Privacy

Last update: 10th April 2016

Dear Users,

EXALINKS S.A.S. company offers NEOPARD service, a data optimization solution for mobile devices: smartphone, tablet or laptop.

We (EXALINKS, EXALINKS SAS company) want you (as a user of NEOPARD service) understand our approach to the confidentiality of your data when you install and use NEOPARD mobile application (NEOPARD, NEOPARD application, NEOPARD service) on your mobile device.

To respect your privacy, we always try to be as transparent as possible on NEOPARD service. Our Privacy Statement explains the data we collect, the reasons for this collection, and the way we use those data.

By using NEOPARD service, you accept the practices described in the Privacy Policy. The Privacy Policy applies solely to information collected by EXALINKS with NEOPARD service and operated by EXALINKS.

If you do not agree with this Privacy Policy, do not use the NEOPARD service.

Information we collect

The data we collect is limited to the information necessary to NEOPARD service in order it can perform data optimization and make statistics on mobile data traffic.

We wish to respect your privacy and we do not collect your personal information such as your name, email address, phone number, email address or contact list book.
Only data concerning identity of the phone is collected by the service as NEOPARD needs to uniquely identify your mobile device in our service.

The NEOPARD service requires access to your data traffic in order to apply the optimizations needed to reduce traffic and improve access to the network. We use the official interface provided by the operating system of your mobile device (vpn type interface) so that the data traffic is redirected to one of EXALINKS optimization server (proxy service type).

Usage of permissions on mobile device

When installing NEOPARD application on your mobile equipment, the following permissions are required:

– Calls (see the status and identity of the phone)
– Network communication (full network access)
– System tools (retrieve running applications)

You therefore agree that NEOPARD application accesses and uses these functions on your mobile device. At the launch of the mobile application NEOPARD, these access rights are used as follows:

Phone identity
We collect information on the identity of the phone to have a unique number identifying the material contacting our NEOPARD service.

Information about the phone as make, model, version are used to improve our service on some mobile devices.

We also use the information about the network operator operating data service, mobile position (GPS and / or IP) and roaming indication, in order to establish service usage statistics.

The list of phone calls is not collected by the NEOPARD application.

Network access
When accessing the network for mobile data traffic optimization, we do collect information on mobile applications installed and used for statistics purposes. It allows EXALINKS to improve its NEOPARD service or mobile network operators to analyze traffic passing on their infrastructure.

Personal identity data is not collected.

Your data traffic consists of information needed to transport data (IP address, domain name, position, roaming …) and content information corresponding to your personal data. List of connections established (transport information) is collected but your content (personal information) is not collected and not stored on EXALINKS servers providing NEOPARD service.

Access to running applications
The mobile application NEOPARD is aware of the running applications on your mobile device as well as data traffic carried by these applications.

The traffic transmitted and received by these applications is optimized and usage statistics per application are collected (volumes exchanged and saved, number of sessions, connection time).

If you do not want an application to be optimized by NEOPARD service, simply remove it from the list of applications optimized by NEOPARD. In this case, network traffic on this application will not be redirected to NEOPARD service.

Data security

EXALINKS draws your attention to the fact that some SSL secured applications like HTTPS are also optimized by NEOPARD service.

We implement the necessary means to preserve encryption and data security. However, be aware that the connections are encrypted between the mobile application and NEOPARD Service and then between NEOPARD service and the application server. The EXALINKS security certificate is used between mobile NEOPARD and NEOPARD service instead of the application certificate.

The data collected for SSL secured applications is identical as previously mentionned in paragraphs above and we limit SSL data optimization to social mobile applications like Google and Facebook.

The fact to use NEOPARD Service on SSL secured applications (option “HTTPS and Security”) is your responsibility and can not engage EXALINKS SAS. EXALINKS implements the necessary means to ensure the safety of applications, EXALINKS can not be held responsible against loss or theft of data or any other incident resulting from the use of NEOPARD Service, whether it is for SSL applications or other types.

If you do not want SSL secured applications to be optimized by NEOPARD service, simply remove it from the list of applications optimized by NEOPARD. In this case, network traffic on this application will not be redirected to NEOPARD service.

How we use information

The information logged by NEOPARD are meant to operate, manage and improve the service, in order we can do our utmost to optimize mobile data traffic.

As some examples, we use the information to:

– Maintain and manage NEOPARD service
– Understand and optimize mobile applications behavior
– Analyse data transactions and protocols to reduce data
– Provide analysis and statistics about traffic generated by mobile devices
– Perform mobile usage reviews for market studies and promote NEOPARD service
– Develop new applications, products or services

You may need to contact EXALINKS to solve an issue that you might encounter in the course of using NEOPARD service. The ID of your mobile device is usually necessary to investigate and diagnose such a potential issue. We may keep a record of your communication (email address or user ID NEOPARD) that may be associated with the identifier of your mobile device to better solve the problem you are facing. This information is only used only in the context of solving the problem and does not serve in any way to enrich a personal identification statistics resulting from the collection of NEOPARD Service data.

NEOPARD service is executed on servers usually hosted by third parties (network operators, service providers, infrastructure and cloud providers) and we implement the necessary means to secure our service. These servers are located in different countries around the world and your personal data is therefore likely to be processed on a server outside your country of residence.

Data we share

Information collected by NEOPARD could be provided to third parties in order they can get statistics on mobile devices usage and understand how is used mobile data network.

In the case where the information would be provided or sold to a third party, data allowing to identify your mobile device or your IP address would be removed or anonimyzed. As a reminder, it only concernas mobile identity as personal identity is not collected.

We do not communicate personal data to enterprises, private organizations or third parties.

We might communicate information to governemental agencies or organizations mandated by governments, in case there are illegal activities and to comply with legal, regulatory and administrative governmental authorities, or to protect and defend EXALINKS company in connection with any action, claim or dispute.

Data retention

EXALINKS stores information collected by NEOPARD service for one year.

Information collected is used as described in this Privacy Policy but is stored and kept by EXALINKS even if you decide to remove NEOPARD application from your mobile device or you decide not to use anymore NEOPARD service.

You can ask to remove all the information collected and associated to the identity of your mobile device by contacting EXALINKS company but the anonymized information already transferred to third parties cannot be removed and so, can be used for an unlimited period by these parties.

In compliance with the French law « informatique et libertés » of 6 January 1978, as later amended, every individual can obtain access to, and if necessary, rectification or deletion of the information concerning him/her, by writing to :

EXALINKS S.A.S.

BUSINESS PÔLE, 1047 ROUTE DES DOLINES,

ALLÉE PIERRE ZILLER BP19

06560 VALBONNE – France

with a copy to privacy@exalinks.com

You may also oppose, for legitimate reasons, the processing of your personal data.

For more information, please visit : www.cnil.fr

Contact us

If you have any questions about our Privacy Policy or any request to understand how EXALINKS is using the data collected by NEOPARD service, you can contact us at the following address:

EXALINKS S.A.S.

BUSINESS PÔLE, 1047 ROUTE DES DOLINES,

ALLÉE PIERRE ZILLER BP19

06560 VALBONNE – France

or using contact form on www.exalinks.com web site.