Last revised: 2nd February 2021
The Treebal services (“Treebal Services”) are a set of electronic communication services provided by AD Breizh (“Treebal”), including instant interpersonal messaging and Internet calling features, that values and respects the privacy of its users and is based on an environmentally responsible approach. The Treebal Services are provided to users on the basis of the Terms of Service.
Data controller – Data protection officer
The controller of your data is Treebal, as provider of the Treebal Services.
Treebal has designated a Data Protection Officer who can be reached at firstname.lastname@example.org.
Information you provide
Account. When you create a Treebal account, you must register your phone number. Phone numbers are used to provide the Treebal Services to you and other Treebal users. You may optionally add other information to your account, such as a profile name and profile picture. This information is end-to-end encrypted.
Messages. Treebal cannot decrypt or otherwise access the content of your messages or calls. Treebal queues end-to-end encrypted messages on its servers for delivery to devices that are temporarily offline (e.g. a phone whose battery has died). Your message history is stored on your own devices.
Technical information. Additional technical information is stored on our servers, including randomly generated authentication tokens, keys, push tokens, and other material that is necessary to establish calls and transmit messages. Treebal limits this additional technical information to the minimum required to operate the Services.
Security. Treebal utilizes state-of-the-art security and end-to-end encryption to provide the Treebal Services for private messaging and Internet calling services to users worldwide. Your calls and messages are always encrypted, so they can never be shared or viewed by anyone but yourself and the intended recipients.
Managing your information. You can manage your personal information in the settings menu of the Treebal application.
How we process your personal dataWe process your personal data for the following purposes and related legal bases:
- Provision of the Treebal Services: we process your personal data to provide the Treebal Services to you and the related user Support, on the basis of the performance of the Terms of Service;
- Contacts: if you opt in for this feature, we will discover which contacts in your address book are users of the Treebal Services, on the basis of your consent. This feature uses a service designed to protect the privacy of your contacts. Information from the contacts on your device may be cryptographically hashed and transmitted to the server in order to determine which of your contacts are registered;
- External communications: if you opt in for this feature, you will receive communications from such as collectivities, associations and/or brands, on the basis of your consent;
- Security: we process your personal data pursuant to detect fraud, security or technical issues in relation to the provision of the Treebal Services, on the basis of our legitimate interest to provide an appropriate level of security for our services;
- Compliance with the Terms of Service: we will process your personal data to monitor compliance with the Terms of Service, on the basis of our legitimate interest to defend our rights;
- Compliance with law: we will process your personal data to comply with regulations applicable to Treebal, on the basis of our obligation to comply with applicable law.
Recipients of your personal dataWe may share your personal data with the following categories of recipients:
- Our authorized personnel: To the extent necessary for providing the Treebal Services, our authorized personnel may process your personal data – including for example to answer a request for support in connection with your use of the Treebal Services;
- Third Parties acting on behalf of Treebal: We may communicate your personal data to third parties provide services to Treebal, in which case such third parties will process your personal data on behalf of Treebal and in accordance with Treebal’s instructions. For example, our third-party providers send a verification code to your phone number when you register for our Services;
- Other users of the Treebal Services: We may share your personal data with other users of the Treebal Services, such as the recipients of your communications, in accordance with your choices;
- Regulators and Competent Authorities: We may share your personal data with regulators and competent authorities when mandated to do so in accordance with applicable law.
Retention of your personal dataTreebal retains your personal data for the duration necessary in respect of the relevant processing purpose, and more specifically as follows:
- Registration data: The personal information relating to your account is retained during the term of your subscription to the Treebal Services;
- User communications: Treebal queues end-to-end encrypted messages on its servers for delivery to devices that are temporarily offline (e.g. a phone whose battery has died). Your message history is stored on your own devices and the messages are removed automatically every 7 days (this is a default setting that you can change);
- Security: the data processed for preventing fraud, security or technical issues in relation to the provision of the Treebal Services, is retained for a duration of 6 months.
International data transfers
If you choose to communicate with users of the Treebal Services that are located outside of the European Union, Treebal will transfer your personal data (including your communications) to such users in the country where they are located, in accordance with your choices. Such transfer is necessary for the provision of the Treebal Services to you.
Your rights – Contact us
You have a right to access your personal data, rectify them, request their deletion or exercise your right to limit the processing of your data. Where the processing of your data is based on your consent, you may withdraw your consent to the processing of your data at any time. You may also object to the processing of your data and exercise your right to the portability of your data in accordance with the applicable legal provisions.
To exercise these rights or if you have any questions about our processing of your data, please contact us at:
- Email: email@example.com
- Postal address: Treebal 10, parc de Brocéliande - Immeuble Axis - 35760 Saint- Grégoire - T. 02 – France
If you believe that your personal data is not processed in accordance with applicable regulations, you may submit a complaint to the French data protection authority – Commission nationale de l’informatique et des libertés.