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Hello eSIM App Privacy Policy

This page sets out the specific provisions relating to the processing of personal data for the Hello eSIM app. The general Orange Luxembourg privacy policy, available here, also applies to the app.

1. Processing

In the context of using Orange and Me, Orange is likely to carry out the following processing:

Anti-spam call functionality

- The application requires access to the contact list to display contact information and allow the User to modify them (add, modify, delete). When the User activates the spam detection function, the application accesses the call log and sends the telephone numbers of incoming and outgoing calls to the server in order to identify unwanted calls and improve the efficiency of the Anti Spam Service algorithm

- when a Qualification ("malicious", "canvassing" or "approved") is transmitted, the User's ICCID, which is the SIM card ID, containing the country code, operator code and a SIM card identifier is processed. This data is used exclusively for the proper realisation of the Qualification and this, for the duration of use of the Service by the User

- the number of the correspondent who has been the subject of a qualification is collected and processed in order to render and improve the service "monitoring and filtering of unsolicited calls" and is kept for a period of 2 months from the call

- the correspondent's number is processed in order to render the services "caller identification and "tariff information" and this, only for the time to render said services, it is then automatically deleted

The legal basis for this processing is contract performance. For purposes related to service improvement, the legal basis for processing is legitimate interest.

The Publisher respects Users' personal data and strictly complies with current regulations on personal data protection. Information communicated directly or indirectly by the User through forms present on the application mentioned in this article are necessary to respond to their requests and are intended for Orange and its subsidiaries and, where appropriate, their Partners. The optional or mandatory nature of the data is indicated to the User during their collection by an asterisk. For more information, the User can consult the Publisher's Privacy Policy.

Customer identification

In the context of customer relations and subscription to a new contract, ORANGE collects Customer personal data to manage customer relations and comply with current legislation. This data is used for billing, ensuring, accounting, archiving and recovery. The Customer gives their consent for this processing. ORANGE implements measures to guarantee data security and confidentiality.

The collected data is kept for 24 months after the end of the contract.

Network improvement

If the User is an Orange mobile customer, with their consent, Orange and me may collect data for network optimisation purposes. The data that is then collected is network and Application usage data, data relating to the terminal (terminal type and battery usage) and location. The content of correspondence and browsing is not concerned.

Usage statistics

If the User consents, Orange may track their usage, in order to improve the quality of offers and services.

The collected data is kept for 24 months.

Personalisation

If the User consents, Orange may personalise the User's experience with Orange.

Orange uses customer profile usage data to personalise the User's experience on its sites and applications by offering you more suitable content or offers. Orange may also test several versions of the site and propose one of them in order to improve the interest and ergonomics of navigation.

Orange may also use the user's interaction data on its sites and applications to personalise communications sent by email, post, call or SMS/MMS according to the User's contact preferences.

The collected data is kept for 25 months.

Targeted advertising cookies

If you consent, Orange and its partners may use targeted advertising cookies allowing you to display advertisements when you browse the internet.

In order to offer you advertisements that are suitable for you, these cookies use data linked to browsing. If you are an Orange or Sosh customer, these cookies may also be based on data linked to the account (e.g.: offer held, postcode, age group, gender, email address, geolocation if you have consented...).

These cookies also allow Orange and its partners to identify advertisements that have been displayed and that have interested you. This allows, in some cases, Orange and its partners to be remunerated for this advertising. They also prevent you from always being shown the same advertisements during browsing.

The collected data is kept for 25 months.

2. Recipients

The processed data is intended for Orange's internal services and its subsidiaries: only authorised employees who need it in the context of their missions can have access to the data.

The processed data may be, depending on the offers, intended for Orange's subcontractors: in this case Orange only communicates data to subcontractors with whom Orange has concluded a contract by which they ensure their commitment and guarantees on their capacity to meet security and confidentiality requirements, and to respect all legal and regulatory obligations regarding personal data protection.

The processed data may also be intended for Orange's partners, public or private: these are situations where partners intervene for the provision of complementary offers or services.

The processed data may be transmitted to competent authorities, at their request, in the context of judicial procedures, in the context of judicial investigations and requests for information from authorities or in order to comply with other legal obligations. They may finally be transmitted to third parties authorised by a court decision.

3. Processing outside the European Union

The collected personal data may be processed outside the European Union. In this case, Orange takes the necessary arrangements with its subcontractors and partners in order to guarantee an adequate level of personal data protection and this in compliance with applicable regulations.

If the concerned subcontractors and partners are not located in a country with legislation considered as offering an adequate level of protection, they will have previously signed the European Commission's "standard contractual clauses" or are subject to binding internal Rules approved by the authorities. When the legislation of the third country does not present protection equivalent to that offered by the applicable regulations in the European Union, Orange ensures the implementation of additional measures adapted to the processing implemented.

3. Rights of individuals

The User has a right of access, rectification and deletion of data concerning them. The User may request the portability of the latter. The User also has the right to object to the processing carried out or to request limitation thereof. The User may issue directives on the conservation, deletion or communication of their personal data after their death.

The User may exercise these rights by using the email address: data.protection@orangeluxembourg.lu. The User may also contact Orange's personal data protection officer by post to: Orange communications Luxembourg Attention of the DPO 8 rue des Mérovingiens L-8070 Bertrange.

Additional information may be requested in case of reasonable doubt as to their identity.

A response will be sent within one month of receiving the request.

If exchanges with Orange have not been satisfactory, the User has the possibility to introduce a complaint with the National Data Protection Commission.