Privacy policy

Purposes	Legal basis
Access to our Services and use of our Proximity Partner Network services: if you provide us with personal data in order to be able to access or use the Services, their functionalities, or our Proximity Partner Network services, we will use your personal data to give you access to the Services, their functionalities, or our Proximity Partner Network services, to manage your account and to provide our customer service.	Contract between us and you (Terms of use of the Services, this Policy and the commercial contract, if any)
Internal use by us to improve our services: your personal data may be used to improve the content and functionality of the Services, to get to know Users better, and to improve our Proximity Partner Network services.	Our legitimate interest in improving our Services and Proximity Partner Network services
Use for internal controls and to comply with our legal obligations: your personal data may be used for our internal controls, enabling us in particular to protect against, identify or counter fraudulent activities, as well as to comply with our legal obligations, such as anti-fraud, accounting, social or tax obligations.	Our legitimate interest in being able to carry out internal controls relating in particular to suspected fraudulent activitiesOur legal obligations in terms of the fight against fraud, accounting, or social or fiscal obligations
Marketing: we may use your personal data to contact you for marketing and advertising purposes, in particular to inform you of offers, competitions or surveys that may be of interest to you.	Our legitimate interest in promoting our services and providing you with our offers and news, subject to your right to object, which may be exercised at any timeYour consent, if any, to receive offers and news from our partners
Personalised display: we may use your personal data to adapt and optimise the display of the content of the Services and promotional offers, to the parameters or preferences, appetites and center of interest, known, assumed or deduced, of the User, which may result from your use of the Services, the information you have entered or from your browsing and your interactions with the Services.	Our legitimate interest in providing you with services and offers that correspond to your preferences and center of interestYour consent, if any, when required by Applicable Regulations (particularly with regard to cookies)
Your specific requests: if you provide us with personal data for a specific request, we may use it to respond to that request. If, for example, you contact us by e-mail, we will use the personal data you have provided to answer your question or try to resolve your problem, at the e-mail address used to contact you.	Contract between us and you (Terms of use of the Services, this Policy and your specific request)

5 – WHO RECEIVES YOUR PERSONAL DATA?

The personal data base created when you use the Services is strictly confidential. Advancia Téléservices undertakes to take all useful precautions, organisational and technical measures appropriate to preserve the security, integrity and confidentiality of personal data, and in particular to prevent them from being distorted, damaged or accessed by unauthorised third parties.

5.1 – Data transferred to public authorities and/or bodies

In accordance with the regulations in force, personal data may be transferred to the competent authorities upon request and in particular to public bodies, exclusively to meet legal obligations, court officers and bodies responsible for debt recovery.

5.2 – Data accessible to third parties

• Personal data may be used by Advancia Téléservices, its subcontractors, its affiliates and/or, if applicable, by its commercial partners, for the purposes described in Article 4 above.
• Advancia Teleservices staff, auditors (auditors in particular) and Advancia Teleservices subcontractors will have access to your personal data collected when using the Services.
  

5.3 – Transfers outside the European Union

The person in charge of the treatment, Advancia Téléservices, is established in Tunisia. Consequently, the User’s Personal Data may be processed outside the European Union, including via remote access.
The transfer of personal data from the European Union to a third country outside the European Union will be carried out in accordance with the Applicable Regulations.

6 – WHAT MEASURES GUARANTEE THE SECURITY OF MY DATA?

Depending on the technologies available, the costs of implementation, the nature, context and purposes of the processing and the potential associated risks, we take technical and organisational measures appropriate to the risks to guarantee the security and confidentiality of your personal data and to prevent the unlawful loss, misuse, alteration or deletion of such data. We have implemented IT security measures incorporating administrative, technical and physical measures designed to ensure reasonable protection of your personal data.
As data controller, we take the necessary measures to protect the security and confidentiality of all personal data communicated to us via our Services and to prevent the theft, misuse, unauthorised access, involuntary disclosure, alteration and/or destruction of such data. We use a variety of security measures, including encryption technology, to protect the information we collect, transfer and store.
Nevertheless, you must understand that the transmission of data over the Internet can never be absolutely secure. If we become aware of a breach of data security systems that could seriously affect your rights and freedoms, we will inform you as soon as possible, in accordance with the Applicable Regulations. We may notify you electronically of security, confidentiality and administrative issues relating to the use of the Services. If you have reason to believe that there has been a breach of personal data on the Services or of our security systems, please notify us by email at [email protected]

7 – PROTECTION OF MINORS’ PERSONAL DATA

Protecting the privacy of children is extremely important to us.
The Services are not intended for use by children. We do not deliberately collect and do not wish to collect personal data from users under the age of 15, except with the consent or authorisation of their legal representative. In the absence of such agreement or authorisation, if you are under 15 years of age, you must not communicate any personal data to us and you must only use the Services after informing a parent or legal representative, with their agreement and assistance. When an adult User enters personal data relating to a minor under the age of 15, he/she undertakes to have the verifiable consent of the holders of parental authority, and to provide on request any element enabling proof of this consent to be produced.

8 – WHAT ARE YOUR RIGHTS CONCERNING YOUR PERSONAL DATA?

In accordance with the Applicable Regulations, subject to an express request and proof of your identity to us, you have a right of access to your personal data, a right of rectification, a right of opposition, as well as a right to erasure, under the conditions of the Applicable Regulations.

Your right to the deletion of your personal data applies subject to the necessities that Advancia Teleservices may justify in order to retain Personal Data, in particular with respect to its legal obligations.

In the event of exercise of the right of opposition, Advancia Teleservices will cease the treatment of your personal data, except in the event of legitimate reason(s) and imperative for the treatment, or to ensure the establishment, the exercise or the defense of its rights in justice, in accordance with the Applicable Regulation.
You may also, subject to the conditions of the Applicable Regulations, request a restriction on the processing of your personal data.
Where the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time.
You also have a right to the portability of some of your personal data, allowing you to request a computer copy in a readable and usable form of your personal data processed by Advancia Teleservices as part of your contractual relationship with us for the provision of products or services to which you have subscribed, which excludes personal data that Advancia Teleservices may have processed for its own purposes or to meet its legal obligations, including accounting, social or tax, as well as information relating to the history of orders placed, amounts paid or payable, and all information that Advancia Teleservices may have generated as part of the legitimate interests it pursues.

You have the faculty to provide to Advancia Teleservices directives relative to the fate of your personal data after your death.
If necessary, Advancia Teleservices will inform you of the reasons for which the rights that you exercise could not be satisfied in whole or in part.
To exercise the rights mentioned in this Article, you may contact Advancia Teleservices at the address indicated in Article 11 below.
You may also file a complaint with the CNIL or the competent data protection authority of the European Union Member State in which you usually reside.

9 – HOW LONG WILL YOUR INFORMATION BE KEPT?

We will keep your personal data for as long as is necessary for the purposes described in this Policy, in accordance with our legal and regulatory obligations. We undertake to archive and delete your personal data as soon as the purpose for which it was collected has been fulfilled and the retention period has expired.

However, personal data may be archived for longer periods for the purposes of investigating, ascertaining and prosecuting criminal offences, for the sole purpose of making such personal data available to the judicial authorities, where necessary, or for the purposes of legal proceedings. Archiving implies that this personal data will be subject to access restrictions.

The maximum retention periods for personal data are summarised in the table below, depending on the category of data and the purpose for which the personal data was collected and processed.

These maximum retention periods apply if you have not requested that your personal data be deleted or cease to be used before the end of the set period, subject to any legal obligations applicable to data retention.

Category	Data retention period
Cookies and other tracers for audience measurement	13 months from the date of deposit of the cookie or other tracker
Data collected via cookies and other audience measurement tags	25 months from the date of collection
Other cookies and other trackers: advertising, personalisation of Services, etc.	13 months from the date of deposit of the cookie or other tracker in the User’s terminal equipment, or 1 week from the date of refusal of the cookie by the User
Data relating to the management of requests to exercise rights and questions about personal data	3 years from the last interaction initiated by the User
Data relating to responses to satisfaction surveys	3 years from the last contact initiated by the User
Data relating to responses to satisfaction surveys	3 years from the last contact initiated by the User
Data relating to the sending of commercial offers and prospecting campaigns, and to the management of interactions with customer service	For customers: 3 years from the end of the commercial relationship or from the last contact initiated by the customer For prospects: 3 years from the date of collection of the data or from the last contact initiated by the prospect
Data relating to the management and archiving of Proximity Partner Network services	10 years from the last transaction or the last full payment for the last service provided, except for data concerning payment methods processed by Advancia Téléservices and/or its affiliated companies’ payment service providers, only for the duration of the payment transaction

10 – HOW WILL I BE INFORMED OF CHANGES TO THIS PRIVACY POLICY?

The Services and our business may change. As a result (and for other business and/or technological reasons), we may change this Policy. We reserve the right to update, alter, amend or modify this Privacy Policy at any time and from time to time without prior notice. We invite you to consult this Policy regularly, and more particularly before communicating your personal data.

If we believe that the planned changes constitute a major revision of this Policy, we will place a notice on the Services to inform Users of such changes and to allow Users to take certain actions prior to the implementation of such changes. In some cases, we may also send an email to notify Users with an account of upcoming changes.

This Policy was last updated on the date indicated above. Your continued use of the Services following the implementation of any changes or revisions to this Policy constitutes your acceptance of the provisions of the revised Policy as it now applies.

11 – CONTACTING US

If you have any questions, comments or concerns regarding our Privacy Policy, please contact us by e-mail at [email protected] or by post at the following address: Advancia Téléservices, ZAC Khéreddine,26, rue Socrate – ZAC Khéreddine – Le Kram 2015 – Tunis – Tunisia.