Data Protection Policy

Data Controller

The personal data on the Site is collected by CROSSCALL as the data controller, in accordance with Regulation (EU) 2016/679 of the European Parliament and Council of April 27, 2016, applicable from May 25, 2018, and Law No. 2018-493 of June 20, 2018.

Contact details of the data controller

CROSSCALL SA
245 Paul Langevin Street
Milles Business Area
13290 Aix en Provence
SIRET: 518 706 890 00069
Representative: Mr. Cyril VIDAL in his capacity as president

Processing of Collected Personal Data

CROSSCALL may collect your personal data through this site for various purposes, namely:

1. Create your customer account and manage your orders

Purpose of collectionPurposesData collectedLegal basisRetention period
Customer account creationThe necessary data is collected for account creationMandatory: First name, last name, date of birth, title, and email address / Optional: address, mobile phone number, professional status, sports practiced, childrenConsentUntil consent is withdrawn
Order managementThe necessary data is collected for processing and tracking your orders on the websiteAccount creation data
Card number, cardholder name, security code
Contract executionPayment by credit card: 540 days from the transaction date (by partner Ogone Worldline)
Payment by PayPal: Personal data used in the ongoing relationship between you and PayPal is stored for the entire duration of the relationship plus an additional 10 years
Commercial documents kept for 10 years from the last contact
Management of payment in multiple installmentsThe necessary data is collected to ensure your creditworthiness and authorize payment in multiple installmentsFirst name, last name, address, date and place of birth, card number, cardholder name, security code, etc.Legitimate interestONEY: If payment is accepted, for the entire duration of the loan + 5 years for proof in case of dispute / 6 months in case of payment refusal
Withdrawal managementThe necessary data is collected to process your withdrawal requests for products purchased online and to inform you about this processFirst name, last name, address, email, phone number, product reference and modelContract executionCommercial documents kept for 10 years from the last contact
Claims / Litigation ManagementThe necessary data is collected to process your claimsLast name, first name, address, email, phone number, IMEI, and purchase dateContract execution / legitimate interestIn case of dispute, data is retained for the duration of the contract plus the limitation period


2. Respond to your requests

Purpose of collectionPurposesData collectedLegal basisRetention period
Management of the contact formThe necessary data is collected to respond to internet users' requests (to obtain information about their order, invoice, or referral), allow people to chat with a CROSSCALL employee, make Partnership/Ambassador requests, and receive CROSSCALL news upon consentLast name, first name, email, message
For partnership/ambassador requests, discipline and profession are also collected
Legitimate interestUntil the request is processed
Management of quote requestsThe necessary data is collected to respond to quote requests and send promotional offers if you have consentedRequired: Last name, first name, phone number, email, country, company name, position, desired product and volume, project descriptionConsent3 years following your last contact / until commercial information is unsubscribed
Management of rights exercise requestsThe necessary data is collected to process the rights exercise request submitted via the dedicated formRequired: Nature of the request, email, name, account or order number
Identity document in the context of an access rights request
Legal obligationIdentity document if requested: Deleted immediately after verification
1 year in active database and 5 years in intermediate database before deletion
Management of requests made via the chatbotImprove the quality of services

Ensure personalized service by consulting the conversation history
Conversations (content of exchanges, number of conversations, duration, date)

Visitor's IP address (for evidence purposes in case of dispute)

Data is provided directly by the visitor (for example identity, email, phone number)
ConsentData is retained for the time needed to provide a response and for a maximum duration of 1 year


3. Handle your requests with customer service

Purpose of collectionPurposesData collectedLegal basisRetention period
Management of requests made by phoneThe necessary data is collected to contact you and process your requestRequired: Last name, first name, address, email, phone number, IMEI, purchase invoiceConsentData is retained for the time needed to provide a response and for a maximum duration of 2 years
Management of support requests within the after-sales service for repairsThe necessary data is collected for product support, to contact you, and to return the repaired productMandatory: Name, address, email, phone number, IMEI, purchase invoiceWarranty contract / Legitimate interestThe time needed to process your request + 2 years / 2 years after the end of warranty if the device is under warranty
Management of customer service requests made via the chatbotRespond to requests related to product after-sales service (SAV)Conversations (content of exchanges, number of conversations, duration, date)

Visitor's IP address (for evidence purposes in case of dispute)

Data is provided directly by the visitor (for example identity, email, phone number)
ConsentData is kept as long as needed to provide a response and for a maximum of 5 years


4. Manage recruitments

Purpose of collectionPurposesData collectedLegal basisRetention period
Management of applicationsThe necessary data is collected to process applications online or by mailName, first name, email CV data: address, phone number, age, gender, family status, education, and professional experienceLegitimate interest2 years from the receipt of your CV


5. To offer you promotional offers and contests

Purpose of collectionPurposesData collectedLegal basisRetention period
Management of marketing and promotional communicationsThe necessary data is collected to send marketing communications or promotional offers by email and/or messaging 
personalized (SMS/WhatsApp).

Data may also be used to analyze your interactions with our communications and, if applicable, your purchasing behavior, to personalize the offers and messages addressed to you.  
Identification and contact data: name, first name, email address, phone number 

Data related to marketing interactions*: opens, clicks, unsubscribes 

Browsing and activity data on the site associated with marketing campaigns: pages viewed, navigation path 
ConsentData deleted upon unsubscription or 3 years after last contact
Management of contestsThe necessary data is collected for organizing events and sending won prizesName, first name, email address, phone number, and postal address (depending on the contest purpose)ConsentData deletion 2 months after prize delivery
If consent to the newsletter: until unsubscribed
Management of refund offersThe necessary data is collected to reimburse you and send newsletters with your consentName, email address, phone number, and postal address (depending on the contest purpose)ConsentData deletion within a maximum of 3 years after the end of the contract / until newsletter unsubscription if consent to the newsletter

*Use of tracking pixels in our electronic communications
When we send you electronic communications (newsletters, commercial offers, etc.), we use tracking pixels embedded in our emails.
These trackers allow us to know if an email has been opened, which links have been clicked, and to measure the overall performance of our campaigns (open rates, click rates, unsubscribe rates, delivery errors).
The information collected on this occasion may include: whether the message was opened, the date and time of opening, the links clicked, as well as a technical identifier associated with your email address. This information is used to measure the effectiveness of our communications, improve their content, and tailor our communication actions.
We do not use these tracking pixels to monitor your browsing on other websites nor to create a detailed profile of your activities outside our electronic communications.
The insertion of these pixels and the related processing of data are based on your prior consent to receive our electronic communications in accordance with the applicable rules governing electronic direct marketing and the recommendations of the French Data Protection Authority (CNIL).
You can withdraw this consent at any time:
– by clicking the unsubscribe link present in each of our marketing emails, or
– by contacting us using the contact details provided at the end of this policy.
Withdrawing your consent does not affect the lawfulness of processing already carried out. However, it will result in stopping our marketing electronic communications and the future use of associated tracking pixels.

As part of our marketing activities and campaign management, we may use a marketing automation provider (e.g., Klaviyo) that may process certain data outside the European Union, notably in the United States. In such cases, transfers are governed by appropriate safeguards (e.g., standard contractual clauses of the European Commission and/or applicable recognized mechanisms).

6. Allow us to manage the loyalty program

Purpose of collectionPurposesData collectedLegal basisRetention period
Loyalty Program Management

Lamanagement of registration and participation in the loyalty program.

Thetracking the accumulation and use of loyalty points.

 Lthe grantingbenefits such as discount coupons or accessories.

 Lacustomer relationship management within the program.

last name, first nameaddresseemail, datebirthday (optional), historypurchases made from the date of joining the program.

ConsentDuring the membership period in the program


As part of the loyalty program, certain personal data processed byYotpoon behalf of CROSSCALLmayto be hosted or accessed from countries outside the European Union, notably theStatesUnited.

These data transfers are governed by the conclusion of standard contractual clauses adopted by the European Commission, as well as, where applicable, by the implementation of additional technical and organizational measuressto ensure an adequate level of protection of personal data in accordance with applicable regulationsble.

7. To allow us to improve our products and services

Purpose of collectionPurposesData collectedLegal basisRetention period
Opinion survey managementThe necessary data is collected to understand your use of our productsName, email address and phone number, company name and professionConsentDeletion after processing survey results / If consent to be recontacted, data deleted upon unsubscription
User experience managementThe necessary data is collected to gather your user experience feedback on products to improve them / contact you for clarifications on your responsesGender, First name, email address, countryConsent2 years then anonymization
Participation in the innovators communityThe necessary data is collected to manage registrations and recruitment to the innovators community, conduct market, satisfaction, needs, and usage studiesFirst name, last name, email, date of birth, city, country, Children Y/N, Sports practiced, frequency, Other possible and optional: apartment/house, type of car (and desired), desired clothing brand, Professional category, working hours, work environment, Income bracketConsent then contract execution / Legitimate interestUntil unsubscribed


RECIPIENTS

The recipients of this data are:

  • The service providerin charge of thecampaign managementmarketing(Klaviyo) ;
  • The provider responsible for managing the loyalty program (Yotpo) ;
  • The provider supplying the Customer Relationship Management (CRM) system and the Marketing Cloud system;
  • The provider supplying the online questionnaire deployment tool;
  • The provider implementing online payment solutions;
  • The provider responsible for order delivery;
  • The repair centers;
  • The provider supplying the application management solution;
  • The external DPO of CROSSCALL in the context of a rights request.

TRANSFER TO THIRD PARTIES AND OUTSIDE THE EUROPEAN UNION

Your personal data is preferably processed within the European Union.

Within the scope of the aforementioned purposes, some of your personal data may, however, be transferred to third-party entities established in countries outside the European Union (e.g., subcontractors of the company involved in the aforementioned processing, etc.).

Some of these recipients of your personal data are considered to provide a sufficient level of personal data protection because they are established in a country whose personal data protection regulations have been recognized as providing an adequate level of protection for said data (see European Commission adequacy decisions)

Furthermore, if the country of the entity receiving your personal data does not offer an adequate level of protection for said data, we ensure that appropriate security and confidentiality measures are taken to guarantee the continued protection of your data.

Also, in these cases, you are informed that the transfers of your personal data to other entities outside the European Union are governed by the implementation of appropriate safeguards such as the conclusion, with the recipients of this data, of contractual clauses in accordance with the recommendations of the European Commission, allowing us to ensure that appropriate safeguards are taken regarding the protection of said data.

We also inform you that transfers of personal data outside the European Union are lawful if (i) the transfer is necessary for the performance of a contract between the data subject and the Data Controller or for the implementation of pre-contractual measures taken at the data subject's request, if (ii) the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the data controller and another natural or legal person, or if (iii) the data subject has given explicit consent to the proposed transfer after being informed of the risks that this transfer may entail for them due to the absence of an adequacy decision and appropriate safeguards.

CROSSCALL may be required to transmit personal data to competent services and authorities in the context of information requests or administrative or judicial decisions.

DATA SECURITY

CROSSCALL ensures the security of your personal data hosted on its servers. The company strives to take the necessary technical and organizational security measures to guarantee the integrity, confidentiality, and availability of your data.

CROSSCALL employees who have access to users' personal data due to their role commit to the utmost confidentiality in this regard.

The CROSSCALL website uses the TLS encryption protocol to ensure the confidentiality and integrity of your data transmitted via the site and also to ensure client-server authentication.

You can view our security certificate, issued by a third party, by clicking on the padlock icon in your browser's address bar.

RIGHTS OF INDIVIDUALS AND HOW TO EXERCISE THEM

In accordance with Law No. 78-17 of January 6, 1978, relating to Information Technology, Files and Freedoms (articles 38, 39, 40), and the General Data Protection Regulation, you have various rights regarding the use of your personal data. These rights are as follows:

  • Access: Exercising the right of access allows the User to verify the accuracy of the data and, if necessary, have it corrected or deleted;
  • Rectification: Exercising the right to modification allows the User to update their data;
  • Portability: Exercising the right to data portability allows the User to transfer their data to a third party of their choice;
  • Deletion: Exercising the right to deletion allows the User to have their data deleted;
  • Objection: Exercising the right to object allows the User to oppose the use of their data for a specific purpose;
  • Restriction: Exercising the right to restriction allows the User to request an organization to temporarily freeze the use of certain of their data.

These rights can be exercised with the data protection officer of CROSSCALL by filling out the form available on the following page:Personal Data Management

Note that CROSSCALL also offers you the possibility to modify your personal information and withdraw your consent to commercial and promotional offers directly from your customer account. It is also possible to unsubscribe from any communication by clicking the unsubscribe link at the end of received emails.

If you believe, after contacting the data controller or the data protection officer of CROSSCALL, that your data protection rights are not respected, you can file an online complaint with theNational Commission on Informatics and Liberty (CNIL)or by postal mail at 3 place de Fontenoy – TSA 80715 – 75334 Paris Cedex 07

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PRIVACY POLICY MODIFICATION

CROSSCALL may modify this privacy policy. We therefore invite you to consult it regularly to be aware of its latest version.