Privacy Policy
ChatNovel application – version dated 28 October 2026
This policy explains which personal data the ChatNovel application uses, why it uses it, who it is shared with, how long it is retained and how to exercise your rights under the General Data Protection Regulation (GDPR) and the French Data Protection Act. It supplements the Terms of Use .
1. Who is responsible for your data?
The data controller is MY SMART BOOK , a French simplified joint-stock company (SAS) with share capital of €1,000, registered with the Nanterre Trade and Companies Register under number 989 655 246, with its registered office at 4 avenue Laurent Cely, 92600 Asnières-sur-Seine, France.
For any questions about your data, contact: [email protected] (subject line “RGPD”), or write to the address above, marked “For the attention of Emmanuel MARIE-CARDINE”.
Apple and Google are responsible for their own processing activities (Apple or Google accounts, payments through the App Store or Google Play, and your phone's speech recognition) and provide their own privacy information.
2. Which data, for what purpose, and on what legal basis?
|
Data |
Purpose |
Legal basis |
Retention period |
|---|---|---|---|
|
Title, first name, surname, email address, country, password (encrypted); username, telephone number, postal address and profile photo if you provide them |
Creating and managing your account and allowing you to sign in |
Performance of the contract |
Until account deletion, or after 3 years of inactivity |
|
Your Google or Apple account identifier, email address and name provided by Google or Apple |
Allowing you to sign in with Google or Apple |
Performance of the contract |
Same as the account |
|
Date of acceptance of the Terms of Use |
Providing evidence of your acceptance |
Legitimate interest |
Same as the account |
|
App Store or Google Play purchase receipt, subscription status and dates |
Verifying and activating your ChatNovel Unlimited access entitlements |
Performance of the contract |
For the duration of the subscription, then for 10 years to meet accounting obligations |
|
Library (complimentary book, catalogue books, ebooks purchased on mysmartbook.fr using the same account), wish list |
Giving you access to your books |
Performance of the contract |
Same as the account |
|
Your questions and the conversational agent's responses, bookshelves, debates, quizzes and scores, rehearsals |
Providing book discussion features and allowing you to retrieve them |
Performance of the contract |
Same as the account |
|
Feedback on responses (thumbs up or down, reactions, comments) |
Improving the quality of responses |
Legitimate interest |
Same as the account |
|
Messages sent to the reading coach |
Suggesting books for you to read |
Performance of the contract |
Processed to provide the response; the conversation remains on your phone |
|
Photo of a printed book's cover |
Finding the book in the catalogue |
Performance of the contract |
Not retained: analysed and then deleted |
|
A passage from a book to be translated |
Translating the passage |
Performance of the contract |
Not retained |
|
Your voice (dictating a message, rehearsing a scene) |
Converting speech to text |
Consent (microphone permission) |
Your voice is processed by your phone's speech recognition; we receive only the text |
|
Your location (“Autour de moi” / “Around me” in travel guides) |
Answering a question about nearby places |
Consent (location permission) |
Remains on your phone; only the question naming the place is sent to us |
|
Reading position, bookmarks, annotations, settings |
Reading your books |
Performance of the contract |
On your phone only |
|
Daily usage counters (quizzes, photos, coach, translations) |
Enforcing usage limits |
Legitimate interest |
For the duration of the subscription, then for 3 years to meet accounting obligations
|
|
Email address and newsletter subscription status |
Sending you the newsletter |
Consent |
Until you unsubscribe |
|
Technical logs (IP address, date and nature of requests) |
Service security and troubleshooting |
Legitimate interest |
12 months |
Audience measurement on the home screen only counts the blocks displayed and tapped, without any reader or device identifier: it does not involve any personal data.
Information marked as mandatory during registration is necessary to create your account. Without it, the account cannot be opened.
3. Artificial intelligence
The conversational agent's responses, quizzes, the reading coach, the analysis of book photos and translations are produced by artificial intelligence models provided by Mistral AI (France). The text of your questions, the relevant book passages and, where applicable, the photo are sent to Mistral AI to generate the response.
MY SMART BOOK does not use your data to train artificial intelligence models and requires its service providers to comply with the same restriction.
To identify a photographed book, only its ISBN may be searched in public bibliographic databases (BnF, ISBNdb, Open Library, Google Books); no personal data is sent to them.
4. Who receives your data?
Your data is intended for the MY SMART BOOK team. It is also processed on our behalf and under our instructions by:
- Mistral AI (France): artificial intelligence models;
- SCALEWAY (France): hosting of the application and its servers;
- Brevo (France): newsletter delivery, and Shopeware for transactional emails (registration, password, etc.).
When you sign in with Apple or Google, subscribe through the App Store or Google Play, or use dictation, Apple or Google process your data as controllers of their own services. These companies may transfer data to the United States under the EU–US Data Privacy Framework or other safeguards provided for by the GDPR.
We do not sell your data or use it for advertising purposes.
5. Data stored on your phone
ChatNovel does not use advertising or third-party audience measurement tools. The application stores on your phone what is necessary for it to operate: your login session, library, downloaded books and settings. The login and registration screens, which are pages on chatnovel.fr, use only a session cookie and a language cookie, both strictly necessary and not requiring consent.
6. Deleting your account
You can delete your account at any time from the application (the “Moi” tab). Deletion removes your account, library, conversations, bookshelves, quizzes, rehearsals and reading data. As your account is shared with mysmartbook.fr, access to ebooks purchased on that website is also removed.
Deleting your account does not cancel a subscription purchased through the App Store or Google Play: you must cancel it in the store.
Backup copies of our databases are deleted as they are replaced, within a maximum of 365 days. Some data may be retained for longer where required by law (for example, accounting records).
Removing a book from “Mes livres” (“My books”) does not delete conversations associated with that book; they reappear if you add it again.
7. Minors
ChatNovel is available from the age of 12. Users under 15 need parental consent to subscribe to the newsletter.
8. Your rights
You have the right to access, rectify and erase your data, restrict its processing and request data portability. You may object at any time to processing based on our legitimate interest, on grounds relating to your particular situation, and to direct marketing. Where processing is based on your consent, you may withdraw it at any time: by unsubscribing from the newsletter or withdrawing microphone and location permissions in your phone's settings. You may also leave instructions regarding what should happen to your data after your death.
To exercise these rights, email [email protected] (subject line “RGPD”) or write to the address given in section 1, providing your surname, first name and email address. If we have reasonable doubts about your identity, we may ask you for supporting evidence. We respond within one month.
If you believe that your rights are not being respected, you may lodge a complaint with the CNIL: www.cnil.fr .
9. Security
Exchanges between the application and our servers are encrypted (HTTPS). Passwords are stored in encrypted form, and access to data is restricted to those who need it.
10. Changes
This policy may change, particularly when new features are added to the application. The last updated date appears at the top of the page. You will be notified in the application of any significant change.