Summary

Please read the following policy carefully to understand our views and practices regarding the personal information of legal representatives, employees or end users of our professional customers and how we will treat it as part of the products or services we provide.

1. Who we are and how we can be contacted

TELEFLOW SAS, 10 rue Barthélémy Thimonnier - Ecoparc d'Activités de Bonvert 42300 MABLY FRANCE (hereafter « TELEFLOW ») acts as data controller for the personal data of its professional customers, that are collected or processed by TELEFLOW for its own purposes, regardless of the needs of its customers and for which it alone determines the means of processing, outside the contractual documentation agreed with the customer.
TELEFLOW can, as a supplier of products and services, act as a controller for the management of its commercial activity (including but not limited to contract management, management of loyalty programs, conducting satisfaction surveys, customer studies, claims management, management of the improvement of its products and services, development of new products and services, predictive analytics).
When a professional customer manages a project with TELEFLOW, TELEFLOW acts as a processor for all personal data that is communicated to it or that is collected or generated by TELEFLOW to provide the services to the concerned customer, according to its instructions and for the satisfaction of its own needs. Each TELEFLOW customer defines the purpose of the processing that it implements as part of the service it subscribes. The processing of personal data is described in the contractual documentation agreed between the customer and TELEFLOW.
If you need to contact us as data controller or data processor you have several options:

• Email: contact@teleflow.net
• You can submit your request through the contact form on our website.
• You can also contact us by phone at +33 04 77 70 71 73.

2. Information we may collect from you as a professional customer and as part of the products or services we provide to you

This section sets out how, when we are (i) on the one hand, data controller:

• how we collect your personal data,
• the categories of personal data that we collect,
• a description of how we plan to use the data we collect,
• the legal basis that we will rely on to process data collected,
• how long we will hold the data collected, and
• specific types of data,

as well as (ii), on the other hand, the way we use data when we act as data processor.

i. Personal data processed by TELEFLOW as data controller

Collected data	Purposes	Type of data	Legal basis of the processing	Retention period
Customer data as part of the commercial activities of TELEFLOW	Customer / prospect relationship management	Identification data: name, surname, professional contact details	The conclusion of a contract with TELEFLOW for the supply of the requested products or services and the legitimate interest of the data controller for the prospects.	The retention period depends on the nature of data according to the legal retention obligations that can last up to the time when the account is completely deleted and until the end of applicable limitation periods if required.
Information you provide to us when you complete a survey or respond to a questionnaire or submit a review or feedback (“Review Data”).	To collect information about a specific matter, for example, our services to you or reviews of our products/services. In many cases surveys, and questionnaires are anonymous, and we only collect personal information for statistical data. If this is not the case, we will let you know at the time of collecting the information.	Information may include your full name, your email address and other personal data requested.	As the legal basis for processing Review Data, we will use our legitimate interests in the monitoring and improvement of our products and services to our customers and users.	3 years after sending replies or any duration mentioned where the data is collected.
Information we use to send you one of our newsletters or marketing communications	Commercial communications management, performing audience analysis and statistics. Keeping an up-to-date list of opposition if you asked not to be contacted.	Name and e-mail address	Performing audience analysis and statistics. Keeping an up-to-date list of opposition if you asked not to be contacted.	Your information will be kept for 3 years after the last contact.
Information related to the services provided	Improvement of our products and services	Usage data of our services	The legal basis is our legitimate interest as a data controller to improve our products and services and develop new services.	The data is aggregated and therefore anonymized.

ii. Personal data processed by TELEFLOW as data processor

Data collected or processed	Type of data	Retention period
Access rights management with project-based authorization assignment	Identification and professional contact details	Retention period necessary to provide the services or longer if required and specified in the contractual documentation agreed between the customer and TELEFLOW
Hosting data and related services	Identification and professional contact details, stored data	Retention period necessary to provide the services or longer if required and specified in the contractual documentation agreed between the customer and TELEFLOW
Incident ticket management	Identification and professional contact details	Retention period necessary to provide the services or longer if required and specified in the contractual documentation agreed between the customer and TELEFLOW

Voluntary Information
When you provide us information (for example, the information set out in the scenario above), in some cases we may ask you for additional, voluntary information. This information will be identified as optional and is used to help us better understand our customers and tailor our services to them. Aggregated Data
The aggregated usage data of the vehicle and of the services (i.e. without any link with an identified or identifiable natural person) may be used by TELEFLOW without restriction.

3. Marketing Communications

You will receive marketing communications or newsletters from us only (i) if you are one of our customers, provided that this communication will concern similar products or services or if (ii) this communication is linked to your business activity.
In this context, we will use the information you provide us, usually just your name and email address.
In any case, you can unsubscribe or make stop direct marketing from us at any time either:

• (i) by clicking on the unsubscribe option at the bottom of each marketing communication we send to you; or
• (ii) by contacting us by email or letter using any of the contact details set out in this notice.

We will generally send you marketing communications until you choose to unsubscribe from receiving them. However, if we have not heard from you for a while or notice that you have not opened our emails in a period of 3 years, we will remove your details from our database. There’s nothing stopping you for subscribing again at any time.

4. Where we store your personal information

All information you provide to us is usually stored on secure servers in the European Economic Area. Otherwise, the location of the accommodation of your data will be specified in the contractual documentation agreed between the customer and TELEFLOW.

5. Sharing your personal information

As data controller or data processor, we may share your personal data with other TELEFLOW entities or with selected service providers/suppliers established in the European Union or outside the European Union. For more information, refer to the contractual documentation approved with the customer which lists the subcontractors/processors used by TELEFLOW.
We require all third parties to respect the security of our customers' personal data in accordance with our standards and to treat them in accordance with applicable data protection laws. We do not allow our external suppliers to use the personal data of our customers for their own purposes. We only allow them to be processed for the purposes specified and in accordance with our instructions and under the conditions defined in our agreements.
When we transfer personal data to an external supplier / service provider established outside the EU in a country that does not offer an adequate level of protection, we sign with these suppliers / service providers the European Commission Standard Clauses that confer on the customer's personal data the same protection as in the EU. We may also transmit them to third parties if we are obliged to disclose them in order to comply with a legal obligation, or to enforce or apply our terms of use or any other contract; or to protect our rights, property or the safety of Michelin Group, its customers or others. In this context and to the extent that it is necessary, we may transmit your personal information to any external consultant who is bound by an obligation of confidentiality.

6. How long will personal information be kept by us

As a rule, when we are data controller, we will not keep your personal data for any longer that it is necessary for the purpose under which the personal data is processed, whatever the purpose, including for the purpose of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period of personal data, we take into account the quantity, nature and level of sensitivity of personal data, the potential risk represented by unauthorized use or disclosure of your personal data, the reasons why we are processing your personal data, our potential ability to pursue these purposes by other means and the legal requirements in force.
In certain circumstances, you may ask us to delete your data: see your right to deletion below for more information.
We may anonymize your personal data (so that they can no longer be associated with you) for reasons of research, statistics, improvement of our products and services, and development of new products, services or offers. In this case, we may use this information indefinitely and for any other purpose, without informing you.
When TELEFLOW acts as a processor, the retention period of the data is related to the duration of supply of the services and it is the responsibility of the customer, responsible for processing (data controller) to determine it. To find out more refer to the contractual documentation agreed with the concerned customer which also defines the retention period agreed with the customer as part of the service provided.

7. Your rights under data protection legislation

Data protection legislation provides you with certain rights when it comes to the processing of your information. These are the right to:

• The right to be informed
• The right to access your information
• The right to correct your information
• The right to delete your information
• The right to restrict processing
• The right to transfer information
• The right to object to processing

For further information on your rights, you can find further information on your data protection rights from the data protection authority of your country.

8. Who do I contact?

• If you wish to exercise your rights regarding your personal data that TELEFLOW treats as a data controller, you can contact us using the online contact form. You can also fill out and print the form and send it by email to contact@teleflow.net .
• If you wish to exercise your rights with respect to your personal data that TELEFLOW treats as a data processor, you must contact the customer to obtain information about your rights and how they can be exercised.
• If you are authorized by our customer to request the assistance of TELEFLOW as a processor to fulfil the exercise of a right benefiting a data subject, you must contact us via the following email address: contact@teleflow.net.

9. How will TELEFLOW handle my request?

The general rule is that we do not request the payment of any fee. Access to your personal data (or the exercise of other rights) is free. However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive. We may also refuse to grant your request in these circumstances.
We may ask you for specific information to help us confirm your identity and guarantee your right to access your personal information (or to exercise your other rights). This is a security measure to ensure that personal data is not disclosed to people who are not entitled to know it. We may also contact you to ask for more information about your request so that we can respond to you quicker.
We try to respond to all justified requests within a month. We can occasionally need more than one month if your request is particularly complex or if you have made several requests. In this case, we will notify you and keep you informed of the progress of your request(s).

10. What you can do if you are not happy with how we use your information

We are committed to protecting and respecting your privacy. However, if you are not happy with how we collect or process your information or just want some further information on your rights, you can contact us in the following ways:

• You can email us at contact@teleflow.net
  We will work with you to resolve any issues you may have and aim to answer any question raised by you as soon as possible.
• You can also make a complaint to the European Data Protection Supervisor (EDPS) –
  further information can be found at https://www.edps.europa.eu/data-protection/our-role-supervisor/complaints_en.

13. About Data Security

TELEFLOW has implemented measures to protect the privacy, security and integrity of your personal data. Access to personal data is restricted to those employees and service providers who need to know this information and who have been trained to comply with rules on confidentiality.
TELEFLOW undertakes that your personal data will not be accidentally lost, used, or accessed without authorization, altered or damaged. TELEFLOW has procedures in place to deal with any suspicion of personal data breach and will notify its customers and any relevant supervisory authority of any violation when we are legally or contractually obliged to do so.

14. Changes to our Privacy Policy

We may change our policy from time to time. Any changes we make to this policy in the future will be posted on this page. If you have an online account with us, we may notify you of any changes by email or through your account the next time you log on.

Date : September 2024