OASIS SMART SIM EUROPE

PERSONAL DATA PROTECTION POLICY

March 2021 


 

Our philosophy and our commitments

OASIS SMART SIM EUROPE is committed to the protection of your personal data and ensuring a high level of protection of your personal data in accordance with European Regulation 2016/679 and the Data Protection Act n ° 78-17.

As such, you will find below our policy of protection of your personal data explaining to you in particular what we collect as personal data, the treatment which is made of it and on what basis, their conservation and your personal rights. We invite you to read it.

Our Personal Data Protection Officer is at your disposal to answer all your questions, you can contact him at the following address: DPO@oasis-smartsim.com

You may find the text of the applicable European Regulation here: https://eur-lex.europa.eu/legal-content/FR/TXT/? uri = CELEX% 3A32016R0679 or ask / enter the regulatory authority (CNIL) via its website www.CNIL.fr.

This version of the personal data policy may be modified by us if necessary and you will be informed.


Your data controller

OASIS SMART SIM EUROPE is the data controller of your personal data, the contact details of which you will find below: 34, rue de La Croix de Fer 78100 Saint Germain en Laye – France; it is referred to by name or “We” herein.


Your personal data and their collection by OASIS SMART SIM EUROPE

Your personal data may be collected during:

your visit to our site,

our exchanges,

our prospecting actions,

the formation or execution of our contracts.

We do not collect any data not necessary for the processing purpose mentioned during the collection or data prohibited by law or regulation.

The collection of certain data may be mandatory or optional and you are informed of the mandatory information. Your personal data may be collected by third party service providers or partners, who comply with European and national regulations on personal data.

Our policy is not to transfer your data outside the European Union; if by exception we do so, this transfer can only take place with a country or an organization subject to an adequacy decision (article 45 RGPD) or presenting sufficient and appropriate guarantees (article 46 RGPD) .

We do not make any automated decisions.


Our processing of your personal data

We process your personal data by entering them into databases; they are stored, kept and if necessary corrected, deleted, archived, anonymized or pseudonymized, transferred to trusted third parties.

We are required to process your personal data for the following processing purposes or for purposes which are specified to you during collection:


Your information on our commercial (products, services …) and promotional offers – Communicate with you

We are likely to use your personal data for commercial prospecting purposes, and in particular to send you information on our products / services, our commercial and promotional offers, quotes and other pre-contractual documents, our news by email, mail or phone.


The execution of your current contracts and customer follow-up

We use your personal data to ensure the execution of current contracts in accordance with your requests. We are also likely to send you all information on your order or your current contracts, their execution, your invoices and contractual documents, advice, the execution of our guarantees where applicable and our legal obligations. We still use your personal data to manage our customer relationship, your requests or complaints, if any disputes and to follow your customer history.


Improving the use of our services and improving our offers

We process your personal data to allow you an optimal use of our services, to improve our offers and products / services, and to follow your user experience, to carry out satisfaction surveys, anonymous surveys and statistics.


Your payments

Your bank details can be collected either directly by us or by a dedicated and selected service provider, which guarantees the complete confidentiality of your bank data and these details are only kept for the time necessary for the duration of the contractual relationship or within the legal limits.


Protection against fraudulent initiatives

The personal data collected can be used to fight against fraud, in particular on payments or direct debits. As such, our payment security providers can be made the recipient of this data.


Ensure respect for the law and court decisions

Your Data may be used to:

– respond to a request from an administrative or judicial authority, a representative of the law, a judicial officer or comply with a court decision;

-ensure compliance with our general conditions of sale / service;

-protect our rights and / or obtain compensation for the damages that we may suffer or limit the consequences thereof; -prevent any act contrary to the laws in force, in particular within the framework of the prevention of the risks of fraud.

We may still need to process your personal data for the following purposes:

– Business relationship

o Protection of goods and people and security by badge

o Sending of marketing campaigns by email, mail or telephone (including via a service provider) Geolocation of users / customers / suppliers

– Security

o Protection of goods and people and security by video surveillance

o Creation of a security directory

– Miscellaneous

o Calendar management

o Electronic signature

– Internet

o Create and manage your user account

o Advertising targeting: We potentially use your data to target advertising on our site or partners by crossing it with other data.

o Customer statistics and surveys: Certain data is processed for statistical purposes, in particular to evaluate and improve the performance of our programs, or to carry out audience measurements on our site. Personal data is then anonymized for this purpose. o

– Managing cookies

oCookies necessary – for the optimized use of the site (for example: identification, basket,

o Performance cookies – (making it possible to establish anonymous statistics and level of traffic on the site) and monitoring and personalization cookies that collect information about your use of the site and allow our offers to be individualized,

o Third-party cookies – to target advertisements that may be of interest to you based on your identified areas of interest (for their issuance and processing, these cookies fall under the policy applied by third parties and not the policy of OASIS SMART SIM EUROPE),

o Analytical cookies – allowing us to understand and analyze your browsing on our site. oo


The basis for processing your personal data

In accordance with the regulations, the processing of your personal data by us is based if it is based on one of the following bases:

– Your consent to the processing of your data by us: you agree to the processing of your personal data by express consent. You can withdraw this consent at any time with our DPO; or The existence of a contract between you and us:

the data processing is then justified by the needs of the execution of the contract; or Our legitimate interest in the processing of your personal data as long as this proportionate interest respects your fundamental rights and your privacy; or The law or regulations in force when this requires us to process and store your personal data.


Modality dates and retention periods for your personal data

We manage your personal data in three phases:

– an active phase where the data is kept for the time indicated below on an “active” basis: your personal data is then accessible only by people with an operational need to access it in order to carry out the authorized processing operations

-an archiving phase (for an additional time to conservation on an “active” basis) when a legitimate reason justifies it: your personal data is then archived with restricted access and for a limited period.

-A deletion or anonymization phase: at the end of the additional archiving within the deadlines below, your personal data are deleted or anonymized (so that they can no longer constitute personal data identifying you). 

Your personal data are kept for the time necessary for the needs of their processing, our customer relationship where applicable and the execution of contracts and within the limits specifically laid down by law; we are likely to keep your personal data in archiving for the purposes of keeping accounting, tax or proof supporting documents for the time of the applicable regulations. By way of example, we indicate below the retention periods that apply to the following processing operations (subject to the regulations imposing a differentiated retention period): 


Purpose of processing

Foundation of treatment

Retention of personal data in the “active” database 

Archiving Additional

Prospecting

Your consent

3 years if you have not actively responded to any solicitation. The deadline will run again in the event of your active solicitation   

X

Fulfilment of our contractual obligations to you (purchase, service, etc.), connection to the site as a registered user) 

Contract

The time necessary for the execution of the contract and 3 years from the end of the commercial relationship (such as 5 years after the end of contract execution) end of contract execution (purchase, service, etc.), connection to the site as a registered user) 

5 years after the contractual Relationship

Customer Relationship


Contract

3 years from the end of the commercial relationship (last activity on your part with us)

5 years after the end of the contractual relationship

Withdrawal of your consent to the collection or processing of your personal data

The consent you granted for the collection of your personal data can be withdrawn by writing to our DPO by email or by post to the addresses appearing in the header mentioning your name, first name, email address and address with the precise nature and purpose of your withdrawal request.

You can also send us any comments on your personal data to OASIS SMART SIM EUROPE 34, rue de La Croix de Fer 78100 Saint Germain en Laye – France 


Exercising your rights over your personal data

You have :

– A right of access, which allows you to obtain:

o Confirmation that data concerning you is or is not being processed;

o Communication of a copy of all personal data held by the data controller.

  • A right to request the portability of certain data: it allows you to retrieve your personal data in a structured, commonly used and machine-readable format.
  • A right of opposition: it allows you to no longer be the subject of commercial prospecting by us or our partners, or, for reasons relating to your particular situation, to stop the processing of your data. research and development, anti-fraud and prevention purposes.
  • A right of rectification: it allows you to have information concerning you rectified when it is obsolete or erroneous. It also allows you to have incomplete information about yourself completed.
  • A right of erasure: it allows you to obtain the erasure of your personal data subject to the legal retention periods. It may in particular be applied in the event that your data is no longer necessary for processing.
  • A right of limitation: It allows you to limit the processing of your data in the following cases

o In the event of unlawful use of your data;

o If you dispute the accuracy of your data;

o If it is necessary for you to have the data to establish, exercise or defend your rights.

They will then no longer be the subject of active processing, and cannot be modified during the exercise of this right.

– A right to obtain human intervention: data controllers may have recourse to automated decision-making with a view to taking out or managing your contract. In this case, you can ask the Data Protection Officer what were the decisive criteria for the decision.

You can exercise these rights by e-mail: DPO@oasis-smartsim.com or by letter to the following address: 34, rue de La Croix de Fer 78100 Saint Germain en Laye – France indicating your name, first name, address and e -mail (if applicable your customer references) as well as the subject of your request in clear and readable terms. OASIS SMART SIM EUROPE undertakes to respond to your verified request within one month of receipt.

In case of difficulty, you can contact our personal data protection officer directly by email: DPO@oasis-smartsim.com or refer to the National Commission for Computing and Liberties (CNIL).


Our subcontractors and partners

OASIS SMART SIM EUROPE may transmit your personal data to subcontractors carrying out services involving processing of your data and in compliance with the purposes referred to herein; these subcontractors must confer on your personal data the same level of confidentiality as OASIS SMART SIM EUROPE and have undertaken to comply fully with the regulations on personal data, in particular with the GDPR.

We do not trade in your personal data; If you want to know more and specifically know the identity of the service providers or partners to whom your personal data has been transmitted, you can contact our DPO at the following address: DPO@oasis-smartsim.com

The service providers or partners likely to access your personal data may, in particular, be:

-providers likely to manage outsourced services for the performance of our services and contracts;

-service providers helping us to improve our services, carry out data analyzes and optimize our offers, carry out surveys and statistics;

-auditors, accountants, consultants, lawyers, audit firm, IT and IT service providers, security providers;

-investors and buyers.

We may also be required to transmit your personal data to French authorities, administrations and courts, in particular in the context of legal action or legal formalities requiring this communication.


Cookies policy

– What is a cookie ?

A cookie is a file placed on your terminal (computer, tablet for example) by OASIS SMART SIM EUROPE when you use the website and depending on your browser. This file will, during its recording period, identify your computer during your next visits to the site, allowing us to keep your visit and navigation data.

OASIS SMART SIM EUROPE may use various personal data collection systems, in particular by means of cookies on our website for which your consent is requested; The following cookies are potentially affected:

OASIS SMART SIM EUROPE is also likely to issue third-party cookies allowing the content of our site to be shared with third parties or tools to express your appreciation (eg: “I like”, from social networks); you are then potentially identified by the social network which can follow your browsing. It is up to you to inform yourself of its confidentiality and cookie management policy, our company being foreign to these tools.

Cookies are subject to your acceptance on our website on your first visit. The period of validity of consent to the deposit of cookies and tracers is 13 months maximum, from their first deposit in your terminal following the expression of your consent.

You can manage your acceptance or refusal of cookies directly from your browser settings.

You can, therefore, either accept all cookies, or be notified when a cookie is placed, or refuse all cookies. If you refuse cookies in whole or in part, some features of the Site may be compromised or some pages may be inaccessible.


  • To disable cookies:

I f you are using Internet Explorer 8. and following:

  1. Go to “Tools” in the menu bar and click on “Internet Options”
  2. Click on the “Privacy” tab at the top Drag the cursor up to the “Block all cookies” setting to block all cookies, or down to the “Accept all cookies” setting to accept all cookies.

For more information, see http://windows.microsoft.com/fr-fr/internet-explorer/delete-manage-cookies

If you are using Firefox 30.0 and later:

  1. Click on the “menu” button and select “Options”
  2. Select the “Privacy” panel.
  3. In the History area, for the option “Retention rules”, select “use custom settings for history”.
  4. Check the “Accept cookies” box to enable cookies, or uncheck it to disable them. If you have problems with cookies, make sure that the “Accept third-party cookies” option is not set to Never.
  5. Choose how long cookies can be kept. Keep them until: “Their expiration”: Each cookie will be deleted on its expiration date, the date set by the site issuing the cookie. Keep them until: “Firefox closes”: the cookies saved on your computer will be deleted when you close Firefox. Keep them until: “Ask me every time”: a warning is displayed each time a website wishes to send a cookie, asking you if you agree to save the cookie or not.
  6. Click on OK to close the “Options” window 


For more information, see https://support.mozilla.org/fr/products/firefox/privacy-and-security/cookies 

f you are using Google Chrome:

1. Go to the “Tools” menu

2. Click on “Settings”

3. Click on “Advanced settings”

4. Click on “Confidentiality / Content settings”

5. “Cookies” must be selected. Then select “Block cookies and data from third-party sites”

For more information, see https://support.google.com/chrome/answer/95647?hl=en 

If you are using Safari 5.0 and higher:

  1. Choose Safari> Preferences and click on “Security”.
  2. In the “Accept cookies” section, indicate if and when Safari should accept cookies from websites. To see an explanation of the options, click the Help button (looks like a question mark). If you have set Safari to block cookies, you may need to temporarily accept cookies to open a page. Repeat the above steps, selecting “Always”. When you are done with the page, turn off cookies again and delete cookies from the page.

For more information, see http://support.apple.com/kb/ht1677?viewlocale=en_FR

If you have a different type or version of browser, we invite you to consult the “Help” menu of your browser.