This Confidentiality Policy informs you about how Wifirst, as a data controller, uses your personal data which it processes from this website as part of the use of its services.
1. General
- Wifirst, with its registered office at 26 rue de Berri 75008 Paris, France, as a controller of your personal data collected within the use of its services, takes particular care to comply with personal data protection regulations: amended data protection law no. 78-17 of 6 January 1978 and European Parliament and Council regulation (EU) 2016/679 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.
- Wifirst respects the confidentiality of all your Personal Data and is committed to protecting it. This Confidentiality Policy governs how Wifirst processes Personal Data as part of its commercial activities.
- For the purposes of this Policy, the following terms are defined below:
"Personal Data": data relating to a living individual who is or may be identified, either directly or indirectly, through this data, either alone or paired with other information that is currently or potentially in Wifirst's possession (or that of its representatives or service providers).In addition to factual information, Personal Data includes any opinion expressed about the person concerned and any intention in their regard expressed by Wifirst or another person.
2. Nature of Personal Data processed by Wifirst
As part of its activities, Wifirst may process Personal Data concerning you in order to perform the services or obligations to which it is bound. Wifirst gathers and processes the following Personal Data:
- Identification data that you provide:
- by filling in the forms on the Wifirst website. This includes the contact form and the recruitment form;
- as part of the use of Wifirst services;
- Data from your computer, which includes but is not limited to your IP address, your operating system and your MAC address;
- Banking data as part of the services it sells;
- Data you have shared yourself on the community portal which is treated as Personal Data.
3. Use of Personal Data processed by Wifirst
- The data collected directly by Wifirst, as well as the data sent to it by its customers where the Wifirst infrastructure is installed, so that you may benefit from its services, is used with the following purposes and legal bases :
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Purposes
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Legal bases
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Managing the contractual relationship with you
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Fulfilling a contract
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Recruitment
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Wifirst's legitimate interests in optimising its staff recruitment
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To process and respond to your requests for information concerning Wifirst or its services
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Wifirst’s legitimate interests in ensuring that you receive the necessary information
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To implement the electronic communication services provided by Wifirst (provision of the service, maintenance, assistance, after-sales and, where applicable, billing and recovery)
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Fulfilling a contract
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To fulfil the legal obligations such as those regarding accounting, taxes, storage of technical data relating to the performance of its activities as an operator registered with ARCEP with a view to its transmission to the relevant authorities, and exercising your rights over your data, etc.
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Legal or regulatory obligations
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To conduct data analyses to understand the needs of Wifirst service users better (statistical studies, satisfaction surveys, audience analyses and measurements, improving and adapting offers and services, etc.)
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Legitimate interests in ensuring the smooth running of commercial operations
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To promote Wifirst’s services
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Legitimate interests in carrying out and developing Wifirst's business
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To manage and administer Wifirst’s services
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Wifirst's legitimate interests in managing its business
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- Wifirst ensures that all Personal Data is used in compliance with the applicable legislation and regulations. It processes your personal data based on your prior consent, insofar as said consent is required by applicable law.
- Wifirst does not use your Personal Data for reasons that are incompatible with the purposes of which you have been informed, unless it is authorised by law, or it is in your vital interest.
4. Storage period of your Personal Data processed by Wifirst
Your data is stored:
- With regard to most data relating to use of the service: for the duration of the subscribed service plus the statute of limitations for any action that might arise in your relationship with Wifirst;
- With regard to the legal storage period obligations: for the duration set by the applicable laws and regulations;
- With regard to data that is necessary for the purposes of client understanding and improving Wifirst’s services: for a maximum of three years following the end of your relationship with Wifirst.
5. Recipients of your Personal Data processed by Wifirst
- Depending on their respective needs, the following are recipients of all or part of the data :
- Wifirst employees as well as Bolloré group employees on a need to know basis;
- Wifirst’s technical service providers or other technical operators who work in routing electronic communications, for the strict needs of providing Wifirst's services;
- Commercial partners with whom Wifirst infrastructure is installed;
- Third party service providers that provide services to Wifirst;
- Insofar as required by the law and regulations, administrative or legal authorities.
- Wifirst will ensure that your Personal Data is only passed on to partners who are contractually bound to comply with a suitable data protection obligation, as well as to personal data protection and confidentiality legislation, within the limits of this Confidentiality Policy.
- If your Personal Data is transferred to a country outside the EEA, Wifirst will ensure that this data is protected and transferred in compliance with the legal requirements.
6. Protection of your Personal Data processed by Wifirst
Wifirst has put in place organisational, physical and technical provisions for all the Personal Data it holds. It has established protocols and control measures as well as appropriate policies, procedures and directives to ensure these provisions are properly applied, taking into account the risks associated with the different categories of Data and its processing.
7. Your rights
- At any time, you may exercise your rights free of charge (except in the case of manifest abuse) in the circumstances and within the limits provided for by the regulations regarding those rights, which are namely the following:
- Right to access and to information about the Data concerning you;
- Right to rectify incorrect or incomplete data;
- Right to erase certain data;
- Right to object to the processing of your Personal Data and to request the limitation of this processing in certain cases;
- Right to request the portability of the data that you have sent to us and that is used by Wifirst solely for the purposes of fulfilling your contract;
- Right to withdraw the consent given to process your Data at any time;
- Right to determine what happens to your data after your death.
Please note that Wifirst may not be able to meet your request in certain cases in order to comply with a legal obligation.
- You can exercise your rights by contacting Wifirst via the contact details provided in article 7 below. In order for Wifirst to respond to your request while also protecting the security of your data, you must provide us with your first name, last name, e-mail address and a copy of an identity document (ID card, passport, residence card).You must also state the e-mail or postal address where you would like to receive a response, as well as any other information required to justify your request in the event that the right you wish to exercise is limited by the regulations in force.
8. Questions and claims
- For any question or claim relating to the processing of your personal data by Wifirst or to this Policy, please contact the Data Protection Officer :
- By telephone: +44 (0) 208 380 628
- By email : personal-data@wifirst.co.uk
- By post: Wifirst – Customer Service– Private Data – 26 rue de Berri – 75008 Paris – France
- As a general rule, Wifirst is able to provide a quick and satisfactory solution to questions and claims relating to the protection of your Personal Data. However, if you are not satisfied with the response you have received from the Data Protection Officer, you may send your questions to the relevant supervisory authority in your country.
- For any other question, the relevant authority designated for Wifirst may be contacted by post at the following address: CNIL, Commission nationale de l’information et des libertés, 3 place de Fontenoy - 75007 Paris, France.
