FrançaisEnglish
SAYLO

NEXERA CONNECT · Privacy notice

Privacy Policy

Personal data protection in the SAYLO mobile application.

Last updated

At a glance

SAYLO is provided by NEXERA CONNECT. This policy describes the personal data collected, its purposes, your rights and retention during the contractual relationship and for five (5) years after it ends, unless an exception justifies a longer period.

Exercise your rights

Provider and scope

The SAYLO mobile application (the “Application”) is published, operated and provided by NEXERA CONNECT, a French simplified joint-stock company with share capital of EUR 38,895,240, whose registered address is 150 boulevard Victor Hugo, 93400 Saint-Ouen-sur-Seine, France, registered with the Bobigny Trade and Companies Register under SIRET number 84036174500010, and whose intra-community VAT number is FR54840361745. NEXERA CONNECT is the sole legal entity authorised to enter into a contract with the Customer under these General Terms of Service.

Accordingly, any reference in this Privacy Policy (the “Privacy Policy”) to “SAYLO”, “we”, “our” or “us” refers to NEXERA CONNECT, operating under the SAYLO brand.

The Application’s main activity is providing access to and delivering voice over IP (VoIP) communication services.

SAYLO places particular importance on protecting personal data and undertakes to process it in accordance with applicable regulations, including Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (the “GDPR”), and French Law No. 78-17 of 6 January 1978, as amended, known as the French Data Protection Act.

When the dedicated Application is used, SAYLO collects and processes Personal Data when a Customer creates a personal account on the mobile Application and provides personal information as part of their subscription.

The Personal Data collected remains the exclusive property of the Users from whom it is collected. This Personal Data is entrusted to SAYLO solely for the purposes of the Services to which the Customer subscribes with express consent, on the basis of detailed and transparent information about the purposes of those Services.

Personal data collected

SAYLO collects and processes Personal Data on its own behalf as part of providing the services integrated into the Application when a user creates a personal account. Without this information, the User cannot create an account to use our Services.

All individuals with a user account on the Application (the “Users”) are asked to expressly consent to the collection of certain personal data, as listed below:

Customer account information

  • Last name
  • First name
  • Email address
  • Phone number
  • Customer ID
  • Login identifiers
  • Technical identifiers associated with the account or service
  • Encrypted password or data required for authentication
  • Account preferences
  • Language
  • Profile photo
  • History of account creation, modification or deletion

Data relating to the use of services

  • Communication content (audio, video, text), whether transmitted or not, and other information relating to communications, including when you interact with SAYLO
  • Information about the user and their use of our websites and Solutions, including system information such as equipment identifiers and telemetry (for example, IP or MAC addresses) when this data is linked or associated with a specific user’s equipment
  • Whether you are online
  • When you last used our Services (“last seen”)
  • When you last updated your status information
  • Content of requests submitted through the Application
  • Attachments or screenshots submitted by the user
  • Time, frequency and duration of your activities and interactions
  • Log files
  • Exchanges relating to the resolution of an incident
  • Technical information required for diagnosis
  • Websites, logs and performance reports
  • Information relating to consumption monitoring
  • Feature usage history
  • Volume of data consumed and remaining
  • Remaining validity period
  • User information on the use of their plan
  • Sending communications, including for marketing or customer satisfaction purposes, directly by SAYLO or its partners
  • Managing communication preferences. You may change your communication preferences at any time.
  • Features used
  • Prospecting and communication data

Technical connection data

  • IP address
  • Usage timestamps
  • Connection logs
  • Connection date and time
  • Duration and frequency of service use (the time, frequency and duration of your activities and interactions)
  • Device type
  • Operating system
  • Application version
  • Browser information
  • Device language
  • Time zone
  • Technical device or application identifiers, when necessary for the operation of the service
  • Mobile network
  • Connection data (including phone number, mobile operator or internet service provider)
  • Location information
  • Data relating to security, authentication and fraud prevention
  • Cookies

Third-party information

  • Information about you provided by and to third parties (individuals and legal entities)
  • Reports about individuals
  • Information associated with your account
  • Third-party services

Collection of personal data

This information is collected to enable SAYLO to operate, provide, improve, understand, personalise, support and market its Services, including when the User installs, uses or accesses our Services.

The information collected depends on how the User uses our Services and is provided directly by the User concerned.

Data is also collected from service providers, partners or public sources.

Managing your personal data

Each User can access and manage their information directly from their customer account.

Depending on the circumstances, the User who created the customer account has the right to access their personal data; to rectify inaccurate or incomplete data; to erase data under the conditions provided by applicable regulations; to restrict processing; to data portability when applicable; to object to processing on grounds relating to their particular situation when processing is based on legitimate interests; to object to direct marketing at any time; to withdraw consent at any time when processing is based on consent; and to define instructions concerning their data after their death, in accordance with French law.

Where there is reasonable doubt about the requester’s identity, SAYLO may request additional information or proof of identity strictly necessary for verification.

To exercise these rights, including requesting erasure of your data, contact the DPO listed in the Contact section.

Contact the DPO

Retention of personal data

SAYLO stores all information collected for the purposes identified in this Privacy Policy, including providing our Services, or for other legitimate purposes, including complying with legal and regulatory obligations, ensuring compliance with our Terms and preventing breaches, or protecting or defending our rights, property and Users.

Personal data collected may be accessed, retained and stored when necessary to:

  • Respond to legal proceedings or government requests in accordance with applicable laws or regulations;
  • Enforce our Terms and any other applicable terms or policies, including investigating potential violations;
  • Detect, investigate, prevent or address fraud, other illegal activity, or technical or security issues;
  • Protect the rights, property and safety of our users, SAYLO or other entities, including preventing imminent death or bodily harm;
  • Manage and resolve complaints and requests;
  • Meet operational retention needs.

Data collected and provided through the Application is retained for the duration of the contractual relationship and then for five (5) years after it ends for evidentiary purposes, unless a legal obligation or particular necessity justifies a longer period.

Transactional and technical communications

Purposes

  • Emails or notifications relating to account creation
  • Order confirmation
  • Information about service activation, top-ups or status
  • Account security messages
  • Information essential to the performance of the contract

Data categories

Identification data, order data, technical data and service-related data.

Legal basis

Performance of the contract.

Policy updates

SAYLO may modify or update this Privacy Policy at any time to reflect legal or regulatory developments, recommendations from supervisory authorities, developments in case law, and technical or functional changes to the website, Application or service. The current version will be indicated directly through the Application.

Transfers of information outside the European Union

Personal data is hosted and processed within the European Union.

SAYLO does not arrange any transfers of data to a country outside the European Union or the European Economic Area.

Contact

Any data subject may exercise their rights by contacting SAYLO’s Data Protection Officer (DPO):

Email: s.rahim@netcom-group.co

By post:

NEXERA – Data Protection Officer
150 boulevard Victor Hugo
93400 Saint-Ouen-sur-Seine

SAYLO will endeavour to respond within the time limits prescribed by applicable regulations. In accordance with personal data protection legislation, any person whose data is processed has rights to object, access, rectify, erase, obtain portability of, restrict or delete information about them that is no longer necessary for the purposes for which it was collected or otherwise processed.

The data subject also has the right to lodge a complaint with the French data protection authority, the Commission nationale de l’informatique et des libertés (CNIL).

SAYLO Customer Service

For any questions about this Policy or how SAYLO processes personal data, you may contact SAYLO Customer Service by email or by post at the address below.

Email: s.rahim@netcom-group.co

FRANCE NUMERIQUE
SAYLO Customer Service
150 boulevard Victor Hugo
93400 Saint-Ouen-sur-Seine

Alternatively, you may email SAYLO’s Data Protection Officer.

Email: s.rahim@netcom-group.co