Updated on October 1, 2020
- Smartphone iD, a simplified joint-stock company with a capital of 10,100 euros, whose head office is located at 38 RUE SERVAN Paris (75011), registered with the RCS of Paris under number 828 147 538, registered as a photographer, declaration of activity 7420Z and authorized to operate and represented by Emile Ménétrey, its Chairman.
Hereinafter “Smartphone iD” or “our Company” or “We” or the “Smartphone iD Group”.
This policy applies to all Users of the Site, whether they are:
We encourage You to periodically review this policy for the latest information on our privacy practices.
ARTICLE 1 – Data controller
The data controller is:
- Smartphone iD, a simplified joint stock company with capital of 10,100 euros, whose head office is located at 38 RUE SERVAN in Paris (75011), registered with the RCS of Paris under number 828 147 538, intra-community VAT number FR56828147538 and
ARTICLE 2 – Information collected by SMARTPHONE iD
Smartphone iD collects and processes personal data concerning You within the meaning of the GDPR and the Data Protection Act (hereinafter indifferently referred to as “information” or “data”).
In this regard, Smartphone iD collects both information that You provide to Smartphone iD, for example when You create your Smartphone iD account, (email = password) as well as information created when You use our Services, such as information concerning your mailing address name.
2.1 Information You Provide to Smartphone iD
This may include:
- User Profile: We collect information when You create or update your iD Smartphone account. This may include your name, email address, phone number, login ID and password, address, photo. In the event that You connect to our services using the social network features made available to you, We will have access to some of your account data on said social network in accordance with the terms and conditions of use of the relevant social network. We are also likely to collect some of your data when You interact with features of these social networks, such as «Like» features.
- Demographic Information: We may collect demographic information about you, including through surveys of Users.
- User Content: We may collect information that You send when You contact Smartphone iD customer support, when You leave reviews on our website, or when You contact Smartphone iD in any other context.
2.2 Data created when You use our Services
They may include:
- Information relating to transactions on the Site (purchase of a photo control, etc.)
- Information relating to the use of the Site (such as the browsing history on the Site)
- Information on the device used to connect to the Site
- Behavioral data, when using our Products and / or Services
- Geolocation data
- Communication data
These may include:
- Users sending comments, such as notes or compliments;
- Users or other persons providing information in the context of complaints or disputes;
- Smartphone iD business partners through which You create or access your Smartphone iD account, such as payment providers or social networks;
- Public sources;
- Marketing service providers.
Smartphone iD may combine information collected from these sources with other information in its possession.
ARTICLE 3 – How We use your information
Smartphone iD collects and uses information so that You can take advantage of Services for the realization of an identity photo to the standards of the International Civil Aviation Organization of ICAO; in English: International Civil Aviation Organization, ICAO ). We also use the information We collect for the following purposes:
- to provide, customize, maintain and improve our sales of Products, provision of Services and Site functionality
- to improve the security of our Users and our Services
- for customer support
- for research and development
- to organize promotions, bonuses or contests
- in relation to legal proceedings
Smartphone iD does not sell or share your personal information with third parties for direct marketing purposes.
More specifically, Smartphone iD uses the information collected for the following purposes:
3.1. Sales of Products, provision of Services and features
Smartphone iD uses the information collected (in particular via data transfer between the various entities of the Smartphone iD Group) to provide, personalize, maintain and improve its Products and Services.
This includes in particular the use of the information for:
- create and update your account;
- perform internal operations necessary for the provision of our Services, such as troubleshooting software bugs or resolving operational issues, analyzing data, testing and research, as well as monitoring and analyzing usage and trends in activity.
We use your data to guarantee the security and integrity of our Services and our Users.
3.3. Customer support
Smartphone iD uses the information collected (including recordings of customer support calls after notifying You and with your consent) to assist You when You contact our Customer Support Services, in particular for the following purposes:
- direct your questions to the right contact person in customer support;
- conduct research and respond to your concerns;
- follow up and improve customer support responses.
3.4. Research and development
We may use the information We collect for the purposes of testing, research, profiling, analysis and Product development. This allows Us to improve the security of our Services, to develop new features and new Products and Services.
3.5. Communications from Smartphone iD
Smartphone iD may use the information collected (in particular via data transfer between the various entities of the Smartphone iD Group) to communicate with You about Products, Services, promotions, studies, surveys, news, updates. day and events.
Smartphone iD may also use this information to promote and manage contests and sweepstakes, deliver associated prizes and deliver targeted advertising and content to Users about our Services and those of our business partners. You may receive some of these communications depending on your iD Smartphone User profile. You have the right to object to this type of processing.
3.7. Legal proceedings and legal requirements
We may use the information We collect to investigate or respond to complaints or disputes regarding your use of the Smartphone iD Services, or to respond to the request of regulatory bodies or government entities, or in connection with administrative inquiries.
ARTICLE 4 – Cookies and third-party technologies
- authenticate Users
- remember User preferences and settings
- establish the popularity of content
- deliver and measure the effectiveness of advertising campaigns
- analyze site traffic and trends, and generally understand the online behaviors and interests of people who interact with our Services.
ARTICLE 5 – Sharing and disclosure of information
Some of the Smartphone iD Products, Services and features require that We transmit information to other Users or at your request.
Smartphone iD can communicate the information collected:
5.1. To other Users
- For example, if You are a user, We can communicate your photo to a driving school, travel agency, etc. if you are linked to the latter.
5.2. To other entities that are part of the Smartphone iD Group
The entities of the Smartphone iD Group may exchange Your data with each other, within the framework provided for by this policy.
5.3. To everyone when You post content to a public forum
We love to hear from our Users, especially through public forums such as social networks. When You communicate with Us by these means, your messages can be viewed by anyone.
5.4. To service providers and business partners of Smartphone iD
Smartphone iD may provide information to its suppliers, marketing partners, research companies and other Service providers or business partners who are expressly bound by written contract not to disclose or use information about You to any other. end. They are in fact contractually bound to confidentiality and security obligations at least equivalent to those provided for in this confidentiality charter.
This may concern, for example:
- payment processing organizations;
- cloud storage providers;
- marketing partners and marketing platform providers;
- data analysis providers,
- consultants, lawyers, accountants and other professional service providers;
- insurance partners and financial partners;
- vehicle solution providers or third-party vehicle suppliers.
5.5. For legal reasons or in the event of a dispute
Smartphone iD & nbsp; may release your information if We believe that it is required by law, regulation, operating contract, legal process, or government request.
It also involves the communication of your information to third parties in connection with a merger, sale of assets, merger, restructuring, financing or acquisition of all or part of our business by a company.
5.6. With your agreement
Smartphone iD may transmit your information other than as described in this policy if We notify You and If You give Us your consent.
ARTICLE 6 – Retention and deletion of information
6.1. With the exception of the categories of data referred to in Articles 6.2. to 6.4. below, your data is archived at the end of the following periods:
- 5 years after the last use of your account, if you have not closed it;
- 6 months after closing your account;
- Photos are destroyed per 6 month period and per hosting server.
6.2. The following categories of Personal Data may be kept for different periods:
- Financial data (eg payments, refunds, etc.) are kept for the time required by applicable tax and accounting laws;
- The content created by you when you use our Services (such as comments, opinions and ratings) are rendered anonymous after the deadlines mentioned in 6.1 but remain visible on our platforms;
- Some of your data may be anonymized for research or statistical purposes. No longer considered personal data, they can be kept indefinitely.
6.3. In the event that your account has been suspended or deleted, we keep your data for a period varying from 6 months to 1 year from the suspension in order to avoid any circumvention on your part of the rules in force on our platforms.
Under certain circumstances, Smartphone iD may not be able to archive your account, for example if there is an unresolved dispute.
6.4. Smartphone iD may also retain certain information as necessary to serve its legitimate business interests, for example to prevent fraud and improve User security.
For example, if Smartphone iD archives a User’s account because of his dangerous behavior, Smartphone iD may keep certain information about this account in order to prevent this User from opening another one later.
ARTICLE 7 – User rights within the European Union
Smartphone iD respects the rights granted to You by the RGPD and the Data Protection Act.
Thus, You have the right to request access to personal data concerning You and which are stored by Smartphone iD, as well as the rectification or erasure of these, or even the limitation of the processing relating to personal data concerning You, as well as the right to object to their processing.
However, in the event of limitation of processing or opposition to processing, Smartphone iD may no longer be able to allow You to access your account, or even provide You with the Products and / or Services that You have ordered. Furthermore, in the event of the exercise of the right of objection or the right to be forgotten, certain information may nevertheless be kept by Smartphone iD in order to comply with its legal obligations.
You can also set guidelines for the retention, erasure and disclosure of your personal data after your death. In the absence of such instructions, personal data concerning You will be kept in accordance with the above paragraphs, unless your heirs request a faster deletion.
To exercise these rights, You can send (i) an e-mail to the address email@example.com or (ii) a letter to the following address: SMARTPHONE ID, Personal Data Protection, 38 RUE SERVAN Paris (75011), accompanied, in all cases, by proof of identity and an explanation of your request.
In addition, You are informed that You can oppose the solicitation by registering on the website www.bloctel.fr.
Finally, You have the right to lodge a complaint at any time with the competent supervisory authority for data protection. To do this, You can contact the competent supervisory authority for data protection of the region in which You live or, in any case, the AEPD: https://www.aepd.es/es.
ARTICLE 8 – Legal basis for processing
Smartphone iD processes information relating to Users within the framework of the following legal basis (s):
- the execution of a contract: for the most part, the data that We collect are those necessary for the execution of the contract concluded between You and Us (your data may in particular be communicated to third parties, such as partners);
- Smartphone iD legal obligations: certain information must necessarily be collected by Our Company in order to comply with legal obligations;
- your consent: the data that We collect may also be data that You spontaneously choose to communicate to Smartphone iD, for example to create an Account or to obtain an insurance product quote. Mandatory data is marked with an asterisk;
- the legitimate interest of Smartphone iD: finally, certain data collected are necessary for the legitimate purposes that We pursue, in particular the creation of Your Account and then the management of the Site, it being specified that neither the collection nor the processing of this data is likely to undermine your interests or fundamental freedoms.
ARTICLE 9 – Personal information protection measures
In its capacity as data controller, Smartphone iD undertakes to implement and maintain, at its expense, appropriate technical and organizational measures in terms of the processing and security of personal data, in accordance with Articles 32 to 34 DE of aepd.
Smartphone iD thus ensures that these technical and organizational measures are at all times adapted to the particular risks presented by its processing activities, with regard to the nature of the information likely to be collected by it, in particular to protect your personal data against destruction, loss, modification, unauthorized disclosure, accidentally or unlawfully.
Thus, with regard to the technical measures implemented by Smartphone iD:
- all personal data is kept on servers located within the European Union;
- your password is encrypted and cannot be accessed by anyone except You. Only a hash of User passwords is stored on iD Smartphone servers;
- Access to our Site is secured by the CloudFare service, which also reduces the risk of denial of service (DDoS) attacks. The CloudFare service allows you to block IP addresses making too many connection attempts or Account creation;
- administrative access to our servers is limited to certain people duly identified with our hosting provider.
Regarding organizational measures:
- only certain members of Smartphone iD staff are authorized to have access to your personal data;
- access to data is protected by user names and passwords.
Smartphone iD also undertakes to keep, update and keep complete and accurate records concerning the processing of personal data carried out by Smartphone iD. These records detail its processing activities.
Smartphone iD uses stripe google pay and apple pay as a payment method.
Apple Pay lets you make simple, secure, and private transactions within iD smartphone apps. Apple Pay is designed with your security and privacy in mind, making it simpler and more secure than your physical credit, debit, or prepaid cards.
Apple Pay relies on security features built into your device’s hardware and software to help protect your transactions. Also, to use Apple Pay, you must set up a passcode on your device. You can also use Face ID or Touch ID. You can use a simple access code or choose a more complex access code for even more security.
Apple Pay also guarantees the confidentiality of your personal information. Apple does not store or access the credit, debit, or prepaid card numbers that you use with Apple Pay. Likewise, when you use Apple Pay with these types of cards, Apple does not keep any transaction information that can identify you: your transactions remain between you, the seller or the developer, and your bank or your card issuer.
When you use an app that uses Apple Pay on iOS, the app can check if that payment service is enabled on the device. You can manage this option in Settings> Safari on your iOS device, as well as in the Privacy tab of Safari preferences on your Mac.
When you make a payment directly in an app, Apple Pay receives the information related to the encrypted transaction and re-encrypts it with a developer-specific key, before sending it back to the developer or the payment manager. This key ensures that only the app can access this encrypted payment information. Neither Apple nor your device sends your actual payment card number to the app.
Apple anonymously maintains certain transaction information (for example, the approximate amount of the purchase, the name and developer of the app, the approximate date and time of the purchase, as well as the indication transaction success or failure). This data enables Apple to improve some of its products and services, including Apple Pay.
When you use Apple Pay on your iPhone to confirm a purchase made in Safari on your Mac, your Mac and the authorizing device communicate over an encrypted channel through Apple servers. Apple does not keep any of this information in a form that could identify you personally. You can turn off the ability to use Apple Pay on your Mac in Settings on your iPhone. Go to Wallet and Apple Pay and turn off Allow Payments.
If you would like more information about Apple Pay, visit the following site: https://www.apple.com/legal/applepayments/privacy-notice/
About Google Pay
Please find the information at the following address: https://payments.google.com/payments/apis-secure/get_legal_document?ldo=0&ldt=privacynotice&ldl=en-GB
Regarding stripe, you will find information at the following address : https://stripe.com/fr/privacy