Updated on: May 25, 2018

The purpose of this Privacy Policy is to inform You about the way We use Your personal data, and protect the data You communicate to Us when using the ONOFF Application. We therefore invite You to read this privacy policy carefully.

For the purposes of this policy, the definitions in the Terms of Use apply.

Contents

1. Purpose
2. What data is collected and processed by ONOFF TELECOM?
3. How is Your data used by ONOFF TELECOM?
4. When can we share Your personal data?
   1. 4.1   Communication with Our affiliates, partners and service providers
   2. 4.2   Transfers to countries outside the European Union
5. Cookies and similar tools
   1. 5.1   What are cookies and similar tools?
   2. 5.2   How are cookies used by ONOFF TELECOM?
6. How is Your personal information protected by ONOFF TELECOM?
7. What are the cases in which ONOFF is likely to contact You?
   1. 7.1   Information about ONOFF TELECOM products and services.
   2. 7.2   Operation of the service
8. WHAT are your rights and HOW TO EXERCISE THEM?
9. How long do we keep YOUR PERSONAL DATA?
10. If you are under 18
11. Notifications
12. Changes to this Policy
13. How to contact Onoff?

1. PURPOSE

This personal data protection policy applies to all personal data of Users of the Application processed by ONOFF TELECOM, a simplified joint stock company, registered in the Paris Trade and Companies Register under number 832 235 253 and having its registered office at 26 boulevard de Bonne Nouvelle 75010, Paris, France, as data controller, under the conditions set out herein.

2. WHAT DATA IS COLLECTED AND PROCESSED BY ONOFF TELECOM?

ONOFF TELECOM may collect and use data concerning You. This includes information collected when You download and use the Application, including when creating the User Account, purchasing Numbers and using features.

When you create your User Account, ONOFF TELECOM may ask You for the following information:

• Your name, first name, password, e-mail address, and where applicable identity documents or proof of Your place of residence when required by applicable regulations;
• Information concerning your profile that you choose to complete (for example your age, sex, country of residence, public profile photo, etc.);

Only the provision of your name, first name, password, email address (and where applicable identity documents or proof of Your place of residence when required by applicable regulations) are mandatory for the creation of your account.

Thereafter, ONOFF TELECOM may collect and process the following information, as part of your use of the Application and your purchases :

• The telephone numbers You have acquired;
• Your traffic data (technical data allowing the transmission of communications, the duration of the call, the numbers called, the category in which they have been placed, etc.);
• Instant messages, SMS and MMS content;
• Your address book (details registered on Your terminal), with Your authorization;
• Your device's electronic identification data (SIM card number, IMEI number, cookies, etc.);
• Your geolocation data, device identifiers and standard identifier of detected Wi-Fi networks.

In addition, as part of Our social network service, You may post User Content (notably on your contacts' wall) which will be processed by ONOFF TELECOM in compliance with this data protection policy. We invite you to refer to the General Conditions of Use for the use of the social network service.

3. HOW IS YOUR DATA USED BY ONOFF TELECOM?

The processing of Your personal data has the following purposes:

• Provide you with an Application offering innovative communications and content sharing services;
• Create, use and store Your User Account;
• Ensure the management of Your Numbers, contacts, conversation groups, etc...;
• Modify and customize the functions and features of the Application;
• Receive and process transactions carried out via the Application;
• Provide you with our assistance and resolve any problems encountered when using the Application;
• Inform you of updates to the Application and Our offers and Services;
• To solicit Your opinions or Your participation in surveys in order to improve Our Services;
• Comply with Our legal, regulatory and regulatory obligations
• Avoid potentially prohibited or illegal activities.

You will find below the legal bases corresponding to the processing purposes:

• Execution of contract or pre-contractual measures
  • Provision of communications and content sharing services ;
  • Creation, use and conservation of Your User Account;
  • Management of Your Numbers, contacts, conversation groups, etc...;
  • Modification and customization of the functions and functionalities of the Application;
  • Receipt and processing of transactions carried out via the Application;
  • Assistance in case of problems encountered during the use of the Application;
  • Soliciting Your opinions or Your participation in surveys in order to improve Our services.
• Legal obligations
  • Compliance with legal, administrative and regulatory obligations
• Legitimate interest
  • Business prospecting
  • In order to offer you offers and services that correspond to your needs.
  • Avoid potentially prohibited or illegal activities.

In order to protect the interests of Users who use the Application in compliance with the Terms of Use and the law as well as the interests of ONOFF TELECOM.

4. WHEN CAN WE SHARE YOUR PERSONAL INFORMATION?

4.1 Communication with Our affiliates, partners and service providers

We never communicate Your personal data to third parties without your prior and express consent, except in the limited cases listed below.

ONOFF TELECOM may be required to communicate Your personal data to third parties acting on its behalf, for the sole purpose of the operation of Our services, and in particular to Our service providers or subcontractors, responsible for the management, hosting, maintenance and administration of the Application and the associated services and transactions.

Your personal data will be communicated in compliance with the provisions of the general regulation on the protection of personal data (No. 2016/679) and within the framework of agreements to ensure compliance with this policy and the confidentiality of Your personal data.

In the event that ONOFF TELECOM is merged, acquired or transferred to another company, all or part of Our activities, We may then share Your personal data with this company, including with companies established outside the European Union, under the conditions and to the extent permitted by applicable regulations and in compliance with the present.

Furthermore, We may be obliged to disclose Your personal data in the context of a law or regulatory provision in force, a court order or regulation, or if such disclosure is necessary in the context of an investigation, or a procedure, on national or foreign territory.

4.2 Transfers to countries outside the European Union

Your use of the Application entails the transmission of Your personal data (surname, first name, e-mail address, use of the Application's functionalities, etc.) for the purposes of hosting, administration and improving the performance of the Application and the services and transactions associated with it to service providers located in countries outside the European Union, in particular in the United States, whose legislation on the protection of personal data differs from that in force within the European Union.

ONOFF TELECOM has implemented the guarantees provided by the applicable regulations to ensure a sufficient level of protection of personal data by regulating transfers through Standard Contractual Clauses established by the European Commission.

5. COOKIES AND SIMILAR TOOLS

Cookies are small text files that are stored on Your device when using certain features of the Application. For more information on cookies, please visit: http://www.allaboutcookies.org/fr/.

5.2 How are cookies used by ONOFF TELECOM?

ONOFF TELECOM uses audience measurement cookies and similar tools to create and generate anonymous statistics on the use of the Application and our websites as well as aggregate data on the use of the Application and our websites.

We use cookies for a variety of reasons detailed below. Unfortunately in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the this site. Therefore it is recommended that you do not disable cookies.

The Cookies We Set

• Account related cookies

If you create an account with us then we will use cookies for the management of the signup process and general administration. These cookies will usually be deleted when you log out however in some cases they may remain afterwards to remember your site preferences when logged out.

• Login related cookies

We use cookies when you are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in.

• Forms related cookies

When you submit data to through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.

• Third Party Cookies

In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.

• This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page.

• From time to time we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimisations our users appreciate the most.

• As we sell services it's important for us to understand statistics about how many of the visitors to our site actually make a purchase and as such this is the kind of data that these cookies will track. This is important to you as it means that we can accurately make business predictions that allow us to monitor our advertising and product costs to ensure the best possible price.

• Several partners advertise on our behalf and affiliate tracking cookies simply allow us to see if our customers have come to the site through one of our partner sites so that we can credit them appropriately and where applicable allow our affiliate partners to provide any bonus that they may provide you for making a purchase.

• We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work the following social media sites including; Facebook, Instagram, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.

More Information

Hopefully that has clarified things for you and as was previously mentioned if there is something that you aren't sure whether you need or not it's usually safer to leave cookies enabled in case it does interact with one of the features you use on our site.

However if you are still looking for more information then you can contact us through one of our preferred contact methods: • Email: support@onoffapp.com

6. HOW IS YOUR PERSONAL INFORMATION PROTECTED BY ONOFF TELECOM?

ONOFF TELECOM takes all the organisational and technical measures necessary to protect Your personal data against any accidental or intentional manipulation, loss, destruction, communication or against any unauthorised access to Your data.

7. WHAT ARE THE CASES IN WHICH ONOFF IS LIKELY TO CONTACT YOU?

7.1 Information about ONOFF TELECOM products and services.

ONOFF TELECOM may send You offers relating to products, services and activities offered by ONOFF TELECOM.

In this context, We comply with the choices You made when You created Your account. Moreover, You can modify Your choices at any time:

• by sending us an email at the following address:[support@onoffapp.com] the email address with which the user creates an account cannot be changed by the user.
• by using the unsubscribe links inserted in Our newsletters or prospecting emails.

7.2 Operation of the service

ONOFF TELECOM may periodically ask You to provide information about Your experiences, which will be used to evaluate and improve the quality of its services, or ask You to rate the application and the new features of the Application. You are under no circumstances and under no circumstances obliged to provide such data.

ONOFF TELECOM may also contact You to inform You of any anomalies and problems related to its services, as well as to provide You with information relating to Your subscription (for example, notification of the expiry of Your subscription to an ONOFF TELECOM number).

8. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?

Within the framework of the treatment which we carry out You have :

• a right of access: You have the right to consult the personal data concerning You that We process and ask that You be provided with a copy;
• a right of rectification: You can ask to correct Your personal data in particular in the event of a change of situation;
• a right of deletion: You may ask Us to delete your personal data under the conditions provided for in article 17 of the general regulation on the protection of personal data (n° 2016/679), in particular when the latter are no longer necessary;
• a right to limit processing: You may ask Us to limit the processing of your personal data under the conditions provided for in Article 18 of the General Data Protection Regulation (No 2016/679);
• a right to data portability: You may retrieve in a structured format the data You have provided to Us when such data is necessary for the contract or when You have consented to the use of such data;
• right of withdrawal: You have the right to withdraw consent given for treatment based on this basis. This withdrawal is valid for the future and does not call into question the lawfulness of processing already carried out;
• a right of opposition: You may oppose the processing of your personal data, in particular for the purposes of commercial prospecting, under the conditions set out in Article 21 of the general data protection regulation (n°2016/67);

You can exercise these rights by sending us a message at the following address: support@onoffapp.com.

You can also lodge a complaint with a supervisory authority.

Note for French users:

You have a right to define guidelines concerning the fate of Your personal data in the event of death which You can exercise by sending a message to Us at the following address: support@onoffapp.com.

You may also object to being solicited by telephone by subscribing to the Bloctel list on the site www.bloctel.fr.

9. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

In accordance with applicable regulations, We keep Your personal data for no longer than is necessary for the purposes for which they are processed.

The personal data We collect when You download and use the Application are converted for the time necessary to manage the commercial relationship and then for 5 years in archive.

Traffic data collected in connection with Your use of the Communications Services is retained for the periods prescribed by applicable law.

If You stop using Your User Account for a period of two (2) years, it will become inactive and will be deleted. You can avoid this by logging into Your User Account at least once every two (2) years. Before proceeding to delete Your User Account, we will send you a notification in order to give you the possibility to keep Your User Account.

When you delete Your User Account or when Your User Account is deleted due to inactivity, We retain some of Your personal data necessary to ensure compliance with Our Terms of Use and to meet Our legal and regulatory obligations. The other personal data associated with Your User Account are deleted.

10. IF YOU ARE UNDER 18 YEARS OF AGE

If You are under 18 years of age, We ask You to obtain the consent of Your parents or legal representatives before providing Us with the data concerning You.

They must contact Us at support@onoffapp.com in order to provide Us with their contact details (name, e-mail address, telephone number) so that they can confirm their agreement and so that We can contact them in the event of a problem or for any additional information. Otherwise, You must refrain from using the Application.

11. NOTIFICATIONS

Your mobile device and the Application must be set up to notify You of incoming calls, discussions and messages when You are not using the Application. If you do not wish to use this feature, You can change Your terminal settings to no longer receive notifications from the Application.

12. CHANGES TO THIS POLICY

We reserve the right to change this Privacy Policy at any time. We therefore recommend that you regularly review this Policy to keep You informed of any updates to its content.

This policy was last amended on May 25th, 2018

13. HOW TO CONTACT ONOFF?

You have the possibility of contacting us for any question relating to the use of Your data, or to exercise Your rights at the following email address: support@onoffapp.com. You can also write to us at the following postal address: OnOffApp OÜ OnOff Telecom SAS, Viru Väljak 2, Tallinn 10111,, Estonia.