Primetel’s Privacy Policy

     Privacy Policy

     1. Introduction

    1.1. This Privacy Policy (this “Policy”) describes how PrimeTel PLC (“PrimeTel” or “We”) will treat any personal information and/or data provided  by PrimeTel subscribers or visitors of the Website.

    1.2. We are aware that there is a great deal of concern about how personal data is dealt with and we are committed to protect, respect and safeguard the privacy of any personal data you may be requested to provide us during your collaboration with PrimeTel. PrimeTel will keep and handle your personal information according to the legislation applicable at the time and we will use reasonable measures to protect your Personal Information and keep it confidential.

    2. Personal Information collected:

    The information we collect about you and the way it is collected may vary according to the products and services you use and you have registered, the relationship you have with us even if you are not a customer and the type of information we have gained from a third party on condition of consensus to share it with us (hereinafter referred to as “Cooperation”).

    In the course of our collaboration, you may be requested to provide PrimeTel any personally identifiable data (“Personal Information”) to be kept and submitted by PrimeTel, such as:

    2.1. Name, address, phone number, email address, date of birth and gender;

    2.2. Credit or debit card information, bank account number and sort code or other banking information;

    2.3. Information about your account or subscription with us, such as dates of payment owed and received, TopUp information, the subscription services, information regarding the traffic data of your account with PrimeTel or any other information related to your account;

    2.4. Calling Data

    2.5. Your access codes, which are given by PrimeTel during the provision of services;

    2.6. The level of service you receive;

    2.7. The date, time and length of your internet browsing, and your approximate location at the time of browsing.

    2.8. Our conversations, such as recording of phone calls with our contact points, letters by e-mail or by mail and any other way of communication.

    2.9. Your location data. This may be accurate when using GPS data or by locating nearby mobile telephony networks and Wi-Fi access points and enabling location-based services or features. Location data will be less accurate where, for example, a location comes from your IP address or your data, such as a zip code or the name of a region or city.

    2.10. Your preferences for specific products, services and lifestyle activities, when you inform us what they are or we assume what they are, based on how you use our products and services.

    We also receive information regarding the use of our products and services, such as:

    -The level of services you receive, e.g. faults and other events that may affect service delivery.

    -Information about using a specific service or product, e.g. when you are using your mobile phone, a file is created that includes duration, time and general location of the phone call or message. However, we do not maintain the content of your call or messages.

    3. PrimeTel collects Personal Information of its Subscribers in the following ways:

    (i) On a personal basis, during the performance of a contract or during the process of examining a candidate Subscriber’s application for the provision of our services and products.

    (ii) By telephone or in person in our branch during the communication between the candidate subscriber and PrimeTels’ employees.

    (iii) Through the use of our website and other electronic programmes and social media.

    (iv) By post or electronic mail.

    (v) By completing any questionnaires and/or documents, for research purposes aiming at the improvement of our services.

    (vi) Through participation of the Subscriber or Visitor in any competition organised by PrimeTel, from time to time.

    (vii) By third parties with whom PrimeTel collaborates and Public Offices.

    (viii) When your information is published

    (ix) When you are a customer of any company that has been purchased by PrimeTel

    (x) By signing up for newsletters, notifications or other services from us.

    We also receive personal information from third parties in other cases permitted by law, such as for exclusion of fraud, bankruptcy register etc

    When you visit our stores you may be filmed, as there is a closed surveillance system for security purposes.

    We use cookies (small text files stored in your browser). For more details regarding cookies  and how to opt out of these, see the “Cookies” section of the web page.

    4. Using Personal Information

    Personal Information submitted to or collected by PrimeTel will be used for the purposes specified in this Policy. Indicatively PrimeTel may use the Personal Information for the following purposes:

    4.1. Supply Subscribers goods or services of Primetel;

    4.2. Send statements, invoices and payment reminders to Subscribers and collect payments from them;

    4.3. In order to update the Subscribers with any promotions, news,  competitions or developments, we send promotional materials or details by SMS to mobile phones, e-mail or post, provided that the Subscriber has given his prior written consent to Primetel to receive such information;

    4.4. Send email notifications that Subscribers have specifically requested;

    4.5. Respond to any questions or concerns of the Subscribers or/and interested parties regarding Primetel’s network, products and/or services;

    4.6. Understand how Subscribers and/or interested parties use Primetel’s network, products and services in order for Primetel to develop new offers, products and services and improve PrimeTels’ services to make sure that they are as useful and enjoyable as possible;

    4.7. To provide targeted advertising on the Internet and on websites of the group PrimeTel based on the use of cookies. PrimeTel may also combine the data collected from cookies with other data collected under this policy. If you do not wish us to collect data based on cookies, refer to “Cookies” section of the web page. We clarify that if you do not wish any information processed through the use of cookies, you will still receive ads that are not related to your own preferences.

    4.8. Contact Subscribers in order to invite them to form part of Primetel’s consumer panel or research groups about its products and services;

    4.9. Detect and prevent any possible fraud or other illegal acts, recover debts or trace those who have outstanding balances with Primetel.

    4.10. Provide Roaming Services to improve your roaming experience, to comply with our fair use obligations as well as to identify and resolve possible fraudulent use of our networks.

    4.11. To protect our network and manage volumes of calls, messages and other possible uses of our network.

    4.12. To understand how you use our network, products and services so that we can review and improve them, develop more interesting and useful products and services and personalize our products and services.

    PrimeTel may process the data that will be necessary for the proper provision of services to customers and for the fulfilment of its obligations to all competent bodies.

    5. Protection of Personal Information

    5.1. PrimeTel will not make your Personal Information available to any third party unless permitted or required to do so by the applicable legislation and it shall not sell or transfer any of this information to any third party.

    5.2. PrimeTel will store your Personal Information for as long as permitted by Law. If there is no legal requirement, the Personal Information will be stored only for as long as PrimeTel deems appropriate in its sole discretion.

    5.3. In case PrimeTel processes Personal Information for which the Subscribers and/or Visitors’ consent is required; it shall seek their express or written consent.

    5.4. In case PrimeTel processes Personal Information for the processing of which the authorization of the Commissioner of Personal Data Protection is required, such authorization shall be obtained before any processing takes place.

    6. Processing of Personal Data

    6.1. We process personal data of our Subscribers according to the provisions of the General Data Protection Regulation of the EU (Regulation 2016/679), and from the time-to-time applicable national legislation relevant to the protection of personal data.

    6.2. The reasons and purposes of processing of Personal Data are the following:

    6.2.1 Implementing our contractual obligations and providing services to PrimeTel’s Subscribers.

    6.2.2. For the protection and security of PrimeTels’ subscribers.

    6.2.3. For investigating and reporting any illegal actions.

    6.2.4. For the proper conduct of PrimeTels’ operations.

    6.2.5. For the effective promotion of Primetels’operations.

    6.2.6. To protect PrimeTels’ rights.

    6.3. The processing of Personal Data by PrimeTel will always rely to one or more of the following legal basis:

    6.3.1. For the execution of a contract between the Subscriber and PrimeTel, or during the process of examining a candidate Subscriber’s application for the provision of our services and products. E.g. in order for you to make calls and send messages, and to use the internet from your mobile phones, PrimeTel has to process the numbers you are calling, the amount of data you use and when you use them, so we can provide connectivity. This allows us to issue your account, based on your personal use. PrimeTel also needs to carry out credit checks when you apply for a product or service.

    6.3.2. Complying with any legal obligation, such as accounting and tax audits, under which retention periods are set, and are subject to rigorous internal policies and procedures.

    6.3.3. Protection of Primetels’ legitimate interests, e.g. prevent possible fraud, maintain the security of our network and services, and improve our services. In this case, we make sure that PrimeTel’s legitimate interest does not exceed your rights. In addition, in some cases you reserve the right to object to the processing. For more information, see Article 9, Rights Regarding Personal Data.

    6.3.4. Subscribers’ consent, where PrimeTel cannot rely on one of the above reasons. Subscriber can revoke consent at any time. For more information see Article 9, Rights Regarding Personal Data.

    6.4. PrimeTel will keep in electronic or any other form, one or more personal data files, where the subscribers’ personal data will be submitted. The personal data files may contain sensitive data, which have been or will be declared from the subscriber to PrimeTel, together with all personal data that will be developed during the collaboration with and the provision of services by PrimeTel.

    7. Time and place of information Retrieval

    7.1. The personal data processed by PrimeTel will be kept in the Republic of Cyprus and all necessary measures will be taken in order to safeguard all relevant information.

    7.2. PrimeTel keeps and processess the Subscribers’ personal data for as long as there is a subscription.

    7.3. Upon termination or interruption of our collaboration by any way, the maintenance and processing of personal information may be continued for a period up to two years unless otherwise deemed necessary for any legal obligation of PrimeTel.

    7.4. In the event Primetel cannot delete your data for legal, regulatory or technical reasons, PrimeTel may keep your data for longer than two years.

    7.5. Regarding personal data of candidate subscribers, with whom PrimeTel does not proceed to an agreement for the provision of services, PrimeTel will keep the personal data for two years starting from the date of notification of the decision not to proceed to the cooperation.

    8. Automated Decision Making Process, Including Profile Making

    8.1  In carrying out its work, PrimeTel can make decisions based solely on automated processing.

    9. Rights regarding Personal Data

    9.1. The following are your rights in accordance with the provisions of the General Data Protection Regulation of the EU (Regulation 2016/679) and the applicable local law on your personal data:

    9.1.1  Right of access – You have the right to receive confirmation as to whether or not your personal data is being processed and, if so, you have the right of access to that information. The above right also includes the right to receive a copy of the data that is retained and processed.

    9.1.2    Right of Correction – You have the right to claim the correction of any incomplete and / or inaccurate personal data that we hold for you.

    9.1.3  Right of Deletion – You have the right to request the deletion of your personal information and PrimeTel is obliged to delete such personal data without unjustified delay if one of the following reasons applies:

    9.1.3.1 The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

    9.1.3.2 If the processing is based on your consent and you have withdrawn such consent and there is no other legal basis for processing; and

    9.1.3.3 Your personal data was illegally processed

    9.1.4    Right of Objection – You have the right to oppose the processing of your  personal data unless there are mandatory legitimate processing grounds that override your interests, rights and freedoms

    9.1.5    Right to Restrict Processing

    9.1.6    Right to Data Portability – You have the right to request the transfer of your personal data to another company.

    9.1.7 Right of Objection in Automated Individual Decision Making – In the event of automated processing of personal data and decisions based solely on it, you have the right to request that you will not be submitted to a decision taken solely on the basis of an automated processing which produces legal effects concerning you or affects you significantly in a similar way.

    9.1.8 Right to withdraw consent – In the event of any processing is based solely on consent received by you, you have the right to withdraw your consent at any time. It is noted that any recall does not affect the lawfulness of the processing that was based on your consent before it was withdrawn by you or any processing is done on any other legitimate basis of processing.

    For more information and in order for you to exercise any of your rights, please contact the Primetel’s Data Protection Officer at dpo@prime-tel.com. PrimeTel will carefully examine any request regarding the exercise of your rights  and will follow and handle in a timely manner such request based on your rights as well as the rights and obligations of PrimeTel.

    PrimeTel will always respond appropriately to whether and how long it may need to implement your request in full or in part, taking into account all relevant elements and obligations underlying it.

    Please be advised that you also have the right to submit a complaint to the Privacy Commissioner in case PrimeTel fails to respond to your request.

    10. Transmission of Personal Data

    10.1. During the fulfilling of our contracting and legal obligations, PrimeTel may transfer your data to third parties such as:

    10.1.1. PrimeTel Service Providers

    10.1.2. Public and regulatory authorities to the extend PrimeTel is obliged by the Law.

    10.1.3. External consultants, such as legal consultants, auditors, accountants and marketing consultants.

    10.1.4. Third parties to promote joint services. Third parties are responsible for implementing the law.

    10.1.5. Third parties with which we collaborate for promotional purposes, e.g. Facebook.

    10.1.6. Third Parties and / or Affiliates. When you purchase products or services of PrimeTel, from a third party or a Partner, we need to exchange information with them for your account management, such as seeing your order and paying off the Third Party and / or Partner.

    In the event that PrimeTel has a contractual relationship with a service provider or other partner providing services on behalf of PrimeTel and therefore has access to your personal data, PrimeTel does not authorize the partner to use or to disclose your personal data in any other way beyond the provision of its services.

    10.2. Any transfer of personal data will always take place after all necessary security measures have been taken, the full control of personal data processors and third party’s assumption of confidentiality obligation and protection of the personal data that they will receive. Please note that third parties are responsible for the application of the applicable data privacy laws, including without limitation the Privacy Policy.

    10.3. Mergers and Acquisitions
    In the event of a acquisition from another organization or reorganization, your personal data will be transferred to this organization.

    10.4. Third party products that you buy through your PrimeTel account.

    When you buy a product or a third party service through your PrimeTel account, the contractual relationship is between you and the party selling this product or service. PrimeTel only charges the amount directly to your account as part of the agreements with the seller (or a third party authorized by the seller). As part of this, you agree that PrimeTel may transfer certain personal information to these parties to complete your purchase.

    11. Transmission of Personal Data to Third Countries

    11.1. In the event that the transmission of your personal data to a third country will be necessary, the processors in third countries are required to comply with the European Data Protection Obligations and provide all appropriate safeguards for the transmission of personal data. The transmission if and when it should take place will be carried out in accordance to the procedure in article 46 of the General Data Protection Regulation of the EU (Regulation 2016/679).

    12. Changes to this privacy policy

    PrimeTel reserves the right to amend this Privacy Policy at any time by posting the amended policy on its Website. Unless otherwise stated.

    13. Applicable Laws and Jurisdiction

    This Policy shall be governed by and interpreted according to the laws of the Republic of Cyprus and any dispute shall be resolved by the competent courts of the Republic of Cyprus.

    14. Miscellaneous

    14.1. This Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

    14.2. This Policy applies only to the Primetel PLC website and not to other organizations. We are not responsible for the privacy policies of such third parties.

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