BELLEDONNE COMMUNICATIONS provides and operates a telecommunication service for instant messaging and voice/video over IP (VoIP), called the “Free Linphone SIP Service” (the “Service”), as well as 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, along with other associated support, maintenance, or development services, and more generally, all products and services provided by BELLEDONNE COMMUNICATIONS, are fully described on the BELLEDONNE COMMUNICATIONS website, available at linphone.org (the “Website”).
To receive information about BELLEDONNE COMMUNICATIONS’ products and services, website visitors may contact the company via our contact form or subscribe to our newsletter.
This Privacy Policy describes, in accordance with Article 13 of the GDPR, how Users’ personal data is collected and processed by BELLEDONNE COMMUNICATIONS when Users visit the Website, contact the company, or subscribe to the newsletter, as well as their rights and how to exercise them.
This Policy, along with any updates, is published on the Website and must be accepted by all Users when subscribing to the Newsletter or completing the contact form.
1. DEFINITIONS
In this Policy, the following terms are defined as follows:
- Application: The Linphone application for iOS, Linphone application for Android, and Linphone application for desktop platforms, downloadable on the User’s Device, developed by BELLEDONNE COMMUNICATIONS.
- Personal Data: The User’s personal data processed by BELLEDONNE COMMUNICATIONS for the purposes outlined in this Policy.
- BELLEDONNE COMMUNICATIONS: SARL BELLEDONNE COMMUNICATIONS, headquartered at 3 Avenue Marie Reynoard, 38100 Grenoble, registered with the Grenoble Trade and Companies Register under number 520 318 437.
- Service: BELLEDONNE COMMUNICATIONS’ VoIP service for audio/video calls and instant messaging using the open SIP (Session Initiation Protocol) standard, allowing Users to create a free SIP account with the domain sip.linphone.org, provided free of charge online or via the Application, under the conditions stipulated in the Linphone Terms of Use.
- Mailing List: One of the BELLEDONNE COMMUNICATIONS’ mailing lists, to which any User can subscribe directly on the Website to receive information or support regarding the Application or Service.
- Newsletter: An electronic document containing information about BELLEDONNE COMMUNICATIONS’ recent activities, sent by email to Users.
- Website: The linphone.org website, managed and operated by BELLEDONNE COMMUNICATIONS, describing and updating the features and requirements of the Application and Service.
- Device: A mobile or fixed telecommunication device with Internet access, such as a smartphone, tablet, or personal computer (PC), enabling the download of the Application and use of the Service, in compliance with the prerequisites indicated during the download process.
- User: A natural person visiting the Website, subscribing to a Mailing List, subscribing to the Linphone newsletter, contacting BELLEDONNE COMMUNICATIONS via the contact form on the Website, downloading and using the Application for personal or professional purposes, or creating an account on the Service.
2. WHO IS THE DATA CONTROLLER?
The Data Controller is SARL BELLEDONNE COMMUNICATIONS, headquartered at 3 Avenue Marie Reynoard, 38100 Grenoble, registered with the Grenoble Trade and Companies Register under number 520 318 437.
All requests related to this Policy and the GDPR can be sent by postal mail to its address: 3 Avenue Marie Reynoard, 38100 Grenoble – France, or by email to: gdpr@belledonne-communications.com.
3. WHO ARE THE DATA SUBJECTS?
The data subjects, as defined in Article 4 of the GDPR, covered by this Privacy Policy are the Users as defined in Section I.
4. WHAT PERSONAL DATA IS PROCESSED?
In providing the Service, the Application, and associated services, BELLEDONNE COMMUNICATIONS processes the following Personal Data:
4.1. Contact Form:
- Name
- Email address
- Company
- Country
- Type of request and full content of the request, and more generally, any information provided to BELLEDONNE COMMUNICATIONS regarding the User’s needs or project.
4.2. Mailing Lists:
- Email address
- Name (optional)
- Any messages exchanged with other Users, whether as new topics or responses to existing topics.
4.3. Website Visit:
4.4. Free Linphone SIP Service:
4.4.a. User Registration Data:
- Name
- Email address
- IP address used during registration
- User’s password stored as an MD5 or SHA256 hash, used for SIP authentication
- User’s international phone number for registrations via the mobile app
- User-agent string used for registration, such as browser or Linphone application user-agent. Mobile app user-agent strings include device identifiers, e.g., “Moto G7,” “Samsung SM518,” “Apple iPad 2,” allowing users to track devices on which their SIP account has been used.
4.4.b. User Activity Data:
- Call logs: caller’s SIP address, recipient’s SIP address, date, time, status (completed or not), duration.
- Instant messaging logs: sender’s SIP address, recipient’s SIP address, date, time, status (delivered or not), type (content or delivery notification). Note: the actual content of these messages is not stored.
- Registration logs: timestamps when User’s applications connect to the service via the network, including date, time, status, and IP address.
- Phone numbers from the User’s mobile address book.
4.4.c. Group Chat Activity Data:
- User’s participation in group chats and secure individual discussions, including identification of User’s devices joining the instant messaging session (via user-agent string). Includes timestamps of joining or leaving a chat.
- Topics entered by Users when creating a group chat.
4.4.d. Debugging Logs:
For troubleshooting purposes only, BELLEDONNE COMMUNICATIONS reserves the right to activate debugging logs in the Application and software used to provide the Service. These logs contain complete protocol-related information on calls, instant messages, and other protocol events generated by Users.
5. WHAT ARE THE PURPOSES OF DATA PROCESSING?
We have outlined the purposes of processing for each type of data mentioned in Section IV.
| Contact Form |
- Responding to the User’s request for information about BELLEDONNE COMMUNICATIONS’ products or services.
- Issuing quotes to Users for specific licenses and services.
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| Newsletter |
- Providing Users with up-to-date information about the Service, the Application, as well as the latest news and activities of BELLEDONNE COMMUNICATIONS.
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| Mailing List |
- Fournir aux Utilisateurs des sourcesProviding Users with sources of information about the Application, its usage, development, or support needs.
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Allowing Users to interact with other users on the Application or any service provided by BELLEDONNE COMMUNICATIONS.
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| Website |
- For audience and statistical analysis purposes.
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| Data related to the free SIP Service sip.linphone.org |
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6. WHAT ARE THE LEGAL BASES FOR THESE PROCESSINGS?
We thought it would be clearer to present the legal bases for each type of data processing.
| Contact Form data |
- The User has consented to the processing;
- The processing is necessary to take steps at the request of the User before entering into a contract;
- The processing of the data is in line with our legitimate interest, as it allows us to expand our customer and prospect base for marketing purposes.
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| Newsletter data |
- The User has consented to the processing;
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| Mailing List data |
- The User has consented to the processing;
- The processing of the data is in line with our legitimate interest, as it allows us to improve the performance of the Service and the Application.
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| Website data |
- The processing of the data is in line with our legitimate interest, as it allows us to measure the audience of our Website.
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| Free SIP Service (sip.linphone.org) data |
a. User Subscription Data:
- The User has consented to the processing;
- The processing is necessary to operate the Service, and therefore for the execution of the contract with the User (Terms and Conditions of the Service).
b. User Activity Data:
- The processing is necessary to comply with our legal obligations.
c. Group Chat Activity Data:
- The processing is necessary to operate the Service, and therefore for the execution of the contract with the User (Terms and Conditions of the Service).
d. Debugging Logs:
- The processing is necessary to execute the Service or the support agreement with the User;
- The processing of the data is in line with our legitimate interest, as it allows us to improve the performance of the Service.
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7. HOW ARE MY DATA PROTECTED?
Belledonne Communications operates the free SIP service on machines hosted by OVH SAS, in France and Germany.
The machines are secured, and only Belledonne Communications employees are authorized to connect.
8. HOW LONG ARE MY DATA PROCESSED?
| Contact Form data |
- The data is kept for a period of 3 years from the User’s last contact, in accordance with the CNIL’s reference guide on commercial management.
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| Newsletter data |
- Until the User unsubscribes from the Newsletter.
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| Mailing List data |
- Until the closing of the Mailing List or a specific thread; in this case, the exchanged messages (threads) are archived for 10 years to retain specific knowledge available for other Users.
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| Website data |
- 13 months, starting from the first date of collection.
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| Free SIP Service (sip.linphone.org) data |
a. User Subscription Data:
Until the closure or deletion of the User’s account. The data is removed from the active database but retained for one year from the closure or deletion of the User’s account, in accordance with the provisions of Decree No. 2011-219 of February 25, 2011, relating to the retention and communication of data allowing the identification of any person who contributed to the creation of content posted online.
b. User Activity Data:
12 months after their collection, meaning that call logs and chat message logs are kept for 12 months from their registration in BELLEDONNE’s systems.
c. Group Chat Activity Data:
As long as the chat session (chatroom) is active, meaning as long as a user device is connected to the chatroom. When all devices of all users have left the chatroom, all data associated with the chatroom is deleted from the active database.
d. Debugging Logs:
1 month.
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9. DO WE DISCLOSE INFORMATION TO THIRD PARTIES?
We do not sell, exchange, or transfer your Personal Data, nor any type of content you may upload or send via Linphone (e.g., text conversations, calls, videos, photos, etc.) to external parties, except in the case of a specific request from 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, specifically Google Analytics.
A consent pop-up window appears when you access the Site, allowing you to accept or reject these cookies.
They can also be disabled at any time through your browser settings.
11. WHAT ARE MY RIGHTS AND REMEDIES?
11.1. User Rights Regarding Personal Data
As a User, you have the right to obtain from us:
- Confirmation of whether personal data concerning you is being processed, and if so, access to it;
- Correction of personal data concerning you that is inaccurate or incomplete;
- Deletion of your personal data, under the conditions specified in Article 17 of the GDPR; for example, you can delete your user account directly via the online Service, which will stop the processing of all Personal Data, subject to the exceptions listed in Section VIII;
- Portability of your personal data to any similar audio/video digital service, in a readable, standard, and structured format; these requests can only concern the data provided by you, or directly linked to your activity (such as the data mentioned in IV.4.b and IV.4.c), excluding (i) any value-added data we may process (such as recommendations based on your profile, or statistical data), and (ii) any data or content generated by the User during the use of the Service, such as call history, messages, or discussions, which are exclusively stored on your Device;
- The organization of your personal data in the event of death (storage, deletion, or communication to a designated person);
- The right to object, under certain conditions, to 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 from our Newsletter.
11.2. How to Exercise Your Rights
You can unsubscribe from a Mailing List by clicking on the “unsubscribe” link in any email, or by changing your settings on the homepage of the Mailing List.
You can unsubscribe from our Newsletter by clicking on the “unsubscribe” link at the bottom of one of our Newsletter emails.
You can delete your account via the online Service.
For any other request, please send us an email at: gdpr@belledonne-communications.com, indicating the subject of your request, your name, and surname(s); and attaching a photocopy (front and back) of your ID card or passport, to allow us to verify your identity and any relevant information for processing your request.
We will respond as soon as possible, no later than one month from receiving your request.
We remind you that you have the right to file a complaint with the CNIL if you believe that your rights have not been respected. For more information about your rights regarding your data, we invite you to visit the following page: https://www.cnil.fr/en
