Privacy Policy

 

 

 

The Privacy Policy below describes how we collect, store and use your personal data in accordance with the requirements of the European Regulation on Data Protection (GDPR). The current policy applies to customers of SBE. Job applicants should refer to the Job Applicant Privacy Notice available from our Careers pages.

 

We take seriously our responsibilities to look after your data and we are committed to protecting your privacy. There are steps you can take to control what we do with your data and we have explained those steps in this Privacy Policy. When we talk about data and personal data in this Privacy Policy, we mean personal data which identify you or which could be used to identify you, such as your name and contact details, the IMEI number of your device and any repair reference or job number. It also includes information about how you use our websites and applications.

 

What you need to know

 

Who is responsible for your data

SBE SAS is responsible for the data you provide to us when contacting us through our websites (SBEGLOBALCARE.COM and SBEGLOBALSERVICE.COM) or when subscribing to our services. In these instances, we are the Data Controller of the data which we collect from you, and as such we control the ways your personal data are collected and the purposes for which your personal data are used. Our registered address is: SBE SAS, 1 BOULEVARD DE LA LIANE, 62360 SAINT LEONARD, FRANCE.

 

SBE SAS also acts as a Data Processor for a large number of clients in the field of smartphone and device repair services, in particular through its digital returns management platform (GlobalCare). For more information regarding the processing of your personal data via our platform for service and repair purposes, please refer to the privacy policy of the manufacturer, insurer or distributor of your device.

 
If you have sent us (or intend to send us) a device for repair and want to find out more about the processing of your personal data by one of our affiliated companies, please refer to the privacy policy of the relevant SBE subsidiary based on your country of residence:

 

• SBE FRANCE – Privacy Policy
• SBE UK – Privacy Policy
• SBE POLAND – Privacy Policy

 

Personal data we collect about you

We collect data from you when you contact us through our website. The personal data we collect from you are:

 

• Your personal information (e.g. name, address, telephone number, email)
• Information related to your query (e.g. message content, letter)

 

We do not collect any sensitive data as defined in GDPR (e.g. health data, political or religious beliefs, etc). Moreover, we do not process any data related to minors without parental consent.

 

How we collect data about you

We collect your personal data:

 

• Either directly, via our online form if you contact us via our website, ou by phone, if you call us to obtain information regarding a product or request a quotation;
• Or indirectly, via public directories or social media platforms such as LinkedIn.

 

How we use your personal data

According to the law, we can only use your personal data if there is a proper reason for doing so. In the table below, we have set out the different ways in which we use your personal data (purpose of processing) and the reasons we rely on for using that data (legal basis for processing).

 

PURPOSE OF PROCESSING	LEGAL BASIS FOR PROCESSING
Market research, sales and marketing	Our legitimate interests
Management of commercial and contractual obligations, provision of services	Execution of a contract
Register a request or query (e.g. request for quote, job application)	Execution of a contract or pre-contractual obligations
Improving our products and services (e.g. sending out a satisfaction survey)	Our legitimate interests
Communicating with you for any other reason (e.g. to send you a newsletter)	Your consent

 

SBE SAS do not carry out any profiling or automated processing of your personal data.

 

Sharing your data

As part of the services we provide, we share some of personal your data with the following categories of third-parties:

 

• Our IT support and hosting partners. Our GlobalCare platform is maintained in house with the help of specialist partners for development and technical support (e.g. EASYTEAM, INEAT, TYMATE). The infrastructure is hosted by MEDIACTIVE GROUP within secure datacenters located in France.

 

• Our digital analytics partners. Our websites and applications use cookies from AT INTERNET and/or GOOGLE ANALYTICS in order to analyse web traffic and produce usage statistics and reports.

 

• Customer relationship management platforms. We share some of your data with platforms to help us manage commercial relationships and measure customer satisfaction. For example, we use services from SNAPENGAGE (chat), TEAMLEADER (customer relationship management) and TRUSTPILOT (to collect customer reviews).

 

SBE SAS commits that we, or any of our subcontractors, will never sell your personal data to any third party, and that we’ll never use your data for any other purpose than the ones outlined in this Privacy Policy.

 

How we protect your data

We protect your personal data against unauthorised access, unlawful use, accidental loss, corruption or destruction. We use technical measures such as encryption, password protection and access control mechanisms to protect your data and the systems they are held in. We also use operational security measures, such as limiting the number of people who have access to the databases where your personal data is stored.

 

We ensure that these security measures are reviewed regularly, and we rely on industry standards and best practices. We make sure that each of our subcontractors who have access to your data provide the same guarantees of security and data protection as we do, as per to the requirements of the European data protection regulation (GDPR).

 

How long we keep your data

We only keep your data for as long as we need it. How long we need data depends on what we are using it for, whether that is to provide services to you, for our own legitimate interests or so that we comply with the law.

 

We will actively review the information we hold and when there is no longer a legal or business need for us to hold it, we will either delete it securely or in some cases anonymise it.

 

The following table shows the retention periods we have set for the data we hold, where SBE SAS acts as a Data Controller:

 

TYPE OF DATA	HOW LONG IT’S KEPT
Sales and marketing data (prospective clients)	12 months
Data related to commercial relationship (contractual)	As long as the contract is active, and 12 months after contract ends (except where there is a legal or statutory obligation to keep the data for a longer period)
Accounting records and supporting evidence (e.g. quotes, invoices, delivery notes)	Legal retention period set by each EU Member State (in France, the period is 10 years)
Data used for sending marketing communications, if applicable (e.g. newsletters)	Until you withdraw your consent

 

 

Where SBE SAS acts as a Data Processor on behalf of a customer (e.g. manufacturer, insurer or distributor), the retention period of the data is defined by the customer (who is the Data Controller). You are advised to check the privacy policy of your device’s manufacturer, insurer or distributor for more information.

 

Sending data outside the European Economic Area

The personal data we collect are hosted within the EU (mostly in France). SBE SAS do not store or send any data outside of the EEA (European Economic Area).

 

Your rights

You are entitled to see copies of all personal data held by us and to amend, correct or delete such data. You can also limit, restrict or object to the processing of your data. To exercise those rights you can send us an email using our contact form or, if you prefer, you can write to us at the address below (under the heading ‘Contact us about this policy’).

 

Please note that, if the legal basis of the data processing is to execute a contract, choosing to exercise certain rights (e.g. the right to restrict or object to the processing of your data) could result in us being unable to provide you with the service you require (e.g. to process an order).

 

If you gave us your consent to use your data, e.g. so that we can send you marketing emails, you can withdraw your consent at any time. Please note that even if you withdraw your consent, we can still rely on the consent you gave as the lawful basis for processing your data before you withdrew your consent.

 

You can object to our use of your data where we rely on our legitimate interests to do so. We explained the legitimate interests we rely on in the table above under the heading ‘How we use your personal data’.

 

When you get in touch, we will come back to you as soon as possible and where possible within one month. If your request is more complicated, it may take a little longer to come back to you, but we will come back to you within a further two months maximum. There is no charge for most requests, but if you ask us to provide a significant amount of data for example, we may ask you to pay a reasonable admin fee. We may also ask you to verify your identity before we provide any information to you.

 

Please note that you have the right to lodge a complaint with the supervisory authority which is responsible for the protection of personal data in the country where you live or work, or in which you think a breach of data protection laws might have taken place. The supervisory authority in France is the CNIL (www.cnil.fr).

 

Contact us about this policy

To send us a general enquiry about this policy or exercise one of your rights under GDPR, please send us an email using our contact form. To contact our DPO (Data Protection Officer), you can also send an email to: dpo (at) sbeglobalservice.com or, if you prefer, write to us:

SBE SAS
SERVICE DPO
1 BOULEVARD DE LA LIANE
62360 SAINT LEONARD
FRANCE