Confidentiality and Use of Cookies Policy
RingOver

1. Preambule

Upon use of our RingOver service and in the process of sign-up to the service, of which the elements are detailed in article 11 below, the processing of certain personal user information is required (“Personal Data”). The present Personal Data Protection Policy (the “Policy”) is intended to inform users who use the service of what is done by RingOver with Personal Data, with respect to Law no. 78-17 from January 6, 1978, which pertains to information technology, files and liberties (the “Data Protection Act”), of EU Regulation 2016/679 of the European Parliament and Council from April 27, 2016, relating to the protection of physical persons with regard to the treatment of data of a personal nature and the free flow of such data, repealing the directive 95/46/CE (the “GDPR”) (together, the “Applicable Regulation”).

The Policy is an integral part of RingOver’s general terms and conditions of use of the service (“GC”) which must be read in addition to the GC.

The Policy may be modified at any time by RingOver, particularly to conform with any legislative, regulatory, jurisprudential, editorial or technical evolutions. Users must therefore consult the latest version of the Policy before any navigation on the site or use of the service. The purpose of this Policy is to inform you of the manner in which we avail ourselves of and use your information, with the strictest respect of your rights.

2. Why do we collect Personal Data?

RingOver collects and processes personal data for purposes of service provision and oversight of customer relations, informing users of coming changes and offers from RingOver and suggesting services and offers adapted to their use of the site, services and their areas of interest. For these reasons, the party responsible for Personal Data treatment is the company RINGOVER GROUP, simplified joint-stock company, registered with RCS Paris under number 480 234 210, of which the address is 26 rue Friant, 75014 Paris, France, and the telephone number 01 84 80 00 00 (“RingOver”). We carry out treatment of Personal Data only within the legal bounds outlines in the Applicable Regulation. In this context, this treatment is necessary for the conclusion or execution of the RingOver service, and in certain cases for the pursuit of our interests, where your rights and liberties do not prevail.

In particular, user data is used by RingOver for:

- saving your subscriptions to the RingOver service and providing you with a phone number;
- channeling calls from this number to your own phones or those of your correspondents;
- providing statistics for your calls;
- allowing access to your personal space (www.myringover.com and dashboard.ringover.com);
- processing payments for service;
- distributing newsletters or information on your calls; and
- any other use permitting us to improve service.

3. To which services does the Policy apply?

This Policy applies to navigation and sign-up on www.ringover.com, use of the service via personal spaces www.ringover.com and dashboard.ringover.com, and use of the Android and iOS applications made available to users of the service.

4. What personal information do we collect?

In the context of sign-up to and use of our service, RingOver is required to collect, process and store Personal Data for the purposes described in article 2. In particular, RingOver may be required to collect the following Personal Data:

- phone numbers that you have acquired
- all data relative to your incoming and outgoing calls (date, duration, numbers calling or called, etc.)
- your first name, surname and address
- the name of your company and its address
- email addresses provided upon sign-up for sending call notifications
- phone numbers that you indicate upon sign-up and the phone numbers that you use for incoming and outgoing calls
- your bank routing number, if you use direct debit
- your geolocation data (IP addresses) upon sign-up and use of service

5. What we won’t do with your data

We will never communicate your data to a third party (partner, commercial contact, etc.) without your express pre-approval.

6. Who can access your data?

Only a limited number of individuals can access users’ Personal Data. Personal Data are intended (i) for RingOver, (ii) for capable persons authorised by RingOver and needing, as part of their function, knowledge of such for the goals of processing, (iii) for the banking institution charged with transmitting payment for your subscription, (iv) for service providers functioning as subcontractors, which RingOver uses for service provision, (v) and for, where applicable, public organisms in response to legal obligations and judicial injunctions.

Lastly, in case of sale, cessation or merging of RingOver with another company, this data could be shared, including with a foreign entity. Protection measures for Personal Data have been put in place with all of these recipients, notably by means of contractual provisions.

Otherwise, Personal Data is not transferred out of the European Union.

7. What are your rights with regard to your Personal Data?

Subject to express request and proving their identity to RingOver, users have the right to access, rectification and opposition of their Personal Data, as well as a right to deletion, under the conditions of the Applicable Regulation, by informing RingOver at its postal or electronic address mentioned in article 11 of the Policy. Users equally have the right to portability of their Personal Data as well as the right to provide RingOver with instructions regarding the fate of their Personal Data after their death.

In case of exercising of the right to opposition, RingOver will cease treatment of Personal Data, except for legitimate reasons critical to this treatment, or to ensure the recognition, exercise or defense of the user’s rights in a legal setting, in accordance with the Applicable Regulations. Where applicable, RingOver will inform users of the reasons for which their rights cannot be exercised in whole or in part.

8. For what period of time will we keep your Personal Data?

Users’ Personal Data are not kept longer than strictly necessary for meeting the objectives detailed in article 2 of the Policy, in keeping with the Applicable Regulation.

Notably:

- Personal Data gathered to manage opposition to treatment are stored for a maximum period of 3 (three) years counting from acknowledgement of the right to opposition;
- Personal Data processed to meet access and rectification requests are stored for a maximum period of 1 (one) year counting from reception of the requests;
- User Personal Data are stored for the entire duration of commercial dealings with RingOver and for a maximum period of 90 (ninety) days counting from closure of the user’s account;
- User Personal Data are stored for a maximum period of 1 (one) year counting from suspension of the user’s account;
- User Personal Data collected by means of Cookies and other trackers are stored for a maximum period of 13 months;
- Personal Data related to payment can be stored for the period defined by article L. 133-24 of the monetary and financial code, and in all cases for a maximum period of 15 (fifteen) months.

RingOver commits to archive or delete Personal Data once the objective of processing has been attained and the storage duration has been reached.

9. Cookies

RingOver must gather and store users’ navigation data in order to provide and improve the service and websites, optimise the use of certain features, and for statistical purposes. This information is stored by RingOver mainly through cookies, which are small text files installed in the user’s device. We mainly use cookies or other trackers to measure traffic to our websites.

During use of the websites, cookies can be installed in the user’s terminal or other device:

- Navigation cookie: upon first access, these cookies allow the sites to function correctly and help the user to visualise content on their device by recognising their language and the country from which they are connecting. Navigation cookies are technical cookies, necessary to the websites’ function.
- Analytics cookie: these cookies are used to create statistical analyses on site users’ browsing methods. The results of these analyses are processed anonymously and for exclusively statistical purposes, only if the service provider uses cookies related to the browser or other devices used to navigate the sites.
- Third-party cookies: these cookies are installed by third parties to analyse use of the sites and users’ paths. We use certain Google cookies, namely Google Analytics. More information on the use of these cookies is available through the following link:

Data collected with RingOver cookies are kept for a maximum period of 13 months. Cookies emitted by RingOver are used for the reasons described above, and subject to the user’s selections, which result from their browser software settings when using the sites, which they can modify at any time.

Users may oppose the installation of these cookies and delete them in their browser settings. However, deleting these cookies can cause issues with RingOver’s use. The procedure for managing cookies and preferences related to cookies differs slightly between browsers. The user can view the steps for managing cookies in their browser’s help menu with the following links:

Firefox - Chrome - Internet Explorer - Opera - Safari

For a better understanding and mastery of all kinds of cookies, not only those used on RingOver sites, users are invited to consult the site Youronlinechoices, edited by the Interactive Advertising Bureau France (IAB) and the specific page for the CNIL:

- http://www.youronlinechoices.com/be-fr/controler-ses-cookies
- http://www.cnil.fr/vos-droits/vos-traces/les-cookies/conseils-aux-internautes/

10. Data protection/Security

Conforming with the Applicable Regulation, RingOver processes personal data in total security and confidentiality. In particular, RingOver has put in place all technical and organisational measures necessary to guarantee the security and confidentiality of personal data that is gathered and treated, notably preventing their damage, corruption or communication to non-authorised third parties by ensuring a security level adapted to the risks associated with the processing and nature of personal data to be protected, while taking into account the technological level and cost of implementation. For example, our secured payment system uses SSL protocol.

11. Contact us to know more about your data

Please feel free to contact us with any questions about your personal information and the security practices that we have established to protect it. We’ll be glad to respond to your inquiries.

- By email: support@ringover.com
- By post: RingOver - BJT Partners - 26 rue Friant, 75014 Paris, France

RingOver will commit to finding a satisfactory solution to remain in keeping with the Applicable Regulation. In case of no response from RingOver, if the issue persists in spite of our efforts, or at any moment, users have the possibility of filing a complaint with the CNIL or supervisory authority of the member state of the European Union in which they reside.