Confidentiality and Use of Cookies Policy
RingOver

Information notice on the protection of personal data

1. Preamble

Upon use of its services, RINGOVER GROUP, of which the contact information is stated hereafter, is compelled to treat your personal data. RINGOVER GROUP commits to ensure the protection, confidentiality and security of your personal data, which constitute an essential element of our relationship, in compliance with law no. 78-17 from 6 January 1978 relating to data, files and freedoms as well as (EU) Regulation 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of physical persons with regard to the processing of personal data and the free movement of such data (“GDPR”), (together the “Applicable Regulations”).

The present notice on the protection of personal data (the “Notice”) describes: (i) the type of information that we are required to gather about you or that you are required to provide us; (ii) our practices related to the gathering, use, protection and communication of said personal data as well as (iii) the purposes for which RINGOVER GROUP will use your personal data. Please be aware that RINGOVER GROUP will not sell your information to any third parties.
The present notice on personal data protection is intended to clarify the nature of the personal data that we collect, the goals and legal basis of their treatment, your rights related to your personal data as well as the length of time for which these data are kept and the security measures put in place to protect them.

The terms beginning with a capital letter not defined in this Notice will have the meanings given to them in our General Terms and Conditions, accessible here.

2. What personal data do we collect?

Personal data, as defined in article 4 of the GDPR, that we collect are treated by RINGOVER GROUP, the party responsible for this treatment, for purposes of provision of the Services, client relations management and to inform you of coming changes and offers adapted to your use of the site and areas of interest.

RINGOVER GROUP may thus be required to gather, treat and store the following personal information:

- information allowing you to be identified and contacted (first name, last name, email, proof of identity, postal code, address, phone number);

- information permitting use of the service (email, IP address, usernames, call and text message logs, voicemails), information related to your incoming and outgoing calls (date, duration, numbers calling or called, etc.), documents necessary to carrying out incoming portability (last invoice from the operator(s) of the phone number(s) concerned by the portability, operator identifiers, proof of residence as well as completed portability mandate and your bank routing number if you use direct deposit); also information created by your needs upon use of the Service (phone contacts imported or created by Users, call comments, tags, greetings, hold music, data necessary to the integration of professional tools;

- information related to your commercial dealings with RINGOVER GROUP (summary of exchanges (subscriptions, options, commitment duration), status of invoices and payments);

- information that you voluntarily provide RINGOVER GROUP, i.e. recorded phone conversations in case of activation of this feature, and in the case of use of the RingOver Android or iOS apps, the app can access contacts in your User phone for the sole purpose of allowing you to call these contacts via RingOver. The contacts in your phone are not imported to our servers.

3. Why do we collect your personal data?

We collect and treat your personal data in conformity with the Applicable Regulation in order to provide you with quality services while respecting your rights and liberties. Your personal data can thus be used for the following purposes:

- client relations management;

- recording your Subscription to the Service and attributing a RingOver number;

- call, fax and text message routing;

- integrations with your professional tools

- management of contacts and user sound files;

- generating and providing statistics on your calls;

- access to and use of your personal space (www.myringover.com and dashboard.ringover.com);

- payment management;

- managing signatures for contractual documentation;

- sending newsletters, updates and other information on your calls;

- improving the Service.

The treatment carried out by RINGOVER GROUP complies with the Applicable Regulation and happens exclusively on one of the following legal bases for (i) execution of contracts signed with you, (ii) the protection of our legitimate interests so as not to conflict with your fundamental rights and freedoms, and (iii) respecting our legal and/or regulatory obligations, notably as a telecom operator registered with ARCEP. Finally, RINGOVER GROUP may treat your personal data in the context of any judicial proceedings or in order to meet our judicial obligations, including but not limited to requests by an administrative or competent judicial authority, in view of applicable laws.

4. Who has access to your personal data?

Your personal data are for (i) RINGOVER GROUP, (ii) personnel enabled and authorised by RINGOVER GROUP who require, as part of their function, certain knowledge to meet processing goals, (iii) the banking establishment in charge of transmitting fees for your subscription to the Services, (iv) service providers functioning as subcontractors, upon whose assistance RingOver relies in providing service (such as our electronic signature provider), and, if necessary, public organisations in response to legal obligations and judicial injunctions.

Only a limited number of individuals can thus access Client and User personal data, with it understood that protection measures for Personal Data have been put in place for each party having such access, notably by means of contractual provisions.

5. Where are your personal data stored?

All personal data are stored on our servers in France. We have equipment in 6 points of presence in the Paris region and overseas departments. We do not use subcontractors for data storage.
Occasionally, it is possible that certain personal data that we have collected for provision of the Services may be transmitted to subcontractors situated outside the European economic area or a third party country that does not provide a level of data protection recognised as adequate by the European Commission. In this case, we will implement the guarantees provided by the Applicable Regulations in order to ensure an adequate level of protection of the data transferred to these service providers; in particular, standard European Commission contract clauses, Privacy Shield certifications or rules of confidentiality restricting these subcontractors.

6. How do we ensure the security of your personal data?

RINGOVER GROUP has put in place all technical and organisational measures necessary to guarantee the security and confidentiality of personal data collected and treated, notably preventing their corruption, damage, or communication to non-authorised third parties while ensuring a level of security adapted to the risks associated with processing and the personal data to be protected, with full consideration of the technological level and cost of implementation.

Calls passing through RingOver’s applications are encrypted (DTLS-SRTP). Requests to the API are made in HTTPS only (TLS).

Incoming and outgoing (except intra-RingOver) calls are transmitted via direct interconnections with the telecom operators (Orange, SFR, Belgacom, Tata etc.) assuring their transit.

Whatever the cause, RINGOVER GROUP will commit to make known any incidental violations of personal data, in compliance with the provisions of articles 33 and 34 of the GDPR. Notably, RINGOVER GROUP commits to inform Clients and Users concerned by personal data violations that may put at risk their rights and liberties, and to do so in simple and clear terms describing the likely consequences of the breach as well as the measures implemented by RINGOVER GROUP to remedy this breach, including those aimed at mitigating any negative consequences.

As a reminder, each User and Client plays a role in the protection of their personal data with respect to the rules prescribed in the general conditions of sale, notably those related to login information.

7. How long will your personal data be stored?

Your personal data are kept for the length of time necessary for meeting the legal and contractual obligations undertaken by RINGOVER GROUP. The duration of data storage depends thus on their nature:

- client and user identification data are stored for the duration of the contract plus a year after its termination;

- login and usage data are stored for a maximum period of 12 months;

- recorded conversations are stored for 12 months, unless you manually delete the files;

- call logs, faxes and text messages are stored for 12 months;

- cookies are stored for a maximum period of 13 months;

- data created by Users are stored for the entire duration of the contract or until deletion by Users, with it understood that no element is saved after deletion.

When the law requires, RINGOVER GROUP will save certain information for the period necessary in order to comply with applicable legal and regulatory provisions, in the context of our activities as telecom operator.

8. What are your rights with regard to your personal data?

Subject to express request and proof of their identity to RINGOVER GROUP when necessary, Clients and Users have the right to access, rectify and delete their personal data, as well as the right to oppose or limit the processing of their personal data, by contacting RINGOVER GROUP at the address or phone number specified in the first article of this Notice.

Clients and Users also have the right to portability of their Personal Data as well as to provide RINGOVER GROUP with directives related to treatment of their data after their death. Otherwise, once Clients and Users have given consent as to a particular form of treatment, they still have the right to rescind consent at any moment.

In case of exercise of the right of opposition, RINGOVER GROUP would cease all treatment of personal data, except for legitimate reasons imperative to such treatment, or to ensure the observation, exercise or the defense of our rights in court in accordance with applicable regulations.

9. How can you exercise your rights related to your personal data?

You simply need to contact the person responsible for Personal Data treatment at the company RINGOVER GROUP, simplified joint-stock company registered with RCS Paris under number 480 234 210, of which the headquarters is located at 26 rue Friant, 75014 Paris, France, and the telephone number +33 (0)1 84 80 00 00 (“RINGOVER GROUP”).

You will receive a response within a maximum delay of one month, with it understood that a response could take longer, depending on the complexity of the request and number of requests to be processed. You will therefore be informed within one month of receipt of your request of any prolongation and the reasons for it.

10. Modification of the Notice

We are likely to modify this Notice from time to time in order to reflect changes in our policies, to clarify our practices or to continue to meet regulations.

In this case, you will be informed by a message on this site inviting you to consult the updated Notice.

Information concerning the use of cookies

Among Personal Data, RINGOVER GROUP collects data with cookies during browsing of the websites Ringover.com or Myringover.com ("Site") or the RingOver Application.

A cookie is a small text, image or software file that is placed and stored on the User’s or Client’s computer, smartphone or any other device allowing internet browsing (“Terminal”).

Cookies are very useful for allowing a website to recognise a User or Client, marking their passage from one page to another and bringing additional benefits such as: increased ease of browsing, secured connection and adaptation of web page content according to their preferences and Terminal.

A cookie does not directly identify a user (it does not contain names or first names), but rather your Terminal’s browser or the application used. However, it allows the actions of the same user to be followed using the unique identifier contained in the cookie file. The term "cookie" is also used generically to refer to other similar technologies such as web beacons or invisible pixels, which are small digital images invisible to the user integrated on web pages or in emails and associated with the placement of cookies used to track and analyse the same user’s navigation.

The information stored by cookies, during a period of limited validity, includes pages visited, advertisements on which the User clicks, the type of browser used and their IP address as well as the information they have entered on the Site.

Types of cookies used on the Sites

1. Technical and feature cookies

Technical cookies include the cookies necessary to obtain information required for navigation of our Site and applications (session identifiers, your operating system version, and the version of the application used), allowing you to use principle features of the site or application. Feature cookies allow you to access specific features and be recognised, marking your movements from one page to the next as well as improving your ease of navigation: adapting site presentation to your Terminal’s preferences (language used, resolution), memorising passwords and other information using forms you have filled out on the Site or Application (sign-up or access through the MyRingOver space). Technical cookies also allow the implementation of security measures (for example, when you are asked to log in again to the MyRingOver space after a certain period of time has elapsed).

We do not ask your permission for the placement of these cookies. Nonetheless, you can object to the use of these cookies and delete them in your browser settings, although such a step may prevent you from being able to access the Site, the Application or services.

These cookies have a very short lifespan: strictly necessary cookies last for the duration of the session, and for feature cookies, from a few hours at least to a year at most.

2. Analytical and traffic measuring cookies

Cookies measuring traffic are emitted by us or by our technical contractors.

Cookies are used for statistical analysis of the navigation modalities for Users of the Site and Application. The results of this analysis are treated anonymously and exclusively for statistical purposes, and only if the service provider uses cookies related to the browser or other Terminals used to navigate the Site.

In addition to traffic analysis, they allow, if necessary, the detection of navigation problems, therefore improving the practicality of our services.

The traffic analysing services used by the Site and Application produce and send to our technical service providers only aggregated statistics and traffic volumes, with the exclusion of any individual information.

These traffic analytics cookies will not last beyond 13 months.

We also use tools to measure the effectiveness of our email campaigns, which enable us to engage in relevant commercial actions based on information collected (for example, sending a new message or a personalised offer).

You can choose to opt out of analytics cookies from your browsing data. To do this, please find the necessary information following this Notice.

3. Advertising cookies

Use of advertising space on our Sites and Application contributes financially to the content and services that we provide to you. Use of advertising cookies allows you to view ads or follow sponsored links that we determine (or that our partners determine) to be most adapted to your user profile according to your areas of interest, your Terminal, your browsing history or geographic position. It also allows ads from other sites to be adapted to your user profile.

The relevance of public content opened on our Site or third party sites can be achieved thanks to third party technology, through the association of navigation information on the terminals that you use to connect to our Sites and Application or other sites or applications, and with the data you provide to us during your registration or access to any of our services.

To prevent the use of third party cookies, please find the information necessary following this Notice.

Refusal of these advertising cookies will not impact the use of our Sites or Application. However, refusing them will not block ads. It instead will only result in showing ads unspecified to your areas of interest.

4. Sharing cookies (social media)

Our Sites and Application contain cookies for links to Facebook and other social media sites, allowing you to share content from our Site with others, make them aware of your tips or opinions concerning the Sites or Application, or even to connect in order to access the entirety of RINGOVER GROUP services via your login information on these social media networks.

This is notably the case with sharing buttons for such social media sites as “Facebook,” “Twitter,” or “”LinkedIn,” which are present on our blog, for example. The social networks providing these buttons are likely to identify you with them, even if you do not use them while consulting our Sites and Application.

These cookies are directly placed by the social media networks. If you are connected to social media while browsing our Sites and Application, the buttons allow content to be shared via your user account.

We invite you to consult these social media networks’ policies on the protection of private life to become more aware of the uses of navigation information, mainly for advertising purposes, gathered through these application buttons.

These cookies do not last longer than 13 months.

Your preferences on cookie placement

When you access the Site or use the Application, you have the possibility of adjusting the settings for cookie placement on your Terminal, notably via the information banner appearing when you access the Site.

You can prevent the placement of all cookies except technical cookies essential to the functioning of the Site, or you can manually prevent the placement of each type.

Otherwise, you have other options for managing cookie types.

Cookie settings in your browser

You can block cookies using dedicated browser settings, in incognito mode or with your browser’s “Do Not Track” setting.

Depending on the browser, the User has the following options: accept or reject cookies of all types and origins, or program a pop-up window asking for User permission each time a cookie is placed on the Terminal.

To refine or review options, Users can refer to the help menu or the dedicated section of their browser.

- for Internet Explorer™ : http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies

- for Safari™ : https://support.apple.com/fr-fr/guide/safari/sfri11471/mac

- for Chrome™ : http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647

- for Firefox™ : https://support.mozilla.org/fr/kb/autoriser-bloquer-cookies-preferences-sites

- for Opera : https://help.opera.com/fr/Windows/10.20/fr/cookies.html

2. Mobile terminal cookie settings

On mobile devices, the placement of advertising cookies can be modified directly in the Terminal’s settings.

You’ll find information on the steps to follow for the main mobile operating systems:

Apple / IOS: 1. Settings / 2. Privacy / 3. Advertising / 4. Disable "Limited Advertising Tracking" to disable iAd Tracking (Apple's Ad Network)

Android: 1. Open / 2. Account or Sync (depending on your device) / 3. Google / 4. Privacy or Announcement (depending on your device) / 5. Click “Deactivate interest-based ads”

Windows: 1. Settings / 2. Ads Settings / 3. Edit Options

The procedures described above are those existing at the time of the writing of this manual; operators of these operating systems may at any time modify the procedures to access these settings.

3. Cookie settings via a platform for managing cookies

For better understanding and control of cookies of any origin, not only those on our Site, Users are invited to consult the site Youronlinechoices, published by the Interactive Advertising Bureau France (IAB), to find out what companies are registered on this platform and which among them offer the possibility to reject or accept cookies they use, in order to adapt the navigation information and advertisements displayed on the Terminal.





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