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Personal Data Notice
“Orange Branded Device”
Last updated: 4 April 2022
Who are we?
Orange S.A. is a telecommunication company with registered Headquarters in 111 quai du Président Roosevelt 92130 Issy-les-Moulineaux, France (hereinafter referred to as “Orange” or “We” or “Us”).
This Personal Data Notice (hereinafter referred to as “Notice”) aims to give you information on how Orange S.A., acting as Data Controller, processes your data when you are using an Orange Branded Device (hereinafter referred to as “OBD”).
Scope of Notice
You have in your hands a powerful and versatile device giving you access to the services of multiple providers, which may process your personal data. Please note that this Notice gives you general information around the processing conducted for the good performance of your OBD.
If you’re using this Orange Branded Device with an eligible Orange mobile plan or prepaid service, this Notice shall be read together with its specific Contract Terms and Conditions for you to better understand the context of your device’s distribution and other Orange’s customer services (for example: billing, customer care, after sales, conditions when providing roaming services, coverage, connectivity and data usage, and other services linked to your contract with Us).
This Notice does not apply:
• If you’re using your device together with another third party apps or services
• To the products, apps and services offered by the phone manufacturer
• To the products, apps and services offered by your device’s operating system (hereinafter referred to as “OS”)
Thus, We invite you to carefully read its Terms and Conditions and/or Privacy Policies of such apps and/or services before installing or using any app or service, to be fully aware of how other parties may process your data on your device.
What is an Orange Branded Device (OBD)?
An OBD is a device branded under Orange’s brand (name and logo) which is printed on the physical phone. This means that the device itself is made by a phone manufacturer (ZTE, Mobiwire…) which has an agreement with Us to use Orange’s brand, as a telecom carrier, to provide a certain amount of phones like this.
The use of Orange as a brand on the physical phone does not mean that Orange collects or process data on behalf of the phone manufacturer or on behalf of the OS of your device and vice-versa.
How does your device’s ecosystem work?
Your OBD proposes you an Orange experience which offers you a set of applications developed by Orange that may vary depending on your OBD, country and whether or not you are using your OBD in conjunction with an Orange SIM card.
To perform its functions, your OBD operates software on several technical layers that interact with each other. Please note that your OBD notably relies on:
• Hardware and software from your device’s manufacturer
• An operating system (“OS”) developed by a third party
• All other apps proposed by third party
Please bear in mind that, depending on the functionalities, apps and/or services you may use, download or activate, you may allow or communicate more data concerning you. Thus, some processing activities may not be initiated, performed or controlled by Orange, but by third parties.
How does Orange experience work in your OBD?
Orange experience is set of applications developed and managed by Us which can notably include the following services:
• Orange Experience launcher: A launcher application with additional features (Gestures, Quick Touch…)
• Orange Phone: A telephone dialer application with additional features (protection against spam calls, reverse directory, emergency numbers….)
• Orange Livescreen: A content aggregator application (providing contents from Orange and our partners)
• Orange App Center: An application catalog (providing applications from Orange and our partners)
• Embedded apps: Third party apps provided by our partners
You are free to activate and use any of these services. Some Orange apps or services may provide you with additional information around a specific app usage for you to better understand the processing of your personal data in a specific context.
Why does Orange process your personal data and under what legal basis?
When using your OBD, Orange processes your personal data in order to ensure the good performance of your device, as well as for the good performance of the Orange services, in particular:
Why We use data?
Under what legal basis?
For your OBD’s performance and the use of Orange apps and services. In particular, to be able to propose firmware upgrades for your OBD, and to route emergency calls to the nearest emergency center.
Orange’s legitimate interest in providing you improved services and non-profiled content. Your consent will be required to access geolocation data when you place emergency calls over WiFi.
Aggregated statistics and analytics.
Orange’s legitimate interest on conducting global market research and to carry out research and statistical analysis, including to monitor how customers use our networks, products and services.
Statistics and analytics are not individualized or personalized.
To take into account your feedbacks, satisfaction and opinion on our services via satisfaction form.
Orange’s legitimate interest in providing you improved services and performance thanks to your feedback.
If you use your device in combination with an Orange SIM card and phone plan, you benefit from the services covered by your phone plan with your device (for example, billing, customer care, after sales, conditions when providing roaming services, coverage, connectivity and data usage, and any other services linked to your contract with Us).
Our contractual relationship will apply. So please, refer to the Contract Terms and Conditions applicable to your phone plan.
If you use Orange App Center.
Orange App Center Terms and Conditions will apply when you are using our apps platform. Please refer to such Terms and Conditions.
When applicable, to comply with legal requirements.
Compliance with laws and regulations applicable to Orange.
What data do we collect and use about you?
Your OBD processes data that gives you access to your device. The general categories of information we collect can be categorized are as follows:
• Technical data (for example: IP address, MAC address, device model, technical logs, device serial number, IMEI, WiFi network identifier…)
• Pseudo-anonymized data (for example: UUID which is App Center unique ID, hashed Android ID, Google Advertising ID…)
• Aggregated statistical and analytics data.
Please bear in mind that some apps or services may require more data concerning you. You are responsible for the personal data you choose to submit while using your device or apps. We invite you to read Terms and Conditions and/or Privacy Policies of such apps and/or services you will use before installing or using any app or service.
We will not collect any data from children without the parents’ consent or other holder of parental responsibility over the child.
We will only use or disclose children’s data in accordance with applicable laws and regulations.
Who can access to your personal data ?
Within the limits of their respective attributions and functions, Orange may give access to data, on a need-to-know basis, to:
• Authorized internal services within Orange Group
•Service providers acting under Orange's instructions and to the extent necessary to carry out the tasks entrusted to it (for example, for providing apps, for managing feedbacks…)
• Authorized Orange's business partner(s)
Please note that we only provide service providers and business partners with the information strictly required to perform their services.
You are informed that, in accordance with the laws and regulations in force, the data may be transmitted to competent authorities, at their request, as Authorized Third Parties.
How long do we retain your personal data?
Orange undertakes to keep your personal data for no longer than is necessary for the purposes for which we process them, and in accordance with the regulations.
You are informed that Orange may be required to keep, in archive file, some of your personal data to be able to fulfil its legal obligations and/or any legal action, and for the duration of prescription provided by the applicable legislation.
What are your rights and how you can exercise them?
In accordance with the regulations in force, you have the right to access, oppose and correct your personal data as well as to object to processing of your information, on grounds relating to your particular situation. You also have the right to portability and to restrict processing of your personal data, in the cases provided by the regulation. You can object to direct marketing information at any time.
When the processing of personal data is based on your explicit consent, you are informed you may withdraw your consent at any time.
You may issue guidelines on the retention, erasure or disclosure of your personal data after your death.
For any question relating to your OBD and to exercise your rights, you can contact Orange’s Data Protection Officer.
You are informed that you have the right to submit a request to the Commission Nationale de l’Informatique et des Libertés (CNIL), the supervisory authority in charge of compliance with the obligations regarding personal data in France. Do not hesitate to contact us before any request, we will be happy to resolve any issue or request you may have.
Data Protection Officer contact details
For any query relating to the protection of your personal data and to exercise your rights, you can contact Orange’s Data Protection Officer at this address with proof of your identity:
Attention: Data Protection Officer (DPO)
111 Quai du Président Roosevelt
92449 Issy-les-Moulineaux Cedex, France
Transfers outside the EU
We may transfer your personal data to Orange entities or third parties located outside the European Economic Area (EEA). This kind of data transfer may happen if a supplier or a service provider is based outside the EEA.
If a transfer is necessary, Orange and its suppliers will make sure that your personal data is properly protected and will take all the appropriate guarantees, including contractual measures, to ensure the protection of your data and the compliance with the applicable personal data protection regulations.
How do we protect your personal data?
Orange undertakes to protect your personal in a secure and confidential way, including when certain operations are carried out by suppliers. In this respect, appropriate technical and organizational measures to prevent any unauthorized access, loss, misuse, alteration and deletion of your personal data are implemented.
Please, find below some examples of the measures we implement:
• We use encryption, where necessary
• We restrict access to the strict minimum of data required
• People collecting or using your data are bound by duty of confidentiality
These measures are adapted according to context of the processing and state-of-the-art security measures.
Manage your privacy
As a general rule, we recommend you:
• Be aware of what you are sharing: read Terms and Conditions and/or Privacy Policies of apps and/or services you would like to use before installing or using any app or service
• Configure your settings: be cautious with the use of your personal data and how you share it (personal contact and account detail, GPS…) by configuring your device’s settings and you apps selection
• Protect your device: use strong passwords and modify them periodically. The more complex, the better! We recommend using passwords that should have at least 8 characters, and include at least 3 out of the 4 categories of characters (upper-case letters, lower-case letters, numbers, and special characters)
Changes to this Notice
This Personal Data Notice may be subject to changes from time to time to keep it up to date.
Last updated on: 4 April 2022