The protection of your personal data is an essential part of our relationship.
In accordance with the French Data Protection Act and the General Data Protection Regulation (RGPD), Netwo is committed, within the framework of its activities, to ensuring the protection, confidentiality and security of personal data. This is achieved by implementing adequate technical and organisational measures to guarantee processing in compliance with the RGPD. The purpose of this policy is to inform you about the categories of personal data we process, the purposes of the processing applied to your personal data and their retention period, and your rights regarding your personal data, etc.
2. What is personal data?
Article 4 of the GDPR defines personal data as "any information relating to an identified or identifiable natural person [...]; "a natural person [...] can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity".
3. What categories of personal data do we process?
Our teams take care to collect and process only the personal data necessary to carry out the services subscribed to within the framework of our activities.
In this respect, we may collect various categories of personal data from our customers by means of telephone recordings agreed to or resulting from the use of our products/services, in particular:
Identification data (e.g. surname, first name, Siren number, etc.))
Contact data (e.g. postal address, e-mail address, telephone number, etc.)
Connection and usage data (e.g. IP address, connection logs, etc.)
Financial data (e.g. means and history of payment, etc.)
Commercial data (e.g. type of service/product from which our customers benefit)
HR information (e.g. CV, cover letter, etc.)
4. Why do we process your personal data?
All personal data we process has specified, explicit and legitimate purposes in accordance with the GDPR.
In this context, your personal data may in particular be processed for the following purposes:
Contract performance purposes
Management of your subscriptions and your use of our services
Authentication and identification on our customer portals
Customer communication in the context of technical maintenance operations
Management of orders and invoices
Processing of complaints and cancellations
Hosting of customer data
Follow-up of application files submitted on our website
Fighting against fraud
Managing unpaid invoices
Deploying Netwo products and services xml
5. Who processes your personal data?
In order to accomplish the purposes mentioned above, this personal data is transmitted only to authorised and competent recipients, in accordance with the regulations in force, namely:
- Netwo's internal departments and subcontractors
- Netwo's partners and possible service providers
- Competent authorities on their requests in response to legal proceedings
In some cases, we may transfer your personal data to our European subsidiary which has national legislation on personal data protection and a data protection authority recognised by the International Conference of Privacy and Data Protection Commissioners.In this event, we take all necessary steps to ensure that such processing is supervised and secured to ensure an adequate level of protection in accordance with the applicable regulations.
6. How do we secure your personal data?
We have defined technical and organisational measures to ensure the protection of your personal data. The measures take into account the nature of the data and the level of risk that the processing presents.
To this end, we have put in place:
An Information Security Policy (ISP), previously established as part of our ISO 27001 certification
An approach based on risk management and control
Security of physical and logical access
Security of operations Security of assets
Security in relations with subcontractors
Management and security of human resources (internal campaigns to raise awareness of the protection of personal data and the security of information systems, and an information technology charter appended to the internal regulations)
7. How long will your personal data be kept?
We retain your personal data for periods of time to meet legal and contractual obligations and to fulfil the purposes set out above.
The length of time we retain this data may depend on the service subscribed to. These periods are described and kept up to date in the RGPD document repository. In particular, telephone recordings are kept for a maximum of 6 (six) months.
When required by law, we keep certain information for a period of time necessary to comply with the legal and regulatory provisions applicable to our activities.
8. What are your rights?
In accordance with the GDPR, you have various rights in relation to your personal data, namely: a right of access, a right to portability, a right to rectification, a right to erasure, a right to restriction and a right to object. It is therefore important that the information you provide to us is accurate and up to date, and that you inform us without delay of any significant changes concerning you.
9. How to exercise your rights?
Internal procedures allow us to process requests for the exercise of rights within the time limits set. Responses also depend on whether there is a technical constraint or legal exemption.
10. Have we appointed a DPO?
In order to underline our commitment to the protection of your personal data, and in compliance with the RGPD, we have appointed a Data Protection Officer (DPO), registered with the CNIL.
This mission is part of a specific organization set up to ensure the most appropriate structure to ensure the confidentiality of your personal data: the DPO committee, composed of various Netwo employees, each with expertise in his or her field (legal, technical, quality, etc.)
You can contact our DPO committee by post at the following address:
35 rue des Jeûneurs
Or by email at the following address: firstname.lastname@example.org
11. Making a complaint to the CNIL
You can also file a complaint with the CNIL via its website https://www.cnil.fr/, in certain specific cases, via the online complaint teleservice; in other cases not covered by the teleservice, via the "Need help" service or by post by writing to :
3 Place de Fontenoy
TSA 80715 - 75334 PARIS CEDEX 07
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