W-HA undertakes, within the framework of its activities and in accordance with the legislation in force in France and in Europe, to ensure the protection, confidentiality and security of the personal data of the users of its services, as well as to respect their privacy.
This Policy informs you about how W-HA, its subcontractors and its banking partners process your personal data.
It may be supplemented by specific information brought to the attention of the user, concerning a particular offer or service.
Why does W-HA process your data?
W-HA only processes personal data for specific, explicit and legitimate purposes directly related to the offers. As such, W-HA processes your data within the framework of the execution of a contract.
The purposes pursued by W-HA are as follows:
- Manage the identity of the client or user and authenticate it
- Manage the order
- Manage the material
- Invoice and collect payments
- Provide pre-sales service and sell
- Provide after-sales service
- Manage personal data, characteristics and rights of a contract
- Process cancellations
- Process complaints
- Communicate under customer management
- Manage incoming mail
- Collect unpaid bills
- Manage litigation
- Manage requests relating to the rights of data subjects
- Store customer or user data
- Offer authentication services
- Operate the network
- Operate the services
W-HA also performs data processing for purposes other than the strict execution of contracts. In this case, W-HA ensures that it has a legitimate interest in carrying out the processing. In addition, processing may be subject, as far as necessary, to the collection of your consent, which you can withdraw at any time.
To this end, the purposes pursued by W-HA are as follows:
- Organize direct marketing operations
- Organize commercial events
- Analyze the uses of offers and services to make proposals to the customer
- Survey customers or users
- Improve offers and customer relations
- Ensure the security of platforms and services
- Deploy and operate offers and services
- Fight against fraud
Your data is kept for the time necessary to accomplish the purposes mentioned above.
W-HA also processes your data to meet its legal or regulatory obligations
To this end, the purposes pursued by W-HA are as follows:
- Keep the data required to be able to meet legal obligations
- Manage data communication requests from authorized authorities
- Ensure the blocking of access to services in the event of a legal request
Your data is kept for the time necessary to accomplish the purposes mentioned above. With regard to processing relating to the performance of the contract, data may be kept for a maximum of 5 years from the end of the relationship, except for legal or regulatory requirements. Your data can then be kept for the time necessary to allow W-HA to meet its legal obligations.
W-HA is also likely to process your data for statistical purposes, including marketing the statistics obtained. In this case, all the data is made anonymous beforehand.
What data is processed?
Depending on the case, W-HA processes your personal data, collected directly from you or resulting from the use of the products or services. W-HA may also be the recipient of data that has been collected from you by a third party.
W-HA only processes data or a category of data if it is strictly necessary for the purpose pursued. You can find information on these purposes above.
W-HA processes the following categories of data:
- Identification data: Name, first names, identifier, SIREN …
- Personal characteristics: date of birth, nationality …
- Contact details: postal address, email, telephone number, etc.
- Economic and financial data: means of payment, payment history, etc.
- Connection, service usage and interaction data: Connection and usage logs, intervention report …
- Products and services owned or used
- Profiles and scores allowing customer segmentation
- Location data
Who are the recipients of your data?
The data collected is intended for the internal services of W-HA and its subcontractors.
The data is also processed by W-HA partners to comply with banking regulatory obligations. These are situations where its banking partners intervene to provide services. It may also be processing to which you are asked to consent.
Finally, the processed data may be transmitted to the competent authorities, at their request, in the context of legal proceedings, in the context of judicial research and requests for information from the authorities or in order to comply with other legal obligations.
Are your data processed outside the EU?
The data collected is likely to be processed outside the European Union. In this case, W-HA takes the necessary measures with its subcontractors and partners to guarantee an adequate level of protection of your data and this in full compliance with the applicable regulations.
If the subcontractors and partners concerned are not adhering to the Privacy Shield agreement with regard to transfers to the United States of America, or are not located in a country having legislation considered to offer protection adequate, they will then have previously signed the “standard contractual clauses” of the European Commission or will be subject to binding internal rules approved by the authorities.
What are your rights ?
You have the right to access, rectify and delete data concerning you. You can request the portability of these. You also have the right to object to the processing carried out or to request its limitation.
You can issue instructions on the retention, deletion or communication of your personal data after your death.
Specific rules for telephone canvassing: Any consumer can register for free on an opposition list called “Bloctel” so as not to be contacted by telephone by a professional with whom he has no current contractual relationship. The consumer can register on the site www.bloctel.gouv.fr or by mail addressed to: Société Opposetel, Service Bloctel, 6, rue Nicolas Siret – 10 000 Troyes
How to exercise your rights?
You can exercise your rights at any time, as well as contact the Data Protection Officer at the addresses below.
Any request to exercise your rights must be accompanied by a photocopy of proof of identity (national identity card issued by the French State or European Union identity card or passport, resident card issued by the French State, residence permit issued by the French State or traffic book issued by the French State). A response will be sent to you within one month of receiving your request.
Electronic Money Offers
W-HA electronic money – Personal data management, 25bis, avenue André Morizet, 92100 Boulogne-Billancourt.
Electronic banking offers
W-HA electronic banking, Personal data management, 25bis, avenue André Morizet, 92100 Boulogne-Billancourt
Possibility of contacting the supervisory authority in charge of compliance with personal data obligations
If your exchanges with W-HA have not been satisfactory, you have the possibility of lodging a complaint with the supervisory authority in charge of compliance with obligations in terms of personal data:
• For customers in France: Commission Nationale l’Informatique et des Libertés – CNIL (address: 3 place de Fontenoy TSA 80715 – 75334 Paris Cedex 07);
• For customers in Belgium: Data Protection Authority (address: rue de a presse, 35 1000 Brussels);
• For customers in Italy: Garante per la protezione dei dati personali (address: Piazza Venezia 11, 00187 Roma – Italy)
• For customers in the Netherlands: Dutch Data Protection Authority (address: Postbus 93374 2509 AJ DEN HAAG – The Netherlands.
How is your data secured?
W-HA ensures that your data is treated securely and confidentially, including when certain operations are carried out by subcontractors. To this end, the appropriate technical and organizational measures to avoid the loss, misuse, alteration and deletion of personal data concerning you are in place. These measures are adapted according to the level of sensitivity of the data processed and according to the level of risk presented by the processing or its implementation.
Modification of the Data protection policy
This Personal Data Protection Policy may change.
Last updated on 17/02/2022
For any request relating to the processing of your personal data, you can contact our data protection officer using the form below:
Part of the Orange group
25 bis avenue André Morizet
92100 Boulogne-Billancourt - France