By using our websites, products, services, or otherwise by interacting with Us, you consent to the following privacy policy (“Privacy Policy”). Please do not engage in any of these activities if you do not agree with the terms of this Privacy Policy. The Privacy Policy applies to the processing of personal data carried out by PVA Wireless AB (publ) or any of its subsidiaries (“We”, “Our”, “Us” or “PVA Wireless”).
Your privacy is important to Us. The purpose of this Privacy Policy is to inform you about the information We may gather about you, how We may use that information, whether We disclose it to anyone, and the choices you have regarding Our use of the information We collect.
Information Collected by PVA Wireless
In general, PVA Wireless will collect personal data
from you based upon our business relationship, your use of the Site, Our services and Our
products, as follows:
CONTACT PERSONS AND CONTENT REGISTRATION
In order for Us to communicate and
provide our services to you or discuss the services you may provide Us with, you will provide us
with your contact information and possibly other information about you. Further, in order to
access and view some content on the Site, you are required to register with PVA Wireless before the
content is made available to you. During the registration process, you are required to provide
Us with certain contact information, including your name, address, phone number and email
address. We use this information to contact you about the services We offer in relation to which
you have expressed interest or vice-versa.
CLIENT SUPPORT PORTAL
When you contact PVA Wireless customer support (“Customer
Support”) using any PVA Wireless client support portal (the “Client Support Portal”), We may ask you
for certain information regarding your enquiry, such as your name, email address or telephone
number.
COOKIES
What Are Cookies and How Do I Manage Them?
A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes:
How do the Site and services use cookies?
Our customer support portals use session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows Us to process your online data and requests. Session cookies help Us make sure you are who you say you are after you have logged in. We use persistent cookies, which only we can read and use, to identify the fact that you are an PVA Wireless customer or prior site visitor.
To view the cookies we use and manage you preferences click on the button below.
We also may from time to time engage third parties to track and analyze non-personally identifiable usage and volume statistical information from visitors to our websites to help us administer the websites and improve its quality. Such third parties may use cookies to help track visitor behavior. Such cookies will not be used to associate individual website visitors to any Personal Data (defined below). All data collected by such third parties on Our behalf is used only to provide Us with information on site usage and is not shared with any other third parties.
FORUMS AND BLOGS
If you participate in any blog or other forum offered by
our website or services, your user ID may be displayed on any content that you post and will
therefore be available to the public. Therefore, if you associate your name with your user ID,
your name and any related content or posts may be available to the public. You are solely
responsible for all liability related to your use of any such blog or forum.
CORRESPONDENCE
If you send Us correspondence, such as emails or letters, We
may collect such information into a file specific to you.
MOBILE USER INFORMATION
As part of Our services, We sometimes receive
information from wireless carriers and operators in order to provision the specific content and
data services requested by individual users. All such information is acquired from either the
wireless carrier’s or operator’s website or from the user’s mobile device via the wireless
carrier’s or operator’s network. This data is usually limited to the user’s cell phone number.
In some cases, such as for prize fulfilment for a mobile contest, the user’s mailing address is
also provided. The user must explicitly “opt in” through the wireless carrier or operator in
order for any of this information to be collected and its use is governed by this Privacy Policy
and any policies or procedures of the user’s wireless carrier or operator. In some cases, We may
receive authentication information directly from mobile users, including in the form of a
personal information number (PIN) previously sent to a mobile user.
HUMAN RESOURCES
We collect information about you when you submit a job
application, resume, survey responses or similar information.
NEWSLETTERS
If you wish to subscribe to Our newsletters, We will use your
name and email address to send the newsletter to you. Out of respect for your privacy, you have
the option to unsubscribe from receiving some or all of the newsletters. Please see the
“Opt-out” section below.
How We Use Information
We may use data We obtain as described above for
purposes relating to our website and services, including (a) providing the website and services
to you, (b) facilitating third parties to participate in the provision and improvement of the
website and services (including without limitation mobile network operators, hosting partners,
and other service providers), (c) raising queries with you, and responding to issues you may
raise, whether relating to our services or otherwise, (d) communications relating to surveys and
other customer satisfaction-related activities, (e) progressing job applications, to perform
credit checks and, (f) verification of personal or business data and payment details and other
checks before offering our services to customers.
SERVICE-RELATED ANNOUNCEMENT
We will send you service-related announcements
when it is necessary to do so. For instance, if Our service is temporarily suspended for
maintenance, We might send you an email. Generally, you may not opt-out of these communications,
which are not promotional in nature. If you do not wish to receive them, you have the option to
deactivate your account.
CUSTOMER SERVICE
We will also communicate with you in response to your
customer service enquiries, to provide the services you request, and to manage your account.
Disclosures and Sharing of Information
As a matter of policy, We do not sell
or rent any of your information to third parties for any advertising or marketing purposes.
However, the following describes some of the ways that We may disclose your information in the
normal course of providing Our services.
DISCLOSURE TO OUR SERVICE PROVIDERS
Your personal data may be transferred to
and processed by third party providers and suppliers which perform services for Us (data
processors), to enable these companies to perform the services requested by Company. Only
personal data that is necessary to fulfill the purposes will be provided to these companies. All
third party providers and suppliers must follow Our instructions and applicable written data
processor agreements and any other agreements that are in place between Us and Our third party
providers/suppliers, and must implement appropriate technical and organizational measures for
the protection of the personal data. For a complete list of Our data processors, please click here.
LEGAL REQUESTS & COMPLIANCE WITH LAWS
We reserve the right to disclose
information as required by law or regulation and when We believe that disclosure is necessary to
protect Our rights and/or to comply with a judicial proceeding, court order, or legal process.
Notwithstanding any provisions herein, We may disclose Personal Data to governmental authorities
when required or reasonably requested to do so by such governmental authorities. This Privacy
Policy does not apply to the extent that it is in conflict with any law that may be applicable
to the Personal Data of a Data Subject.
PROCESSING OF PERSONAL DATA OUTSIDE EU AND SWITZERLAND
PVA Wireless processes
Personal Data on behalf of its clients (“Customers”), that has been collected by or on behalf of
those Customers including Personal Data received from the European Union. With the objective to
validate transfers of Personal Data under European data protection laws to countries outside EU
and Switzerland we are making available the European Commission’s controller-to-processor
standard contractual clauses, commonly referred to as “model clauses” (in the form adopted by
decision 2010/87/EU of 5 February 2010 and with Appendices 1 & 2. Any Customer of PVA Wireless who
undertakes processing activities on the PVA Wireless platform (in respect of Personal Data which
is governed by the European data protection laws), should contact DPO@PVA Wireless.com for more details.
DISCLOSURE OF INFORMATION TO PVA Wireless AFFILIATES
Because PVA Wireless is a global
company, We may share your information with other PVA Wireless affiliates and business units in
other parts of the world in order to provide you with Our services. Your Personal Data may be
transferred by Us from your home country to PVA Wireless employees in PVA Wireless offices around the
world, who may communicate with you regarding your enquiry. Please understand that We limit
access to your Personal Data to only those PVA Wireless employees who We believe need access in
order to provide services to you or to otherwise perform their duties.
Data Processor
As Data Processor, PVA Wireless will only process Personal Data
pursuant to the instructions of the applicable Customer (for example where We act as a Data
Processor in relation to the processing activities of Customers on Our platform). PVA Wireless may use
the services of third party Data Processors to process Personal Data in accordance with purposes
identified for such Personal Data by the applicable Customer (including but not limited to the
provision of services). PVA Wireless will not be responsible for determining the authenticity of
any purported Data Subject’s request to access his or her Personal Data. In the absence of
express instructions to do so from the applicable Customer, PVA Wireless will not provide a
purported Data Subject with access to his or her Personal Data unless it is demonstrated to
PVA Wireless’s satisfaction that the applicable Data Controller has refused such access.
Data Controller
As Data Controller, PVA Wireless receives Personal Data about Our
business contacts. PVA Wireless owns and controls such Personal Data as stated in this Privacy Policy.
In parallel and in accordance with Recital 47 of the European Data Protection Directive 95/46/EC
(as amended from time to time of replace by other EU regulation), We shall act as an independent
Data Controller with respect to the processing of Personal Data which is necessary for the
operation of Our service which shall include any information processed for the purpose of the
conveyance of a communication on an electronic communications network or for the billing
thereof.
HIPAA
From time to time, PVA Wireless provides messaging services to health
care providers, and serves as a “Business Associate” (as that term is defined pursuant to HIPAA
Regulations) to such providers in relation to the handling of protected health information
(“PHI”) that is made a part of Our services.
De-identification
PVA Wireless may de-identify or depersonalize data into
anonymized and aggregate data that it derives from Customers (“Anonymous Data”). Anonymous Data
means data that includes no Personal Data or unique identifiers that could later be used to
refer to the Personal Data to which the data was once associated. PVA Wireless uses only Anonymous
Data in performing analyses, and may disclose Anonymous Data to its Customers who have requested
such analyses and to third parties where We are contractually entitled to do so.
This Site is Not for Use by Children
Protecting the privacy of children is
important to PVA Wireless. For that reason, the Site is structured specifically to not attract anyone
under 13, nor do We collect or maintain Personal Data on the Site from those who PVA Wireless actually
knows are under 13. If PVA Wireless learns or is notified that it has collected information from users
under the age of 13, PVA Wireless will immediately delete such Personal Data.
Opt-Out
We provide you the opportunity to ‘opt-out’ of having your Personal
Data used for certain purposes, when We ask for this information. For example, if you register
with Us but no longer wish to receive Our newsletters and/or related communications, you may
opt-out of receiving them by following the instructions included in each newsletter or
communication or by emailing Us at legal@PVA Wireless.com.
Security
We take appropriate technical and organizational measures to guard
against unauthorized or unlawful processing of your Personal Data and against accidental loss or
destruction of, or damage to, your Personal Data. PVA Wireless uses industry-standard security measures
to protect the integrity and confidentiality of any Personal Data it owns or processes on behalf
of Customers, including, in appropriate circumstances, the use of firewalls, restricted access,
and encrypted transmissions. PVA Wireless limits access to Personal Data to those persons in
PVA Wireless’s organization who have a business need to process such Personal Data. However, no
company, including PVA Wireless, can fully eliminate the security risks associated with such Personal
Data. Due to factors beyond PVA Wireless’s control, PVA Wireless cannot ensure that Personal Data will
not be disclosed to third parties. For example, PVA Wireless may become legally obligated to
disclose such data, or, despite precautions, third parties may circumvent security measures to
intercept or access such data.
Disclaimer
We cannot ensure that all of your private communications and
other Personal Data will never be disclosed in ways not otherwise described in this Privacy
Policy. By way of example (without limiting the foregoing), We may be forced to disclose
Personal Data to the government or third parties under certain circumstances, third parties may
unlawfully intercept or access transmissions or private communications, or users may abuse or
misuse your Personal Data that they collect from the Site. PVA Wireless does not review, comment
upon, or monitor its Customers’ compliance with their respective privacy policies, nor does
PVA Wireless review Customer instructions to determine whether they are in compliance or conflict
with the terms of a Customer’s published privacy policy.
Third Parties
Please be advised this Privacy Policy does not apply to the
practices of companies that PVA Wireless does not own or control, or to people that PVA Wireless does
not employ or manage. This includes links to other websites on the Site as well as any companies
from whom you may have ordered services or products that are transmitted over PVA Wireless’s network,
and any companies from whom you may be purchasing telecommunications services. PVA Wireless recommends
that you be aware when you leave the Site and read the terms of use and privacy policies of any
site, product or service that collects Personal Data.
Changes to this Privacy Policy
We reserve the right to modify this Privacy
Policy at any time, so please review it regularly. If We make changes to this Privacy Policy, We
will post the revised Privacy Policy on the Site and other places We deem appropriate. All such
changes shall be binding on you 30 days after they are initially posted on the Site unless you
are a new user, in which case they are binding on you immediately.
Acquisitions
If another company acquires PVA Wireless or its assets, that
company will (a) process that Personal Data held by PVA Wireless, and (b) assume the rights and
obligations regarding such Personal Data described in this Privacy Policy.
Your rights
RIGHT TO ACCESS AND RECTIFICATION
You have the right to request access to
the personal data relating to you. This includes the right to be informed whether or not
personal data about you is being processed, what personal data is being processed, and the
purpose of the processing. You also have the right to rectify or add personal data if the
personal data is inaccurate or incomplete.
RIGHT TO ERASURE
You may also request that your personal data be erased if
e.g. the personal data is no longer necessary for the purposes for which it was collected, the
processing is unlawful, or the personal data has to be erased to enable us to comply with a
legal requirement. There are other circumstances where your personal data can be erased; please
contact Us if you would like to find out whether your personal data can be erased (see below for
contact details). Please note that We may reject your request if the processing is permitted or
required according to law or any other relevant legal ground.
RIGHT TO OBJECT
You are also entitled to object to certain processing or
request that the processing of the personal data be restricted if you believe the personal data
may not be correct, if you believe the processing is unlawful, or if you believe that PVA Wireless no
longer needs the personal data for the purposes stated in this policy.
RIGHT TO DATA PORTABILITY
If you request access to personal data about you
that you yourself have provided and if the personal data is being processed automatically with
your consent or in accordance with a contract between you and Us, you may request that the data
is provided in a structured, commonly-used and machine readable format and you may also request
that the personal data is transmitted to another controller, if this is technically feasible.
Contact Information
If you would like to contact us with enquiries or
complaints or regarding your rights, limit or opt-out of certain communications, or if you have
suggestions for improving this privacy policy, please send an e-mail to DPO@PVA Wireless.com, or fill out the form in the Contact Us
link on this website. Once we have confirmed your identity we will use reasonable commercial
efforts to address any concerns that you may have in accordance with applicable law. Please note
that even if you object to certain processing of personal data, We may still continue this
processing if permitted or required to do so by law, for example to enable us to fulfill legal
requirements, or fulfill obligations under a contract with you.