This privacy policy is effective as of July 2022.
STREAMWIDE SA, owner of TOTR NFC WRITER has always been committed to the protection of privacy and personal data.
When STREAMWIDE (hereinafter “STREAMWIDE” or “we”) collects and processes personal data for its own account and the needs of its own personnel, it acts as a Data Controller (hereinafter “the Controller”) and thus determines the means and purposes of the processing within the meaning of Article 4 of the EU Regulation 2016/679 of April 27, 2016 (“RGPD”) on the protection of individuals with regard to the processing of personal data and on the free movement of this data.
When STREAMWIDE processes personal data in accordance with the instructions of its clients, who are the data controllers, it acts as a processor.
This Privacy Policy sets out the basis and principles under which we
will process and use the personal data that we collect about you or that you provide to us when you use the TOTR NFC WRITER application (access, download), and/or related services (together “the Application”). Please read the following carefully to understand our policies and practices regarding your personal data and how we handle it. If you do not agree with this policy, you are not authorized to access and use the Application.
This Privacy Policy only covers data processing carried out by
STREAMWIDE as a Data Controller. Where the processing is not defined by STREAMWIDE, please contact the relevant Data Controller to access their policies and practices to learn more about the processing of your personal data.
Changes and Updates to this Privacy Policy
We may change this Privacy Policy at any time. Any changes we may make in the future will be posted on the Application and we will notify you by email of the revised version.
Collection and reception of information
When collecting your personal data, STREAMWIDE respects the principle of data minimization, set forth in Article 5 of the GDPR, according to which the data collected must be adequate, relevant and limited to what is necessary for the purposes for which they are processed.
We may collect and process the following information based on your allocated role when using the Application
The customer is fully responsible for the information and content transmitted to the system on his own behalf or on behalf of the users of the Application in his company.
Information provided by the Admin: the information provided to us upon registration as an Admin, namely: company name, email address, billing information, information used to create users in our system, as mentioned below.
Information provided by the User: the information you provide to us when you register as a user (customer organization, administrator and end users) and throughout your use of the Application, such as (but not limited to) your cell phone number, email address, usernames, various identifications (rank or position within the organization) and passwords.
We do not copy, store or archive the content of messages delivered by the Application, except in the following cases:
(a) upon failed delivery, captured messages may be retained on our servers for up to 30 days (or 7 days if they have a multimedia attachment) for the User to resend. After the 30 or 7 day period (as the case may be), or if the undelivered message has been successfully delivered, we will delete said message from our servers;
(b) where any action required by law, regulation or court order is applicable.
Where STREAMWIDE acts as a processor, the relevant Data Controller may copy, store or archive the content of messages when hosting the operation of the Application. If this is the case, it will be responsible for collecting, copying, storing and archiving your data on its own servers. You are therefore required to check its own applicable privacy policy.
Device Information: For the administration of the Application and related Services, we may collect information about your mobile device that you may use to download and use the Application, including, if applicable, the mobile device’s unique identifiers, operating system, browser type, and information about the mobile network used, as well as the device’s phone number.
Location Information: Users may voluntarily share their location with other users via the Application. If your account holder uses the geolocation feature, your location may be tracked, if the option is enabled on your device.
Log Information: When you use the Application, we may automatically collect and process certain information in server logs, including Internet Protocol (IP) addresses, Internet Service Provider (ISP), click stream data, browser type and language, and page view and time stamp information.
Cookies: TOTR NFC WRITER may use cookies to distinguish you from other users of the Application. A cookie is a small text file containing information about your browsing activity, the main purpose of which is to improve the user experience by customizing the services provided and thus increasing the flow. This helps us improve the quality and design of the Application and create new features, promotions, functionality and services by storing, tracking and analyzing user preferences and trends. We may use cookies and log file information to: (a) remember information so that you do not have to re-enter it the next time you use the Application, (b) provide personalized content and information, and (c) monitor and measure individual and aggregate usage. You can set your Application to store cookies on the device or reject them, either automatically or according to the cookie vendor, or to notify you when a cookie is placed on the device, so that you can accept or reject it.
1. Transfer of your personal data
The data we collect from you may be processed outside the European Economic Area (EEA) by our suppliers and/or our subsidiaries located in Tunisia, Singapore and the United States.
In these cases, we will secure the transfer and processing of your data with an appropriate legal framework through the implementation of the European Commission’s standard contractual clauses (updated version of June 4, 2021) to ensure a high level of data protection.
2. Purpose of the processing and legal basis
We may collect your personal data for various purposes. For each of these purposes, we rely on a legal basis for processing.
STREAMWIDE SA will not process personal data in a manner incompatible with these purposes or with the instructions given by the Data Controller.
- We use your personal data to operate, manage and provide you with the functionality of the Application and associated Services. This processing is necessary for the performance of the contract we have with the Data Controller
- We use your personal data to improve, maintain or administer our Application. When we process your personal data in this regard, we are pursuing our legitimate business interest.
- We use your personal data for marketing purposes. We have a legitimate interest in informing you about our latest products.
- We use your cell phone number without further consent for non-commercial and administrative purposes (such as customer service). We have a legitimate interest in doing so.
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3. Information sharing and disclosure
We may disclose your personal data to any member of our Group, which means our subsidiaries and/or affiliates where applicable. We may also disclose your personal data to trusted third parties :
- If TOTR NFC WRITER, or substantially all of its assets, are acquired by a third party, personal data held by it about its users will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
- Other events that may cause us to use trusted third parties and share your personal information (excluding your address book and related information) may occur such as, but not limited to, customer and user support, hosting services, or other various technical issues.
TOTR NFC WRITER will always require such third parties to take appropriate organizational and technical measures to protect your personal data and traffic data and to comply with any applicable laws in this regard.
We may also disclose your personal data in order to:
- to enforce or apply our terms of use and other agreements or to investigate potential violations;
- protect our rights, property or safety, and those of our other customers. This includes exchanging information with other companies for purposes such as fraud protection and credit risk reduction.
We may also share or disclose non-personally identifiable information, in aggregate or otherwise, with third parties for the purposes of analyzing the use of the Application, administering, providing and further developing the Application or as we deem necessary.
4. Data retention
Except in the case of specific information and personal data for which the storage period is provided for by law, STREAMWIDE stores other information and personal data for a period not exceeding the purpose for which the data is processed.
Your personal data may be retained for up to two weeks after you close or deactivate your account.
5. Your rights
Subject to the conditions provided by the applicable laws, we guarantee the enforcement of the following rights:
- right of access: you can obtain information about the processing of your personal data and a copy of this information;
- right of rectification: when you consider that your personal data is inaccurate or incomplete, you may request that this information be amended accordingly;
- right to erasure: you may request the deletion of your personal data, to the extent permitted by applicable laws;
- right of limitation: you can request the limitation of the processing of your personal data;
- right to object: you may object to the processing of your personal data on grounds relating to your particular situation. You have the absolute right to object to the processing of your personal data for direct marketing purposes, including profiling in connection with direct marketing;
- post-mortem data rights: in accordance with French law, you have the right to define directives for the retention, erasure or deletion of your personal data, applicable after your death;
- right to data portability: you have the right, where appropriate, to receive the personal data you have provided to us or, if technically possible, to transfer them to a third party.
You can exercise your right by contacting us at dpo@streamwide.com. We undertake to reply to you as soon as possible, and in any event within one month of receiving your request.
If necessary, this deadline can be extended by two months, taking into account the complexity and number of requests. In this case, you will be informed of the extension and the reasons for the delay.
You can always file a complaint with the French National Commission for Information Technology and Liberties (Commission Nationale de l’Informatique et des Libertés CNIL) (https://www.cnil.fr).
6. Security
We will take all necessary action to ensure that your data is treated securely and in accordance with this Privacy Policy. Once we receive your information, we will use technical and organizational procedures and security features to prevent unauthorized access.
Whenever we have provided you with (or you have chosen) a password that allows you to access certain parts of the Application, you are responsible for keeping that password confidential. You should not share your password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Therefore, we cannot guarantee, legitimize or ensure the security of any information transmitted to TOTR NFC WRITER, stored in our services, transmitted via the Application or transmitted to or from your phone or mobile device; any transmission is at your own risk.
Some features of the Application may involve the release of your information. When using these features, you should ensure that you do not transmit any personal data that you do not wish to see, collect or use from other users of the Application.
7. Applicable law and jurisdiction
This Privacy Policy and any dispute or claim arising out of or in connection with it, its subject matter or its formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of France and each party irrevocably attorns to the exclusive jurisdiction of the French courts.
