Privacy policy

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Privacy Policy

BELLEDONNE COMMUNICATIONS provides and operates an instant messaging and voice/video over IP (VoIP) telecommunication service, called “Linphone free SIP service” (“the Service”), and distributes a VoIP application for mobile and desktop platforms, called Linphone (“the Application”), to any individual user, whether for personal or professional purposes.

This Service and Application, as well as other associated support, maintenance or development services, and more generally all products and services provided by BELLEDONNE COMMUNICATIONS, are fully described on BELLEDONNE COMMUNICATIONS’s website, available at linphone.org (“the Site”).

For the purposes of receiving information on BELLEDONNE COMMUNICATIONS’s products and services, Internet Users visiting the Site may contact the company through our contact form, or subscribe to our newsletter.

This Privacy Policy describes, as required by art.13 of GDPR, how Users‘ personal data are collected and processed by BELLEDONNE COMMUNICATIONS when Users visit the Site, contact the company, or subscribe to the newsletter, as well as their rights and ways to exercise them.

This Policy, as well as any amendment thereof, is published on the Site, and shall be subject to acceptance by all Users upon subscribing to the Newsletter, or filling the contact form.

1. DEFINITIONS

As used in this Policy, the following terms shall be defined as follows:

–      Application: the Linphone application for iOS, the Linphone application for Android, and the Linphone application for desktop platforms; downloadable on the User’s Terminal; published by BELLEDONNE COMMUNICATIONS;

–      Personal Data (or “Data”): personal data of the User, processed by BELLEDONNE COMMUNICATIONS for the purposes set forth in this Policy;

–      BELLEDONNE COMMUNICATIONS: SARL BELLEDONNE COMMUNICATIONS, whose head office is located at 12, Allée des Genets 38000 GRENOBLE, registered with RCS of Grenoble under the number 520 318 437.

–      Service: Belledonne Communications’ VoIP service for audio/video calling and instant messaging, using the open protocol SIP (Session Initiation Protocol), allowing Users to create a free SIP account with the SIP domain sip.linphone.org, and that is made available for free online or via the Application, under the conditions set forth in Linphone T&Cs;

–      Mailing List: one of BELLEDONNE COMMUNICATIONS’s mailing lists, to which any User may subscribe, directly on the Site, for the purposes of getting information or support on the Application or the Service.

–      Newsletter: electronic document containing information about the recent activities of BELLEDONNE COMMUNICATIONS, and sent by email to the Users;

–      Site: linphone.org website, published and operated by BELLEDONNE COMMUNICATIONS, describing and updating the features and requirements of the Application and the Service;

–      Device: a mobile or fix telecommunication device with Internet access, such as a smartphone, tablet, or personal computer (PC), which allows the Application to be downloaded and the Service to be used, in accordance with the prerequisites indicated at the time of download;

–      User: natural person visiting the Site, subscribing to a Mailing List, subscribing to Linphone’s newsletter, contacting BELLEDONNE COMMUNICATIONS through the contact form on the Site, having downloaded and using the Application for personal or professional purposes, or having created an account on the Service.

2. WHO IS THE DATA CONTROLLER?

The Data Controller is SARL BELLEDONNE COMMUNICATIONS, whose head office is located at 12, Allée des Genets 38000 GRENOBLE, registered with RCS of Grenoble under the number 520 318 437.

All requests regarding this Policy and GDPR may be sent, by mail to its postal address: Le Trident Bat A – 34 avenue de l’Europe 38100 Grenoble – France, or by email at: gdpr@belledonne-communications.com.

3. WHO ARE THE DATA SUBJECT?

The Data Subject, as defined under art.4 of GDPR, and concerned by this Privacy Policy, are the Users, as defined under Section I.

4. WHAT KIND OF PERSONAL DATA ARE PROCESSED?

For the purposes of providing the Service, the Application, and related services, the following Personal Data are processed by BELLEDONNE COMMUNICATIONS:

4.1. Contact Form:

  • Name
  • Email address
  • Company
  • Country
  • Type of request, and full text of the request; and more generally, all information given to BELLEDONNE COMMUNICATION on its specific needs or its project;

4.2. Mailing Lists:

  • Email address
  • Name (optional)
  • All messages exchanged with other Users, whether new topics or responses to opened topics;

4.3. Visiting the website:

  • IP address
  • Cookies

4.4. Linphone free SIP service:

4.4.a. User subscription data:

  • Name
  • Email address
  • IP address used while subscribing
  • User’s password stored as a MD5 or SHA256 hash, used for SIP digest authentication.
  • User’s international phone number, for Users subscribing from the mobile application.
  • User-agent used for subscription: it can be the browser’s user-agent string, or the Linphone app user-agent string. The user-agent string of mobile apps includes an identifier of the device, for example “Moto G7”, “Samsung SM518”, “Apple Ipad 2”, which is used to allow users to easily track the devices on which they have used their SIP account.

4.4.b. User activity data:

  • Calls logs. They comprise: caller’s SIP address, callee’s SIP address, date, time, status (completed or not), duration.
  • Chat message logs: sender’s SIP address, recipient’s SIP address, date, time, status (delivered or not), type (content or delivery notification). For clarity, the actual content of these messages is not stored.
  • Registration logs: these logs represent the instants when a user apps connects to the service through the network. They contain: date, time, status, IP address.
  • Telephone numbers of User’s mobile phone address book,

4.4.c. Group chat activity data:

  • User’s membership to group chat and secure one to one chatrooms, including User’s device identification (thanks to user-agent string) actually joined to the IM session. It also contains date and time where the User has joined or left a chatroom.
  • Subject entered by the User while creating a group chat.

4.4.d. Debug logs:

For the sole purpose of troubleshooting, Belledonne Communications reserves the right to activate the debug logs in the Application and in the software used to provide the Service. Such debug logs contain full protocol information for the calls, chat messages and other protocol events generated by the Users.

5. WHAT ARE THE PURPOSES OF DATA PROCESSING?

We decided to list processing purposes, for each type of Data processed under Section IV.

Contact Form Data
  • Answer to User’s request for information on BELLEDONNE COMMUNICATIONS’s products or services
  • Issuing quotes to Users on specific licenses and services;
Newsletter
  • To provide Users with up to date information on the Service, the Application, and on BELLEDONNE COMMUNICATION’s latest news and activities;
Mailing List
  • Provide User with sources of information on the Application, its use, its development, or any needs for support;
  • Enable Users to exchange with other users on the Application, or any service provided by BELLEDONNE COMMUNICATIONS
Visiting the Site      Audience and statistical purposes
Linphone free SIP service data      a. User subscription Data:

  • User’s subscription to the Service;
  • User’s operation of the Service;

b. User activity Data:

  • Compliance with BELLEDONNE COMMUNICATIONS’s legal obligations
  • Ability to proceed with requests from legal or regulatory authorities, regarding User identification or use of the Service;
  • Statistical analysis on use of the Service by Users; such as call peaks, interaction with third party software, volume and nature of data exchanged by time of day; based on fully anonymized data of Users; in order to improve the Service’s operation and functionalities;

c. Group chat activity data:

  • providing group chat and secure one to one chat services: data collected are necessary to enable delivery of a message sent by a User to other Users, members of the group.

d. Debug Logs:

  • Support and troubleshooting services;
  • Correct operation of the Service

6. WHAT ARE THE LEGAL BASIS FOR SUCH PROCESSING?

Once again, we thought it would be clearer to present such legal basis for each kind of Data processing.

Contact Form Data
  • User consented to the processing;
  • Processing is necessary to take steps at the request of the User prior to entering into a contract;
  • Processing of the Data is in accordance with our legitimate interest since it enables us to increase our customer and prospect base for marketing purposes;
Newsletter
  • User consented to the processing;
Mailing List
  • User consented to the processing
  • Processing of the Data is in accordance with our legitimate interest since it enables us to improve performance of the Service and of he Application;
Visiting Data
  • Processing of the Data is in accordance with our legitimate interest since it enables us to measure the audience of our Site;
Linphone free SIP service data      a. User subscription Data:

  • User consented to the processing;
  • Processing is necessary to operate the Service, and therefore for the performance of the agreement with the User (Terms and Conditions of Service);

b. User activity Data:

  • Processing is necessary to comply with our legal obligations;

c. Group chat activity data:

  • Processing is necessary to operate the Service and therefore for the performance of the agreement with the User (Terms and Conditions of Service);

d. Debug Logs:

  • Processing is necessary to perform the Service or support agreement with the User;
  • Processing of the Data is in accordance with our legitimate interest since it enables us to improves performance of the Service;

7. HOW ARE MY DATA PROTECTED?

Belledonne Communications runs the Free SIP service on machines hosted by OVH SAS, in France and Germany.

The machines are secured, only Belledonne Communications workers are entitled to login.

8. HOW LONG ARE MY DATA PROCESSED?

Contact Form Data
  • Data are retained for a period of 3 years from User’s last contact, in accordance with CNIL’s reference guide on commercial management;
Newsletter
  • Up to un-subscription from the Newsletter by User;
Mailing List Data
  • Until the Mailing List, or a specific topic is closed; in which case, messages exchanged (threads) are archived for 10 years, in order to keep specific knowledge available to other Users;
Visiting Data
  • 13 months, from the first date of collection
Linphone free SIP service data      a. User subscription Data:

  • Until closing or deletion of User’s account;
  • Data are deleted from active database, but stored for one year from closing or deletion of User’s account, pursuant to the provisions of Decree No. 2011-219 of February 25, 2011 relating to the storage and communication of data allowing the identification of any person having contributed to the creation of content published online

b. User activity Data:

  • 12 months after collection; i.e. call logs and chat message logs are retained for 12 months from their registration in BELLEDONNE’s systems;

c. Group chat activity data:

  • as long as the chat session (chatroom) is alive, i.e. as long as there is a User Device joined to the chatroom. When all Device from all users have left a chatroom, all data associated to the chatroom are deleted from active data base.

d. Debug Logs:

  • 1 month

9. DO WE DISCLOSE ANY INFORMATION TO THIRD PARTIES?

We do not sell, trade, or otherwise transfer to outside parties your Personal Data, or all type of content that you may upload or send with Linphone (e.g. text conversations, calls, videos, photos; etc.), unless specifically requested by legally competent authorities, under a judicial or administrative order (see IV.2 and IV.3).

10. DO WE USE COOKIES?

We only use audience cookies, i.e. Google Analytics.

A consent pop-up is displayed when accessing the Site, enabling you to accept or refuse such cookies.

They also may be disabled at any time through your browser’s settings.

11. WHAT ARE MY RIGHTS AND REMEDIES?

11.1. User’s rights on Personal Data

As a User, you have the right to obtain from us:

  • confirmation that personal data concerning you are or are not being processed, and if necessary, to have access to them;
  • the correction of personal data concerning you that are inaccurate or incomplete;
  • the deletion of your personal data, under the conditions set forth in art.17 of GDPR; you may, for instance, delete your user account directly via the Service online, which will stop processing of all Personal Data, subject to the exceptions set forth in Section VIII;
  • the portability of your personal data to any similar digital audio/video service, under a standard and structured readable format; these requests may only deal with data provided by you, or in direct link with your activity (such as Data mentioned in IV.4.b. and IV.4.c.), to the exclusion of (i) any value-added data that we may process (such as profile-based recommendations, or statistical data), and (ii) any data or content generated by the User when using the Service, such as call history, messages, chat messages; which are exclusively stored on his Device.
  • organizing the fate of your personal data in the event of your death (storage, deletion, or communication to a designated person).
  • to oppose, under certain conditions, the processing of your personal data.

You may also, at any time, object to the processing of your data for commercial prospecting purposes by unsubscribing to our Newsletter.

11.2. How to exercise them

You may unsubscribe to a Mailing List by clicking on the “unsubscribe” link on any email, or changing your settings in the Mailing List homepage.

You may unsubscribe to our Newsletter by clicking on the “unsubscribe” link at the end of one of our Newsletter emails.

You may delete your account via the online Service.

For all other requests, please send us an email to: gdpr@belledonne-communications.com,

  • indicating the subject of your request, your name(s) and first name(s);
  • enclosing a photocopy of both sides of your identity card or passport, to enable us to verify your identity and any information that would be useful in processing your application.

We will get back to you as soon as possible, at the latest within one month of receiving your application.

We remind you that you have the right to file a complaint with the CNIL if you feel that your rights have not been respected. For more information on your rights with regard to your data, we invite you to consult the following webpage: https://www.cnil.fr/fr/plaintes.