Privacy Policy

Last updated: 27 February 2019

Preamble

This Privacy Policy governs privacy of the users (“User”, “You”, “Your”) of the https://cash4sms.today website (“Website”) provided by TELENUMBERS HOLDINGS LTD (“Company”, “We”, “Us”, “Our”) and applies to any personal data (“Data”), collected, used, processed, and stored by us or provided by you in relation to your use of this Website and our Services (“Services”), and explains your rights in that regard.

We respect your privacy, protect it and take it very seriously and in accordance with applicable law and regulations. Please, read this Privacy Policy carefully. 

By visiting and using this Website and our Services, you accept and agree to this Policy, abiding by this Policy provisions enclosed herein.

The User is also responsible for being acquainted with any amended or updated version of our Privacy Policy placed on our Website. The provisions of updated versions shall apply from the date of publication, unless otherwise expressly stated.

Controller

To comply with the applicable data protection laws, the EU General Data Protection Regulation 2016/679 as of 27 April 2016 (GDPR), together with the Cyprus LAW 125(I) of 2018, and any implementing legislation, we are the Data Controller responsible for your personal Data collection and processing. Our company has appointed the Data Protection Officer (DPO), who can be contacted by details indicated in the Contacts section of this Policy. 

This Policy is incorporated into our Terms of Use and applies to the Data obtained by us through your use of the information, software, products and services made available through our Website.

What Data and When the Data are Collected

We collect the Data given to us by you when you specifically decide so, the Data collected automatically, and the Data obtained through concluded contracts.

We may collect the following Data in cases, as follows:

  • Identity Data (name, username or similar identifier) and Contact Data (billing/payment address, delivery address, email address, phone numbers), when you contact us through the Website, email, phone, post, any other means; when you register, complete contact forms, sign up to newsletters;
  • Financial Data (payment card details, bank account details, activity log, billing, payment methods, etc.), when you use our services;
  • Technical Data (IP address, login, web browser type and version, time zone, location, OS, data from your devices when you use Android and/or IOS mobile apps, and other technology on the devices you use to access our Website, the address of the website from which you linked to our Website), when you connect to our Website;
  • Usage Data (date of your visit, times and frequency of visiting our Website, preferences, interests, favourites, and other characteristics of your use of our Website), when you connect to our Website.

We do not wilfully collect personal Data relating to children. If you are under the age of 18, do not use our Website. In case of account registration with our Company and personal Data submission by a person under 18, please notify us by details stated in the Contacts section of this Policy and we will remove the Data and rescind such person's account.

We do not collect data from third parties, except for cases where we are represented as a party to Data processing (eg, as a service provider, through agent(s), partners, etc.)

You represent and confirm to provide us with only true and authentic information.

Please, be noted that if you directly disclose your personal Data, including your sensitive financial Data (e.g., plastic card details) and sensitive Data in terms of the GDPR as per Article 9(1) (i.e., special categories of personal data, e.g., among others,  racial or ethnic origin, political opinions, religious beliefs, health, sexual orientation, trade union membership, etc), through public features, this information may be collected and used by other persons.

The Data Storage Security

We process personal Data, including sensitive data if provided and where applicable, handled strictly confidential and in accordance with the industry standards and internal security policies.

Our employees responsible for your Data security are highly trained and legally obliged to keep confidential the information they access. Such employees will process your personal Data confidentially and strictly in accordance with our instructions.

Our Company adheres to appropriate telecommunications and IT industry standards, applicable law and regulatory requirements.

We will keep your Data secure, using technical and organisational arrangements to safeguard your Data (e.g., the user account access is controlled by password and unique username; the Data are stored on secure servers, etc).

We have taken appropriate security measures for your personal Data, which enable to protect our User’s Data against accidental loss, unauthorised access, use, destruction, alteration, disclosure; to manage third party risks, through use of contracts and security reviews; to ensure business continuity and disaster recovery; to train our personnel on Data security, and other organizational arrangements.

Our technical arrangements include measures to deal with any suspected Data breach, where applicable, with due notifications of our Users and/or competent authorities.

To use our Website functions, you may or will be required to submit certain Data, including passwords. You are responsible for keeping your passwords and similar security information safe and confidential.

We stick to any security measures, however any downloadable documents, software or media obtained through our Website are provided to you at your own risk.

We strive to do our utmost to protect your Data, however please note that information provided through the Internet is not absolutely secured and, therefore, is carried out at your own risk and discretion, whenever and wherever that is beyond our reasonable control. Please, notify us of an unauthorized access to your account or any other breach of security straight away by contact details indicated in the Contacts section of this Policy.

The Data Retention

Unless a longer retention period is required or permitted by law, we will hold your Data on systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request us to delete/erase your Data (under the “right to be forgotten” as per GDPR). However, please mind that even if your Data are deleted/erased, it may persist on backup or archival media for legal, tax or regulatory purposes. Please, also note that deletion/erasure will be fulfilled without undue delay, however there might be some latency in deleting your Data from our servers and backup storage.

The Legal Basis For Data Processing

The legal basis for us to process your personal Data shall be based on the grounds as follows:

  • Consent: when you explicitly agree for us to process your personal data for a specific purpose (e.g., cookies acceptance, account registration, newsletters and notifications receipt, advertising and marketing, transaction execution, etc).
  • Contract: when processing is necessary for contractual obligations.
  • Legitimate interest: this basis may be used by us for the purposes of preventing fraud, for direct marketing purposes, for commercial interests, etc.
  • Legal obligation: when processing is necessary for you to comply with the law or as a statutory obligation, not a contractual obligation.

The Purpose of Data Use and Processing

The Data are processed to the extent of legal basis stated above, as well as for the purpose of identification/verification of our customers, to provide our Services, to customize our Website content to make it in line with your interests and our Services, etc.

Upon the account registration on our Website, your Data will be also processed for the purpose of notifications (about eventual changes in the Services we provide to you, in contract, in ToU and our policies and procedures, etc.)

We can and/or will also use and process your Data for advertising newsletters and direct marketing notifications, after you give us your consent by ticking the box for the advertising and marketing notifications receipt confirmation. Where your data is processed for that purpose, you have the right to object to such processing, whether with regard to initial or further processing, at any time and free of charge. To exercise your right to object to the Data processing for advertising and marketing purposes, including both initial and further processing, the User can notify us about it by contact details indicated in the “Contacts” section. Further processing for advertising and marketing purposes can be also objected by clicking "unsubscribe" in the notification.

We also process your Data to ensure the Information Security, so that to prevent unauthorised access to your Data.

We can use your personal Data, including but not limited to, in order:

  • to identify/verify your Data for the purpose of managing our customer relationships and observing (if applicable) the Know Your Client (KYC) rules;
  • to comply with legal and regulatory obligations with respect to any illicit or criminal activity;
  • to keep our Website safe and secure;
  • to run our Website and render our Services appropriately;
  • to screen the use of our Website for overall statistics;
  • to send you welcome email following registration procedures and our Services updates;
  • to maintain accuracy of our records, etc.

The Data processing based on your consent may be terminated due to your consent withdrawal. You can withdraw your consent at any time notifying us by contact details indicated in the Contacts section of this Policy.

You may also subscribe or unsubscribe of our mailing services, contacting us by our contact details or through the details provided in that message.

We also use the information collected by cookies, to improve your use of our Website.

Use of Cookies

We will use cookie files and tracking technologies to store and manage our User’s preferences on our Website and analyse the User’s Data and usage data. Our Cookies Policy envisage the information on what types of cookies and technologies we use, why we use them and how you can control and manage them.

You can set your browser to refuse all or part of browser cookies. If you refuse or opt out of cookies, some features or information on our Website may not operate in a proper manner.

The User’s Rights

You have the following rights (“data subject rights”) in relation to your Data and you may make enquiries to exercise any of your rights mentioned below, as follows:

(i) right to access - the right to request copies of the information we hold about you at any time, as well as the right to request us to modify, update and/or delete such information;

thereupon, we will not charge you for providing your access to your personal Data, and we will not refuse to act on your request, provided that your requests are reasonable, justified and well-grounded, as stipulated in the clause 5 of the Article 12 of the GDPR;

(ii) right to rectify - the right to have your Data corrected if it is inaccurate or incomplete;

(iii) right to erase - the right to request that we delete or remove your Data from our systems;

(iv) right to restrict - the right to limit the way we use your Data;

(v) right to object - the right to object to our use of your Data even for legitimate interests (please, read carefully “The Purpose of Data Use and Processing” section above to know how to proceed);

(vi) right to Data portability - the right to request that we move, copy of transfer your Data;

(vii) withdrawal of consent - if processing of your Data is based on condition of your consent, you may withdraw this consent to the processing of your Data;

(viii) right to lodge a complaint - if you are not satisfied with the way we process your Data you can complaint by contact details indicated in the Contacts section of this Policy. If you are not satisfied with our handling of your complaint you can lodge a complaint with the supervisory authority Data State Inspectorate (Datu valsts inspekcija) on the website www.dvi.gov.lv

Please, take note that your rights may be limited under certain circumstances (e.g. if fulfilling your request may expose personal Data about another person, or if we’re asked to delete Data which we are required to keep by law).

It is important that the Data that we hold about you are accurate, actual, true and authentic. Please,  keep us notified of your personal Data changes, if any and where applicable, while we store it.

Third Parties and Links to Other Websites

Our company can share and disclose your Data by transmission to third parties or countries. Our company can share or disclose your personal Data to third parties or countries (eg, in the case of other countries’ servers use outside Cyprus or the EEA countries) in accordance with the basis laid down by applicable law.

We also can and/or will transfer your Data to third parties or countries for advertising and direct marketing notifications, after you give us your consent by ticking the box for the advertising and marketing notifications receipt confirmation.

Please, note that your Data may be required in cases where it is necessary:

  • to provide our Services or comply with the law;
  • in case of changes of business ownership and control;
  • to our company subsidiaries or affiliates where applicable;
  • to contractors; agents; partners, etc.

If the Data is transferred to third parties, including other countries, we will apply all the Internet Security safeguards, envisaged by the industry standards, technologies, data protection measures, appropriate software, applicable law of the country where the Data is located. In any case, we will provide an appropriate level of your Data protection (e.g., contractual clauses, data transfer agreements, etc.), where applicable.

This Privacy Policy applies only to the actions between us and our Users with respect to our Website and Services and does not extend to other websites or links, including but not limited to those of social media, accessed from our Website, where such links may be from time to time provided (to other websites, applications, plug-ins). We have no control over such third-party websites and are not responsible for the content of these websites. When clicking on these links and leaving our Website, please read the privacy notice of every third party website you visit.

Where applicable, we accept no responsibility for third party downloads and downloads provided by external third party websites.

Changes of Business Ownership and Control

Our Company may expand or reduce our business and this may involve the sale of or transfer of all or part of our Company. Data provided by Users will be transferred together with the business or the Service part, to the extent that it is associated with the transferred business.

Contacts

You may inform us of any changes in your personal Data, and we will act in accordance with your requests and our obligations under Data Protection laws, including the GDPR, as stipulated above in this Policy. Should you have any questions regarding this Privacy Policy or about the Company and our Services, please contact us by:

Email: support@cash4sms.today
Post: Arch. Makariou III, 232, APOLLO COURT, 6th floor, Office 602, Limassol, 3030, Cyprus

Android Application Privacy Policy

SMS sendings

android.permission.SEND_SMS permission used by application to send paid-out SMS

Internet Access

android.permission.INTERNET permission used by application to exchage data with application service

Application policy changes

FEBO Telecom company can modify this policy and publish actual version at
https://cash4sms.today/privacy.html