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Effective date: April 30, 2025

Section I – Introduction.

 

Hello and welcome,

Respecting your private life and your personal data are a priority for the SoftAtHome company.

Please take the time to read our privacy policy before deciding whether or not to provide us with your personal data. Personal data is information that can be used to directly or indirectly identify you.

SoftAtHome commits to respect the French and European Legal regulation of the protection of data, in particular the GDPR (The General data protection regulation) of the 27th April 2016 and The Data Protection Act 1978.

This document explains how we process and protect your personal data, who we are, the way we collect and use your personal data, your individual rights under the GDPR (General Data Protection Regulation) and the legislation adopted pursuant to this regulation.

This privacy policy is an integral part of SoftAtHome terms and conditions accessible on our website.

 

Section II – Definitions

 

Under this Data Protection Policy, the words hereunder listed have the following meaning:

  • Personal Data :

It’s data relating to a natural person who is identified or identifiable, directly or indirectly.

  • GDPR (General Data Protection Regulation) :

The GDPR frame the personal data processing in the territory of The European Union. It came into force in 2018.

  • Processing of personal data :

This refers to an operation, or several operations, involving personal data, for all process used (example: collection, conservation, adaptation, modification, etc).

  • Data Processor :

It’s legal or natural person who determines the purposes and resources of processing, i.e. the goal and the way of achieving it.

  • Subcontractor :

It’s a natural or legal person who process personal data for another organism (the Data Processor), in frame a service.

  • Person involved / concerned :

This refers to all natural person identified or identifiable whose personal data is processed.

  • Legal base :

It is the legal ground that authorizes an organization the process personal data.

  • Duration of conservation :

The necessary duration to realize the goal (purpose of processing) to justify the collection or the registration of personal data.

  • Data protection officer (DPO) :

The natural person who is responsible for implementing GDPR compliance in the organization that has appointed him for all processing carried out by this organization.

 

Section III – Who processes your personal data ?

 

The data controller for the personal data collected through this website is SoftAtHome, a French Société Anonyme, registered at the French Trade Register of Nanterre under the N° B 500 440 813 RCS Nanterre, and having its registered office at 9-11 rue du Débarcadère, 92700 Colombes, France.

We are the Data controller, so SoftAtHome takes appropriate action to ensure the protection and confidentiality of the personal data that it has or that it trades in accordance with the GDPR.

For any questions regarding the protection of your personal data, you can contact our Data Protection Officer (DPO) at the following address:

  • By email: dpo@softathome.com
  • By post : 9 rue du Débarcadère – 92700 Colombes – France

 

Section IV – Personal data management: Sources, processing activity, purposes, data processed, legal base, category of person concerned, duration of conservation

 

Personal data is kept by SoftAtHome for a period not exceeding that necessary to achieve the purposes specified above, plus, where applicable, the statutory and regulatory periods in France and Europe, including statute of limitation.

The data is intended for SoftAtHome and will also be communicated to third parties as listed in the table below.

It may also be communicated to any administrative, judicial or supervisory authority which benefits from a right of communication based on a provision of the Law within the framework of a French or European administrative or judicial procedure, at their request.

 

Data source Explanation of the source Processing activity Purpose Personal data category Legal ground of processing Category of person concerned Recipients

Data collected from you

These data are obtained directly from you in the following contexts:

Our current or past clients

 

Individuals who have purchased or used our products or services.

Customers experiencing bugs or anomalies with the services provided

 

collection, recording, organisation, structuring, storage, adaptation, retrieval, consultation, use, disclosure by transmission, making available, combination, restriction, erasure or destruction -Management of customer files required for the supply of goods and/or services

 

-Communication with customers in connection with the supply of goods and/or services

 

-Management of complaints, after-sales services or warranties

 

-Correction of bugs and anomalies of internet / Homegateway / SetTopBox / Mobile phone / phone / IOT / devices

 

-Managing the implementation of our customer assistance or IT support

 

– Management of orders for goods and/or services

 

– Management of deliveries of goods and/or services

 

– Management of corporate restructuring operations (mergers and acquisitions) and internal and external audits

 

– Manage outstanding debt and collection activities.

 

Identity data

Contact details

Login data / web navigation data / TV programs, mobile phone, connected devices and IOT

Usage data

Contractual execution

Consent

Customers

Past customers

Users

 

Providers of IT hosting and website services.

IT and IT maintenance service providers.

Providers of web analytics and optimisation services.

Providers of customer support solutions.

Providers of delivery service solutions.

Providers of database management solutions.

Providers of accounting and financial solutions.

Providers of document management solutions.

Providers of automated email and/or newsletter mailing solutions.

Providers of marketing services and solutions.

Providers of solutions for optimising social network strategies.

Providers of statistical analysis solutions

Professional advisors including regulated professions

Our partners / clients

Other entities of our Group

Public authorities

New buyer and their advisors

Employees and external service providers of SoftAtHome’s R&D, debug, commercial and marketing teams

 

Our prospects / / commercial contacts Individuals who have shown interest in our products or services or have been contacted by us for potential business opportunities

Commercial contacts

 

collection, recording, organisation, structuring, storage, adaptation, retrieval, consultation, use, disclosure by transmission, making available, combination, restriction, erasure or destruction -Management of the relationship with our potential customers before concluding a contract with them

 

-Prospecting and marketing activities

 

– Management of orders for goods and/or services

 

– Management of deliveries of goods and/or services

 

-Keeping commercial contact for projects and potential projects

 

Identity data

Contact details

Professional data

 

Contractual execution

Legitimate interest

agreement

 

Prospects

commercial contacts

 

Providers of IT hosting and website services.

IT and IT maintenance service providers.

Providers of web analytics and optimisation services.

Providers of customer support solutions.

Providers of delivery service solutions.

Providers of database management solutions.

Providers of accounting and financial solutions.

Providers of document management solutions.

Providers of automated email and/or newsletter mailing solutions.

Providers of marketing services and solutions.

Providers of solutions for optimising social network strategies.

Providers of social media web sites

Providers of statistical analysis solutions

Professional advisors including regulated professions

Our partners / clients

Other entities of our Group

Public authorities

New buyer and their advisors

Employees and external service providers of SoftAtHome’s commercial and marketing teams

 

Filling out an online form Individuals who complete a form on our website collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, making available, combination, restriction, erasure or destruction -Management of users of the internet website who filed a form online or used the contact interface

 

-Prospecting and marketing activities

Identity data

Contact details

Internet navigation data

Information provided in the online form or through the contact interface (at the user’s choice)

Contractual execution

 

Legitimate interest

Users filling a form or using contact interface Providers of IT hosting and website services.

IT and IT maintenance service providers.

Providers of web analytics and optimisation services.

.

Providers of database management solutions.

Providers of document management solutions.

Providers of automated email and/or newsletter mailing solutions.

Providers of marketing services and solutions.

Providers of statistical analysis solutions

Recruitment service providers

Professional advisors including regulated professions

Our partners / clients

Other entities of our Group

Public authorities

New buyer and their advisors

Employees and external service providers of SoftAtHome’s marketing, legal, compliance, HR, R&D and commercial team (depending on the request)

 

User of our website SoftAtHome Individuals who visited our website (www.softathome.com) and interacted with our online content or services collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, or otherwise making available, alignment or combination, restriction, erasure or destruction -Ensure the proper functioning of our website and display the correct version for your device

 

-Guarantee the security of computer networks, IT systems, servers, information and data

 

-Ensure the safety and protection of goods and people

 

-Managing the implementation of our customer assistance or IT support.

 

Identity data

Contact data

Internet navigation data

Legitimate interest

 

Users Providers of IT hosting and website services.

IT and IT maintenance service providers.

Providers of web analytics and optimisation services.

Providers of marketing services and solutions.

Providers of solutions for optimising social network strategies.

Providers of statistical analysis solutions

Professional advisors including regulated professions

Our partners / clients

Other entities of our Group

Public authorities

SoftAtHome employees and external providers of IT and security teams of SoftAtHome

 

Our partners Individuals or organizations that collaborate with us for commercial activities, R&D projects or other activities. collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, or otherwise making available, alignment or combination, restriction, erasure or destruction -Partner selection

 

 

Identity data

Contact details

Professional data

Contractual execution Partners Providers of IT hosting and website services.

IT and IT maintenance service providers.

Providers of web analytics and optimisation services.

Providers of customer support solutions.

Providers of delivery service solutions.

Providers of database management solutions.

Providers of accounting and financial solutions.

Providers of document management solutions.

Providers of automated email and/or newsletter mailing solutions.

Providers of marketing services and solutions.

Providers of solutions for optimising social network strategies.

Providers of statistical analysis solutions

Professional advisors including regulated professions

Our partners / clients

Other entities of our Group

Public authorities

New buyer and their advisors

SoftAtHome employees and external providers in touch with partners for the performance of common projects,

SoftAtHome employees and external providers in commercial, R&D, and Marketing teams

 

Our candidates Individuals who apply for a position at SoftAtHome, whether through our website or other recruitment channels. collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, or otherwise making available, alignment or combination, restriction, erasure or destruction -Application management

 

-Manage recruitment and applications, including via our website or third-party sites

Identity data

Contact details

Professional data

Professional background, education,

Potential other information provided by the candidate

Contractual execution

Or

consent

Candidates Providers of IT hosting and website services.

IT and IT maintenance service providers.

Providers of web analytics and optimisation services.

iders of database management solutions.

Providers of accounting and financial solutions.

Providers of document management solutions.

Providers of automated email and/or newsletter mailing solutions.

Providers of marketing services and solutions.

Providers of solutions for optimising social network strategies.

Providers of statistical analysis solutions

Recruitment service providers

Professional advisors including regulated professions

Our partners / clients

Other entities of our Group

Public authorities

New buyer and their advisors

Employees and external service providers of SoftAtHome’s HR and recruitment team

 

Our visitors (trade show, congress, events…) During trade shows, congress and events visitors may approach our booths to engage with our representatives. In this context, they may choose to voluntarily provide their contact details and other personal information in order to receive further information about our products, services, or company.

 

Individuals who have shown interest in our products or services or have been contacted by us for potential business opportunities or that we met during events such as trade, shows, congress or else

 

collection, recording, organisation, structuring, storage, adaptation, consultation, use, disclosure by transmission, or otherwise making available, alignment or combination, restriction, erasure or destruction

 

-Management of the relationship with our potential customers before concluding a contract with them

 

-Prospecting and marketing activities

 

 

Identity data

Contact details

Professional data

Photos and videos taken during events, congress or trade shows

Consent Visitors

natural persons met at trade shows, congress or events (including SoftAtHome employees’, executives and partner’s),

commercial contacts,

 

Providers of IT hosting and website services.

IT and IT maintenance service providers.

Providers of web analytics and optimisation services.

Providers of database management solutions.

Providers of accounting and financial solutions.

Providers of document management solutions.

Providers of automated email and/or newsletter mailing solutions.

Providers of marketing services and solutions.

Providers of solutions for optimising social network strategies.

Providers of social media web sites

Providers of statistical analysis solutions

Professional advisors including regulated professions

Our partners / clients

Other entities of our Group

Public authorities

New buyer and their advisors

Employees and external service providers of SoftAtHome’s commercial and marketing teams

Employees and external service providers of SoftAtHome’s HR and recruitment team

 

 

Our employees

 

employees, executives and external providers of SoftAtHome present at Congress or events

 

SoftAthome employees, executives and external providers being commercial contacts of our clients

 

video showing SoftAtHome activities may contain personal data, regarding family, job, gender, opinions …

 

 

collection, recording, organisation, structuring, storage, adaptation, consultation, use, disclosure by transmission, or otherwise making available, alignment or combination, restriction, erasure or destruction

 

-Management of the relationship with our potential customers before concluding a contract with them

 

-Prospecting and marketing activities

 

Identity data

Contact details

Professional data

Photos and videos taken during events, congress or trade shows and opinions expressed

Consent

Execution of the contract

SoftAtHome employees, executives and external providers on photos /videos

 

SoftAtHome employees, executives and external providers being commercial contacts of our clients

Providers of IT hosting and website services.

IT and IT maintenance service providers.

Providers of web analytics and optimisation services.

Providers of customer support solutions.

Providers of delivery service solutions.

Providers of database management solutions.

Providers of accounting and financial solutions.

Providers of document management solutions.

Providers of automated email and/or newsletter mailing solutions.

Providers of marketing services and solutions.

Providers of solutions for optimising social network strategies.

Providers of statistical analysis solutions

Professional advisors including regulated professions

Our partners / clients

Other entities of our Group

Public authorities

New buyer and their advisors

Employees and external service providers of SoftAtHome’s HR commercial and marketing team

 

  Data collected from a third party

These data are obtained from third parties (other data controllers) in the following contexts:

One or more other data controllers .

 

To perform recruitment, SoftAtHome may receive CV, resumé, cover letter or other personal information through Linkedin, social media or other data controllers as recruitment agencies.

 

 

collection, recording, organisation, structuring, storage, adaptation, retrieval, consultation, use, disclosure by transmission, making available, combination, restriction, erasure or destruction

Recruitment

Identity data

Contact details

Professional data

Professional background, education,

Potential other information provided by the candidate

Contractual execution

Or

Consent

Individuals presented by recruiting services’, or social media

 

Providers of IT hosting and website services.

IT and IT maintenance service providers.

Providers of web analytics and optimisation services.

Providers of customer support solutions.

Providers of delivery service solutions.

Providers of database management solutions.

Providers of document management solutions.

Providers of automated email and/or newsletter mailing solutions.

Providers of marketing services and solutions.

Providers of solutions for optimising social network strategies.

Providers of statistical analysis solutions

Recruitment service providers

Professional advisors including regulated professions

Our partners / clients

Other entities of our Group

Public authorities

New buyer and their advisors

Employees and external service providers of SoftAtHome’s HR and recruitment team

 

Subscribers of SoftAtHome’s clients SoftAtHome provides software products and services to service providers and clients (mainly telecom operators). In this context, SoftAtHome may need to access data related to bugs or other technical information coming from other data processors or other data controllers (such as their client or other subprocessors of its clients)

 

Individuals who use the services provided by SoftAtHome including via their telecom operator (Internet Home gateway, Set Top Box, mobile phone, IOT or services provided by their telecom operator subcontracted to SoftAtHome).

Customers of our clients experiencing bugs or anomalies with the services provided

 

collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, or otherwise making available, alignment or combination, restriction, erasure or destruction -Debug and resolution of anomalies for internet /Home gateway / Set Top Box / mobile phone / IOT and connected devices Identity data

Contact data

Login

Internet navigation data

TV programs data, mobile phone, connected devices and IOT,

Usage data

 

Contractual execution

Or

consent

Subscribers of SoftAtHome’s clients

Users

Providers of IT hosting and website services.

IT and IT maintenance service providers.

Providers of customer support solutions.

Providers of database management solutions.

Providers of document management solutions.

Professional advisors including regulated professions

Our partners / clients

Other entities of our Group

Public authorities

New buyer and their advisors

Employees and external service providers of SoftAtHome’s R&D, debug teams

 

Visitors (trade show, congress, events…) During trade shows, congress and events organisers provide SoftAtHome with the datas of visitors who approached our booths to engage with our representatives in order to receive further information about our products, services, or company.

 

 

collection, recording, organisation, structuring, storage, adaptation, consultation, use, disclosure by transmission, or otherwise making available, alignment or combination, restriction, erasure or destruction

 

-Management of the relationship with our potential customers before concluding a contract with them

 

-Prospecting and marketing activities

 

 

Identity data

Contact details

Professional data

Photos and videos taken during events, congress or trade shows

Consent Visitors

natural persons met at trade shows, congress or events,

commercial contacts,

 

Providers of IT hosting and website services.

IT and IT maintenance service providers.

Providers of web analytics and optimisation services.

Providers of database management solutions.

Providers of accounting and financial solutions.

Providers of document management solutions.

Providers of automated email and/or newsletter mailing solutions.

Providers of marketing services and solutions.

Providers of solutions for optimising social network strategies.

Providers of social media web sites

Providers of statistical analysis solutions

Professional advisors including regulated professions

Our partners / clients

Other entities of our Group

Public authorities

New buyer and their advisors

Employees and external service providers of SoftAtHome’s commercial and marketing teams

 

  Data collected from public sources:

These data are obtained from publicly accessible sources:

 

Social Network Data available in public directories, professional social networks, etc.

 

Data collected from the SoftAtHome pages of the social media X, Linked’IN and Youtube pages

collection, recording, organisation, structuring, storage, consultation, use, disclosure by transmission, dissemination or otherwise making available, erasure or destruction -Marketing

 

 

Identity data

Public contact details

Professional data

Post published on SoftAtHome social media pages

Legitimate interest Prospects

Candidates

Users

Users of the social media (they have access to the post)

Providers of IT hosting and website services.

IT and IT maintenance service providers.

Providers of web analytics and optimisation services.

Providers of database management solutions.

Providers of document management solutions.

Providers of automated email and/or newsletter mailing solutions.

Providers of marketing services and solutions.

Providers of solutions for optimising social network strategies.

Providers of statistical analysis solutions

Professional advisors including regulated professions

Our partners / clients

Other entities of our Group

Public authorities

New buyer and their advisors

Employees and external service providers of SoftAtHome’s marketing and HR teams

 

Section VII- What are your rights regarding you personal data and how to exercice them ?

 

Introduction

You have rights concerning the use of your personal data. These rights vary depending on the lawful basis used to justify the processing of your personal data and certain data processing purposes.

When you exercise a right (e.g. the right of access, deletion, rectification, etc.), we may require you to attach a document to prove your identity if we have any reasonable doubt about it, for example to avoid identity theft and protect you against the risk of fraud.

Your rights may be exercised free of charge, except where the requests are repetitive or excessive, in which case we are entitled to charge a reasonable fee based on our administrative costs.

Right to be informed about the use of your personal data.

You have the right to receive clear information about the use of your personal data and the exercise of your rights.

Right of access and obtain a copy of your personal data.

You may obtain a copy of your personal data, as well as the following information:

whether or not we process your personal data and which data; why your personal data is processed;

the recipients it is disclosed to, and how we obtained your personal data; the data retention period or the criteria that determines this period.

This right is subject to exceptions and respecting the rights and freedoms of third parties (for example: we cannot provide you with information on other people).

You may make your request through the various communication channels we provide.

Right to rectification of your personal data.

Where your personal data is incomplete, inaccurate or simply no longer up to date, you have the right to request its rectification. This right allows us to avoid processing or distributing inaccurate information about you.

Right to deletion/erasure of your personal data.

You may request the erasure of your personal data when it is no longer necessary for the purposes it was processed for. However, we may refuse to do this if we are required to continue processing your personal data, such as when we need it to meet our legal obligations or for evidentiary purposes.

Right to define directives regarding the fate of your data after your death (French residents only).

You have the right to define directives relating to the storage, erasure and communication of your personal data after your death. These directives can be general or specific. General guidelines need to be registered with a trusted third party. Specific directives need to be sent directly to us.

Right to restrict the processing of your personal data.

You have the right to request a limitation on the processing of your personal data (i.e. “blocked”, “locked”) in certain specific cases. In this case, we must refrain from carrying out any further processing whatsoever of the personal data in question, for the time necessary to exercise your right.

Unless such notification proves impossible or requires disproportionate effort, we will notify each recipient to whom the personal data has been disclosed.

Right to object to the processing of your personal data.

You have a right to object to the processing of your personal data in certain cases.

You have the right to object to the processing of your personal data when it is based on our legitimate interest. It is worth noting that this right is not a right to the outright and permanent removal of all your personal data or the account linked to you. We may refuse this request if there are legitimate and compelling reasons or if the processing of personal data is necessary for the establishment, exercise or defence of legal claims.

You have the right to object to the processing of your personal data for direct marketing purposes. This right mainly applies to the processing of your personal data for the purpose of advertising (e.g. to stop receiving canvassing, online newsletters, etc.). You have the right to object to profiling, a right which always applies when profiling is related to direct marketing.

The right not to be the subject of a decision based entirely on automated processing, including profiling.

You have the right not to be subject to a decision based entirely on automated processing, including profiling, which has a legal impact on you or significantly affects you. In this case, you have the right:

to be informed that an entirely automated decision has been taken against you; to request to be informed of the logic and criteria used to make the decision; to challenge the decision and express your point of view; to request human intervention to review the decision.

Profiling is permitted, however, if you have given your consent or if it is necessary for the performance of a contract, the fulfilment of a legal obligation, to protect your vital interest, the public interest, the exercise of public authority or the legitimate interest of the data controller or a third party. You may always refuse profiling for prospecting purposes.

Right to withdraw your consent at any time.

When the processing of your personal data is based on your consent, you may withdraw your consent to the processing of your data by ourselves or our processors at any time.

You may make your request through the various communication channels we provide. You may also change your mind through the same channels.

Right to data portability.

When we process your personal data via automated processes and on the basis of your consent or the existence of a contract, you have the right to receive the data you have provided to us free of charge (in a structured, commonly used and machinereadable format) and, as applicable, to transfer it to another data controller.

However, this right to data portability is not general. It only concerns data collected with your consent or in the context of a contract. The right to portability concerns information that you have actively and knowingly provided (e.g. by completing an online registration form) but also data collected through the use of our service or product. However, it does not apply to data derived or inferred from the information you have provided.

If it is technically impossible to directly transfer the data to another data controller, we will provide you with a copy of your personal data in a structured, commonly used and machine-readable format.

Exercice of such Rights.

The aforementioned rights may be exercised by contacting SoftAtHome’s Data Protection Officer at the postal address “Délégué à la protection des données (DPO), SoftAtHome, 9-11 rue du débarcadère, 92700 Colombes – France” or at the email address dpo@softathome.com

Section VIII – Consequence of refusal to provide your personal data to SoftAtHome

Depending on the case, SoftAtHome might unfortunaltely not be able to provide you with goods and services, and would be forced to refuse to establish a contractual relationship with you.

Section IX – Security

SoftAtHome as a Data Provider undertakes to make its best efforts to ensure the security and confidentiality of the data processed in accordance with the provisions of the French Data Protection Act and the RGPD.

To preserve the security of data so that it is not deformed, damaged, or accessed by unauthorized third parties.

Section X – Cookies

Please check our cookies policy available at: https://www.softathome.com/resources/

Section XI – Transfer outside the European Area (EEA)

In the context of the data processing purposes described in Section, your personal data may be transferred outside the European Economic Area (EEA). In this case, we have taken the following protective measures to ensure the security of your personal data and your individual rights. Transfer to a country subject to an adequacy decision by the European Commission (Art. 45 of the GDPR). Transfer on the basis of the standard contractual clauses (SCCs) adopted by the European Commission (Art. 46-2(c) of the GDPR) or by supervisory authorities (Art. 46-2(d) of the GDPR). You can obtain further information on the transfer of your personal data to third party countries by contacting us via our 5/7 communication channels indicated in Section I “How to contact us”.

 

Section XII – Complaints to the supervisory authority

If you are not satisfied with the way we process your personal data, you have the right to lodge a complaint with the supervisory authority responsible for the protection of personal data in your country of residence or work. The list of supervisory authorities in EU countries is available on the website of the EDPB (European Data Protection Board).

France : CNIL Place de Fontenoy TSA 80715 3 75334 Cedex 7 Paris

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