Updated on : Friday 20th May, 2016
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The present personal data protection policy applies to all personal data of Users of the Application processed by ONOFF TELECOM, as the data controller, under the terms set out herein.
2. WHAT DATA IS COLLECTED AND PROCESSED BY ONOFF TELECOM?
ONOFF TELECOM may collect and use data relating to You. This includes data collected when You download and use the Application, in particular when creating a User Account, when purchasing Numbers, and when using functions.
When you create your User Account ONOFF TELECOM may ask You for the following information:
· Your surname, first name and email address;
· Information concerning your profile which you choose to complete (for example, your age, sex, country of residence, public profile picture, etc.);
Only your surname, first name, password, email address and date of birth are required to create your account.
ONOFF TELECOM may subsequently collect and process the following information, in connection with your use of the Application and our purchases:
· The telephone numbers You have purchased;
· Your traffic data (technical data allowing communications to be transmitted, call length, numbers called, the category in which they have been placed, etc.);
· Your contact book (details registered on Your terminal), with Your authorization;
· The electronic identification data of Your terminal (SIM card number, cookies, etc.);
· Your geolocation data, the identifiers of the device, and the standard identifier of the detected Wi-Fi networks.
3. HOW DOES ONOFF TELECOM USE YOUR DATA?
The main purpose of processing Your personal data is to provide You with an Application offering secure, simple, efficient and customised services, in particular to:
· Provide You with innovative communication and content-sharing services;
· Create, use and store Your User Account;
· Manage Your Numbers, contacts, conversation groups, etc.;
· Modify and customise the Application’s functions and functionalities;
· Receive and process transactions made via the Application;
· Provide You with Our technical assistance, and resolve any problems encountered in using the Application;
· Inform You of updates of the Application and of Our Onoff offers and services;
· Seek Your opinion or Your participation in surveys to improve Our services;
· For all other purposes mentioned when You voluntarily send Us Your personal data to comply with the applicable regulations, and to provide You with Our services.
· To prevent potentially prohibited or illegal activities.
4. WITH WHOM MIGHT WE SHARE YOUR PERSONAL DATA?
4.1 Communication with Our affiliates, partners and suppliers
We never communicate your personal information to third parties without your express prior consent, except in the cases listed below.
ONOFF TELECOM may have to disclose your personal data to third parties acting on its behalf, for the sole purpose of the operation of our services. This may include our suppliers or subcontractors responsible for providing management, accommodation, maintenance and administration of the application and services and transactions associated with it.
Your personal data will be communicated in accordance with the provisions of French law of 6 January 1978 concerning data processing, files and personal liberties, and under the agreements enabling the present policy to be implemented.
Should onoff Telecom merge, be purchased or be transferred to another company – all or part of our activities – we would then share your personal data with this company, including with companies established outside the European Union, on the terms and to the extent authorised by law and in accordance herewith.
In addition, we may be constrained to communicate your personal data under a law or a statutory provision in force, a legal order or a regulation, or if this disclosure is required in the context of an investigation or proceedings, within the national territory or abroad.
5. COOKIES AND SIMILAR TOOLS
Use of the Application supposes that cookies are installed on your terminal with your agreement. You should know that certain functions of the Application are available only by using cookies, and that if You choose not to accept them it is possible that these functions will not be accessible to You.
5.1 What are cookies and similar tools?
Cookies are small text files which are saved on Your device, when using certain functions of the Application. For more information on cookies, we invite you to visit the following site – www.allaboutcookies.org
5.2 How are cookies used by ONOFF TELECOM?
– Recognise You when You log in to Your User Account, and use Our Application, and to enable You to access Your account and the services associated with Your account by this means;
– Record Your preferences, such as: Your contact groups, the selected language, the type of subscription opened, etc.;
– Enable us to detect any malfunctions, and to establish corrective measures and preventive or corrective security measures;
– Produce and generate statistics, as well as global data concerning use of the Application.
6. HOW IS YOUR PERSONAL DATA PROTECTED BY ONOFF?
ONOFF TELECOM takes all organisational and technical measures required to protect Your personal data, in compliance with the applicable obligations and exceptions under the laws in force, in order to protect the data against any accidental or intentional manipulation, loss, destruction, communication, and against any unauthorised access of Your data.
7. FOR WHAT REASONS MIGHT ONOFF CONTACT YOU?
7.1 Information on ONOFF products and services
ONOFF TELECOM may send You offers concerning the products, services and activities offered by ONOFF TELECOM
In this regard, We follow the choices You expressed when you created Your account. You can also modify Your choices at any time:
– by configuring the settings of Your User Account, or
– by sending us an email to the following address: firstname.lastname@example.org. The email address with which the user creates an account cannot be changed by the user.
– by using the “unsubscribe” links contained in Our newsletters or prospecting emails.
7.2 Service operation
ONOFF TELECOM may ask You to periodically give information concerning Your experiences, which will be used to assess and improve the quality of its services, or ask You to rate the application and new functions of the application. Under no circumstances are you obliged to provide such data. ONOFF TELECOM may also contact You to inform you of any anomalies and problems relating to its services.
8. HOW CAN YOU ACCESS AND MODIFY YOUR PERSONAL DATA, OR EXERCISE YOUR RIGHT OF OBJECTION?
You have the right to access, correct and delete Your personal data, and also the right of objection, for a legitimate reason, to the processing of your data. You may exercise these rights via the “Feedback” function of the Application, or by sending us a message to the following address: email@example.com. You can also at any time exercise Your right of objection to the processing of Your personal data for purposes of commercial marketing prospecting, by sending us a message to the following address: firstname.lastname@example.org.
9. What happens when you delete your account?
When you delete your User Account, we keep some of Your personal data necessary to enforce our Terms and Conditions and to meet our legal obligations.
Other personal data associated with Your User Account are deleted.
10. IF YOU ARE UNDER 18
If You are under 18, We request you to ask for the agreement of Your parents or legal representatives before sending Us data relating to You.
They must contact Us at the address email@example.com to give Us their contact details (name, email address, telephone number) in order to confirm their agreement, and in order that We may contact them in the event of a problem or for any additional information.
Your mobile device and your Application may be configured so that you may be informed of incoming calls, discussions and messages when you are not using the Application. If you do not wish to benefit from this function, you can modify the settings of your terminal so that you no longer receive notifications from the Application.
12. MODIFICATIONS OF THE PRESENT POLICY
We reserve the right to modify the present Personal Data Protection Policy at any time. Consequently, We recommend that you view this Policy regularly to learn of any new update of its content.
The present policy was last modified on 24/02/2015.
13. HOW TO CONTACT ONOFF?
You can contact us with any questions relating to use of Your data, or to exercise Your right of access, modification or deletion of Your data at the following email address: firstname.lastname@example.org, Onoffapp OÜ Subsidiary of OnOff Telecom SAS, Suur-Karja str.13. – 10140 Tallinn, Estonia.