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Privacy

The purpose of this privacy charter (hereinafter referred to as the “Charter”) is to describe the terms on which Orange SA, as part of the Libon service (hereinafter the “Service”), collects, process and backs up your personal data. This Charter is fully part of the General Terms of Use of the Libon Service. It may be amended through a new document that will be effective upon being published on line.

1. Why does Orange processes your data?

Orange only processes personal data for specific, explicit and legitimate purposes. Orange does not process such data in a manner incompatible with these purposes.

Orange processes your data as part of the performance of a contract.

To this end, the purposes pursued by Orange are as follows:

  • Manage the identity of the user and conduct his / her authentication
  • Bill and cash payments
  • Provide After Sales Service
  • Manage the personal data, features and rights of a contract
  • Deal with cancellations
  • Deal with complaints
  • Communicate for customer management
  • Manage disputes
  • Manage requests for data subjects' rights
  • Store user data
  • Operate the network
  • Operate services

Your data are kept for the time necessary to fulfil the purposes mentioned above. For processing related to the performance of the contract, the data may be retained for up to three years from the end of the relationship.

Orange also carries out data processing for purposes other than the strict performance of contracts. In this case, Orange makes sure that it has a legitimate interest in carrying out the processing. In addition, any processing may be subjected, as necessary, to the collection of your consent, which you can withdraw at any time.

To this end, the purposes pursued by Orange are as follows:

  • Set up direct marketing operations
  • Set up commercial events
  • Analyse the uses of offers and services to make proposals to the customer
  • Survey robe customers or users
  • Improve offers and customer relations
  • Ensure platform and service security
  • Roll-out and operate offers and services
  • Prevent fraud

Your data are kept for the time necessary to fulfil the purposes mentioned above.

Orange also processes your data to meet its legal or regulatory duties.

To this end, the purpose pursued by Orange are as follows:

  • Keep the required data to be able to meet legal duties
  • Manage requests for data communication from authorized authorities
  • Manage interception requests
  • Ensure the blocking, upon use, of cell phones that have been reported stolen

Your data may be kept as long as necessary to enable Orange to meet its legal duties.

2. What data are processed?

Depending on the case, Orange processes your personal data, directly collected from you or resulting from the use of the products or services. Orange may also receive data that has been collected from you by a third party.

Orange processes a data or a category of data only if it is strictly necessary for the purpose pursued. You can find information about these purposes above.

Orange processes the following categories of data:

  • Contact details: When you register, you fill in your mobile phone number, which will be your identifier for the Service. In case of purchase on our web purchase site, your postal address will be asked from you so as to issue the invoice to be sent to you by e-mail.
  • ID data: In addition, your phone number that was requested UPON registration, when using Libon, your IP address will also be collected. Your ID card number may be required when you use the support check the ownership of the mobile phone number.For advertising and / or analytical purposes regarding the user, LIBON collects three types of mobile advertising identifiers:
    • Apple Advertising ID (IDFA): an advertising identifier provided by Apple as part of iOS as part of its advertising infrastructure.
    • Android Advertising ID: an advertising identifier provided by Google as a component of Android.
    • Facebook app user ID: An identifier for a person who uses a recoverable application through the Facebook development kit (SDK).
  • User contacts: When activating the Service on the user's mobile terminal, a request to read the contact book of your terminal will be issued by Libon. All of this information in your contact book remains in the Terminal and is not sent to our servers. Only certain aggregated statistics are escalated: total number of contacts for optimization of certain algorithms and top 3 countries called.This authorization is not necessary for the use of Libon: you can refuse the use of your address book and call by dialling the phone numbers of the persons you call.
  • Connection and usage data: connections to, and use of, the Libon application (which screens are viewed...) for optimizing the customer journey.Once the Account is set up, the Service will retain user data such as call records and microphone sensor data (call duration, called numbers, calling numbers, etc.).the Service will retain user data such as call records: call duration, called numbers.
  • Economic and financial data: The history of minute purchases and consumption is saved on the servers of the Service. However, no bank details of the User are registered.
  • Products and services held: Phone model, screen resolution, MCC and MNC (country and operator), version of Android OS or Apple OS, type of network used (3G, 4G, Wifi ...).
  • Location data: Based on the IP address, only as part of its fight against fraud.

Libon offers two payment methods for buying minutes.

In the case of a purchase via mobile marketplaces (Google Play or iTunes), payment data (credit cards, etc.) will be processed by mobile marketplaces and are subject to the terms and conditions of these marketplaces.

In the case of a purchase via the Libon online shopping site, payment data (credit cards, etc.) will be processed by the secure payment platform and subject to its general terms and conditions. Libon does not store any payment information.

3. Who are the recipients of your data?

The data collected is intended for Orange's in-house departments and its subcontractors.

Data can also be processed by Orange partners. These are situations where partners are involved in the provision of services. It may also be processing that you are asked to consent to.

On the date of publishing hereof, if can be, depending on the case, solvency checking or fraud prevention agencies (KOUNT), Firebase, CleverTap, Crashlytics, HockeyApp, Facebook, Anovo, Google and Apple.

The processed data can finally be passed to relevant authorities, at their request, in the framework of legal proceedings, in the framework of court investigations and requests for information from the authorities or in order to comply with other legal duties.

Are your data processed outside the EU?

The collected data may be processed outside the European Union. In this case, Orange makes the necessary arrangements with its subcontractors and partners to ensure an adequate level of protection for your data, in compliance with the applicable regulations.

If the subcontractors and partners concerned are not members of the Privacy Shield agreement with regard to transfers to the United States of America, or are not located in a country with legislation considered as providing adequate protection they will then have signed the "standard contractual clauses" of the European Commission or will be subjected to binding internal rules approved by the authorities.

4. What are your rights?

You have a right to access, rectify and delete your data. You may request the portability of the latter. You also have the right to object to the processing or to request the limitation thereof.

You may issue instructions on the retention, deletion or disclosure of your personal data after your death.

5. How to exercise your rights?

It is possible to disable the collection of use data. This option is available in the settings menu of the application. If you do not have access to this option, we invite you to update your application and try again.

You can exercise your rights at any time, as well as contact the Personal Data Protection Officer at the address below:

support.web@libon.com

Any request to exercise your rights should be accompanied by a photocopy of a proof of identity (national identity card issued by the French State or European Union identity card or passport, resident card issued by the French State, residency card issued by the French State or circulation book issued by the French State). An answer will be sent to you within one month of receiving your request.

If your exchanges with Orange are not satisfactory, you may file a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL), i.e. the agency in charge of compliance with personal data-related duties in France.

6. How is your data secure?

Orange ensures that your data are handled securely and confidentially, including when certain operations are performed by subcontractors. For this purpose, appropriate technical and organizational measures to prevent the loss, misuse, alteration and deletion of your personal data are set up. These measures are adapted according to the level of sensitivity of the processed data and the level of risk offered by the processing or implementation thereof.

This personal data protection Policy is subject to change.

Last updated on 20/06/2018.