Basic information on privacy and data protection

• Responsible Entity
TELECOMING S.A.
CIF: A-64067549
Paseo de la Castellana, 95, Torre Europa, Planta 16, 28046 Madrid (España)
• Purpose
1. Managing the contracting of the products selected by the User as well as executing mobile payment services authorized by the User in the contracting of the products / services
2. Sending electronic commercial communications
• Legitimacy
1. Execution of the contractual relationship
2. Legitimate interest
3. Sending relevant information
• Recipients
Will only be accessible to our service providers in order for them to comply with the purposes subject of the processing, as well as to certain Administrations in the case of a legal obligation therefor.
Data may be communicated to Group entities for administrative purposes.
• Rights
Access, rectification, deletion, opposition, processing limitation and data portability

PRIVACY POLICY

1. IDENTIFICATION.

• Owner: TELECOMING S.A (hereinafter, “TELECOMING”)
• CIF (Tax ID number): A-64067549
• Company registered office: Paseo de la Castellana 95, Edificio Torre Europa 28046, Madrid (España)
• Data Protection Officer (DPO): The User can contact DPO by a letter addressed to DPO above mentioned registered office, to the attention of “Data Protection Officer”.
• E-mail: privacy@telecoming.com

2. INFORMATION AND CONSENT.

TELECOMING commits to observe your privacy and ensure the protection and security of your personal data. Therefore, we inform you about the way in which we collect, process and protect the personal data that you may be willing to provide to us.
Consequently, you need to read carefully this privacy policy which has been written in a clear and simple way so as to enable you to understand it and thus decide freely and voluntarily if you wish to provide your personal data to TELECOMING.

3. OBLIGATION OF DATA PROVISION.

The data requested in the forms provided on the web site are, in general, mandatory (unless specified otherwise in the required field) for accomplishment of the established purpose. To the contrary, however, the result may be the impossibility to provide the service to the user.

4. WITH WHAT PURPOSE WILL THE COMPANY PROCESS THE USER’S PERSONAL DATA AND FOR HOW LONG?

Your collected personal data will be processed by TELECOMING in conformity with the following purposes:

• Managing the contracting of the products selected by the User.
• Managing subscription plans selected by the User.
• Performing mobile payment services authorized by the User at contracting the products / services.
• Managing, conducting and giving answers to the petitions, demands, incidences, complaints, claims or Users’ consultations as well as managing the refunds.
• Maintenance, support and updating of the web site. Resolution of possible technical incidents or of those of any other nature that may arise in relation to the web site.
• Draw-up of anonymous statistical reports on access habits and the activity developed by users on the web site.
• Evaluation of the User’s candidacy and, if applicable, its incorporation into the selection processes that fit his profile, if he submits his Curriculum Vitae via form / e-mail. – Sending relevant information

5. WHAT DATA WILL WE PROCESS?

We will be processing the data that we will seek from you and, in any case, those indicated as mandatory for contracting the product selected by the User, such as among others:

– Identification data such as the name and surname, address, telephone number, email address.
– Location data through IP’s, such as browser, device and operating system.

In the event that the User provides data of third parties, he / she declares to have their consent and undertakes to transfer the information contained in the Privacy Policy to the interested party, owner of said data, exempting TELECOMING from any responsibility in this regard. However, TELECOMING may carry out the necessary verifications to verify this fact, adopting the appropriate due diligence measures, in accordance with current regulations on data protection.

6. WHAT IS THE LEGITIMACY OF DATA PROCESSING?

The legitimacy of dealing with the data will be:

– Execution of a contract for:
o contracting of any of the products offered through the web page is execution of a contract as well as, where appropriate, for the request and management of reimbursements.
– User’s consent to:
o management of queries, requests for information, complaints and claims, receiving relevant information.
– Legitimate interest of TELECOMING in:
o Draw-up of anonymous statistical reports
o Sending Communications for marketing purposes related to products and services of TELECOMING for its clients.

You may revoke your consent given to any of the dealings provided such consent shall not affect the lawfulness of the processing previously carried.

To revoke the consent, the User may contact TELECOMING through the following channels: privacy@telecoming.com.

7. WHO THE DATA WILL BE SHARED WITH?

User’s data may be communicated to:

• TELECOMING suppliers, being the said access necessary for adequate meeting of legal obligations and/or the provision of services for the aforementioned purposes. The said suppliers will not process your data for their own purposes that have not been previously informed by TELECOMING.
• Data may be communicated to Group entities for administrative purposes.
• Public administrations, in relation to the competences attributed to them.

8. FOR HOW LONG WILL WE KEEP USER’S DATA?

The data will be processed during the time necessary to accomplish the indicated purposes, differentiating between the data necessary for the contracting of products and services, as well as for the collection thereof, of those processed for reasons of publicity or customer service, unless the User requests his withdrawal from TELECOMING, opposes or revokes his consent.

9. RESPONSIBILITY OF THE USER.

The User:
• Guarantees that his/her age is over 18 and that the data provided to TELECOMING are true, accurate, complete and up-to-date. For these purposes, the User is responsible for the truthfulness of all communicated data, and will keep the provided information updated so as to reflect his/her real situation.

• Guarantees to have informed third parties from whom he/she provides your data, if appropriate, of the aspects contained in this document. Likewise, he/she guarantees to have obtained your authorization for providing your data to TELECOMING for the mentioned purposes.

• Will be responsible for false or inaccurate information provided through the web site and for damages, direct or indirect, inflicted to TELECOMING or to third parties thereby.

10. COMMERCIAL AND PROMOTIONAL COMMUNICATIONS.

One of the purposes for which TELECOMING processes personal data provided by Users is to send them electronic communications with information regarding products, services, promotions, offers or relevant news for Users. Whenever any communication of this type is made, it will be addressed solely and exclusively to those Users who have expressly authorized the sending of such communications.

In the event that the User wishes to stop receiving commercial or promotional communications from TELECOMING, he/she may request cancellation of the service by sending an e-mail to the following e-mail address: privacy@telecoming.com or indicating it by means of the option of withdrawal provided in each of the commercial communications that is sent.

In the same way, you can oppose and / or revoke the consent and for this purpose you will be informed in each of the commercial communications sent to you of the means by which you can do it.

11 EXERCISE OF RIGHTS.

The User may at any time and free of charge send a letter to the address indicated in the heading of this Policy or send an e-mail to the address privacy@telecoming.com with the Reference “Data Protection”, attaching a photocopy of his identity document, to:

• Revoke the granted consent.
• Obtain confirmation of whether at TELECOMING are processed personal data concerning the user or not.
• Access your personal data.
• Rectify inaccurate or incomplete data.
• Request deletion of your data when, among other reasons, the data are no longer necessary for the purposes they were collected for.
• Obtain from TELECOMING the limitation of data processing when any of the conditions provided in the data protection regulations is met.
• Obtain human intervention, to express your point of view and to challenge the automated decisions adopted by TELECOMING, in the cases foreseen in the regulations.
• Seek portability of your data in the cases envisaged in the regulations.
• File a complaint regarding the protection of your personal data with the Spanish Agency for Data Protection at the address Calle de Jorge Juan, 6, 28001, Madrid,

12. SECURITY MEASURES.

TELECOMING will process the data of the User at all times in an absolutely confidential manner and keeping the secret thereof, in accordance with the provisions of the applicable regulations, adopting the necessary technical-organizational measures to ensure the security of your data and to help avoid their alteration, loss, processing or unauthorized access, taking into account the state of the technology, the nature of stored data and the risks they are exposed to.