PERSONAL DATA PROTECTION POLICY
Yuboto LTD as Processor or Processor asks for and processes the minimum necessary data needed to acquire in order use our Services as well as browsing our Site.
YUBOTO, with a commitment to legality and transparency, manages with absolute respect the personal data communicated to it and the processing operations are limited to the minimum possible and only for the fulfillment of their purposes.
Any processing is done in accordance with the General Data Protection Regulation (2016/679/EU )and in general the current national and European legal and regulatory framework for the protection of personal data.
Katsantoni & Olympias, Metamorfosi Athens, 14452
(+30) 211 114 4111
For any clarification as well as for related requests regarding Personal Data, we have designated a "Data Protection Officer" and you can contact us directly at firstname.lastname@example.org
PURPOSE OF PROCESSING
The purpose of data processing is the smooth execution of telecommunication and subscription services in accordance with the law and service during the contract. This purpose includes:
- Provide the relevant Service you obtained.
- Provision of Technical Support and Customer Service.
- Provision of Pricing and Information Services.
- Provision of Access and Complaint Requests,
- Provision of Information, Balance, Payments and Settlements.
- Compliance with regulatory requirements, including legislation on the protection of communications secrecy and the identification of crimes in cases of requests by public authorities.
- Protect the legitimate interest and function of YUBOTO, your privacy, your security, and effectively address the problems that arise.
For direct marketing purposes, YUBOTO can make decisions or profile, based on automated data processing, if you give your consent.
CATEGORIES OF DATA
For the above reasons, YUBOTO could possibly collect and process:
User IDs: * Name * Surname * Address * Birth Date
Unique User IDs: * VAT * ID Number
User Billing Elements: * Name * Billing Address * Bank Account
Connection Details: * Address to install the connection
User Contact Details: * Phone * Email
Items that can be imported/created by the user: * End User / Recipient Telephone Numbers * Messages History * Messages Statistics
User IDs when browsing: * Address of the connection provider (IP) * Cookie
Data generated during use: * Communication Data * End User Actions
More about the Cookies and Data we process while browsing our Websites can be found here
The transfer of personal data to legal and/or natural persons cooperating with YUBOTO takes place only when it becomes absolutely necessary for the implementation of the services provided to the users or when the applicable legislation requires so.
Data Recipients may be the following:
- YUBOTO and its employees in the framework of their responsibilities.
- Its agents and / or subcontractors for the purpose of supporting, promoting and performing the contract.
- Relevant Public Authorities, including the National Telecommunications Commission, the Communications Integrity Authority and the Judicial Authorities.
- The providers with which we have interconnected the networks to serve the traffic.
YUBOTO partners have agreed and contractually agreed in writing that:
- Keep confidential, like their employees, of personal information they may know.
- Not to transfer data to third parties without the written permission of YUBOTO.
- To take organizational and technical data security measures that protect their logic and physical security.
- Design their systems so that by design and by definition they can be assured that they will be able to fulfill these obligations.
- Promptly inform YUBOTO of any incident relating to the violation of CUSTOM personal data, comply with the legal framework for the protection of personal data and in particular the General Data Protection Act (GDPR) as processors.
YUBOTO undertakes not to sell, rent or otherwise publish or / and disclose visitor / user personal data to any third party for purposes other than the contractual relationship.
DATA RETENTION / DELETION
YUBOTO keeps the data in a physical / electronic file for the entire duration of the contract.
Data for dormant contracts are held for a necessary period for winding-up purposes 14 months after expiry of the telecommunication contract and 2 years for other services unless, under the law, they have been complied with until the final settlement of cases or if it is defined by other legislation period (eg tax provisions). They are then completely deleted without the chance recovery.
TECHNICAL AND ORGANIZATIONAL SECURITY MEASURES
Any data processing in any way is only allowed to authorized persons, employees and partners solely for the purposes mentioned above.
YUBOTO has taken the necessary and appropriate organizational and technical measures for the security and protection of your Data in the context of the Information, Communications and Personal Data Security Policy, in accordance with the ADAE Regulatory Framework, on a standard comparable to a minimum level of protection during concept of the ISO 27001 standard of protection. Furthermore, it holds ISO 9001/2001 quality assurance certification.
These measures shall be reviewed and amended as necessary.
DATA SUBJECT RIGHTS
In any case, the CUSTOMER has the right to information, at the stage of collecting the identity data of YUBOTO, the purposes of the processing, the recipients of the data, any third parties to whom the data is transmitted.
The CUSTOMER has the right to have full access to his / her data. This means that the CUSTOMER has the right to update how and if it is processed in his / her data. The CUSTOMER may request information, in writing or electronically, of the above, has the right to correct inaccurate personal data, the right to delete it (if it is no longer necessary for the above mentioned processing purposes or in case of withdrawal of consent, where applicable) data in mechanically readable form, right to restrict processing (for as long as your processing objections are pending), the right to recall / oppose the processing of the data.
In the event of any objection to processing, YUBOTO will cease processing the data if there are no compelling and legitimate reasons that prevail over the CUSTOMER's right or are no longer necessary for the above mentioned processing purposes.
The CUSTOMER's request is received free of charge without delay, and in any case within (1) one month from the date of receipt. However, if the request is complex or there are a large number of requests, YUBOTO will inform if another two (2) months are to be extended. If the claims are manifestly unfounded or excessive in particular because of their recurrence, YUBOTO may impose a reasonable fee, taking into account the administrative costs of providing the information or executing the requested action, or refusing to respond to the request by giving reasons its answer.
AMENDMENT OF THE PERSONAL DATA PROTECTION POLICY
REQUESTS - QUESTIONS - COMPLAINTS
For any request and exercise of a right, in relation to your personal data and for the provision of specialized information, the CUSTOMER may contact the Service Department electronically by sending it to mail: email@example.com.
The CUSTOMER has the right to file a complaint with the Personal Data Protection Authority (Kifisias 1-3, PC 115 23, Athens, tel. 210 6475600, firstname.lastname@example.org) if he considers that the processing of Personal Data violates the current national and regulatory framework for the protection of personal data.