MYBTMobile Privacy Policy

We hereby provide you, as a business end user of the MYBTMobile application (hereinafter referred to as “App”) with the below information concerning the collection of personal data when making use of the App. Personal data includes all data that relates to you personally, such as: name, address, email address or user behavior.

COMPANY CONTACT INFORMATION

You can find our contact information here:

Blue

Address: 32 rue Blaise Pascal, 35220 Châteaubourg

Email: dpo@bt-blue.com

Phone: +33 2 30300000

Data Protection Officer

We have a Data Protection Team and a Data Protection Officer (DPO). If you have any questions relating to the processing of your personal data or want to contact our DPO, feel free to contact us using the details provided below.

Centile Data Protection Team Email: dpo@bt-blue.com

CONTROLLER

In accordance with GDPR, the data controller of the personal data processed within the App is Centile Telecom Applications (hereinafter referred to as “Centile”). Please note that the App will not work properly without an appropriately configured server, provision by us on the behalf of your employer. The processing of data on this server is the responsibility of the controller who provisioned it from Centile, in most cases this will be your employer. This relationship will be stated in a data processing agreement defining how we and our respective counterpart complies with our obligations under GDPR.

FUNCTIONS OF OUR APP

The functions of our App can only be used in conjunction with a server, for which you, your company or your employer has purchased and configured a licensed version of the Centile communication software. App functions will be only available after authentication and synchronization of the data with the corresponding servers.

HOW WE COLLECT YOUR PERSONAL DATA

Centile is the data controller for the processing of your personal data for the purposes described in this statement. If you choose not to provide the personal data, you might not be able to make use of the desired service / function or technical assistance.

For business end users

Personal data is collected directly from you or through your employer. If you choose to log in and make use of our services, we will process the personal data needed for the provision of this service.

For business customers

Personal data can be collected through your employer. If your employer provides us with your personal data we assume that they have informed you about the scope and purpose of this collection.

WHAT PERSONAL DATA WE COLLECT AND PROCESS

When downloading the App, we process the information required to download it from the respective marketplace, in particular user name, email address and the customer number of your account, time of download, payment information and individual device ID. We do not control the purpose and means for the collection of this data and are therefore not responsible for it. We only process the data to the extent necessary for downloading the App to your device and for other technical purposes related to the availability and development of the App.

Required for the provision of our service

The categories of personal data described below is processed and generated when using the App. This data is required for technical purposes to increase ease of use for App functions and to ensure stability and security.

• User information
• Contact information
• Traffic data
• Business contacts
• Device contact list (Consent required)
• Photo and Media (Consent required)
• Usage statistics (Consent required)
• Chat information

User information

When you log into our App we will process the User information connected to your profile. This data consists of: User name and password.

We process this data on the basis of a contractual obligation agreed to with your employer.

Contact information

If you contact us via email or via our contact form, we will process information required to answer your query. This data consists of: Email address and, if provided, your name and telephone number.

We process this data on the basis of our legitimate interest to answer your business related queries.

Traffic data

When using our App, traffic data will be processed. This data is required to facilitate communication. Traffic data is generated and processed automatically when end users communicate via the App and consists of: information about the participants, calling and called number, the connected IP address, the date, the time, the duration of the call, the amount of data used, and when roaming, we register the network that was used.

We process this data on the basis of a contractual obligation agreed to with the party that has provided you with access to the App. In most cases, this will be your employer.

Business contacts

When using our app, business contacts can be processed by the service for which you, your company or your employer has purchased and configured a licensed version of the Centile communication software. The business contacts are managed and configured by your employer and, if applied, will provide you with an overview of other business end users registered by your employer.

Business contacts are access and processed after authentication and synchronization of the data with the corresponding servers.

We process this data on the basis of a contractual obligation agreed to with the party that has provided you with access to the App. In most cases, this will be your employer.

Device contact list

When you make use of certain features, we ask you for your consent to use your device contacts. We will not use this data if you do not consent. If you do not consent, you may not be able to use all functions of our App.

You may subsequently grant or withdraw your consent at any time by using the settings in the App or your operating system.

If you do consent, your device contacts will be accessible through the App. The data is stored on the device and on per single contact base the user can request to sync this data to our server to enhance the user experience.

We process this data on the basis of your consent.

• Use case 1: giving the access to contacts, you will be able directly from the app to search for your corporate contacts AND your phone contacts and place a call on the desired contact.
• Use case 2: When selecting a phone contact after use case 1, You may want to click on “import” to import this contact as a private contact within the corporate directory and allow you to identify the caller on all your corporate devices and call him directly from the corporate directory on any of your corporate devices.

Photo and Media

When you make use of certain features, our App, we ask you for your consent to use your, photos and media. We will not use this data if you do not consent. If you do not consent you may not be able to use all functions of our App.

You may subsequently grant or withdraw your consent at any time by using the settings in the App or your operating system.

If you do consent and make use of the feature, your data will can stored on our servers relating to the party that has provided you with access to the App. In most cases, this will be your employer.

We process this data on the basis of your consent.

Usage statistics

Subject to appropriate consent, our App collects anonymous usage data to determine usage-related statistical indicator that we can use for business intelligence purposes to improve our App and make it more attractive for you as a end user. The data is anonymized from the outset and cannot be associated with a identified or identifiable person at any time. You may subsequently grant or withdraw your consent at any time by using the settings in the App.

We process this data on the basis of your consent.

Chat information

When using our messaging functionality within our App, we will process the data necessary to facilitate communication, this data consists of: IP address, login data, chat messages, chat partner, status of the chat messages, transmitted files.

The data collected in the App and then synchronized with the corresponding server on which the Centile software is installed to the extent necessary to provide the relevant functions. Only you have access to data stored solely in the App. The corresponding party that has provided you with access to the App, has access to the data located on the server.

We process this data on the basis of a contractual obligation agreed to with the party that has provided you with access to the App. In most cases, this will be your employer.

WHO WE SHARE DATA WITH

In certain circumstances, for example due to legislation, it may be necessary to pass on information to the authorities. Disclosure may also take place if necessary to establish or defend legal claims.

Centile is a group of undertakings located within the EEA, as part of our group wide activities we can share aggregated usage statistics about our customers and end-users in the form of business intelligence and statistics with members of the group. We do this on the basis of group wide agreements, where we have mapped the transfers and designated the responsibility for compliance with the data protection law amongst the members.

In order to communicate via our App, it is necessary for us to transmit traffic data via operators. Centile uses several European infrastructure providers, and these operators therefore process personal data. These operators are independently data controllers for the processing of data within their respective networks.

We might also pass on your personal information to internal or external third parties acting as (sub) data processors for us, this could be in relation to the hosting of your data, our chat functionality, business intelligence analyses, etc.

STORAGE AND RETENTION

All data is stored on servers within the EEA and your personal data is therefore not subject to international transfers to third countries without an adequacy decision.

Uninstalling the App permanently deletes all data in the App. We have no influence over, and are therefore not responsible for, the duration for which data is stored on the servers.

SECURITY

Centile has implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, alteration or destruction. Only authorized Centile personnel are provided access to personal data and these employees are contractually or statutory obliged to ensure confidentiality of this data.

Centile will implement appropriate technical and organizational measures to ensure that the processing of your personal data is performed in accordance with data protection law, in particular ensuring an appropriate level of security.

The App uses SSL encryption for the data and audio connection to the server. The data is therefore not accessible by third parties.

YOUR RIGHTS

Under GDPR, you have a number of rights regarding our processing of your personal data. To exercise these rights, please contact us via our contact information.

• Right of access
• Right of rectification or erasure
• Right of restriction of processing
• Right of objection
• Right of data portability

Centile does not have access to the data contained within the App. Within the App you can view, correct, erase data or revoke consent. As a general rule you can exercise your rights through the party that has provided you with access to the App, in most cases, this will be your employer.

QUESTIONS OR COMPLAINTS

In case you have any questions with respect to the processing of your personal data, you can contact Centile or our DPO via the contact Information.

Please note that you have the right to lodge a complaint with the competent Supervisory Authority if you are of the opinion that the processing of your personal data by Centile infringes on the GDPR or other data protection laws.

Version 1; December 2023