Privacy Policy

This Privacy Policy will be effective as of December 10, 2018.

What This Policy Covers

We respect the confidentiality of your personal data and take measures to safeguard it. This Policy describes the information we collect, how we use that information, our legal basis for doing so, and your rights regarding the information we collect. We also use cookies and similar technologies, as described in our Cookie Policy, which is an integral part of this Privacy Policy.

Who We Are

When we refer to “we”, “our” or “us” in this Policy, we mean the company Telecommunication Technologies LLC, which acts as a controller of the information that is being collected from you. We list our contact details, as well as the contact details of our EU representative, at the end of this Policy.

What We Collect

In the course of our business activities, we collect certain personal data as described below.

• Information you provide by filling out forms on our websites. When you fill out forms on our websites, we collect the information that you enter in these forms, which includes your name, email and postal address, telephone number, country of residence.
• Information you provide when entering into a contract with us or otherwise request our services. We collect your name, email and postal address, telephone number, country of residence, MAC address and serial number of your device that you provide to us in the process of negotiation, execution or performance of contracts (e.g. supply or technical support).
• Information we collect when you visit our websites. We may collect information about your device and how you use our website, including IP address; the type of device you are using; platform type; operating system version; mobile device’s identifiers; your browser type and language; URLs of websites that you visit; the number of clicks on an web page; the amount of time spent on web page; pages viewed on our website.
  
  We use cookies and other similar technologies to collect such data. We may use third-party services, such as Google Analytics, that collect, monitor and analyze this type of information in order to increase the functionality of our website, and Google AdWords to optimize the delivery of ad content specifically targeted to your interests based upon previous visits to our website. You can opt out of being included in Google Analytics and Google AdWords here and Hothar here.
  
  You can also set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Lawful Basis and Use of Collected Information

We process personal date based on several lawful grounds:

• Performance of the contract we have with you. This also includes negotiation of a prospective contract. We use your personal data to provide you goods and services under the contract, communicate with you regarding the contract and otherwise exercise our rights and perform obligations related to the contract.
• Our legitimate interests. We use personal data collected from you to realise and protect our legitimate interests as follows.
  
  We use identity, device, and location information collected when you visit our website to prevent fraud and abuse and to prevent security breaches.
  
  We use cookies on our websites to analyse how users interact with our websites so that we can understand where they need to be improved in order to enhance the quality of the online experience of the websites visitors; to record and remember data such as language and cookie choice; to serve targeted advertising based on your interaction with our websites and our brands. The information used for this purpose comprises your browser type and language; IP-address; location; cookie choice; URLs of websites that you visit; the number of clicks on a web page; the amount of time spent on web page; pages viewed on our website.
  
  We use your personal data (name, email) for direct marketing purposes to provide you with the best offers and current information on our business activities if you have filled out the forms on our website and submitted this information to us or otherwise have requested our services.
  
  We also use social plugins ('buttons') of social networks such as Facebook, LinkedIn, Twitter, and YouTube to allow for smooth interaction with these platforms.
  
  We use your personal data, in particular device and location identification, to protect our intellectual property rights and prevent counterfeiting of our products.

How We Share Information We Collect

We do not normally share with third parties personal information we collect. However, in some cases, we may share the information where it is necessary or obligatory.

• Service providers. It may be necessary to share some of personal information with third-party service providers (e.g. delivery or payment processing services). We may share this information solely to the reasonably necessary extent (e.g. to deliver products in the course of performance of a contract).
• Affiliates, successors and assigns. We may share personal information with our affiliated companies in the course of normal business activities (e.g., where it may be necessary to perform a contract). Personal information may also get into possession of another controller as a result of a merger, acquisition or another business transaction. We will inform you of this in advance and ensure that your personal information is secure.
• Legal requirements. We may share personal information to comply with law or law enforcement, to prevent fraud or abuse, or to protect our legal rights and interests.

How Long We Keep Information

How long we keep information we collect about you depends on the legal basis and purpose for which the information has been collected and is being stored. After such time, we will either delete or anonymise your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

• Performance of a contract. If the information has been collected on the basis and for the purpose of negotiation, conclusion or performance of a contract between you and us, then we will keep this information during the period of negotiations of the contract and, if the contract is entered into, during the contract performance or its effective term. We may also continue to keep this information for five years after the end of the contract negotiations or for five years after the expiration or termination of the contract in case any legal dispute occurs and to the extent it may be necessary to protect us from any legal claims.
• Legitimate interests. The information collected on the basis of our legitimate interests may be kept by us as long as we continue to pursue these interests. For example, if the information has been collected for the purpose of direct marketing, then we will keep this information as long as we continue to promote our products and services. You may notify us at any time that you object to your data being used by us for direct marketing, and we will expeditiously stop use of your information for this purpose. We may continue to keep some of this information for five years after we stop its use in case any legal dispute occurs and to the extent it may be necessary to protect us from any legal claims.

Your Rights

Data subjects residing in certain countries, including the EU, are afforded certain rights regarding their personal information. However, these rights are not unlimited and are subject to exceptions and exemptions. To exercise your rights, you can contact us at our email dataprivacy@infomir.com. These rights include:

• Access to your data. You can clarify whether your data is being processed and ask us for a copy of your personal data in machine-readable form.
• Change or correct your data. You can ask us to change, update or fix your data in certain cases, particularly if it is inaccurate.
• Restrict processing or delete your data. In some cases, you can ask us to restrict processing of your data or delete all or some of your personal data.
• Object to processing. If you believe that the collection or processing of your data is unlawful on grounds related to your situation, you can object to such collection or processing.
• Data portability. In certain cases, you can transmit your data collected for to another controller or ask us to transmit your data to another controller.
• Opt out of communications. You can opt out of receiving promotional communications from us by using the unsubscribe link within each email.
• File a complaint with a supervisory authority. You may have the right to file a complaint with a relevant supervisory authority if you believe that your data protection rights are being infringed.

How We Protect Personal Data

While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others. We will respond to requests about this within a reasonable timeframe.

Our Policy Towards Minors

We do not knowingly collect personal information from natural persons under 18. If we become aware that a natural person under 18 has provided us with personal information, we will take steps to delete such information. If you become aware that such a person has provided us with personal information, please contact us promptly.

Changes to Our Privacy Policy

We may change our Privacy Policy from time to time. We will inform you in advance to your email address of any changes and their effective date.

Contact Information

If you have any questions or complaints regarding this Policy or you want to exercise your data protection related rights, you can communicate with us at the email address dataprivacy@infomir.com or by post at the addresses below:

Controller:

Telecommunication Technologies LLC
1 Mytna Square
Odesa 65026
Ukraine

EU representative:

Infomir OÜ
Rävala pst. 8, kabinet A312
Tallinn 10143
Estonia