Privacy policy and protection of the personal data of our users

Effective date : 13 July 2021


"Website" or "leBolide" refer to
"Philéas" refers to Philéas SARL, the operator of the Website and its subsidiaries and commercial brands
"User(s)" refers to buyers, sellers, visitors, users of the Website
"Member(s)" refers to one or all of the Users who have completed one of the registration forms, which has been validated by Philéas, whether or not they use its Services
"Account" is a space reserved for each Member to which he/she has access by means of a login and a personal password
"Personal Data" refers to all nominative information allowing the Member to be identified
"Seller" refers to a Member offering a Lot for online auction through leBolide internet platform
"Buyer" refers to a Member who can place bids on the Lots offered by Sellers on leBolide platform and thus become the purchaser
"Lot(s)" refers to the items offered for sale by the Sellers on the Website
"Sponsor" refers to a User introducing one or more other Users unknown to leBolide who will become Sellers on the Website
"Content" refers to texts, images, photos and other information published on leBolide by Members
"Service(s)" refers to all the services offered by the Website
"We" and "Our" refer to Philéas SARL and its subsidiaries.

Our Privacy Policy and Protection of Our Users’ Personally Identifiable Information are an integral part of Website General Terms and Conditions of Use and Sale. Any User, Member or simple visitor is invited to consult this document in order to be informed of the way in which Philéas collects, processes and exploits ‘’Personal Data’’ from the website.
Nominative Information or Personal Data is information that identifies a specific or determinable natural person, directly or indirectly, in particular by reference to an identifier, such as a name, identification number, location data, online identifier, or one or more elements specific to his/her physical, physiological, genetic, psychological, economic, cultural or social identity or with other elements to identify, contact or locate a person or even locate him/her in his/her environment.
Philéas SARL - 2 rue du Gabian - 98000 Monaco is responsible for the processing of Personal Data.

1 - When do We collect Personal Data and what Personal Data do We collect?

We collect Personal Data when a User browses the Website, when he/she registers by completing a form, completes a questionnaire to submit his/her Lot, makes a comment, places or wins an auction, makes a payment, when he/she subscribes to a newsletter, responds to a marketing survey or survey, updates his/her leBolide Account, or uses other features on leBolide.
When a Member unsubscribes from, his/her Personal Data is stored for a period of 5 (five) years and then permanently deleted.
The User’s Personal Data that We collect are:

  • their full name, username, date of birth, e-mail address, telephone number (landline and/or cell), country of residence, region or city of residence, zip code;
  • the languages they speak;
  • a copy of one or more official identity documents;
  • their banking information and, if applicable, VAT identification and registration in the trade register;
  • their credit card number, cryptogram and expiration date;
  • their billing address;
  • various information about their Lot and its history;
  • photos and/or videos of their Lot;
  • a copy of one or more official or unofficial documents relating to their Lot.

We may also receive Personal Data about a User from third parties, including, among other things, data on their transactions, purchase history, relationships with various product and service providers, and use of certain Services. For instance, if he or she accesses the Services on Our Site via a third-party connection such as Facebook, by "following", " liking", adding leBolide, linking his or her account to leBolide, etc., that third party may transmit certain data regarding his or her use of leBolide's Services. This data may include, but is not limited to, the User ID associated with his or her account, any data that he or she has authorized that third party to share with Us, and any data that he or she has made public on that site.
Users should always review and, if necessary, adjust their privacy settings on third-party websites and services before linking or connecting them to leBolide Service.

2 - How do We use Our User’s Personal Data?

The Personal Data that We collect from Our Users is processed for the following purposes:

  1. the creation and management of their personal leBolide Account (customer Account)
  2. the creation, management and publication of their ad(s) for the sale of their Lot(s) online on leBolide :
    • processing requests for information and responses to requests or questions;
    • processing invoicing for Our Services;
    • processing comments;
  3. information to Members on the Services offered by leBolide:
    • to promote Lots for sale on Our Website as well as on third-party sites;
    • promotional and/or information campaigns addressed to Users and Members;
    • processing Newsletter subscriptions;
  4. organizing events or contests;
  5. optimizing access to the Website:
    • linking the different devices Our Users use to access Our Services;
    • communications with Users and Members by e-mail, telephone or other means;
  6. sponsorship administration;
  7. fighting fraud or other illegal activity; dealing with inappropriate behavior or content;
  8. processing requests for advertising space on leBolide.

Credit Card Data will be transferred to Our credit card payment service provider, Verifone, whose registered office is located at 12, rue Paul Dautier - 78140 Velizy Villacoublay in France.

3 - Use of Cookies

In accordance with what is set out in Our Terms and Conditions, We use cookies to help Us obtain aggregate data on traffic and activity on the Website.
Cookies are small files that a site or its service provider installs on a computer’s hard drive through the web browser (if the user allows), which permits the site’s or its service provider’s systems to recognize the browser to acquire and remember certain information.
We may collect information about a User’s computer or other device, including, when available, his/her IP address, operating system and the browser he/she uses. We may use his/her IP address to identify the geographic area from which he/she accesses However, no IP address will be linked to Personal Data.
To give you examples, We may use cookies to help Us remember and process Users’ purchases. We might also use them to monitor advertising impact.
We may use Google AdSense Advertising on Our Website including:

  • Remarketing with Google AdSense
  • Google Display Network Impression Reporting
  • Demographics and Interests Reporting
  • DoubleClick Platform Integration.

This means that the User may find third-party advertising or content on based on his/her preferences and previous web-browsing.
We use and may allow others to use cookies and similar technologies (e. g. web beacons, pixels) to recognize a User and/or his/her device(s), authenticate him/her, remember his/her preferences and settings, analyze traffic and trends on the site, ensure and measure the effectiveness of advertising campaigns, and enable him/her to use social features. A banner or pop-up window will warn each User, the first time they connect, of the presence of cookies on the Site and will invite them to give or refuse their consent.
Users can define or modify their cookie management options at any time in their browser settings. Any modification made by Users to the cookie settings may make the experience of browsing the Website less satisfactory, which may in some cases lead to the inability to use the Website or part thereof.

4 - Do Not Track signal

Some Internet browsers (including Safari, Internet Explorer, Firefox and Chrome) have a "Do Not Track" ("DNT") feature that tells a website that a user does not want their online activity to be tracked.
As not all browsers offer a DNT option and DNT signals are not yet standardized, We do not recognize Do Not Track (DNT) signals or their cookies.

5 - Links to external sites

From time to time, and at Our discretion, We may allow other sites to include or propose products or services through links published on Our Website. These other sites have separate and independent privacy policies from Ours. Consequently, leBolide bears no liability for the policies, practices and activities of these sites with which leBolide is only bound by commercial agreements relating to advertising. Any User who, by clicking on the advertising link of the third-party site, goes to that site, acts under his or her own responsibility. The User should refer to the websites’ own privacy policies to understand how they collect and use their Personal Data.

With regard to payments to leBolide, they are subcontracted to the company Verifone whose privacy policy can be found here In order to preserve the integrity of Our Website.

We will carefully consider the comments that Users might have regarding these sites.

6 - Commercial e-mail

We offer a Newsletter, published and distributed on a regular basis. This Newsletter is sent to Non-Member Users via the e-mail address they have given in the box provided for this purpose on the home page of the Website, as well as to leBolide Members via the e-mail address registered in their leBolide Account.
In accordance with the legal provisions in force:

  • We monitor the compliance of third-party marketing emails if We use them;
  • We include a link at the end of each email allowing Our Users and Members to unsubscribe.

7 - Non-commercial e-mail

We also use their Personal Data to send Members emails related to the Service (e.g., current auctions, Account verification, purchase and billing reminders, changes/updates, service features, technical and security advisories), but also to send them ads strictly related to the Service on rare occasions when We deem it necessary to do so. For example, if Our Service is temporarily suspended for maintenance, We can send them an email to notify them. Members may not opt out of these communications that are not promotional in nature, except by disabling their Account.

8 - How do We protect Our User’s Personal Data?

We implement a variety of security measures to maintain the security of the Personal Data We collect and process when Users visit, connect, complete a form, complete a questionnaire to submit a Lot, make a comment, place an bid or win a sale, place an order, make a payment, submit or access their information, when they subscribe to a newsletter, they are responding to a marketing survey or survey, are updating their Account, or when they use other features on the Website.
Personal Data is stored in secure networks that are accessible only to a limited number of people. Such persons are required to keep such Data confidential.
All Data collected for payment purposes are encrypted using Secure Socket Layer (SSL) technology and all financial transactions are processed by an external service provider. They are not stored or processed on Our servers.
We also strongly recommend that Users carefully choose a password and ensure that their access codes to the Website remain confidential. However, despite all these precautions, no method of transmission over the internet or electronic storage is 100% safe. The information included in the advertisements of the Lots is accessible to visitors to the Site and also to visitors to third party sites that may provide access to Our Site. They can be seen by anyone with access to the internet and leBolide cannot guarantee the security of Members’ Personal Data, nor can it be accessed, copied, exploited, disclosed, modified or destroyed.

9 - Sharing Personal Data with a third party

To the extent that Our objective is to help Members sell and/or buy an auctioned Lot(s) on leBolide, the main sharing of Personal Data takes place with all Users of the Website who access ads, comments and pseudonyms while browsing.
We do not sell, market or transfer Personal Data collected through leBolide to third parties except as set out below:

9.1 - To disclose information to the extent that such disclosure is necessary to comply with the law, to enforce leBolide’s General Terms and Conditions, or to protect Our rights, Our property or Our security as well as those of persons or third-party companies assisting Us in the operation of the Website;

9.2 - To share information with all Users of leBolide through the Website or third-party sites to allow a greater dissemination of Lots. Each User who register as a Member agrees when registering that his/her pseudonym is published and visible to any User when that Member makes a comment, puts a Lot up for sale or places a bid;

9.3 - When a Member buys or sells a Lot on the Website and other Members have access to their Personal Data such as their full name, postal address, email address, phone number and other information needed to complete transaction (including the delivery of the Lot and its recovery). We may also provide Personal Data prior to the conclusion of a transaction to, for example, allow a Buyer to arrange an appointment with the Seller to inspect a Lot. We may also provide other Personal Data, such as the email address, to a Member in the event of a problem between him/her and another Member;

9.4 - We use third parties to help Us operate and improve Our Services. These third parties are involved on Our behalf in data hosting and maintenance, data analysis, customer support, marketing, advertising, payment processing and security operations.
We conduct a rigorous selection process before engaging any service provider or working with any partner. All Our service providers and partners must comply with strict Confidentiality and Personal Data Protection conditions;

9.5 - To ensure secure payments, We use a third party payment service provider. Verifone processes all payments made to leBolide. As such, Members’ Payment data, such as name, bank account number, date of birth and, if applicable, VAT identification and trade registration number, will be transmitted to this service provider via an encrypted connection.

9.6 - The processing operations referred to in points 2 and 3 above are likely to involve transfers of Personal Data from Monaco to countries outside the European Economic Area, whose legislation on the protection of Personal Data and the right to one’s own image differs from that in force in Monaco and/or the European Union (in particular the United-Kingdom and the United States). In this case, a precise and demanding framework, in accordance with the legal requirements in force in Monaco and within the European Union, ensures the protection of the Personal Data transferred to Our service providers and partners. These transfers, made necessary for the operation of the Website, take place under conditions and under guarantees to ensure the confidentiality and security of Personal Data.

10 - Third-party breach of Personal Data

In the event of a breach of Personal Data, We will notify Members by means of notices on the Website as soon as possible.

11 - Rights in terms of Personal Data Protection

In accordance with Act No. 1.165 of 23 December 1993, as amended, on the protection of personal data, any natural person concerned has the right to access, rectify, delete and limit the processing of their Personal Data.
Any natural person may also object at any time, for reasons relating to his/her particular situation, to the processing of said Personal Data by Philéas.
It is specified that, in individual cases, exercising some of these rights may make it impossible for Philéas to provide the Service, or even result in the termination of a Member's Account. For example, if a Member objects to the sharing of his/her Personal Data, We will not be able to connect him/her with other Members during sales or purchases, nor to allow him/her to comment on Lots.
Members may also, at any time and free of charge, without having to justify their request, object to the use of their Personal Data for commercial purposes.
They also have the right to request the deletion of the Personal Data Philéas holds about them. This right will only be exercised on the Data held by Phileas, excluding those held by third parties.
Members can exercise their rights and contact Philéas’ Privacy Officer by writing to the following address: leBolide - Privacy Officer - Philéas SARL - 2 rue du Gabian - 98000 Monaco - Principality of Monaco -, specifying the subject of their request. They also have the right to file a complaint with the Commission de Contrôle des Informations Nominatives (CCIN), the supervisory authority responsible for compliance with Personal Data obligations in the Principality of Monaco.

12 - Changes and Acceptance of Our Privacy Policy

leBolide may, at its sole discretion, amend, supplement or update this Privacy Policy. If We decide to change Our Privacy Policy, We will update the "effective" date at the top of this document. The original version of Our Privacy Policy is the one in French. All other versions are translations designed to inform Users. In the event of a conflict, the French version prevails. Browsing the Website implies acceptance by Users of this Privacy Policy. We recommend that Users visit it regularly to be informed of updates. Continued use of the Website following the posting of changes to Our Privacy Policy will be considered acceptance of these changes.
Users who disagree with Our Privacy Policy should refrain from using the Website.

13 - Changes in Our Users’ Personal Data

Members can change and/or update their Personal Data at any time by logging into their Account.

14 - Unforeseen circumstances

In the event that Philéas or one of its assets is acquired by a third party, the Personal Data that We have acquired may also be transferred to the purchaser.

15 - Contact Us

If a User has any questions about Our Privacy Policy and does not find the answer in the text above, in Our General Terms and Conditions, or in the FAQ, he/she can contact Us at or at leBolide - Privacy Officer - Philéas SARL - 2 rue du Gabian – 98000 Monaco - Principality of Monaco.