Personal data protection policy

The Sagemcom Group takes privacy and the protection of personal data very seriously. For this reason, the Sagemcom Group undertakes to process personal data in accordance with the applicable national regulations and Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation or GPDR), which entered has applied on 25 May 2018. In this respect, the Sagemcom Group has based its personal data protection policy (the Policy) on the principles set out in the GDPR and applicable national regulations.

The purpose of this Policy is to inform you about how the Sagemcom Group processes your personal data and ensures compliance with the GPDR.

We also invite you to consult the personal data protection policies of the companies of the Sagemcom Group.

Why does Sagemcom process your personal data and on what grounds?

Sagemcom only processes your personal data for specific, explicit and legitimate purposes. Sagemcom does not process this data in a way that is incompatible with these purposes.

Under the GDPR, the main grounds for processing personal data are as follows:

a) the processing is necessary for the conclusion or performance of a contract: Sagemcom may be required to process your personal data for the performance of commitments entered into with the other party, the management of the contract, invoicing and monitoring of the contractual relationship; 

b) the processing is necessary to comply with a legal obligation: we are subject to certain legal requirements that may require us to process your personal data. We may also be required by law to disclose your personal data to a regulatory or law enforcement agency, in accordance with the GDPR and national laws;

c) the processing is necessary for the purposes of legitimate interests: we or a third party must process your personal data for the purposes of the legitimate interests pursued by us, provided that we have established that your rights and freedoms do not prevail over these interests, including your right to the protection of your personal data;  

d) Consent: we may ask you, in certain circumstances, for your consent to the processing of your personal data in a particular way.

Which personal data are processed?

Business contacts: 

In the context of our contractual relations with our customers or suppliers (the "Co-contractors"), Sagemcom is required to collect and process personal data concerning its Co-contractors, employees, representatives and/or managers of the Co-contractors in order to enable it to manage the contractual relationship.

 In addition, Co-contractors and prospects may receive newsletters, invitations to events or commercial offers, in an exclusively professional context.  

Finally, Sagemcom may receive business cards from its Co-contractors or prospects. 

In this context, Sagemcom, as Data Controller, is required to implement a Data Processing, in compliance with the GDPR, the purposes of which are the management of Co-contractors or prospects (including for contact and communication purposes, the performance of contractual obligations, the management of the contract, invoices, accounting, the monitoring of the contractual relationship), and more generally the management of operations enabling it to communicate with them. 

Visitors to the Sagemcom.com website 

When using the website accessible at www.Sagemcom.com (the "Site"), Sagemcom may collect and process certain personal data concerning you in your capacity as a user of the Site. 

The data that may be collected from our CSIRT section, as part of the reporting of a security incident or vulnerability that could impact Sagemcom, is carried out exclusively by means of an electronic message.

In this context, Sagemcom, as Data Controller, is required to implement a Data Processing, in compliance with the GDPR, whose purposes are to allow communication between you and Sagemcom (including the management and follow-up of contacts with visitors) and to manage the Site by carrying out statistical analysis of the use of the Site and market research. 

Regarding the cookies that are collected when you connect to the Site, we invite you to consult our Cookies policy. 

Application / co-optation

Sagemcom may also collect personal data about you when you apply online via the recruitment module. With regard to recruitment, we invite you to consult the personal data protection policy for candidates.

How long is personal data kept?

Personal data collected and processed in the contexts described in this Policy are stored for periods of time established in accordance with applicable national regulations and defined in the personal data processing register. These periods are available on request from the Data Protection Officer.

To whom are your personal data transmitted? Are they transferred outside the EU?

Personal data collected and processed in the contexts described in this Policy are intended for the internal services of the Sagemcom Group.

These data may be processed by companies of the Sagemcom Group or third parties, acting as subcontractors, bound by a subcontracting agreement to perform, in particular, hosting, storage, communication, data processing, database management or computer maintenance services. These subcontractors act only on instructions from Sagemcom and will only have access to your personal data to carry out their assignments. They will be bound by the same security and confidentiality obligations as those of the Sagemcom Group. Sagemcom ensures that it takes the necessary measures with these third parties to ensure an adequate level of protection of your personal data in accordance with applicable regulations. In the event of data transfer outside the European Union, Sagemcom will have previously signed with certain companies of the Sagemcom Group or any third party the "standard contractual clauses" of the European Commission and/or will have submitted them to binding corporate rules governing the processing and approved by the authorities in charge of compliance with obligations regarding personal data.

How are your personal data secured?

Sagemcom ensures that your personal data are processed in complete security and confidentiality, including when certain operations are carried out by subcontractors. To this end, appropriate technical and organisational measures are used to prevent the loss, misuse, alteration and deletion of your personal data. These measures are adapted according to the sensitivity level of the data processed.

What are your rights and how can you exercise them?

You can exercise your rights of access and rectification of your personal data at any time. You also have the right to the deletion, limitation, opposition and portability of your personal data. Where the processing of personal data is based on your consent, we inform you that you may withdraw this consent at any time. 

To exercise your rights, you can write to us with proof of your identity at dpo@sagemcom.com

You are informed that you have the right to submit an application to the Commission Nationale de l'Informatique et des Libertés (CNIL), the supervisory authority in charge of compliance with personal data obligations in France. We invite you to contact us before making any request to the CNIL so that we can try to process it together.

Contacts

You have the possibility to contact the Data Protection Officer of the Sagemcom Group for questions relating to the protection of your personal data:

- by email to the address: dpo@Sagemcom.com

- by post to the following address: Group Sagemcom, Attention: Data Protection Officer, 4 allée des Messageries, 92270 Bois-Colombes, France

Changes to this Policy

This Policy may change from time to time. It was last updated on 10 September 2019.

Cookies

When someone visits the site www.sagemcom.com, Sagemcom installs cookies on the hard disk of the visitor’s computer.

Cookies are data used by a web server to send status information to a user’s browser, and for the browser to send back status information to the original web server.

The status information may for example be a session login, a language, an expiry date, a response domain, etc.

This status information may be stored by the browser in various ways (a separate text file per cookie, a single file containing all cookies, possibility to encrypt this single file, etc.)  or not stored at all: it depends on the type of browser, its version, configuration, etc.

Cookies are used to keep this status information in the memory when a browser accesses different pages of a website or when the browser returns to the same website later.

Some of these cookies are only used to facilitate electronic communication.

Others are strictly necessary to provide an online communication service at your express request.

Finally, when a visitor visits the Site, the company collects information about the connection and the behaviour of visitors for statistical purposes (number of visitors, pages visited).

This information does not enable direct identification of visitors and Sagemcom undertakes no measures to identify visitors. In particular, it does not cross-reference personal data requested for example in forms on the site or when you connect to your private area with the information required for statistics, to identify you.

Most browsers are configured by default and accept the installation of cookies. However, if you so desire, you may deactivate the use of cookies by selecting the appropriate parameters in your browser.

Depending on the browser, the procedure may differ. Your attention is drawn to the fact that by configuring your browser to refuse cookies, some functions, pages or areas on the website will not be accessible.

Cookies strictly necessary for the operation of the Site

These cookies are deposited on your terminal and are necessary for the operation of the Sagemcom site for the reasons described below. Your opposition to the implementation of these cookies is likely to affect your use of the Sagemcom site. For this reason, and in accordance with the recommendations of the Commission Nationale de l'Informatique et des Libertés (CNIL), you may not oppose the installation of cookies on your terminal. The processing of these cookies is based on the legitimate interest as referred to in Article 6, 1 (f) of the General Data Protection Regulation ("GDPR") of the companies referred to in the introduction to this cookie policy.