Privacy Policy

1. Data controller

2. Data collected

Depending on your use of the service, we may process in particular:

• Account data: name, email, phone number, address, login credentials, preferences, settings.
• Subscription/billing data: plan, history, status, invoices (payment data is generally processed by our payment provider; we do not store full card details).
• Technical data: IP address, logs, device identifiers, browser, language, operating system, playback/error events, security data.
• Usage data: listening/broadcast history, playlists, favourites, interactions, logins.
• Business client data (professional customers): company name, address, SIREN number.
• Support: correspondence and attachments sent to support.
• Cookies/trackers: according to your choices (see cookie policy).

3. Purposes and legal bases

We process your data to:

• Create the User account — with login information.
• Provide the Service (account creation, access, broadcasting) — contract performance.
• Manage plan subscriptions (billing, accounting, fraud prevention) — contract performance / legal obligations.
• Security (fraud, abuse and attack prevention) — legitimate interest / legal obligations.
• Improvement (audience measurement, diagnostics, performance) — legitimate interest and/or consent depending on trackers.
• Communication (service-related messages, support) — contract performance / legitimate interest, customer relationship management.
• Marketing (where applicable) — consent or legitimate interest depending on the case and applicable regulations.
• Comply with legal and accounting obligations.

4. SACEM procedures

When requested by the client, Newphonia may use business data (company name, address, SIREN) to carry out procedures with SACEM, including termination procedures. This data is used only to the extent necessary to complete these procedures.

5. Recipients and processors

Data is disclosed to authorised RAGENCIA departments and, where applicable, to its processors (hosting provider, payment provider) as well as to organisations concerned by requested procedures (including SACEM). Processors are bound by confidentiality and security obligations compliant with the GDPR.

6. Processing on behalf of business clients

Where, in the context of the Service, RAGENCIA processes personal data on behalf of a business client, RAGENCIA acts as a processor within the meaning of the GDPR. The terms of this processing (duration, nature, purposes, security measures, fate of data at end of contract) are set out in a data processing agreement (DPA) concluded with the client.

7. Retention periods

We retain data for as long as necessary:

• to operate the Account and Service;
• to manage the subscription;
• to comply with legal obligations (e.g. accounting);
• to handle disputes.

Exact retention periods may depend on the nature of the data and the context.

8. Security

RAGENCIA implements appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure or destruction.

9. Your rights

In accordance with the GDPR, you have rights of access, rectification, erasure, restriction, objection, portability (subject to conditions) and withdrawal of consent.

To exercise your rights: contact@ragencia.com (subject line: "Personal data – Newphonia").

You may also lodge a complaint with the CNIL (French data protection authority).

10. Cookies and trackers

See the cookie policy (consent, purposes, settings).

11. Updates

We may amend this policy. The applicable version is the one published on the website/Application at the time of consultation.