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Privacy policy and personal data management

Preamble

We value transparency and clarity and aim to build strong and lasting relationships with our clients based on trust and mutual interest. In line with this objective, we believe that the protection of your personal data is essential. Thus we wish to inform you through this “Personal Data Protection Policy” of the manner in which we collect and process this data, but also how you can control their use.

This policy is consistent with the European Personal Data Protection Regulation (GDPR), which came in application on May 25th 2018.

Definitions

Personal data: Every data that permit to identify directly or not a natural person

The data controller: The easyOne S.A.M. is responsible for the processing of personal data collected directly or indirectly from visitors to the www.easyone.mc website and users of the service. In this capacity, we guarantee that your data will be processed in compliance with the European Personal Data Protection Regulation (GDPR).

Processing of personal data: “Processing” means any operation or set of operations carried out on personal data, such as collection, recording, use, transmission or communication.

Subcontractor: Legal entity that processes personal data on behalf of the controller.

Telis Group: easyOne S.A.M. is a subsidiary company of the Telis Group.

Security and confidentiality

The easyOne S.A.M., as controller, shall determine and implement the means necessary to protect personal data processing systems in order to avoid, as far as possible, any malicious intrusion and prevent any loss, alteration or disclosure of data to unauthorized persons.

Indeed, we identify and implement technical and organizational measures to guarantee the confidentiality of data in accordance with the requirements of the CCIN and the GDPR.

And in particular:

  • Designation of a Personal Data Protection Officer (DPO): A DPO within the TELIS group has been appointed for the easyOne S.A.M.

The DPO is in charge of all the missions foreseen by the GDPR, and of complementary missions. In addition, it is able to answer all your questions concerning the application of the above mentioned regulation.

  • Awareness of the processing of personal data, and the commitment to respect the GDPR, of all our employees.
  • Complex passwords with regular resets.
  • Securing workstations: all necessary measures are taken (antivirus, anti-malware and firewall)
  • Backup and business continuity (a secure backup and archive management system)
  • Physical security: our premises are physically secure (access codes, alarms).

Collected personal data

The easyOne S.A.M. collects data to provide services to clients and to exploit the group’s activities. Some of this data is provided directly, especially when the user fills out a contact form, to send a request to the company. We also receive data by recording how users browse our site, for example by using technologies such as cookies, receiving error reports, or usage data from software.

Personal data collected by easyOne S.A.M can include the following elements:

  • last name, first name
  • e-mail
  • personal address / professional address
  • personal phone number / professional phone number
  • request short description
  • job title
  • message content

The easyOne S.A.M. ensures the collection and processing of relevant, adequate, non-excessive and strictly necessary personal data for the attainment of the purposes previously determined. And takes all necessary steps to ensure that your data is accurate, complete and, if necessary, updated.

Moreover, the easyOne S.A.M. undertakes to collect the consent of the persons concerned as soon as it is required and to inform them of the processing of their data.

Exclusion of any sensitive data: The easyOne S.A.M. does not collect any sensitive data on its website. Sensitive data include: racial or ethnic origin, political opinions, religious or philosophical beliefs, union membership, health or sexual orientation data. If such information were in any way communicated to the easyOne S.A.M. it will be deleted.

Purpose of the collection

Processing of your personal data by easyOne S.A.M. and the TELIS group, answers to determine and explicit purposes:

  • Answer with efficiency to users that contact us by the contact form
  • Permit to users to discover all of our products and solutions
  • Permit to users to ask information about our services.
  • Identify users that wish to contact easyOne S.A.M.
  • Identify user needs to provide the most appropriate services.

easyOne S.A.M. and the TELIS Group are committed to processing and collecting your personal data fairly and lawfully.

easyOne S.A.M. and the TELIS group guarantees that, in this context, the legal basis of the aforementioned treatments is the legitimate interest of easyOne S.A.M. and the TELIS group, more specifically their economic interest in continuously improving their sites and services and understanding your needs to meet your expectations.

Recipients and data transfer

The personal data collected on the websites of the TELIS group, are intended only for the TELIS group and processed by our subsidiaries, or even to any service providers.

In any case, the personal data of our employees are only communicated to authorized and specific recipients.

The information system of the website of the easyOne S.A.M. is located in Monaco, therefore a data transfer is carried out from the moment a connection is made outside Monaco. Nevertheless, easyOne S.A.M. guarantees you a level of protection of your personal data in accordance with the GDPR.

Retention of personal data

All personal data collected shall be retained for a limited period depending on the purpose of the processing and the shelf-life provided for by the legislation in force.

Cookies

You are informed that, during your visits to our websites, cookies (login cookies) can be installed on your browsing software to allow you, optimal navigation, in compliance with the GDPR. Cookies are data stored in the user’s terminal equipment. They are used by our websites to send information to the browser of the user, and allow this browser to return information to the original site (for example a session identifier, the choice of a language or a date). However, no personal data are collected via tracer systems.

For more information please consult our cookie management policy by clicking on the following link: More about cookies management

Rights of the concerned people

All means necessary to guarantee the effectiveness of your rights to personal data are implemented by easyOne S.A.M. in accordance with the GDPR, namely:

  • The right of access: You have the right to obtain confirmation that personal data about you is or is not processed and, when it is processed, to obtain access to and a copy of such data.
  • The right of rectification: You have the right to obtain rectification of personal data concerning you that are inaccurate.
  • The right to erasure: In some cases, you have the right to obtain the erasure of your personal data. However this right is not absolute, in fact the easyOne S.A.M. may have legal or legitimate reasons to keep said data.
  • The right to portability: that is, in some cases, the right to receive the personal data you have provided to us in a structured format, commonly used and the right to transmit this data to another controller, where technically possible. This right applies only when the processing of your personal data is based on your consent or on the performance of a contract and is carried out using automated processes.
  • The right of opposition: You have the right to oppose at any time, for reasons relating to your particular situation, to a processing of personal data concerning you when said processing is based on the legitimate interest of the easyOne S.A.M.
  • The right to lodge a complaint with a supervisory authority: You have the right to contact a supervisory authority in order to lodge a complaint concerning the practices relating to the protection of personal data of easyOne S.A.M. or the TELIS group.

To exercise these rights, you can contact our DPO by mail at: easyOne S.A.M. to the attention of the Data Protection Officer 14 avenue de Grande Bretagne “Le George V” 98000 Monaco, or by email with proof of your identity at Write to easyOne's DPO

Policy modifications

The easyOne S.A.M. may update this Data Protection Policy at any time to adapt it to any new regulations or practices. It is then up to you to check any updates to this data protection policy on the websites of the TELIS group. If significant changes are made, you will be notified through information on our websites.

Contact

If you have any questions about this personal data processing policy, you can contact us:

  • By sending a letter to our Data Protection Officer at the following address: easyOne S.A.M. to the attention of the Data Protection Officer 14 avenue de Grande Bretagne “Le George V” 98000 Monaco.
  • By sending an email to our Data Protection Officer at: Write to easyOne's DPO