Privacy & Cookie Notice

By using our websites, products, services, or otherwise by interacting with Us, you consent to the following privacy policy (“Privacy Policy”). Please do not engage in any of these activities if you do not agree with the terms of this Privacy Policy. The Privacy Policy applies to the processing of personal data carried out by 23 Telecom LTD (publ) or any of its subsidiaries (“We”, “Our”, “Us” or “23 Telecom LTD”).

Your privacy is important to Us. The purpose of this Privacy Policy is to inform you about the information We may gather about you, how We may use that information, whether We disclose it to anyone, and the choices you have regarding Our use of the information We collect.

Information Collected by 23 TELECOM LTD

In general, 23 Telecom LTD will collect personal data from you based upon our business relationship, your use of the Site, Our services and Our products, as follows:

CONTACT PERSONS AND CONTENT REGISTRATION

In order for Us to communicate and provide our services to you or discuss the services you may provide Us with, you will provide us with your contact information and possibly other information about you. Further, in order to access and view some content on the Site, you are required to register with 23 Telecom LTD before the content is made available to you. During the registration process, you are required to provide Us with certain contact information, including your name, address, phone number and email address. We use this information to contact you about the services We offer in relation to which you have expressed interest or vice-versa.

CLIENT SUPPORT PORTAL

When you contact 23 Telecom LTD customer support (“Customer Support”) using any 23 Telecom LTD client support portal (the “Client Support Portal”), We may ask you for certain information regarding your enquiry, such as your name, email address or telephone number.

COOKIES

What Are Cookies and How Do I Manage Them?

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes:

What Are Cookies and How Do I Manage Them?

Our customer support portals use session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows Us to process your online data and requests. Session cookies help Us make sure you are who you say you are after you have logged in. We use persistent cookies, which only we can read and use, to identify the fact that you are an 23 Telecom LTD customer or prior site visitor.

To view the cookies we use and manage you preferences click on the button below.

COOKIE PREFERENCES

We also may from time to time engage third parties to track and analyze non-personally identifiable usage and volume statistical information from visitors to our websites to help us administer the websites and improve its quality. Such third parties may use cookies to help track visitor behavior. Such cookies will not be used to associate individual website visitors to any Personal Data (defined below). All data collected by such third parties on Our behalf is used only to provide Us with information on site usage and is not shared with any other third parties.

FORUMS AND BLOGS

If you participate in any blog or other forum offered by our website or services, your user ID may be displayed on any content that you post and will therefore be available to the public. Therefore, if you associate your name with your user ID, your name and any related content or posts may be available to the public. You are solely responsible for all liability related to your use of any such blog or forum.

CORRESPONDENCE

If you send Us correspondence, such as emails or letters, We may collect such information into a file specific to you.

MOBILE USER INFORMATION

As part of Our services, We sometimes receive information from wireless carriers and operators in order to provision the specific content and data services requested by individual users. All such information is acquired from either the wireless carrier’s or operator’s website or from the user’s mobile device via the wireless carrier’s or operator’s network. This data is usually limited to the user’s cell phone number. In some cases, such as for prize fulfilment for a mobile contest, the user’s mailing address is also provided. The user must explicitly “opt in” through the wireless carrier or operator in order for any of this information to be collected and its use is governed by this Privacy Policy and any policies or procedures of the user’s wireless carrier or operator. In some cases, We may receive authentication information directly from mobile users, including in the form of a personal information number (PIN) previously sent to a mobile user.

HUMAN RESOURCES

We collect information about you when you submit a job application, resume, survey responses or similar information.

NEWSLETTERS

If you wish to subscribe to Our newsletters, We will use your name and email address to send the newsletter to you. Out of respect for your privacy, you have the option to unsubscribe from receiving some or all of the newsletters. Please see the “Opt-out” section below.

How We Use Information

We may use data We obtain as described above for purposes relating to our website and services, including (a) providing the website and services to you, (b) facilitating third parties to participate in the provision and improvement of the website and services (including without limitation mobile network operators, hosting partners, and other service providers), (c) raising queries with you, and responding to issues you may raise, whether relating to our services or otherwise, (d) communications relating to surveys and other customer satisfaction-related activities, (e) progressing job applications, to perform credit checks and, (f) verification of personal or business data and payment details and other checks before offering our services to customers.

SERVICE-RELATED ANNOUNCEMENT

We will send you service-related announcements when it is necessary to do so. For instance, if Our service is temporarily suspended for maintenance, We might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

CUSTOMER SERVICE

We will also communicate with you in response to your customer service enquiries, to provide the services you request, and to manage your account.

Disclosures and Sharing of Information

As a matter of policy, We do not sell or rent any of your information to third parties for any advertising or marketing purposes. However, the following describes some of the ways that We may disclose your information in the normal course of providing Our services.

DISCLOSURE TO OUR SERVICE PROVIDERS

Your personal data may be transferred to and processed by third party providers and suppliers which perform services for Us (data processors), to enable these companies to perform the services requested by Company. Only personal data that is necessary to fulfill the purposes will be provided to these companies. All third party providers and suppliers must follow Our instructions and applicable written data processor agreements and any other agreements that are in place between Us and Our third party providers/suppliers, and must implement appropriate technical and organizational measures for the protection of the personal data.

LEGAL REQUESTS & COMPLIANCE WITH LAWS

We reserve the right to disclose information as required by law or regulation and when We believe that disclosure is necessary to protect Our rights and/or to comply with a judicial proceeding, court order, or legal process. Notwithstanding any provisions herein, We may disclose Personal Data to governmental authorities when required or reasonably requested to do so by such governmental authorities. This Privacy Policy does not apply to the extent that it is in conflict with any law that may be applicable to the Personal Data of a Data Subject.

PROCESSING OF PERSONAL DATA OUTSIDE EU AND ENGLAND

23 Telecom LTD processes Personal Data on behalf of its clients (“Customers”), that has been collected by or on behalf of those Customers including Personal Data received from the European Union. With the objective to validate transfers of Personal Data under European data protection laws to countries outside EU and England we are making available the European Commission’s controller-to-processor standard contractual clauses, commonly referred to as “model clauses” (in the form adopted by decision 2010/87/EU of 5 February 2010 and with Appendices 1 & 2. Any Customer of 23 Telecom LTD who undertakes processing activities on the 23 Telecom LTD platform (in respect of Personal Data which is governed by the European data protection laws), should contact GDPR@23telecom.co.uk for more details.

DISCLOSURE OF INFORMATION TO 23 Telecom LTD AFFILIATES

Because 23 Telecom LTD is a global company, We may share your information with other 23 Telecom LTD affiliates and business units in other parts of the world in order to provide you with Our services. Your Personal Data may be transferred by Us from your home country to 23 Telecom LTD employees in 23 Telecom LTD offices around the world, who may communicate with you regarding your enquiry. Please understand that We limit access to your Personal Data to only those 23 Telecom LTD employees who We believe need access in order to provide services to you or to otherwise perform their duties.

Data Processor

As Data Processor, 23 Telecom LTD will only process Personal Data pursuant to the instructions of the applicable Customer (for example where We act as a Data Processor in relation to the processing activities of Customers on Our platform). 23 Telecom LTD may use the services of third party Data Processors to process Personal Data in accordance with purposes identified for such Personal Data by the applicable Customer (including but not limited to the provision of services). 23 Telecom LTD will not be responsible for determining the authenticity of any purported Data Subject’s request to access his or her Personal Data. In the absence of express instructions to do so from the applicable Customer, 23 Telecom LTD will not provide a purported Data Subject with access to his or her Personal Data unless it is demonstrated to 23 Telecom LTD satisfaction that the applicable Data Controller has refused such access.

Data Controller

As Data Controller, 23 Telecom LTD receives Personal Data about Our business contacts. 23 Telecom LTD owns and controls such Personal Data as stated in this Privacy Policy. In parallel and in accordance with Recital 47 of the European Data Protection Directive 95/46/EC (as amended from time to time of replace by other EU regulation), We shall act as an independent Data Controller with respect to the processing of Personal Data which is necessary for the operation of Our service which shall include any information processed for the purpose of the conveyance of a communication on an electronic communications network or for the billing thereof.

HIPAA

From time to time, 23 Telecom LTD provides messaging services to health care providers, and serves as a “Business Associate” (as that term is defined pursuant to HIPAA Regulations) to such providers in relation to the handling of protected health information (“PHI”) that is made a part of Our services.

De-identification

23 Telecom LTD may de-identify or depersonalize data into anonymized and aggregate data that it derives from Customers (“Anonymous Data”). Anonymous Data means data that includes no Personal Data or unique identifiers that could later be used to refer to the Personal Data to which the data was once associated. 23 Telecom LTD uses only Anonymous Data in performing analyses, and may disclose Anonymous Data to its Customers who have requested such analyses and to third parties where We are contractually entitled to do so.

This Site is Not for Use by Children

Protecting the privacy of children is important to 23 TELECOM LTD. For that reason, the Site is structured specifically to not attract anyone under 13, nor do We collect or maintain Personal Data on the Site from those who 23 Telecom LTD actually knows are under 13. If 23 Telecom LTD learns or is notified that it has collected information from users under the age of 13, 23 Telecom LTD will immediately delete such Personal Data.

Opt-Out

We provide you the opportunity to ‘opt-out’ of having your Personal Data used for certain purposes, when We ask for this information. For example, if you register with Us but no longer wish to receive Our newsletters and/or related communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing Us at GDPR@23telecom.co.uk

Security

We take appropriate technical and organizational measures to guard against unauthorized or unlawful processing of your Personal Data and against accidental loss or destruction of, or damage to, your Personal Data. 23 Telecom LTD uses industry-standard security measures to protect the integrity and confidentiality of any Personal Data it owns or processes on behalf of Customers, including, in appropriate circumstances, the use of firewalls, restricted access, and encrypted transmissions. 23 Telecom LTD limits access to Personal Data to those persons in 23 Telecom LTD organization who have a business need to process such Personal Data. However, no company, including 23 TELECOM LTD, can fully eliminate the security risks associated with such Personal Data. Due to factors beyond 23 Telecom LTD control, 23 Telecom LTD cannot ensure that Personal Data will not be disclosed to third parties. For example, 23 Telecom LTD may become legally obligated to disclose such data, or, despite precautions, third parties may circumvent security measures to intercept or access such data.

Disclaimer

We cannot ensure that all of your private communications and other Personal Data will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting the foregoing), We may be forced to disclose Personal Data to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your Personal Data that they collect from the Site. 23 Telecom LTD does not review, comment upon, or monitor its Customers’ compliance with their respective privacy policies, nor does 23 Telecom LTD review Customer instructions to determine whether they are in compliance or conflict with the terms of a Customer’s published privacy policy.

Third Parties

Please be advised this Privacy Policy does not apply to the practices of companies that 23 Telecom LTD does not own or control, or to people that 23 Telecom LTD does not employ or manage. This includes links to other websites on the Site as well as any companies from whom you may have ordered services or products that are transmitted over 23 Telecom LTD network, and any companies from whom you may be purchasing telecommunications services. 23 Telecom LTD recommends that you be aware when you leave the Site and read the terms of use and privacy policies of any site, product or service that collects Personal Data.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time, so please review it regularly. If We make changes to this Privacy Policy, We will post the revised Privacy Policy on the Site and other places We deem appropriate. All such changes shall be binding on you 30 days after they are initially posted on the Site unless you are a new user, in which case they are binding on you immediately.

Acquisitions

If another company acquires 23 Telecom LTD or its assets, that company will (a) process that Personal Data held by 23 TELECOM LTD, and (b) assume the rights and obligations regarding such Personal Data described in this Privacy Policy.

Your rights

RIGHT TO ACCESS AND RECTIFICATION

You have the right to request access to the personal data relating to you. This includes the right to be informed whether or not personal data about you is being processed, what personal data is being processed, and the purpose of the processing. You also have the right to rectify or add personal data if the personal data is inaccurate or incomplete.

RIGHT TO ERASURE

You may also request that your personal data be erased if e.g. the personal data is no longer necessary for the purposes for which it was collected, the processing is unlawful, or the personal data has to be erased to enable us to comply with a legal requirement. There are other circumstances where your personal data can be erased; please contact Us if you would like to find out whether your personal data can be erased (see below for contact details). Please note that We may reject your request if the processing is permitted or required according to law or any other relevant legal ground.

RIGHT TO OBJECT

You are also entitled to object to certain processing or request that the processing of the personal data be restricted if you believe the personal data may not be correct, if you believe the processing is unlawful, or if you believe that 23 Telecom LTD no longer needs the personal data for the purposes stated in this policy.

RIGHT TO DATA PORTABILITY

If you request access to personal data about you that you yourself have provided and if the personal data is being processed automatically with your consent or in accordance with a contract between you and Us, you may request that the data is provided in a structured, commonly-used and machine readable format and you may also request that the personal data is transmitted to another controller, if this is technically feasible.

Contact Information

If you would like to contact us with enquiries or complaints or regarding your rights, limit or opt-out of certain communications, or if you have suggestions for improving this privacy policy, please send an e-mail to GDPR@23telecom.co.uk, or fill out the form in the Contact Us link on this website. Once we have confirmed your identity we will use reasonable commercial efforts to address any concerns that you may have in accordance with applicable law. Please note that even if you object to certain processing of personal data, We may still continue this processing if permitted or required to do so by law, for example to enable us to fulfill legal requirements, or fulfill obligations under a contract with you.