Privacy Policy

At EM DISTRIBUTION ("BubbleAds", "BubbleShop", "we", "our", "us"), we take the protection of your personal data seriously. This Privacy Policy explains what data we collect, why, how it is used and shared, and what rights you have — whether you are an individual connected with a partner through BubbleShop inside a conversational AI assistant, or a business partner using the BubbleAds portal.

By using our Services (the bubbleads.fr website, the partner portal, or the BubbleShop conversational service embedded in third-party AI assistants), you acknowledge that you have read this Privacy Policy.

Table of Contents

1. Scope
2. Personal Data We Collect
3. How We Use Your Data
4. How We Disclose Your Data
5. Cookies and Tracking Technologies
6. Data Retention
7. Data Security
8. Children
9. Your Rights
10. International Transfers
11. Contact

1. Scope

This Privacy Policy applies to personal data we collect when:

• you visit the bubbleads.fr website;
• you interact with BubbleShop inside a conversational AI assistant (Claude, ChatGPT, or others) to be connected with a partner business;
• you create or use a partner account on the BubbleAds portal.

It does not apply to third-party websites or services we may link to, nor to processing carried out by partners once a connection has been made and your contact details transmitted — each partner is then responsible, as an independent data controller, for its own processing, in compliance with GDPR.

2. Personal Data We Collect

a) Data shared when you request an introduction (BubbleShop users) When you express, during a conversation with an AI assistant, a wish to be contacted by a professional (quote, booking, appointment, order), we collect only the information necessary to make that introduction: name, phone number and/or email, postal code, the nature of your request, and any contextual details you choose to share (budget, preferred dates, preferences).

This information is transmitted only after your explicit confirmation. Where the AI assistant you are using technically supports it, a dedicated confirmation step shows you your contact details before anything is sent, so we can verify that the request genuinely comes from you and prevent someone else from submitting your contact details without your consent.

b) Account data (business partners) Company name, contact name and email, address, business sector, products/services covered, and — if you subscribe to Compte Pro+ — advertising campaign settings (budget, target cost-per-click, ad creative and copy).

c) Payment data (business partners) We never see or store your banking details. All payments (subscription, Compte Pro+) are processed directly by Viva Payments, a PCI-DSS certified payment provider. We only retain the billed amount, payment status, and a Viva transaction reference.

d) Technical data IP address, device and browser type, pages visited on bubbleads.fr — collected automatically when you visit the site.

e) Conversational signals (BubbleShop) When BubbleShop is integrated into a conversational AI assistant, we process the type of request made (the product or service category sought) and session metadata (language, timestamp) — but never your full conversation with the AI. We only receive what the BubbleShop tool explicitly sends to our API to carry out the requested introduction.

Important:

• We never sell your personal data.
• We never use your conversational data to train any AI model, proprietary or third-party.
• We do not receive the full transcript of your exchange with the AI assistant — only the information you explicitly agreed to transmit for the introduction.

3. How We Use Your Data

• Carrying out the requested introduction with a partner covering your need and geographic area;
• Managing partner accounts and subscriptions, including recurring billing;
• Providing support and responding to your requests;
• Preventing fraud and abuse (for example, requests submitted using a third party's contact details without their consent);
• Complying with our legal and accounting obligations.

We will not use your data for materially different purposes without notifying you first.

4. How We Disclose Your Data

The partner you are connected with: only your contact details and the elements of your request, only after your confirmation, and only to the single partner selected for your request (never broadcast to multiple partners simultaneously without your consent).

Our technical subprocessors, contractually bound to protect your data:

• Supabase (database, authentication)
• Railway (application infrastructure hosting)
• Lovable (web interface hosting)
• Viva Payments (payment processing)

Legal obligations: where required by law, a court order, or a competent authority.

Business transfers: in the event of a merger, acquisition, or sale of EM DISTRIBUTION, your data may be transferred as part of that transaction, subject to this Privacy Policy.

5. Cookies and Tracking Technologies

The partner portal uses a cookie that is strictly necessary to maintain your login session (authentication). As of today, we do not use advertising cookies or third-party analytics trackers on bubbleads.fr. Should this change, this Privacy Policy will be updated and, where required, your consent will be requested in accordance with applicable law.

6. Data Retention

• Unfulfilled introduction requests (no available partner, or unconfirmed request): deleted within 12 months.
• Requests transmitted to a partner: retained for as long as necessary to follow up on the introduction, then archived for evidentiary and dispute-resolution purposes for the applicable legal limitation period.
• Partner accounts: retained for the duration of the contract, then archived in accordance with French accounting and tax obligations (generally 10 years for accounting records).
• Aggregated or anonymized data (that can no longer identify you) may be retained for longer for statistical purposes.

7. Data Security

We implement technical and organizational measures designed to protect your data against unauthorized access, loss, alteration, or disclosure: encrypted communications (HTTPS/TLS), hosting with recognized providers, and restricted access controls on our systems. No system can guarantee absolute security.

8. Children

Our Services are not directed to individuals under 18 years of age. We do not knowingly collect data from minors. If we become aware that such data has been collected, it will be deleted promptly.

9. Your Rights

Under the GDPR and French data protection law, you have the following rights over your personal data: access, rectification, erasure, restriction of processing, objection, and data portability. You may also set directives regarding what happens to your data after your death.

To exercise these rights, contact us at hello@motyro.eu. We may request proof of identity before processing your request. You also have the right to lodge a complaint with the French data protection authority, the CNIL (www.cnil.fr), if you believe your rights have not been respected.

10. International Transfers

EM DISTRIBUTION operates from France. Some of our technical subprocessors (hosting, infrastructure) may process data within the European Union or, depending on their configuration, outside the EU (including in the United States). Where a transfer outside the EU takes place, we ensure appropriate safeguards are in place, such as the European Commission's Standard Contractual Clauses.

11. Contact

EM DISTRIBUTION 33 avenue Albert Petit, 92220 Bagneux, France Email: hello@motyro.eu