Privacy Policy

1. General
At SPE conseil développement edition SAS (“Dot to Dots”, “DtoD”, "us", "we" or "our"), we are committed to protecting your privacy. 

For this reason, we collect and use personal information only as it might be needed for us to deliver to you our products and services through DtoD website (our “Site”)

This Privacy Policy explains: 

  • What Information we collect and why we collect it;
  • How we use that Information; and,
  • To whom we disclose it; 

It also describes options we provide for you to access, update or otherwise take control of your personal information that we process.  

If at any time you have questions about our practices or any of your rights described below, you may reach out to us on and our data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy will help you out.

Likewise, we’ve also created a [Insert Name of Preference Management Dashboard] to provide answers to your most common questions, quick links to access your Account Settings, and instructions on how to exercise certain rights that might be available to you.

2. What are your rights as a data subject?
At any point while we are in possession of or processing your personal data, you have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances, you can ask for the data we hold about you to be erased from our records. If we are legally obligated to keep the information or if it is impossible for us to do so, we will only keep it for as long as it is needed and we have time limits on our data systems.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right not to have a computer make decisions about you directly (this doesn’t include general marketing based on your age or gender).
  • Right to judicial review – if we refuse your request under rights of access, we will provide you with a reason as to why. You have the right to complain.

Our Site may contain links to other sites not owned or controlled by us. We are not responsible for the privacy practices of those sites, so if you have questions regarding such sites, you need to contact the site directly. 

3. How we collect data?
3.1 We take your privacy very seriously, so we’ll only ask for the information we need to have so we can offer you a great service. 

Whenever we collect customer data, we make sure:

  • We ask for permission to collect the data
  • We only use the data for the agreed reason and for the time it’s needed
  • We will as a minimum meet the local data protection laws in the country where we provide you with a service through our Site
  • We keep data that we’re legally required to have on record
  • We explain why we need the data and how we’ll use it 
  • We check and update privacy information on a regular basis 
  • We don’t share data with anyone unless we have a legal or legitimate reason, or we have permission from you, or, if you are a child under 16, from your parents.

3.2 We collect your personal and anonymous information from you when you visit our Site. We also receive information via third party when you visit our page on social media sites or channels (e.g Facebook, Instagram, etc).

4. What data do we collect?
When you’re visiting any of these online channels, we may collect:

  • Registration information that we use to help you set up an account (e.g. your name, country, email address, username and password).
  • Payment or transactional information that we use when you buy products or use online services (e.g. postal address, phone number or credit card number).
  • Location information or your IP Address that we use to give you relevant online content.
  • Information you’ve shared publicly.
  • Information you provide when you use our own online channels or third-party channels (such as social networks) or if you link your registration account to a third-party platform.

5. Why we need to process personal data?
In legal terms, the way we ‘process data’ describes how we collect, store, use, share and delete the data we receive from customers. When you share your personal information with us on our online channels, we’ll process your data as described in this Privacy Policy.

We need to process personal customer data, so that:

  • Customers can buy products from our online store and have them delivered where they want
  • We can send customers any information they’ve asked us for or answer their questions
  • We can ask customers to give us feedback on our services through questionnaires and surveys
  • We can provide our customers with relevant marketing information about our services and products.

If you’re using our service through a third-party channel like social media, your personal data may also be processed by that third-party according to their own privacy processes. 

6. How we process personal data?
When you visit our Site or when you use third-party sites or platforms, we use cookies, flash cookies, pixels and web beacons to process your personal data.
Please read our Cookie Policy in section 10 below for more information, including information about how to disable cookies on your device and how to prevent them from being put there.
Be mindful that if you do enable a “prevent cookies” functionality on your device, some of our services and functionalities on the Site will no longer work.
We also collect information from other trusted sources, so we can update or add to the personal information we’ve collected ourselves. 

7. What happens when you share information on Social Media (“Features”) and Widgets?
Our Site includes social media links such as the Facebook ‘like’ button, widgets like ‘Share this button’ and interactive mini-programs. If you click on any of these links, the Features may collect your IP Address and record which page you were visiting at the time. The Features may also use cookies so that the Feature can function properly. Social media Features and widgets are hosted by third parties or may be hosted directly on our Site. When you’re using these Features and widgets, your personal data will be processed by that third-party according to their own privacy policies.

8. Do we share information with other companies?
We won’t share your personal information except:

  • When we need to enforce the terms of use or the policies that we ask customers to agree to;
  • When we need to protect the safety, security, rights and property of our customers or third-party partners;
  • When we need to meet legal processes or if disclosure of the data is required by law;
  • When we’re asking other companies like e.g. couriers, shipping and warehouse service providers, payment providers, IT platform providers, fraud detection and prevention providers, survey providers, product catalogue providers and customer service suppliers to deliver services on our behalf; We have contracts with the companies to make sure they only use your personal information for agreed services and meet legal requirements;
  • When we store your information using secure cloud storage services/facilities. We have contracts with companies to make sure they only use your personal information for the agreed services and meet legal requirements;
  • When you have given us permission to share your information with third parties, so they can provide you with marketing information and promotions regarding our products (as an example personalized advertising provided via a social media platform). You can opt out of such marketing activities by adjusting your cookie settings on your device. In some cases, you may also need to contact the third party directly (in case of social media adjust your privacy settings and request deletion of collected information by the third-party site)
  • When you’ve asked us to share your personal information with third-party sites or platforms like social networking sites – once it’s been shared, your personal data will be processed by that third-party according to their own privacy processes.

9. How long do we keep your personal information?
We’ll keep your personal information as long as your account is active or as long as it’s needed to provide a service. We have so called retention polices for each of the categories of personal information that we process.
If you’d like to cancel your account or for us to delete your data, we’ll only keep information that we need for legal reasons, to resolve disputes or to enforce our agreements.

10.Cookie Policy
Cookies are small data files that your browser places on your computer or device. A cookie itself does not contain or collect information. However, when it is read by a server via a web browser it can help a website deliver a more user-friendly service – for example, remembering previous purchases or account details. 
Like most websites, our online channels collect some information (e.g. information on IP addresses, browsers, internet service providers, referring pages, exit pages, operating systems, date stamps, time stamps and clickstream data). This information won’t be linked to any other information we collect about you unless you have given your consent that we may do this.
Both we and our third-party tracking utility partners use browser storage, app storage, cookies, pixls, beacons, scripts and tags to analyze trends, administer the site, track user movement through the site and collect demographic information about our overall user base. We may receive reports on these from our third-party tracking utility partners on an individual and aggregate basis. 

11. Keeping children safe online
We care deeply about making sure children are safe online and have extra privacy processes in place to make sure we’re keeping our younger fans safe when they’re using our Site. 
We follow relevant laws for children aged between 13 and 18 and when it comes to personal data, we consider anyone under the age of 16 years a child.
 If you have any questions or concerns about our Privacy Policy, you may reach out to us on and our DPO will help you out. When we do process personal information from children, we take extra steps to protect their privacy including:

  • Making sure we tell parents what personal information we collect, store, use and process from their child and explaining whether we share the information;
  • Meeting legal requirements by asking for parental consent to collect, use and process a child’s data and asking for consent to send their children information about our products and services;
  • Limiting how we collect, store, use and process personal information from children so only data that is reasonably needed for them to take part in an online activity is collected;
  • Giving parents access or the option to ask for access to personal information we’ve collected from their child – parents can also ask for their children’s personal information to be changed or deleted.

12. What if we accidentally collect children’s data?
If we discover that we’ve unintentionally collected information from a child, we will delete the information immediately.

13. What are the parental choices and controls?
At any time, parents or guardians can refuse to allow us to use and collect further personal information from their child. Parents or guardians can ask us to delete the personal information we have collected in connection with their child’s account from our records. As personal information is required for some services, deleting a child’s records may result in an account, membership, or service being unavailable to the child in future.
If we make material changes to how we use Personal Information collected from a child under the age of 16, we’ll tell their parent or guardian by email and ask for ‘verifiable parental consent’ for the new uses of the child's personal information.

14. Sharing information we have consent to share with others
If we’ve received high-level parental consent to share a child’s personal information publicly, we may also share these personal information with our service providers or legal authorities. We may share information with our service providers including software solution companies, online security partners and customer services. Our contracts with these companies make sure they only use personal data for the agreed purpose.

We may share personal information to meet legal processes or if disclosure is required by law. As allowed by relevant laws, we may also share personal information collected from children to:

  • Comply with a request from to a law enforcement or public agency (including schools or children services) or to avoid liability
  • Make a disclosure that we believe may stop a crime being committed
  • Help an investigation related to public safety
  • Protect the safety of a child who’s using our online channels
  • Protect the technology of our service providers or security of our online channels themselves

Parents have the right to consent to the collection, use and processing of their child’s personal information without also having to consent to the disclosure of that information to third parties. We don’t share information with third parties other than as described above.

15. Data security and integrity
The security, integrity and confidentiality of customer information is extremely important to us. We use technical, administrative and physical security measures to protect personal information from unauthorized access, disclosure, use and modification. All external transfers that contain personal information are done using encrypted technology. Credit card information is handled by approved service providers that have appropriate safeguards in place.

Although we regularly review our security procedures and evaluate new technology and methods to make our online channels safer, no security measures are perfect or impenetrable.

Our customers, employees and partners also play an important role in protecting information. We encourage customers to choose passwords that are difficult for others to guess and to keep their personal passwords secret.

Should you notice any flaws or concerns in our security, please contact us on and our Customer Service team will take required steps as soon as possible.

If we ever experience a data breach in which customer information is at risk of being misused, we’ll contact customers according to legal requirements. If necessary, we’ll also contact data protection authorities. 

16. Compliance with GDPR legal requirements
We want to make sure we comply with the standards of data privacy and security included in the European General Data Protection Regulation (“GDPR”) anywhere in the world where we collect, store, use or share your personal data.

17. Changes to this Privacy Policy
DtoD may change this Privacy Policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide prior notice to users by email and post the information on our Site if these changes are material and request your consent if and when legally required.