PRIVACY POLICY

At MANIFONE, we accord as great an importance as you do for the protection and confidentiality of your private life and more particularly of your personal data. This Personal Information Protection Policy informs you how MANIFONE uses and safeguards the information that you transmit to us, the personal data that we collect and how we treat it, and how you can protect your private life in the context of the services that we deliver within the KiESS application for IOS or Android.

The data controller is the company Manifone, having its registered office at Rue H Becquerel 56000 Vannes – France.

• 1. WHICH PERSONAL DATA IS COLLECTED BY MANIFONE?
  MANIFONE only treats data or types of data if it is strictly necessary in relation to the relevant purposes.
  These categories of data are the following:
• 1) Personal Identification: telephone number
• 2) Usage data: products used, usage amount, etc.
• 3) Client follow-up data: assistance requests, correspondence with the client, etc.

The categories of persons concerned by the processing are:

o Users of our services

• 2. HOW DOES MANIFONE USE YOUR DATA?
  When you provide us with personal data, we use this to bring you information on our products, in the treatment of sales orders, create accounts, provide sales assistance, answer specific questions, provide assistance, reply on reclamations or give you access to other offers or information. We also use the information that we collect to modify our Internet Site, inform our clients about updates to our web site or our products, and contact them about commercial and marketing issues, of which, contract renewal, in relation to their needs and specific interests.
  MANIFONE could provide information in reply to legal or administrative requests. Manifone could also provide data in order to safeguard national security. In each case, MANIFONE will act in conformity with the current legislation in place on data protection.
  Your personal data will only be conserved as long as needed for the purpose of the data collection, which cannot in any case exceed 24 months from the end of our contractual relationship.
  Manifone will be able to justify the fate reserved for personal data at the end of its services. (Destruction, return, …)

• 3. WHAT ARE YOUR LEGAL RIGHTS AND HOW CAN YOU USE THEM?
  Pursuant to Articles 15 to 22 of the GDPR, you have the right to access, correct or delete data which concerns you. You have the right to request the transfer of the latter. You also have the right to prohibit the data processing or to request the limitation thereof. You can request these rights at any time, by contacting the Data Protection Officer email address:
  dpo@manifone.com or by postal address to MANIFONE SAS – DPO, Rue Henri Becquerel, 56000 VANNES, France.
  Any request to exercise these rights must be accompanied by a photocopy of two different proof of identity. You will receive a reply within one month of the reception of your request.
  In the event that MANIFONE has not replied to you in a satisfactory manner, you may address a complaint to the Commission Nationale de l’Informatique et des Libertés (CNIL), the French administrative regulatory body in charge of enforcing data privacy laws.
  In order to avoid receiving phone calls on French numbers from people with whom you do not have a contractual relationship with, you can subscribe freely to the opposition list called « Bloctel ». Each consumer has the right to subscribe on this site www.bloctel.gouv.fr or by post to be addressed to: Société Worldline, Service Bloctel – CS 61311 – 41013 BLOIS - France.

• 4. WHO ARE THE RECIPIENTS OF YOUR PERSONAL DATA?
  The data collected are destined for MANIFONE’s internal services.
  The personal data could also be processed by one of MANIFONE’S partners. This may arise in situations where partners need to intervene for the provisioning of services. It could also be processing that has been offered to you and needs your consent.
  Finally, the personal data processed could also be transmitted to the competent authorities, at their request, in the case of a legal procedure, in the case of legal research and requests for information from authorities and/or in conformity with other legal obligations.

• 5. IS YOUR PERSONAL DATA PROCESSED OUTSIDE THE EU?
  The personal data collected could be apt to be processed outside of the European Union. In that case, MANIFONE takes all necessary precautions in regard to its subcontractors and partners to guarantee an adequate level of protection and this in conformity with current legislation.
  If the subcontractors and partners concerned do not adhere to the Privacy Shield Agreement, in regard to the transfer of personal data towards the United States of America or are not situated in a country where they dispose of a legislation considered inapt to offer adequate data protection, they will have previously signed a « contractual clauses document » edited by the European Commission or will be submitted to internal rules approved by the authorities.

• 6. HOW DOES MANIFONE PROTECT YOUR DATA?
  MANIFONE will ensure a secure and confidential processing of your data. To this effect, every appropriate technical and organizational measure is put in place to avoid loss, bad usage, alteration or deletion of data concerning you. These measures are adapted depending on the level of sensitivity of the data treated and depending on the risk level that presents the treatment or its putting in place thereof.
  These measures may include, where appropriate:
  
  

o Pseudonymization and encryption of personal data;

o The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;

o The ability to restore availability and access to personal data in a timely manner in the event of a physical or technical incident.

o The integration of “Privacy by design” into its development process.

• 7. PERSONAL DATA BREACH
  Manifone will notify any breach of Personal Data as soon as possible, not to exceed 72 hours, after becoming aware of it. This notification must, at a minimum:
  a) describe the nature of the Personal Data breach including, if possible, the categories and approximate number of Your affected individuals and the categories and approximate number of Personal Data records affected;
  b) provide the name and contact details of the Data Protection Officer or other point of contact from whom further information may be obtained;
  c) describe the measures taken or proposed to remedy the Personal Data breach, including, where applicable, measures to mitigate any adverse consequences.

• 8. COOKIE MANAGEMENT
  When consulting the MANIFONE Sites, Cookies are placed on your computer, mobile or tablet.
  A Cookie is information placed on your browsing device by the server of the Site visited. Certain parts of the Site may therefore not be functional without the acceptance of cookies by the user.
  The information collected through this will only be used to monitor the volume, type and configuration of traffic using this Site, to develop its design and layout and for other administrative and planning purposes and more generally to improve the service we provide to you.
  This information will not, unless you agree, be kept for more than 13 months.
  You have the option of disabling Cookies from your browser settings.
  For more information :
  
  

o https://www.cnil.fr/fr/site-web-cookies-et-autres-traceurs

o https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser

Functional cookies
A cookie is read or transmitted by the website server to your browser, which saves it on your device. Each cookie is assigned an identifier which allows its issuer to identify the terminal in which it is registered during the period of validity or registration of the cookie concerned. Functional cookies are used to guarantee the important functionalities of the site.
The session cookie reserved for people with a Manifone account. It is reserved for people who are identified on the Manifone/Manivox/Manidirect sites. It is placed on the browser when the user arrives on a page of the site as soon as he is identified by his Customer account. This cookie is attached to the account holder. It provides access to its customer area and its communication services.

Statistics cookies
These cookies make it possible to establish statistics of visits to these sites and to detect browsing problems in order to monitor and improve the quality of our services.
You can configure your browser at any time to express and modify your wishes in terms of cookies and in particular regarding statistics cookies. You can express your choices by setting your browser to refuse certain cookies. If you refuse our cookies and those of our key partners, your visit to our sites will no longer be counted in our traffic measurement tools, but you will no longer be able to benefit from a certain number of functionalities which are nevertheless necessary to navigate in certain areas of our site.
We inform you that you can however oppose the registration of cookies.

How to manage cookies?
Several possibilities are offered to the User to manage cookies. However, it is specified that any configuration made by the User is likely to modify Internet browsing and the conditions of access to certain services requiring the use of cookies.
The User can choose at any time to express and modify his wishes in terms of cookies, by the means described below.
Settings of your browser:
For Chrome:
https://support.google.com/chrome/answer/95647?hl=fr&hlrm=en
For Internet Explorer
http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-Cookies
For Firefox
http://support.mozilla.org/en/kb/cookies-information-sites-register?redirectlocale=en&redirectslug=G%C3%A9rer+les+cookies
For Opera
http://help.opera.com/Windows/10.20/en/cookies.html

• 9. MODIFICATION OF THE CONFIDENTIALITY POLICY
  The present policy concerns all the contracts, services and web sites of MANIFONE. This policy could be amended following legislative and regulatory changes.
  Last update 19/10/2022