising it are the exclusive property of Shabon.

8.2. License of Use

Shabon grants you a personal, non-exclusive, non-transferable, and revocable license to use the Application, solely for your personal and non-commercial use, in accordance with these Terms.

This license does not authorize you to:

• Copy, modify, distribute, sell, lease, or sublicense all or any part of the Application
• Reverse engineer, decompile, or disassemble the Application or its components, except to the extent expressly permitted by applicable law
• Attempt to extract the source code, algorithms, or data structures of the Application
• Create derivative works based on the Application
• Remove, obscure, or alter any intellectual property notices, logos, trademarks, or copyright notices

Shabon reserves all rights not expressly granted to you under these Terms.

8.3. User Content

Professional creators are subject to a supplementary agreement that governs the specific conditions for publishing.

You retain full intellectual property ownership of all content you publish. However, by publishing content on the Application, you grant Shabon:

• A worldwide, non-exclusive, royalty-free, transferable, and sublicensable license
• The right to use, reproduce, modify, adapt, translate, publish, distribute, and display your content
• The right to create derivative works for the purpose of improving the Service
• The right to use your content for promotional purposes (with attribution)

License duration: this license ends within a reasonable period following the deletion of your content from the Application, taking into account technical constraints (backups, caches, content delivery networks). However, if your content has been shared, republished, or used by other Users or by Shabon prior to its deletion, existing copies and ongoing uses may continue in accordance with these Terms.

8.4. Feedback, Suggestions, and Ideas

If you submit comments, suggestions, ideas, feedback, improvement proposals, or any other feedback relating to the Service, you agree that Shabon may use, reproduce, modify, distribute, and exploit them freely, without restriction, without attribution, and without compensation of any kind. You waive all intellectual property rights over such feedback.

8.5. Intellectual Property Monitoring

Shabon implements automated detection mechanisms but does not guarantee the detection of all infringements. Please report any violations to .

9. Moderation and Sanctions

9.1. Moderation Principles

Shabon implements proactive and reactive moderation combining automated algorithmic detection, human moderation, and community reports.

Shabon reserves the right to remove any public content (posts, comments, profiles) or sanction any User, at its sole discretion, without prior notice and without justification, particularly in the event of a violation of the Terms, the GTC, or to protect the safety and integrity of the Service.

Public content: Shabon reserves the right to access, read, analyze, and monitor all content published on the Application (posts, comments, profiles, biographies) for the purposes of:

• User safety, in particular the protection of minors
• Detection of unlawful content or content in violation of these Terms
• Compliance with legal and regulatory obligations

Private messages: Private messages and group conversations are protected by asymmetric encryption. Their content is encrypted on the user's device and stored in encrypted form on our servers. Shabon's teams do not have the technical ability to read the content of private messages as part of their regular operations, including for moderation purposes.

In accordance with applicable legal obligations, Shabon may be required to decrypt and transmit the content of private messages to competent authorities exclusively pursuant to a judicial or administrative order, under the conditions strictly provided by law. Shabon may also be required to retain necessary data even after account deletion, for a period consistent with legal retention obligations.

9.2. Scale of Sanctions

1. Warning: notification of the violation with a request for correction
2. Content removal: immediate removal of the offending content
3. Temporary restriction: limitation of certain features (24 hours to 30 days)
4. Temporary suspension: account suspension (7 to 90 days)
5. Removal of Bulle Avenir or Professional status: loss of the ability to publish
6. Permanent ban: permanent deletion of the account, with a prohibition on creating a new account. A banned User is no longer authorized to access the Service in any manner whatsoever, including through a third party's account, a VPN, a new phone number, or any other circumvention method. Any new account detected as belonging to a banned User will be deleted immediately without prior notice.

9.3. Right of Appeal

In accordance with the Digital Services Act (DSA), you have the right to appeal any moderation decision within 30 days via .

10. Personal Data Protection

The collection and processing of your personal data are governed by our Privacy Policy, in compliance with the GDPR and the French Data Protection Act (Informatique et Libertés).

You have the following rights in particular: access, rectification, erasure, restriction, portability, and objection. To exercise these rights, contact our DPO:

10.1. Approximate Location

Bulle uses your IP address to estimate your connection city, once per day maximum. This approximate location (30 to 100 km precision) is used to promote local content and creators. No GPS data or exact address is collected. You can disable this feature at any time in the privacy settings of the application.

10.2. Minors Protection and Advertising

Bulle is committed to protecting minor users. No precise advertising targeting is applied to accounts under 18 years of age: no behavioral targeting, no age-based targeting, no geographic targeting. Advertisements shown to minors are selected randomly, without any form of profiling.

10.3. Recommendation algorithm

Bulle uses general-purpose recommendation algorithms that are not based on your individual behaviour. All users benefit from the same algorithms, there is no behavioural profiling. You may at any time switch to chronological mode in the application settings to see posts in order of publication. These algorithms have no legal effect or any significant consequence on you.

10.4. Private Message Encryption

Private messages exchanged through the Application are protected by asymmetric encryption (RSA-OAEP + AES-256-GCM). Messages are encrypted directly on your device before being transmitted to and stored on our servers. Shabon's teams do not have access to the plaintext content of your messages, and message content is not used by any recommendation algorithm, automated moderation system, or analytical process.

In accordance with applicable legal obligations, decryption may only occur pursuant to a judicial or administrative order issued by a competent authority, under the conditions strictly provided by law.

10.5. Main sub-processors

Data is processed by service providers subject to strict contractual obligations. The main sub-processors are: Supabase (hosting, authentication), Mux (videos), Stripe / France Identité (identity verification, no identity documents stored by Shabon), RevenueCat (subscriptions), Twilio (SMS), OVH (web hosting). The full list is available in our Privacy Policy.

Certain additional integrations are reserved for professional creators and are governed by a supplementary agreement.

11. Duration and Termination

11.1. Duration

These Terms are entered into for an indefinite period from your first use of the Application.

11.2. Termination by the User

You may delete your account at any time through the Application settings or by contacting . Deletion results in the immediate deactivation of the account and the deletion of personal data within 30 days (subject to legal data retention obligations).

Important: Account deletion results in the loss of all current subscriptions, credits, and benefits, without refund. See the GTC for the terms of termination of paid services.

11.3. Termination by Shabon

Shabon reserves the right to suspend or terminate your account at any time, without prior notice and without compensation, in the event of:

• Serious or repeated violation of the Terms or the GTC
• Fraudulent or illegal behavior
• Prolonged inactivity (after 6-month notification)
• Request from judicial or administrative authorities
• Cessation of the Service (subject to 30 days' notice)
• Commercial or strategic decision

11.4. Consequences of Termination

Termination results in the permanent loss of access to your account and your content.

Surviving clauses: the following provisions of the Terms and GTC survive termination or account deletion, regardless of the cause:

• Section 2.3 (User Warranties)
• Section 5.5 (Platform Integrity and Anti-Circumvention)
• Section 5.6 (Content Redistribution)
• Section 6 (Limitation of Liability)
• Section 7 (Indemnification by the User)
• Section 8 (Intellectual Property, including the content license)
• Section 13 (Governing Law and Jurisdiction)

12. General Provisions

12.1. Entire Agreement

These Terms, together with the GTC, the Privacy Policy, and the Code of Ethics, constitute the entire agreement between you and Shabon regarding the use of the Application.

12.2. Severability

If any provision of these Terms is declared invalid, the remaining provisions shall remain in full force and effect.

12.3. No Waiver

Shabon's failure to exercise any right provided under these Terms shall in no way constitute a waiver of such right.

12.4. Assignment

You may not assign your rights or obligations without the prior written consent of Shabon. Shabon may freely assign all or part of its rights and obligations.

12.5. Amendments to the Terms

Shabon reserves the right to amend the Terms at any time. In the event of a material change, you will be notified by notification within the Application or by email. Changes take effect 7 days after notification.

12.6. Consent to Electronic Communications

By creating an account, you consent to receiving electronic communications from Shabon, including:

• Service communications (mandatory): moderation notifications, security alerts, Terms updates, account-related information, these communications cannot be disabled while your account is active
• Promotional communications (optional): news, special offers, recommendations, you may unsubscribe at any time through the Application settings
• Operational communications (mandatory, participation optional): satisfaction surveys, feedback requests, invitations to user interviews, new feature testing, quality surveys. These communications are intended to ensure service quality, improve the Application and meet the expectations of the community. They fall under Shabon's legitimate interest within the meaning of Article 6.1.f of the GDPR. They are sent at a reasonable frequency (typically a few per year). You are free not to respond. Only reception cannot be disabled while your account is active.

12.7. Governing Language Version

These Terms are drafted in French. In the event of translation into other languages, the French version shall prevail in the event of any discrepancy, ambiguity, or contradiction between versions. Translations are provided for informational purposes only.

13. Governing Law and Jurisdiction

13.1. Governing Law

These Terms are governed by French law and European Union law, in particular the GDPR and the Digital Services Act (DSA).

13.2. Mandatory Prior Mediation

13.3. Competent Jurisdiction

In the absence of an amicable resolution, any dispute shall be submitted to the exclusive jurisdiction of the courts of Paris, without prejudice to the mandatory rules of jurisdiction applicable to consumers.

13.4. Limitation on Class Actions

To the fullest extent permitted by law, you waive the right to participate in any class action against Shabon.

13.5. Statute of Limitations

To the fullest extent permitted by applicable law, any claim or legal action related to the use of the Service or these Terms must be brought within one (1) year from the date of the event giving rise to the claim. After this period, the claim shall be deemed time-barred. This clause does not affect mandatory limitation periods applicable to consumers under French or European law.

14. Contact