We collect personal data in a variety of ways, such as when you visit any of our websites, download our apps, interact with electronic advertisement, use our services, make a purchase, contact us and use our customer portal.
Categories of personal data we may collect and process:
The data that is collected we use for different purposes in accordance with the list below. Basically we use the data to provide, perform and improve our services. The legal ground for the processing is stated below.
|How do we use it? (purpose of processing)||Legal basis for the processing|
|To confirm your identity and verify your personal and contact details, provide and market our services, to fulfil relevant agreements with you and to otherwise administer our business relationship with you.||Fulfil our contractual obligations towards you, to comply with applicable laws and to pursue the legitimate interests of Rebtel|
|To conduct payment for services.||Fulfil our contractual obligations towards you, to comply with applicable laws and to pursue the legitimate interests of Rebtel|
|Marketing, product and customer analysis to improve our services and to optimize our offer to customers.||Fulfil our contractual obligations towards you and to pursue the legitimate interests of Rebtel|
|Product and customer analysis for internal operations, including troubleshooting, data analysis, testing, research and statistical purposes.||Fulfil our contractual obligations towards you and to pursue the legitimate interests of Rebtel|
|To carry out risk analysis, fraud detection and risk management, to prevent misuse of the services to keep the services safe and secure.||Pursue the legitimate interests of Rebtel|
|To improve our services and for general business development purposes, such as developing new products and features and explore new business opportunities.||Pursue the legitimate interests of Rebtel|
|To comply with applicable laws and regulations (for example bookkeeping, lawful intercept).||Comply with applicable laws and to pursue the legitimate interests of Rebtel|
|To communicate with you in relation to our services and to provide customer support.||Fulfil our contractual obligations towards you and to pursue the legitimate interests of Rebtel|
|To establish, exercise or defend a legal claim or collection procedures.||Fulfil our contractual obligations towards you, to comply with applicable laws and to pursue the legitimate interests of Rebtel|
We process your personal data in accordance with applicable data protection legislation and regulations. To protect your personal data from unauthorized disclosure or access, misuse, loss, alteration or destruction we have implemented appropriate legal, technical and organizational security measures. The implemented security measures are created to ensure a level of security appropriate to the risks that are associated with our data processing activities. Should you have any questions related to our security measures please contact firstname.lastname@example.org.
We work with carefully selected third-party service providers (or group companies) to operate, provide, improve, understand, customize, support, and market our services. For example, we work with companies to distribute our apps, provide infrastructure, delivery, supply location, prevent fraud or other criminal behaviour, storing data, process payments, help us understand how our services are used, market our services and customer support. In connection herewith, we may share personal data with these service providers and, in some cases, also receive personal data from them.
In addition, we may also share your personal data in the following situations: upon request we may provide authorities (for example the police and the tax authority) with personal data if we have a legal obligation to do so; in order to enforce or apply our Terms of Service and/or any other agreement with you; or to protect the rights, property, or safety of us, our users, or others; and finally in case of a sale of the assets of Rebtel or a group company or corporate restructuring or as a result of a change of control of Rebtel or a group company.
When sharing your data we are dedicated to make sure that the relevant third party shall have appropriate legal, technical and organizational measures to protect and safeguard the personal data in accordance with applicable data protection legislation, relevant supervisory authorities’ applicable regulations and guidelines regarding security of personal data and what is otherwise appropriate.
We promise to never sell your personal data to a third party unless we have your explicit permission to do so.
We prefer to process your data within the EU/EEA. However, in certain cases we do transfer data outside the EU/EEA. Before transferring data outside the EU/EEA we take reasonable measures to ensure that:
Rebtel may use your personal data to communication with you. The communication may include messages about updates, faults, alerts and other types of issues relating to technical aspects and/or the usability of the app and other parts of the services. Such communication is considered part of the service.
Occasionally we may ask you to provide information on your experiences of using the app or other parts of the services which will be used to improve the quality and provision of the services. You are under no obligations to provide any such information. Such information is used for the purposes of reviewing improving our services.
Rebtel may from time to time contact you by email, phone, SMS or through any other appropriate information channel to keep you up to date with news about Rebtel and the services, including new products, campaigns, promotions and payment methods.
If you don’t want to receive promotional messages from Rebtel you can unsubscribe by following the instructions in the promotional message you have received or by contacting our customer support at email@example.com.
We may occasionally send promotional SMS to customers residing in the USA. To cancel these messages text STOP to the number you received the SMS from. If you want to join again, just let us know by sending an email to firstname.lastname@example.org and we will start sending promotional SMS to you again. As always message and data rates may apply for any messages sent to you from Rebtel and from you to Rebtel.
Collected personal data is kept for as long as it's needed for us (however no longer than two years and 10 months after your account was closed) unless we are legally required to keep the data in our records for a longer period. When Rebtel saves data for other purposes than contractual obligations (for example to fulfill book keeping requirements or requirements to keep records of phone calls for lawful intercept) we only keep the data for as long as it's necessary and legal for each purpose.
Under applicable data protection legislation you have the following rights in relation to personal data.
Version: November 2018