Personal data protection policy and cookie management

ONIRI, a Société par Actions Simplifiée [simplified joint-stock company] with a registered share capital of 15 000 euros, registered at the Trades and Companies Register of Paris under number 834 609 984, whose registered office is located at 101 Rue De Sèvres - Lot 1674- 75279 Paris Cedex 06, (hereinafter 'ONIRI') is concerned about protecting the personal data of each user of its platform www.tomo.video (hereinafter the ‘Platform’) and undertakes to protect them in compliance with Applicable data protection regulation.

It is specified that a user (hereinafter ‘User’) means any natural person who creates a User Account, but also any natural person who simply comes to browse and view the Platform.

When it collects User’s personal data, ONIRI processes such data as a ‘controller’ within the meaning of the above-mentioned regulation. As such, ONIRI undertakes at all times to comply with the requirements of the Applicable data protection regulation and only process Users’ personal data in the conditions provided for below.

 

  1. Definitions

The following terms, whether they are used in the singular or plural, shall always have the following meaning:

1.1 Personal Data: refers to any type of information, data which, within the meaning of the Applicable data protection regulation, makes it possible to directly or indirectly designate or identify an individual.

1.2 Applicable data protection regulation: means any regulation applicable to data protection, in particular the General Data Protection Regulation n°2016/679 or “GDPR” and the Law n°78-17 of 6 January 1978 as amended, known as the “French Personal Data Protection Act”.

 

  1. Collected Personal Data

ONIRI collects the following personal data from Users:

  • When opening a User account:
    • surname; first name:
    • telephone number, and business email address
    • hotel name and country
    • user password
  • When browsing and using the Platform:
    • IP address, connection data

The mandatory or optional data collection is specified by an asterisk affixed next to the data to be informed in a mandatory way. Mandatory disclosure of certain personal data is necessary for ONIRI to implement the following specified purposes. Optional data allows ONIRI to get to know the User better.

 

  1. Purposes of processing personal data

ONIRI collects the personal data of Users for the following purposes:

  • Enable User to access and use the Platform;
  • Operate and optimise the Platform;
  • Technical User support;
  • Checking, identifying and authenticating User’s connection settings;
  • Preventing and detecting fraud, malware (malicious software) and managing security incidents;
  • Managing any disputes with Client;
  • Compiling statistics.

 

  1. Storage period for User’s Personal Data

User’s Personal Data collected shall be held by ONIRI for the duration of the contractual and commercial relations with ONIRI.

After this, Personal Data is archived by ONIRI in a secure environment for the statutory limitation period as proof to establish, exercise or defend a legal right.

Any User is entitled to ask for their personal data to be deleted at any time by sending an email to the following address contact@tomo.video.

 

  1. Recipients of User’s Personal Data

User’s personal data is strictly confidential and for ONIRI’s exclusive use.

Excepting a legal or judicial obligation to do so, ONIRI shall never disclose, assign, rent or transfer the personal data of User to third parties other than:

  • the host of the Platform, as mentioned in the legal notices, available here, in order to provide technical hosting and database management services
  • Service providers and subcontractors of ONIRI whenever they act in accordance with the provisions of the Applicable personal data protection regulations, on ONIRI’s instructions and when contractually bound to ONIRI. Recipients are technical service providers for the operational needs of the Platform and analytical solution providers.

 

  1. Storage and transferring personal data outside of the European Union

User acknowledges that he/she has been informed that his/her Personal Data be hosted on the servers of Gandi SAS located in France or in the European Union.

The User acknowledges that he/she has been informed and accepts that his/her Personal Data may be communicated to subcontractors whose services are hosted outside the European Union. ONIRI's subcontractors ensure that these transfers are made under appropriate security and confidentiality conditions to ensure a level of protection of the User's Personal Data equivalent to the level required within the European Union, in accordance with the Regulations applicable to the protection of personal data.

In particular, User acknowledges that he/she has been informed that his/her Personal Data is sent to the following subcontractors located outside the European Union:

 

  1. Security measures implemented

ONIRI undertakes to provide the security & integrity of User’s personal data. As such, ONIRI implements and maintains technical and organisational security measures for the Platform, User accounts and, more generally its computer system which are adapted to the personal data processed and the processing risks involved. These measures aim to (i) protect personal data from being destroyed, lost, damaged, disclosed to unauthorised third parties (ii) ensure that the personal data is restore and available within an appropriate period in the event of a physical or technical incident.

 

  1. User rights over his/her Personal Data

User has the following rights over his/her Personal Data, which he/she may exercise at any time by writing to the following address: contact@tomo.video

  • Right of Access: know what Personal Data is held;
  • Right to update and rectify: get the controller to rectify or update Personal Data when it is incorrect or incomplete, either by logging into his/her User Account and configuring the account settings, or by asking to update his/her Personal Data.
  • Right to erasure: ask to erase his/her Personal Data when it is no longer needed for the purposes for which it was collected or when User objects to the processing of his/her Personal Data.
  • Right to restrict the processing: ask to restrict the processing of his/her Personal Data when User disputes the accuracy of the data, in case the User still need his/her Personal Data to be stored after the expiration of the storage period, in order to establish, exercise or defend a legal right, or if the User objects to it being processed;
  • Right to data portability: recover the Personal Data that User sent to ONIRI in a legible format, or ask ONIRI to send the personal data to another data controller.
  • Right to object: at any time, object to the processing of his/her Personal Data for personal reasons, including when the objection is about commercial prospection purposes, including profiling;
  • Withdrawal of consent: withdraw consent to ONIRI processing User's Personal Data in the future, when such processing is based on consent;
  • Right to file a complaint: file a complaint with the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés), if User considers that ONIRI’s processing constitutes a violation of his/her Personal Data.

Before implementing one of these rights, ONIRI may ask User to present a proof of identity in order to check for accuracy.

In the event of problems exercising his/her rights, User may file an online claim with CNIL, at the address: https://www.cnil.fr/fr/plaintes  or by post at the following address: CNIL - 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.

 

  1. Managing cookies

ONIRI uses cookies to ensure its Platform operates correctly and to monitor and analyse visitor traffic on its Platform. A ‘cookie’ is a small data file sent to User’s browser by a web server and stored on the hard drive of his/her computer. They will not damage computers in any way.

Data collected via cookies is only and strictly intended for ONIRI, in compliance with the applicable personal data protection regulations.  It is never sent to third parties.

Some cookies used by WINNDLE are strictly necessary for the Platform to operate correctly.  They are generally only created in response to the actions of User on the Platform, which involve requesting services, such as to connect to the User Account. These cookies do not collect any data which makes it possible to identify User.

In order to track and analyse visitor traffic on the Platform, ONIRI uses the Google Analytics cookie. This cookie makes possible to differentiate between visitors and to produce statistics on how visitors use the Platform, such as the number of pages visited, the frequency, duration and recurrence of visits. The use of this cookie is limited to the duration of the session and is automatically deleted when User leaves the Platform. User may configure his/her browser to automatically accept or desactivate these cookies.

ONIRI uses the following cookies:

Strictly necessary cookies

Cookies used by ONIRI which are strictly necessary to make the Platform work properly. Usually only established in response to actions taken by the User on the Platform that require a request for services or fill out forms. The User can set the settings of his web browser to block the use of these cookies, but some features of the Platform will no longer be accessible. These cookies do not retain information that can personally identify the Use

Name of cookie

Storage period

Google Analytics (anonymous - no IP tracking)

per session

Performance cookies

These cookies allow the Platform to provide functionality and customization of the User experience, based on its previous visits and selections.

Javascript verification

Per session

 

The User is free to consent to the use of all or part of the cookies (other than the cookies strictly necessary for the operation of the Platform) used by ONIRI on the Platform. Users can make their choice when they first log in by clicking on the categories of cookies they accept.

Users can also set up their browser to accept cookies or disable them. Cookie instructions for the most commonly used browsers can be found at the following links:

Cookies are stored in User’s browser for a maximum period of thirteen (13) months after they are first stored in the terminal device.

In accordance with the applicable regulations on personal data protection, User may object to such cookies being saved onto their devices at any time. User may exercise this right by contacting ONIRI at the following email address: contact@tomo.video.