Foreword
This Privacy Policy contains information concerning the Processing of personal data performed by MATOOMA.
In the interests of transparency, MATOOMA provides Data Subjects with a specific policy for the protection of their personal data.
MATOOMA puts in place all of the measures needed to guarantee that its activity complies with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter the “Regulation”) and Law No.78-17 of 6 January 1978 on information technology, data files and civil liberties (hereinafter the “Law”), as amended by Law No.2018-493 of 20 June 2018 relating to personal data protection.
Definitions
CLIENT: Any client of MATOOMA.
CONSENT: Any freely given specific, informed and unequivocal indication of his or her wishes by which the Data Subject agrees, by a declaration or by a clear, positive act, to the Processing of his or her personal data.
RECIPIENT: The natural or legal person, public authority, agency or any other body that receives personal data, whether or not it is a third party to MATOOMA.
DATA PROTECTION OFFICER: The private individual responsible for implementing compliance with the Regulation and the Law within the body that appointed him or her with respect to all processing implemented by said body.
PERSONAL DATA: Any information relating to a natural identified or identifiable person; an “identifiable natural person” is a natural person who 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.
ACCOUNT OPENING FORM: Contractual document created for each Client in order to confirm the creation of the M2MMANAGER account.
M2MMANAGER: Online platform specifically designed so that Clients can remotely manage SIM card orders, those for associated equipment and invoices through personalised access.
DATA SUBJECT:
Any natural person whose personal data are collected by MATOOMA in the course of its business, in particular:
Any natural person browsing the www.matooma.com website, irrespective of the device used (computer, tablet, mobile telephone).
Any natural person whose personal data are on the Account Opening Form, such as:
The Client’s representative;
The people designated as “Main User” and “Additional User” on the Account Opening Form.
DATA CONTROLLER: The natural or legal person, public authority, agency or any other body that, alone or jointly with others, determines the purposes and means of the Processing - in this instance, MATOOMA.
DATA PROCESSOR: The natural or legal person, public authority, agency or any other body that processes personal data on behalf of the Data Controller.
PROCESSING: Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Categories of personal data processed by MATOOMA
In the course of its business, MATOOMA processes the following personal data:
The information provided by Clients on Data Subjects when they fill in the account opening form, such as surname, first name, telephone number and e-mail address.
The information provided by Clients on Data Subjects when filling in the subscription forms for the “MATOONEWS” newsletter, such as surname, first name and e-mail address.
The information collected by cookies on Data Subjects while they visit the www.matooma.com website, such as their IP address.
Data Controller
The identity and contact details of the Data Controller are as follows:
MATOOMA, a French simplified joint-stock company (société par actions simplifiée), registered in the MONTPELLIER Trade and Companies Register under number 751 918 541, whose registered office is situated at 2630 avenue Georges Frêche – entrée 2SIS - LE LINER - ZAC de l’aéroport MONTPELLIER – 34470 PEROLS.
Contact details of the Data Protection Officer
The Data Protection Officer can be contacted at: notificationDPO@matooma.com
Purposes of the Processing
In accordance with the data minimisation principle, the personal data of Data Subjects are limited to what is strictly necessary in relation to the purposes for which they are processed.
MATOOMA processes the personal data of Data Subjects for the following purposes:
Managing the registration of Clients and the orders they have placed on the service platforms.
Executing the agreement concluded by MATOOMA and the Client.
Managing subscriptions to the “MATOONEWS” newsletter.
For analytical and statistical purposes: MATOOMA collects the personal data of Data Subjects who visit the www.matooma.com website by means of cookies, in order to assess the traffic rate of the website and the M2MMANAGER platform. For further details, Data Subjects are invited to consult the cookie management clause in Article 12 of this Privacy Policy.
Legal basis for Processing
The legal basis for Processing the personal data of Data Subjects depends on the purpose for which the data are processed.
The bases for the Processing undertaken are as follows:
As regards the management of the M2MMANAGER platform by the Client and the execution of the agreement concluded with the Client, the Processing is based on the execution of said agreement;
With respect to the management of subscriptions to the “MATOONEWS” newsletter, the Processing is based on MATOOMA’s legitimate interest, in view of its activity of disseminating news and commercial offers to its existing Clients, its potential clients and its partners.
The Processing of data collected for analytical and statistical purposes, by means of cookies, is based on the consent of the Data Subjects visiting the www.matooma.com website.
Personal data recipients
MATOOMA only discloses the personal data of Data Subjects to specific authorised recipients.
These recipients are:
Firstly, the staff and trainees who work for MATOOMA
Secondly, the external providers with which MATOOMA collaborates, such as IT service providers in charge of development, maintenance and hosting services.
Transfer of personal data to countries outside the European Union
MATOOMA informs Data Subjects that it transfers their personal data to countries outside the European Union under the terms and conditions defined in Articles 44 to 50 of the Regulation. Therefore, said transfer shall be authorised subject to an adequacy decision made by the European Commission or, failing that, provided that the appropriate safeguards are put in place and that the Data Subjects have enforceable rights and effective remedies, under the terms and conditions defined by the Regulation and by the Law.
The personal data of Data Subjects is transferred to the United States and Canada.
Personal data retention period
In accordance with the storage limitation principle, MATOOMA processes the personal data of Data Subjects no longer than strictly necessary in relation to the respective purposes as described in Article 5 of this Privacy Policy.
The data retention period is defined as follows:
As regards the service platform management, the personal data of Data Subjects are retained and processed as long as the Clients remain registered, that is, until the end of the agreement and therefore the deletion of their account.
As regards the execution of purchase agreements concluded with the Clients, the personal data of Data Subjects are retained until the end of said agreement.
Data Subject data provided by the Clients in connection with subscription to contact forms including the “MATOONEWS” newsletter are retained for three years from unsubscription from the newsletter.
Audience measurement cookies, used for statistical purposes and collected when Data Subjects visit the www.matooma.com website are retained by MATOOMA for 13 months.
MATOOMA shall delete the personal data of Data Subjects in accordance with the periods mentioned above, without prejudice to applicable statutes of limitations or the expiry of ordinary and extraordinary remedies.
Data Subject rights
The purpose of this Privacy Policy is to inform Data Subjects of the rights they have under the Regulation and the Law.
Data Subjects may therefore ask MATOOMA in all circumstances:
For access to their personal data which it holds;
To correct and erase their personal data; in this respect, MATOOMA recommends that Data Subjects notify it of any changes to their personal data.
To delete their personal data, provided they are no longer necessary for the purpose for which MATOOMA needed to process them.
To restrict the Processing of their personal data, which in some cases means that Data Subjects can ask MATOOMA to temporarily suspend the Processing of their data.
If Data Subjects have given their consent to the Processing of their personal data for any particular purpose, they are also entitled to withdraw it at any time.
Where the Processing is based on consent or the execution of the agreement, Data Subjects may also request portability of their personal data. This means it is possible to receive the data provided to MATOOMA, in a structured, commonly used and machine-readable format, in order to transmit those data to another Data Controller.
Where the Processing is based on MATOOMA’s legitimate interest, Data Subjects are also entitled to object to the Processing.
To be able to exercise the aforementioned rights, Data Subjects are invited to send their request by post to MATOOMA, accompanied by a copy of a valid piece of identity, to the address opposite:
Société MATOOMA, Le Liner, ZAC de l’aéroport de Montpellier Méditerranée, Entrée 2 SIS – 2630 Avenue Georges Frêche – 34470 PEROLS.
Or by writing to the Data Protection Officer at the address opposite: notificationDPO@matooma.com
MATOOMA shall respond to the request within one month from the date its services receive it.
Complaining to the competent supervisory authority
Notwithstanding the rights listed in Article 10 of this Privacy Policy, Data Subjects also have the right to lodge a complaint with the competent supervisory authority. Since MATOOMA’s registered office is situated in France and one of its subsidiaries is based in Madrid, the contact details of the authorities in question are as follows:
In France, the Commission Nationale de l’Informatique et des Libertés (French National Data Protection Commission - CNIL): 3 Place de Fontenoy – TSA 80715 – 75334 PARIS 07. The CNIL is designated as the lead supervisory authority.
In Spain, the Agencia Española de Protección de Datos (Spanish Data Protection Agency - AEPD): C/ Jorge Juan 6, 28001 MADRID
Cookie management
Data Subjects who visit the www.matooma.com website are informed that when browsing the www.matooma.com website, a cookie may be installed automatically on their browser software.
A cookie is a small file stored locally on the hard drive of the device (PC, telephone, tablet, etc.) by the server of the website visited.
In the course of its business, MATOOMA uses the following cookies through its www.matooma.com website:
Functional cookies for enabling basic functions such as navigation and access to secure areas of the website. These cookies are essential for the website to function properly.
Preference cookies which enable a website to retain information which changes the way the website is displayed, such as the language used or the region where the user is situated.
Audience measuring cookies which are used to assess the website’s traffic rate.
The cookies are used to collect personal data such as IP addresses in order to optimise and customise navigation on the website visited. The cookies are used to retain the Data Subject’s preferences while they are logged in to the website and during subsequent logins, such as the path on the website or the preferred language.
Subject to obtaining the consent of the Data Subjects visiting the www.matooma.com website, MATOOMA may use the cookies to send them targeted advertising offers based on their browsing preferences.
MATOOMA uses cookies for the following purposes:
Firstly to facilitate browsing on the www.matooma.com website:
By adapting the website’s presentation to the device’s display preferences (language used, country, operating system, etc.)
By memorising the information collected when the Client fills in the form to subscribe to the newsletter.
Secondly, to compile statistics for assessing the www.matooma.com website’s traffic rate.
However, MATOOMA does not store cookies dealing with personal and confidential information, such as addresses, passwords, banking data, etc.
The information stored in the cookies from the www.matooma.com website is used solely by MATOOMA’s services, except for third-party cookies which are used by external entities in the framework of relations with its providers.
To configure the use of cookies, and if need be delete them, Data Subjects visiting the www.matooma.com website should follow each browser’s instructions, as follows:
From Internet Explorer
Tools
Internet Options
Under the General tab: Browsing history then Settings
Show files
Select then delete the files beginning with the prefix “cookie”.
From Mozilla Firefox
Tools
Options
Privacy
Show cookies
From Google Chrome
Tools
Options
Advanced options
Privacy
Show Cookies
From Safari
Menu
Preferences
Security
Show cookies
Changes to the Privacy Policy
MATOOMA reserves the right to change this Privacy Policy. Data Subjects are invited to consult it regularly.