1. Platform

Identity

The platforms are available at the following addresses: https://www.tupai-lifeproject.com et app.tupai-lifeprojet.com (hereinafter referred to as the “Platform”) are published by LIFE PROJECT, a simplified joint-stock company with a share capital of XPF 1,000,000, currently being registered with the Tahiti Trade and Companies Register - French Polynesia and registered under number T.A.H.I.T.I. G13486 and whose registered office is located at Pointe Matira AP FARE POTEE – MATIRA - 98730 BORA BORA (hereinafter “LIFE PROJECT”) which can be contacted by post at the following address: BP 918 98730 NUNUE BORA BORA and by telephone on +33 6 61 23 30 60 (France) / +689 87 35 48 35 (French Polynesia).

Intra-Community VAT: pending

Publishing director: Mr. Stéphane PRIEUR MAUX, in his capacity as President of LIFE PROJECT.

Contact : Email: contact@tupai-lifeproject.com Postal address: 3 place des Vosges, 75004 PARIS Phone number: +33 6 6123 30 60 (France) - +689 87 35 48 35 (Tahiti)

Accommodation

The website https://www.tupai-lifeproject.com is hosted by Webflow (https://webflow.com/) and the app.tupai-lifeproject.com is hosted by Vercel (https://vercel.com/).

2. Social networks

The websites and social networks, particularly the Instagram, Facebook, YouTube, Discord, Twitter and LinkedIn accounts and/or pages, are also published by LIFE PROJECT.

3. Content and use of informations

All content, pages, scripts, texts, graphics, photographs, illustrations, presentations, icons and databases on the Platform and/or social networks are the exclusive property of LIFE PROJECT or third parties that have authorized LIFE PROJECT to use them. All rights of reproduction or representation are strictly reserved.

Consequently, any reproduction, representation, use, adaptation, modification, incorporation, translation, commercialization, in whole or in part, of the Platform and/or social networks of LIFE PROJECT by any process and on any medium whatsoever (paper, digital, etc.) are prohibited without the prior written authorization of LIFE PROJECT, under penalty of constituting an offense of copyright and/or design and/or trademark infringement.

The logos, trademarks, and iconographies relating to all other companies and products mentioned on the Platform and/or LIFE PROJECT's social networks are the respective property of their authors and/or owners.

4. Advertising and hypertext links

4.1 Advertising

LIFE PROJECT reserves the right to insert any advertising or promotional messages on any page of the Platform and in any communication to users in a form and under conditions at LIFE PROJECT's sole discretion.
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Users therefore accept the display of such messages on the Platform. In its capacity as publisher of the Platform, LIFE PROJECT is free to market the advertising space on the Platform to advertisers of its choice. Users acknowledge that they have no rights over this advertising space and shall refrain from any request or action in this respect.

4.2 Hyperlinks

When using the Platform, LIFE PROJECT reserves the right to make recommendations for services from third parties or potential partners. As a result, users may have access to various links directing them to third-party sites and/or the sites of potential partners.
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LIFE PROJECT will not be liable in any way for:
▪︎ the content of the websites referenced on the Platform and/or LIFE PROJECT's social networks;
▪︎ and  the information or content provided by third parties and/or potential partners.LIFE PROJECT has no control over hypertext links and/or other promotional formats.

Consequently, LIFE PROJECT makes no warranty regarding, in particular:
▪︎ the truthfulness, quality, completeness and comprehensiveness of the content of the indexed websites; or
▪︎ difficulties in accessing and operating the indexed websites;

and cannot under any circumstances be held liable in the event of a dispute arising between a website indexed on the Platform and/or LIFE PROJECT social networks and one of the users, particularly due to losses or damage suffered, as the operators of the indexed websites are solely responsible for the content of their site.

5. Processing of personal data

When browsing the Platform, users are required to provide personal data.
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In its capacity as a host, LIFE PROJECT may collect personal data.
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The provisions relating to this section are available in the privacy policy accessible on the Platform under the heading “Privacy Policy”.
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As such, the data collected by LIFE PROJECT is used for the purposes and duration stipulated in the privacy policy available in the “Privacy Policy” section on the Platform.
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It is intended for the services of LIFE PROJECT and its potential service providers for registration, identification and the provision of services offered by LIFE PROJECT.
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In accordance with:
▪︎ Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, known as the “GDPR” on the protection of individuals with regard to the processing of personal data and on the free movement of such data; and
▪︎ to law no. 78-17, known as the “Data Protection Act”, of January 6, 1978, amended by law 2004-801 of August 6, 2004, relating to data processing, files and freedoms;
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users have the right to access, modify, rectify, limit, transfer and delete data concerning them.
To do so, the user must contact the support service by email at the following address: contact@tupai-lifeproject.com
LIFE PROJECT is committed to the confidentiality and protection of user data.

6. Changes to legal information

LIFE PROJECT reserves the right to modify this legal notice at any time, in particular to take into account any legal, jurisprudential, editorial, functional and/or technical developments.
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The prevailing version is the one accessible online on the day the Platform is consulted.
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Any consultation of the Platform after publication of the modified legal notice constitutes unreserved acceptance of the new legal notice.

7. Responsibility

LIFE PROJECT endeavors to ensure, to the best of its ability, the accuracy and timeliness of the information disseminated on the Platform.
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LIFE PROJECT declines all responsibility (a) for any imprecision, inaccuracy or omission relating to the information available on the Platform, (b) for damage resulting from a modification of the information appearing on the Platform caused by possible fraudulent manipulation by third parties and (c) for any damage, direct or indirect, whatever the causes, origins, nature or consequences, caused by anyone accessing the Platform or the impossibility of accessing it, as well as the use of the Platform and/or the credit given to any information coming directly or indirectly from the latter.

8. Applicable law

The Platform is governed by French law.

The platforms are available at the following addresses: https://www.tupai-lifeproject.com et  app.tupai-lifeprojet.com (hereinafter referred to as the “Platform for ”) are published by LIFE PROJECT, a simplified joint-stock company with a share capital of XPF 1000000, currently being registered with the Trade and Companies Register of Tahiti - French Polynesia under number T.A.H.I.T.I. G13486 and whose registered office is located at Pointe Matira AP FARE POTEE – MATIRA - 98730 BORA BORA (hereinafter referred to as “LIFE PROJECT”) which can be contacted by post at the following address: BP 918 98730 NUNUE BORA BORA and by telephone on +33 6 61 23 30 60 (France) / +689 87 35 48 35 (French Polynesia). The purpose of this privacy policy is to inform anyone using the Platform (hereinafter referred to as the “Users” or the “User”) of LIFE PROJECT's practices regarding the conditions for the collection, use and sharing of the information that Users are required to provide, as well as of their rights, when browsing the Platform.
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The Platform complies with French and European standards relating to the protection of privacy and personal data, and in particular with Law No. 78-17, known as the “Informatique et Libertés” (Data Protection Act) of January 6, 1978, relating to data processing, files and freedoms, amended by law 2004-801 of August 6, 2004 and Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, known as the “GDPR” on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

IMPORTANT: NOTE TO USERS
BY NAVIGATING ON THE PLATFORM FOLLOWING THE PUBLICATION OF THIS PRIVACY POLICY, YOU ARE ACCEPTING IT WITHOUT RESERVATION.

If the User wishes to withdraw his or her consent to the processing of his or her data, he or she can simply send a request by email to the following address: contact@tupai-lifeproject.com.

In addition, where required by law and/or in certain circumstances, the User's consent will be obtained or an opportunity to refuse will be provided before any data is transmitted.

1. Person responsible for processing the personal data collected

The personal data controller is LIFE PROJECT.

2. Type of data collected

The data collected on the Platform in the context of the use of the Platform is that which allows LIFE PROJECT to identify Users directly or indirectly.This may include the following categories of data concerning Users:
▪︎ civil status, identity and identification data, such as surname, first name, postal address, e-mail address, telephone number;
▪︎ data relating to personal life, such as investment;
▪︎ economic and financial data such as payment methods and history; and
▪︎ connection data such as IP address, web pages visited on the Platform and browsing data such as cookies.

The mandatory or optional nature of the personal data collected and the possible consequences of failure to respond are indicated when it is collected on the associated forms.Users who communicate the personal data of a third party must confirm that they have the consent of that third party for the Platform to use their personal data.

3. Purpose and legal basis of processing activities

3.1 Purpose of the personal data collected

The personal data collected on the Platform is used only for and during the execution of the services for the following purposes:
▪︎ management of commercial relations:
▫︎ validation of the Users' profile;
▫︎ processing and management of Users' orders;
▫︎ communication with Users;
▪︎ fight against money laundering and terrorist financing;
▪︎ collection of information through cookies and other trackers;
▪︎ proper functioning and continuous improvement of the Platform and its functionalities:
▫︎ general administration of the Platform;
▫︎ monitoring of the Platform's performance;
▫︎ general management of the Platform's security.

In addition, LIFE PROJECT may use the data to meet its legal and/or regulatory obligations, where applicable.

3.2 Legal basis for treatment activities

Processing activities and the collection of personal data are authorized on the following legal bases:
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▪︎ the fulfillment of contractual or pre-contractual obligations for the management of commercial relations;
▪︎ the fulfillment of legal or regulatory obligations for the fight against money laundering and terrorism;
▪︎ LIFE PROJECT's legitimate interest in guaranteeing the best level of operation and quality of the Platform for the proper functioning and continuous improvement of the Platform;
▪︎ the User's consent for the deposit of cookies and other trackers.

3.3 Aggregation with non-personal data

LIFE PROJECT reserves the right to publish, disclose and use aggregated information (information about Users or specific groups or categories of Users combined in such a way that an individual User can no longer be identified or mentioned) and non-personal information for sector and market analysis, demographic profiling, promotional and advertising purposes, and other commercial purposes.

4 Collection time

The data collected by LIFE PROJECT is freely provided by Users when creating an account on the Platform or during the subscription process.It may also be collected automatically when using the Platform, in particular when the User:
▪︎ browses the pages of the Platform;
▪︎ registers on the Platform; and/or
▪︎ subscribes to services.This automatically collected data does not reveal the User's identity but relates to the use of the services. This collection is necessary for the maintenance and functioning of LIFE PROJECT's services as well as for its internal analyses and reports.This information includes:
▪︎ information on how to use the services (frequency, traffic data, how the User reaches the Platform);
▪︎ information concerning the device used to access the services (name of the device, country, location, IP address, browser and device characteristics, operating system, language preferences, referral URL).In any case, the personal data collected:
▪︎ will be obtained and processed fairly and lawfully;
▪︎ will be recorded for specific and legitimate purposes;
▪︎ will be used in accordance with these purposes; are adequate, relevant and not excessive in relation to these purposes; and
▪︎ will be subject to precautions to ensure the security and confidentiality of the data in order to prevent it from being damaged, modified, destroyed or communicated to unauthorized third parties.

5. Recipients of personal data

The recipient of the personal data collected on the Platform is, first and foremost, LIFE PROJECT.

Personal data will not be communicated to third parties, with the exception of LIFE PROJECT partners, to whom personal data must be communicated in order to provide the services offered by LIFE PROJECT (execution, processing, management and payment of subscriptions), and for data analysis and monitoring.

However, the partners undertake to scrupulously respect the provisions of the Data Protection Act, the GDPR and any new provisions in the future.

Furthermore, other recipients may have access to personal data. These are, where applicable, service providers and subcontractors providing services for the Platform (hosting provider, site security tool, customer service and support tools) and its external service providers (electronic signature service provider, electronic payment service provider, access providers, communication agency, etc.).

In the event of a change of control of LIFE PROJECT, a merger, acquisition, collective procedure or any other form of asset transfer, the data collected by LIFE PROJECT may be transferred to third parties. Nevertheless, LIFE PROJECT undertakes to guarantee the confidentiality of the personal data collected and to inform Users before it is transferred or subjected to new confidentiality rules.In the event that it is required by law, the User's consent will be obtained or an opportunity to refuse will be provided before any data is transmitted.

The collected data may also be transferred if vital interests are at stake and LIFE PROJECT deems it necessary to investigate, prevent or take measures to prevent potential violations of its policies and, more broadly, in situations involving suspected fraud, potential security threats and illegal activities, or may be used as evidence in a dispute involving LIFE PROJECT.

6. Users Rights

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, known as the “GDPR” on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and the law n°78-17 known as the “Informatique et Libertés” of January 6, 1978, amended by the law 2004-801 of August 6, 2004 relating to data processing, files and liberties, the User has:
▪︎ a right of access to their personal data;
▪︎ a right to rectify their personal data;
▪︎ a right to delete and erase their personal data;
▪︎ a right to object to the processing of their personal data;
▪︎ a right to limit the processing of their data;
▪︎ a right to the portability of their data, when the data is subject to automated processing based on consent or on a contract;
▪︎ a right to withdraw their consent at any time; and
▪︎ a right to define the fate of their data after their death.
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Users wishing to exercise one of their rights may send their request by email or post to the following addresses:
▪︎ Postal mail: LIFE PROJECT - Pointe Matira AP FARE POTEE – MATIRA - BP 918 98730 BORA BORA
▪︎ Email: contact@tupai-lifeproject.com
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In the event of exercising one of these rights, the User must send LIFE PROJECT the information required for identification: surname, first name and e-mail address.
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In addition, in accordance with current regulations, the User's request must be clear and specify in detail the right he wishes to exercise and the address to which he wishes to receive a response in the event of the exercise of one of the rights listed above. LIFE PROJECT may ask the User to provide a photocopy of an identity document bearing his signature in order to verify his identity.
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LIFE PROJECT then undertakes to respond within a maximum period of one (1) month following receipt of the User's complete request.
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Due to the complexity of the request and/or the number of requests, this period may be increased by two (2) months provided that LIFE PROJECT informs the User of the reasons for the postponement within one (1) month of receipt of the User's request.
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LIFE PROJECT informs Users of their right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (hereinafter referred to as the “CNIL”) in one of the ways indicated below:
▪︎ Via the CNIL website: www.cnil.fr/fr/plaintes or www.cnil.fr▪︎ By post: Commission Nationale de l'Informatique et des Libertés - CNIL 3 Place de Fontenoy TSA 80715 - 75334 PARIS CEDEX 07

7. Data storage period

7.1 Storage of data for the duration of the contractual relationship

The personal data of Users collected is not kept beyond the time necessary for the fulfillment of LIFE PROJECT's obligations defined at the conclusion of the contract or the predefined duration of the contractual relationship, except with regard to data that LIFE PROJECT may need to keep as evidence, for legal or administrative purposes, or in accordance with current legislation.

7.2 Retention of anonymized data beyond the contractual relationship

LIFE PROJECT keeps the personal data of Users collected for the duration strictly necessary to achieve the purposes described in this privacy policy.

At the end of the commercial relationship, LIFE PROJECT will keep the information provided by the User for three (3) years from the end of the commercial relationship, namely:
▪︎ surname and first name; e-mail addresses; and
▪︎ phone numbers

Beyond this period, they will be anonymized and kept for exclusively statistical purposes and will not be used in any way whatsoever.

8. Transfer of personal data abroad

As far as possible, LIFE PROJECT processes User data only within the European Union and does not transfer this data outside this area.

Nevertheless, in the event of international transfer of User data outside the European Union, a distinction should be made between:
▪︎ countries that have been the subject of an adequacy decision by the European Commission: in this case, the data is transferred to a country that ensures a level of protection deemed sufficient and adequate under the provisions of European data protection regulations; and
▪︎ countries whose level of data protection has not been recognized as adequate: in this case, to guarantee a transfer in compliance with European regulations, and in particular to ensure data security, LIFE PROJECT will base its transfer on protection mechanisms adapted to each service provider and subcontractor, such as the conclusion of standard contractual clauses approved by the European Commission, the application of binding corporate rules or under an approved certification mechanism.

9. Security

LIFE PROJECT undertakes to implement the appropriate technical and organizational measures that are reasonably necessary in accordance with the regulations applicable to the protection of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage in order to ensure a level of security appropriate to the risks to the rights and freedoms of natural persons in the context of the processing operations referred to in this privacy policy.
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When personal data is transferred to third parties for processing, LIFE PROJECT ensures that these third parties implement all appropriate technical and organizational measures to ensure the protection of personal data in accordance with applicable laws.
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These measures are defined taking into account the state of knowledge, the costs of implementation and the nature, scope, context and purposes of the processing as well as the identified risks.
Depending on the needs, risks, costs and purpose of processing, these measures may include pseudonymization and encryption of data.
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This protection can be ensured by the mention “https” in the browser's URL address as well as by the representation of a closed padlock at the bottom of the screen.
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Finally, in the event of a violation of personal data rights that is likely to create a high risk for the User's rights and freedoms, LIFE PROJECT undertakes to inform the User of this violation within a maximum period of seventy-two (72) hours.

10. Links

On the Platform, Users may have access to various links directing them to third-party sites.
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LIFE PROJECT will not be responsible for the information sent to or collected by these third parties.
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This privacy policy does not govern third-party sites or third-party content accessed by the Platform User.
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LIFE PROJECT has no control over hypertext links and/or other promotional formats.
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Consequently, LIFE PROJECT does not give any guarantee concerning, in particular, the personal data protection practices of indexed websites and cannot under any circumstances be held liable in the event of a dispute arising between a website indexed on the Platform and one of the Users, in particular due to losses or damage suffered, the operators of the indexed websites being solely responsible for their personal data protection practices.

11. Cookies

A cookie is a text file that can be saved in a dedicated space on the hard disk of the User's computer when an online service is consulted using their browser.
In practice, cookies are small text files that are placed on the User's computer by the websites that the User visits. They are used to make websites work and improve the user-friendliness of these sites.
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The cookie is transmitted by a website's server to the User's browser. Each cookie is assigned an anonymous identifier. A cookie does not allow tracing back to a natural person.
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When consulting the Platform, Users are informed that cookies or other means of recording browsing data are used by the Platform or by third parties, service providers for the Platform, and deposited on the User's terminal (computer, mobile or tablet).
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LIFE PROJECT or its partners may install, subject to the User's acceptance, various cookies, including:
▪︎ session cookies, which disappear as soon as the User leaves the Platform;▪︎ permanent cookies, which remain on the User's terminal until their lifespan expires or until the User deletes them using the functionality of their browser; and
▪︎ statistical cookies (to measure the Platform's audience).
Only the issuer of a cookie can read or modify the information it contains.
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In accordance with the recommendations of the CNIL, when connecting to the Platform for the first time, the User will be expressly asked to accept the Platform's cookies.

11.1 Purpose of cookies

The cookies used by LIFE PROJECT or its partners make it possible to identify Users, to recognize their browser when they connect to the Platform, to record their access frequencies (traffic measurement) and their display preferences of the Users' terminal, adapt and/or personalize the presentation of the Platform to improve the User experience and optimize the Platform for the sole purpose of providing the services requested by the User.

In addition, the cookies used on the Platform are based on the International Chamber of Commerce guide by category:
▪︎ strictly necessary cookies.

11.2 Strictly necessary cookies

Strictly necessary cookies enable the User to browse the Platform.
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These cookies do not collect any information about the User that could be used for marketing purposes.
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LIFE PROJECT uses these cookies to:▪︎ ensure the functioning of the Platform;
▪︎ secure the forms and protect them against malicious scripts.
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LIFE PROJECT does not use these cookies to:
▪︎ collect information that could be used to promote products or services to Users; or
▪︎ remember User preferences or names after their visit.

11.3 Cookie retention period

In accordance with the recommendations of the CNIL, the lifespan of cookies is a maximum of thirteen (13) months after they are first placed on the User's device. The information collected via these cookies is stored for a maximum of twenty-five (25) months. Furthermore, the lifespan and storage periods are periodically reviewed.

11.4 User's right to refuse cookies

When browsing the Platform for the first time, a banner explaining the use of cookies will appear. This will allow the User to enable or disable certain cookies. It will only disappear once the User has accepted, or not accepted, the use of cookies and continued browsing.

The saving of a cookie remains subject to the will of the Users. In accordance with the legislative and regulatory provisions, LIFE PROJECT collects the prior consent to the deposit of cookies.Users also have the option of configuring their browser software so as to oppose, totally or partially (in particular according to the issuer), the saving of cookies. The configuration also offers the possibility of accepting or refusing cookies on an ad hoc basis, before they are saved in the Users' terminal.

Therefore, Users who wish to prevent cookies from being saved can follow the specific procedure for each browser, as described in the browser's help menu.
Chrome
‍ Internet Explorer 
‍Edge
‍Safari
‍Firefox
‍Opera

However, in the event of opposition to the registration of cookies or the uninstallation of a cookie, Users are informed that some services may no longer function correctly.

12. Change to the privacy policy

LIFE PROJECT reserves the right to modify and update this privacy policy at any time, in particular to take into account any legal and/or jurisprudential developments and to meet the requirements of the regulations applicable to the protection of personal data.

The prevailing version is the one accessible online on the day of consultation of the Platform.

Any consultation of the Platform after publication of the amended privacy policy constitutes unreserved acceptance of the new privacy policy.

13. Contacts

For any inquiries or to learn more about the processing of personal data, including the exercise of the rights indicated above, the User may contact LIFE PROJECT by email or post at the following address:

▪︎ Postal mail: LIFE PROJECT - Pointe Matira AP FARE POTEE – MATIRA - BP 918 98730 BORA BORA
▪︎ Email address: contact@tupai-lifeproject.com
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For any complaint or dissatisfaction regarding the use of their personal data by LIFE PROJECT, Users can contact LIFE PROJECT by email or post at the following address:
▪︎ Postal mail: LIFE PROJECT - Pointe Matira AP FARE POTEE – MATIRA - BP 918 98730 BORA BORA
▪︎ Email: contact@tupai-lifeproject.com
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When the User contacts LIFE PROJECT, they will be asked to identify themselves.
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Version updated on December 13, 2024.