PRIVACY POLICY

 

I. Personal data protection policy

Last update: September 2020

Ocedis is the publisher of the website www.melconnect.fr (the “Website”), the purpose of which is the marketing of pool water analysis and treatment and pool equipment management products and services (the “Mel’Connect products”).

Ocedis also provides a mobile app intended for use on compatible iOS and Android devices via “App Store” and “Play Store” services (the “App”).

The Website, the App and any document or media, printed or digital, originating from the company Ocedis relating to O’Connect products and designed to collect personal data shall be known hereinafter as the “Services”.

The Ocedis Group pays particular attention to the protection of personal data. It applies a continuous improvement approach to its compliance with the General Data Protection Regulation (GDPR), the ePrivacy Directive, as well as Law no. 78-17 of 6th January 1978 known as the French Data Protection Act, to ensure the highest level of protection for its customers’ and users’ personal data (the “Customers” or the “Users”).

Should you have any questions relating to our personal data protection policy, please contact us by e-mail (monassistantpool@melconnect.fr). You can also visit the French Data Protection Authority’s website at www.cnil.fr.

Which of my personal data is collected?

Within the framework of its activity and the products offered for sale, in particular on the Website and the App, Ocedis collects personal data in its capacity as the data controller.

This data falls into two categories:

1.               Personal data enabling a person to be directly or indirectly identified, which is collected when configuring the app and/or visiting the Website (the “Personal Data”)

This Personal Data includes specifically:

your email address, surname, first name, address, mobile and/or land line telephone number, the type of treatment for your pool, the type of coating of your pool, the number of pieces of pool equipment / accessories and their description, the age of your pool, the average number of users of your pool, your stock of disinfectant and/or other pool care products, your smartphone’s operating system, serial number, place of purchase, size of the pool, year of construction, type of integration and brand of the pool.

Ocedis also stores your password(s), it being understood that it is (they are) not accessible and may not form the subject of any use.

Finally, we hereby inform you that Ocedis shall not, under any circumstances, collect information relating to your credit card or any other financial information.

2.               Personal data forwarded by connected objects (the “Measurements”)

Ocedis also collects Personal Data or Measurements when you install or use an O’connect Product, including specifically:

-        information relating to your O’connect Product, its capacities and applications and the way in which it is used,
-        the installation location,
-        the quality of the water sampled by the connected objects, the consumption of disinfectant and/or other pool care products over the course of the season, the average water temperature and in real time, the consumption status of pool care products, the alkalinity level, the hardness level, the conductivity level, the pH level, the chlorine or bromine level, the salt level and the average time for which the pool is used over the course of the year,

-        the User’s IP address, browser, etc.

 

When is my personal data collected?

Personal Data is collected by Ocedis:

-        following your registration on the Website and/or when configuring the App,

-        by Mel’connect connected products

-        via other Mel’connect Services (for example when the User completes a survey, subscribes to the newsletter, sends an email message or interacts with our blog articles)

 

Which data is collected by the mobile apps?

If you use the App, some Personal Data may be collected by the publishers of the operating systems used by your mobile phone.

Please familiarise yourself with the operating system (iOS, Android, Windows, etc.) publishers’ privacy policies in order to discover what use is made of your data by operating system publishers in their capacity as data controllers.

1.               Geolocation

The App incorporates a geolocation function, which specifically allows us, with your consent, to send you information and personalised marketing offers based on your location and your customer profile. By authorising the App to access your location data and to send you notifications, you may receive information on our offers, products or services based on your geographic location (in particular relating to Retailers) by SMS, push notification or email. We hereby inform you that you may receive notifications based on your geographic location even when the App is in sleep or “hidden” mode.

You can choose not to authorise geolocation by refusing permission when downloading or using the App for the first time. However, certain operating systems (Android) do not allow apps with geolocation to be downloaded if access to location data has not been authorised. Downloading the App shall constitute agreement on your part. You may also disable access to your location data in your mobile phone’s settings at any time by referring to your device’s technical documentation.

2.               Notifications

By authorising the App to send you notifications, you may receive marketing offers and information based on your profile.

The sole purpose of the App’s “Notifications” function is for Ocedis to send information and personalised marketing offers.

You can choose not to receive notifications, by refusing permission when downloading or using the App for the first time.

You may disable notifications in your mobile phone’s settings at any time by referring to your device’s technical documentation, as well as in the App, by going to your settings. Cookies associated with the App

 

How will my personal data be used?

The Personal Data and Measurements that we collect may only be used under the following conditions:

1.               Performance and monitoring of Services

Ocedis may use Personal Data and Measurements to allow access to Services and to monitor use of these Services. Within the framework of Services, Ocedis uses your Personal Data and Measurements to provide you with analyses and customised advice.

2.               Questions and requests from users

Should the User contact Ocedis by email or by any other means, the Personal Data provided shall only be used to answer the question or resolve the issue.

3.               Communication relating to Products, Services and Events

When the User registers for O’connect Services, they agree that Ocedis may occasionally use Personal Data and Measurements in order to be contacted in future and to be kept informed of Products, Services and events that may interest them. This communication will be undertaken in accordance with your right to object and, therefore, by providing for the possibility of declining to participate at any time, by means of a simple request.

4.               Data Search and Analysis

Ocedis regularly carries out searches relating to the profile, interests and behaviour of its users, as well as in relation to the Measurements taken by O’Connect Products.

These searches are based on data, measurements and other anonymised information. They may be combined and analysed as raw data or in an aggregated form and Ocedis may share this anonymised data with advertisers, researchers, commercial partners, publications or any other third party, provided they do not allow the User to be identified.

5.               Improving Services

Ocedis may use Personal Data and Measurements or any other anonymised data collected by means of Services, in order to improve the content and functionality of Services, and to better understand users’ requirements.

All personal data is stored on the basis of the purposes described above in accordance with the legal retention periods.

 

To whom may my personal data be transferred?

The Personal Data and Measurements that we collect may only be transferred subject to the following conditions and guarantees:

1.               Sharing with third party partners, distributors/retailers:

Ocedis may transmit Personal Data and Measurements within the framework of certain partnerships with retailers or distributors from which O’connect Products have been purchased.

2.               Internal operational functions

Should a third party company be used to perform certain internal operational tasks (updating databases, internal audit of services, etc.), Personal Data and Measurements may be communicated to the company in question, but these must only include the information needed to perform their tasks.

3.               Legal requirements:

Ocedis may disclose Personal Data in order to:

-        comply with a legal or statutory provision (or should it legitimately believe that such a disclosure is necessary in order to comply with a legal or statutory provision),

-        respond to legitimate requests from public authorities or comply with requirements relating to national security, combating fraud or another legal obligation,

-        protect or defend Ocedis’ rights or property,

-        protect or defend the security of Website Users or the public.

4.               Transfers of data to third party partners:

Ocedis may disclose Personal Data and Measurements to third party partners, which must undertake to only use this Personal Data and these Measurements within the framework of and for the purposes of the Mel’Connect Service. Under no circumstances may the distributor or retailer sell on the Customer’s Personal Data and Measurements.

5.               Anonymised Personal Data:

Ocedis may disclose Personal Data and Measurements in an aggregated, raw or anonymised form and share them with advertisers, commercial partners, technical R&D departments or any other third party, provided they do not allow the Users to be identified.
You are hereby informed that Personal Data may be transmitted for the purposes set out above to companies located in countries outside the European Union, which offer a level of data protection that is less stringent than within the European Union. Prior to transfer outside the European Union, Ocedis will take all the steps and provide all the guarantees necessary to secure such transfers.

 

How do I express my choices relating to the use of my data?

The Customer may decide to use the Website and the App without disclosing personal data. However, in this case, certain Website and App functionalities may not be accessible or fully functional (in particular the “Retailers” page).

The Customer may also decide not to disclose Measurements. However, in this case, Ocedis products and services would become inaccessible or inoperational, as the transmission of Measurements and their analysis is a key element of the operation of the majority of our Products and Services.

The Customer also has the right to suspend the transfer of their Personal Data and Measurements to third parties.

The Customer has the option of choosing whether to be contacted by Ocedis or not, and/or by third parties offering their products, Services and/or events that may be of interest.

 

How do I exercise my rights relating to the use of personal data?

You have the right to decide and to control the use of your personal data at any time, subject to fulfilment of the following conditions:

-        The right of access to your data,

-        The right to rectification,

-        The right to object to processing for a legitimate reason (except in the case of canvassing, where you do not need to specify a reason)

-        The right to request its erasure,

-        The right to request the restriction of processing,

-        The right to data portability,

-        The right to define rules relating to the retention, erasure and communication of your data after your death.

To exercise this right, simply send your request by post to the registered office of Ocedis: Ocedis, 69 Allée des Peupliers – ZI de Fétan – 01600 Trévoux, France, or by e-mail to monassistantpool@melconnect.fr accompanied by sufficient information to provide proof of your identity (email, order number, customer number, address, etc.).

Ocedis will respond to your requests to exercise a right without undue delay and, in all cases, within a period of one month from receipt of your requests.

You have the right to lodge a complaint with the French Data Protection Authority (CNIL), the supervisory authority in France in charge of compliance with the obligations relating to personal data.

 

Links to other websites

The Website may display links to other websites not managed or controlled by Ocedis (“Third-party Websites”). This personal data protection policy only applies to the Website or Mel’connect Services and does not apply to Third-party Websites. We recommend that you refer to the personal data policies of Third-party Websites or contact them in order to obtain more information on their data management policy.

Ocedis does not manage data collected by Social Networks via buttons. The User must familiarise himself/herself with the policy relating to the protection of personal data published by the Social Networks in question, in order to understand how the data gathered is processed and used by the latter, as well as the configuration options he/she has for protecting his/her privacy.

 

Scope of our personal data protection policy

This personal data protection policy does not apply to personal data collected by Ocedis other than Personal Data and Measurements collected by means of the Website, as well as Mel’Connect Services and Products.

Changes to this Privacy Policy

The Ocedis’ Website, App, Services and activities may evolve. As a result, it may be necessary for Ocedis to make changes to its personal data protection policy. Ocedis reserves the right to update or amend this personal data protection policy at any time, without prior notice or authorisation. Ocedis advises Customers to regularly visit and read this personal data protection policy, in particular before providing Personal Data or Measurements.

 

II. Notices relating to cookies and data collected during your visit

When an internet user accesses Mel’connect Services via the Website, certain data of a non-personal nature is retained by means of trackers.

To this end, Ocedis makes use of technology known as “Cookies” within the framework of operating the Website. A “Cookie” is text file stored in a dedicated area of the hard disk of a device (e.g.: computer, tablet, smartphone, etc.) belonging to a media user (internet, apps, etc.) when online content or advertisements are viewed. This Cookie file allows its issuer to identify the device on which it is stored and thus to monitor the media users’ activity, and to memorise information, such as the user’s preferences or information previously entered by the User in forms available on the medium, for the validity or storage period of the Cookie. Cookies help to improve the Website’s performance and to display a customised offering.

Ocedis also uses cookies within the framework of use of the App, in particular in order to better identify the User and to customise its services. To this end, when the User installs the App, we collect information on his/her use of the App or his/her phone. We use this information to understand and improve commercial relations (in particular services, suggestions and advertisements). As is the case on the web, we can use these technologies to store an identifier or other information on your device. Depending on the operating system, you can disable these cookies by going to your phone’s app management settings.

The User’s prior written consent will be requested in order to be able to use certain types of Cookies. In the event that the use of Cookies is active, Ocedis only collects personal information with your permission. For more information on Cookies and on disabling them, please refer to your Internet browser’s help menu.

Ocedis recommends leaving Cookies enabled insofar as they allow you to benefit from certain Website functions and Services.