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Contact Info
15A Main Street, Blackrock, Co.
Dublin, IR A94 T8P8
contact@dibotioo.com
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BOTI & PARTNER’S LIMITED (“DIBOTIOO”) attaches great importance to the protection and confidentiality of your privacy and in particular of your personal data (“personal data”) and to the respect of your choices concerning the latter. This Privacy Policy will help you understand what Personal Data we collect and what we do with it, and how you can protect your privacy in connection with the services we provide.

I – SUBSCRIBERS

1. WHAT PERSONAL DATA DO WE COLLECT?

As part of the subscription to DIBOTIOO services and during the provision of these services or as part of the visit to the DIBOTIOO website, we collect personal data about you in a fair and transparent manner, directly from you, automatically in order to provide you with these services. DIBOTIOO mainly processes the following categories of personal data, the purposes of which are presented below :

  • Identification data: surname, first name, email address, telephone number, postal address, identifiers, etc.
  • Billing and/or payment data: bank details, purchase code, invoice, etc.
  • Subscriber relationship monitoring data: support requests, correspondence with the subscriber, survey results, etc.
  • Technical and connection data: hardware technical characteristics, terminal identifiers (MAC address, serial number, etc.), traffic data generated by the use of communication networks, IP address, crash report, connection logs, etc.
  • Usage and activity data on all your services: user account(s) and related information, browsing history, usage statistics, subscriptions, user preferences (language, type of currency, etc.), abandoned cart, etc.
  • Location data: for each of the processes implemented, DIBOTIOO undertakes to use only personal data that is adequate, relevant and limited to what is necessary for the purposes for which it is processed.

2. WHY DO WE USE YOUR PERSONAL DATA?

1) Service delivery and contract management DIBOTIOO uses your personal data for the purposes of executing and managing the contract.

This includes in particular the management of your subscriber account and the contractual relationship, configuration, hosting of the shop, maintenance, access to the service, provision and management of the services subscribed to or product(s), the provision of assistance, after-sales service and the processing of your requests, invoicing of the service, management of complaints and disputes and collection procedures, also through third parties.

In this context we may also send you information messages and notifications in connection with your subscription and coordinate the delivery of any services you may have subscribed to to your customers.

2) Possible customisation of your services (DIBOTIOO) With respect to managing your preferences, we may collect, including with your consent which you may withdraw at any time, some of your personal data and information about you and your use of all your services in order to improve the quality of services.

3) Commercial communications and canvassing DIBOTIOO may also use your personal data to carry out loyalty, canvassing, surveys and promotions or even surveys and competitions or possibly to send you personalised offers or inform you about our press events.

Unless you object, you may receive, by e-mail and by telephone, offers from DIBOTIOO, from companies in the group to which DIBOTIOO belongs or from its commercial partners, as well as e-mails for services similar to those offered by DIBOTIOO.

You can change your choices at any time in your subscriber area or by writing to our Data Protection Officer.

4) Advertisements tailored to your interests DIBOTIOO may also use some of your personal data with your consent, which you may withdraw at any time, in order for us and/or our partners to carry out promotional activities and send you advertisements tailored to your interests.

5) Statistics and improvement of our services DIBOTIOO may also use your personal data to analyse your usage, evaluate and improve services to better understand its subscribers and to develop new products and services.

6) Security and fraud prevention DIBOTIOO also uses your personal data to guarantee the security of the services and the network and to prevent possible fraud.

7) Compliance with legal obligations and defence of our interests in court DIBOTIOO may also use your personal data in order to comply with its legal obligations (including personal data regulations, anti-fraud laws, money laundering laws and late or default payment provisions) and/or to respond to requests from public, judicial and governmental authorities as well as any legal requests from data subjects in relation to any processing of their personal data carried out by DIBOTIOO.

If DIBOTIOO carries out further processing of your personal data for other purposes, we always ensure that these are proportionate and justified and that these processing operations are based on an authorised legal basis.

3. WHO MAY HAVE ACCESS TO YOUR PERSONAL DATA?

Your personal data is processed by DIBOTIOO and its commercial partners for the purposes of managing the contract and carrying out the services you have requested or authorised, as well as in the context of managing disputes. Only our employees who are authorised and aware of the need to protect personal data may have access to your personal data in the context of their duties.

When we use a service provider, we only communicate your personal data to them after having obtained a commitment and guarantees on their ability to meet our security and confidentiality requirements and we conclude contracts in compliance with legal and regulatory obligations specifying the terms and conditions of personal data processing. We ensure that they have strict policies in place to ensure that your personal data is only passed on to those authorised to access it.

Where the latter are located in a country that has not been recognised as providing an adequate level of protection, DIBOTIOO will take the necessary steps to ensure that they provide an adequate level of protection and security for your personal data equivalent to that provided for by European legislation (for example, on the basis of a transfer contract incorporating the European Commission’s Standard Contractual Clauses) as well as requiring them to comply with confidentiality requirements and to process your personal data only for strictly determined purposes.

Finally and upon request, your personal data may also be transferred to persons and authorities (judicial authorities, lawyers, public bodies, etc.) whose right of access to personal data is recognised by law, regulations or provisions emanating from authorities empowered by law.

4. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

Your personal data is strictly confidential and is kept for the time necessary to achieve the purposes presented to you or according to the applicable legal and regulatory periods.

More specifically, we keep :

  • up to five years from the end of the contractual relationship in general (e.g.: exception for invoices, 10 years) the personal data necessary to achieve the purposes of providing the services and managing the contract;
  • for up to 6 months the personal data necessary for the purposes of personalising your online shop service by DIBOTIOO;
  • for a period of 3 years from the end of the contractual relationship or from your opposition, the data necessary for the purposes of commercial communications and prospecting;
  • for a maximum of 13 months the data necessary for the purposes of sending advertising adapted to your centres of interest.

The personal data collected for the purposes of statistics, service improvement and security and fraud prevention are kept for different periods of time depending on the services concerned before being deleted once these purposes are fulfilled.

Personal data that DIBOTIOO needs for the purpose for which it was collected, necessary for compliance with a legal obligation and/or for the establishment, exercise or defence of legal rights may not be deleted but will be subject to archiving, limited access or anonymisation measures.

II – NON-SUBSCRIBERS

On the basis of your consent or our legitimate interest, we may collect the following personal data for the purposes of :

  • Commercial proposals (via all channels) of offers adapted to your needs, new products, promotional or event-based operations: identification data (title, surname, first name, telephone numbers, e-mail and postal addresses), request for a callback by an advisor.
  • Carrying out satisfaction surveys and processing responses: identification data (title, surname, first name, telephone numbers, e-mail and postal addresses), survey returns.

This personal data may also come from Subscriber distributors of the group to which DIBOTIOO belongs “ALLIANCE In MOTION”.

We keep this personal data for a maximum period of 3 years from the date of collection, unless you object.

III – SUBSCRIBERS AND NON-SUBSCRIBERS

1. HOW DO WE ENSURE THE SECURITY OF YOUR PERSONAL DATA?

DIBOTIOO attaches particular importance to the security of personal data and we take all necessary steps to protect the personal data we process. Your personal data is processed electronically, automatically and/or manually and in any case, in such a way that its security, protection and confidentiality are ensured with regard to its level of sensitivity, through administrative, technical and physical measures to prevent loss, theft, unauthorised use, disclosure or modification.
DIBOTIOO thus implements measures that respect the principles of protection by design and protection by default of personal data processed. In this respect, DIBOTIOO is able to use data anonymisation or encryption techniques where possible and/or necessary.

For any notification of a personal data breach, please contact us at support@dibotioo.com

2. HOW CAN YOU MANAGE THE USE OF YOUR PERSONAL DATA?

You may at any time access your personal data and request a copy, rectify them, request their deletion on specific grounds or exercise your right to the limitation of processing or to the portability of your data in the cases permitted:

  • via your subscriber area ;
  • by sending an e-mail with proof of your identity to: support@dibotioo.com

You also have the right to object at any time, for reasons relating to your particular situation, to the processing of your personal data whose legal basis is our legitimate interest. If you exercise such a right to object, we will no longer process your personal data unless we can demonstrate that we have compelling legitimate grounds for continuing the processing operation(s) concerned. Where the processing of your personal data is part of commercial prospecting, you may object without giving any reason when you call.

By contacting the Data Protection Officer, you can also define directives concerning the fate of your personal data after your death.
In the event of a complaint to which DIBOTIOO has not given you a satisfactory response, you are entitled to contact the Commission Nationale de l’Informatique et des Libertés (CNIL), which is responsible for compliance with the obligations relating to personal data.

3. EVOLUTION OF THE PRIVACY POLICY

This Privacy Policy may change from time to time, particularly as a result of legislative and regulatory developments and to reflect changes in our practices and technologies. We invite you to consult it regularly.