Privacy

Privacy Policy

This policy sets out the data protection and information collection practices of Naka AG, which is the service provider of EUi-Mobile. Where EUi-Mobile is trading under the name of FreeTime Telecom. This Privacy Policy applies to information we collect, when you access or use any of our websites and products, when you communicate to our staff, or when you otherwise interact with us (collectively, the “Services”).

When we refer to NAKA, we refer to Naka AG, Switzerland, and other NAKA group companies (“NAKA”, “Naka Mobile”, “Naka AG”, “we” or “us”).

Please take time to review this policy carefully as it tells you how your personal information will be treated by us. In order to make unconditional use of the EUi-Mobile Services, you must unconditionally agree to this policy.

Information We Collect

Personal information

The term “personal information” refers to information that tells us specifically who you are, such as your name, company name, phone number, email address, postal address or payment information (e.g credit card holder information, bank account holder information).

Personal information is collected during your registration with EUi-Mobile and is necessary to provide our products and services. No personal information is collected without your consent or prior to your registration. We may use information collected about you to protect our rights and to investigate and prevent fraud or other illegal activities and for any other purpose disclosed to you in connection with our Services.

Other information

We also automatically collect other non-personal information as you use our Services. While this information does not contain any personal data, it is still stored together with your registered account with us. This information includes:

  • Logged web data. As with most technology services offered over the internet, our servers automatically collect information when you access our Services and record it in log files. This log data may include your Internet Protocol (IP) address, address of web sites visited before using our Services, your browser type and settings, time and date and cookie data.
  • Your account activity. As part of our core service, a record of calls, data sessions, SMS and other consumed services, transactions and account activity is kept and stored for retrieval.
  • Device and location information. As part of our core service, information on your device (International Mobile Equipment Identity, IMEI), as well as an approximated location (network identity, GSM Cell ID and Location Area Code) is collected and stored, as a requirement for being able to use the Services.
  • Payment data. When making payments using our Services, we store partial data on the payment method in use, such as an account identifier or type of payment method in use.

Cookies

Cookies are small files that make it easier for you to use our Services online. Your Internet browser receives these files automatically from our servers and saves these cookies on your computer. We use two types of cookies, so-called session cookies and permanent cookies. We send a session cookie to your computer when you visit our web services and is used to remember your visit on each page you visit, and in order to keep you logged in for the duration of your visit, if necessary. When you close your browser, this cookie is deleted and is no longer effective.

We also set a permanent cookie once you have logged in to your personal account, for the purpose of remembering your visit for a longer period of time.

You can set your browser so that it informs you when it accepts a cookie or so that it does not accept cookies. Please make sure that your browser settings allow cookies so that you can take advantage of all our services without any loss of quality.

Our Sites and Services do not collect personal information about your online activities over time and across third-party websites or online services.

How is the information we collect processed?

General

Information is collected solely for the purpose of being able to provide you with our Services; either due to actual technical requirements of the core product (such as collecting GSM networking data and web activity), or in order to provide you a personalised Service experience.

Email and correspondence

We may send you email directly related to the use of our Services, such as notifying you of payments or the status of your service. We may also send you email or other forms of correspondence that are intended to notify you of our new products, services, special offers or updates or improvements to our existing products and services. You have the right to “opt-out” and prohibit use of your personal information for direct marketing purposes. If you prefer not receive any such email correspondence or marketing information concerning our products and services, please contact us at info@freetimetele.com or click “unsubscribe” as instructed in any email from us.

Personal information

The information that we collect from you via the Site and otherwise is an integral part of our business, and NAKA is not in the business of selling or renting your personal information to third parties.

Transferring information internationally

Our products and services may be provided using members of our group of companies and third parties acting on our behalf located in various countries around the world that may be located in countries outside of the European Economic Area (EEA), or countries deemed by the European Commission to have satisfactory data protection. These other countries may not offer the same level of protection for the information collected about you, although we will at all times continue to collect, store and use your information in accordance with this Privacy Policy and the General Data Protection Regulation (GDPR). NAKA will ensure we share data only with those organizations that satisfy an adequate level of data protection in line with applicable data protection legislation.

Operators and partners

As our core service depends on telecommunications services provided to us by various national mobile network operators, (collectively, the “Operators”), we may be required to share your personal information with them, in order to be able to provide you our Services, if the Operators have made the transmission of personal information a mandatory condition for granting service using their network. From time to time NAKA may also employ or engage other companies and individuals to perform services on our behalf.

Examples of this include sharing a copy of your identification document in order to receive a phone number from a country that requires registration of personal information for all prepaid and postpaid customers, provision of accounting, legal and financial services, fulfilling orders, shipping packages, sending postal mail, processing credit card payments and providing customer service. NAKA maintains ownership and control of the information so used.

Personal information is also shared with EUi-Mobile in full.

Disclosure required by law

We may disclose personal and non-personal information collected about you with state institutions and authorities if (i) disclosure is necessary to comply with any applicable law or regulation; (ii) to enforce applicable terms and conditions or policies; (iii) to protect the security or integrity of our Services; and (iv) if we believe such disclosure is necessary to protect our rights.

Sale of business

We may pass your personal information to a third party as part of the reorganisation or a sale of the assets of NAKA. You acknowledge that any acquirer or successor of NAKA may continue to use your information as set forth in this policy.

Disclosure with your consent

Other than as described in the foregoing, you will receive prior notice from us in the event we propose to share your personal information with third parties, and you will have a reasonable opportunity to give us such explicit consent.

Your right to data access

GDPR affords EU data subjects with additional rights that are summarized below. We also extend these rights to all of our registered customers.

  • Right of Confirmation: You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed.
  • Right to Access Your Data: You can retrieve a copy of your personal data and information collected on you at any time online.
  • Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data or to limit our use of it.
  • Amend Data: You can request the correction or update of personal data that we hold about you.
  • Right to Erasure (Right to Be Forgotten): You can at any time terminate your account with us, resulting an erasure of all of your personal data.
  • Right to Individual Decision Making, Including Profiling: You have the right not to be subject to a decision based solely on an automated processing, including profiling.
  • Right to Withdraw Consent: Where consent forms the basis for processing, you shall have the right to withdraw your consent to our further processing as described in this Privacy Policy.
  • Data Portability: You have the right to transmit the data to another controller without hindrance from NAKA.

In a case of objecting to our use of data, erasure of your data, or when withdrawing your consent, please note that we may no longer be able to provide you with the Services you have requested and may therefore terminate relevant agreements with you. In addition, we may be required to continue to hold your personal data to fulfil legal and regulatory obligations.

We reserve the right to reject or remove any information or content posted on our Site at our sole discretion.

Retention

We shall retain certain records of the information collected about you for a period of time as required by the law of Switzerland after termination of your account. Otherwise, we reserve the right to delete and destroy all of the information collected about you upon termination of your account unless you request otherwise.

Notwithstanding the above, you have the right to request the deletion of your data. Depending on the Services that we have provided to you, we may be required to hold certain data for as long as required to do so by the law of Switzerland, for legal purposes. We cannot continue to provide our Service to you if you request the deletion of your data.

You can request the deletion of your data as described above.

Governing law

This Privacy Policy shall be governed by and construed under and in accordance with the laws of Switzerland.

The English language version of this Privacy Policy shall be binding. Any translation or other language version of this Privacy Policy shall be provided for convenience only. In the event of a conflict between the English version and any translation or other language version of this Privacy Policy, the English-language version shall prevail. This Privacy Policy (including, if applicable, our terms and conditions) specify the entire agreement between you and us and supersede any and all prior agreements, terms, warranties and/or representations to the fullest extent permitted by the law.

Notification of changes

If we decide to change our privacy policy, we will post those changes on this page, and/or provide you with notice by other methods, so that you are always aware of what information we collect, how we use it, and under what circumstances it may be disclosed. It is your responsibility to check back to this page occasionally to see these changes.

This Privacy Policy was last amended on May 24, 2018.

Contacting us

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your personal information, you can do so by sending an email to us at info@freetimetele.com.

Disclaimer

Liability for content

NAKA AG (herewith „NAKA“) is the service provider for EUi-Mobile. Where EUi-Mobile is trading under the name of FreeTime Telecom.

The contents of this website have been created with utmost care. However, NAKA cannot guarantee the accuracy, completeness and up-to-dateness of the contents. The responsibility and the risks connected with the use of the information contained in this website stays in full with the user. Parts of the pages or the complete publication including all offers and information might be extended, changed or partly or completely deleted by NAKA without separate announcement. NAKA endeavours the uninterrupted availability of the service. Despite all due care and attention, downtimes cannot be precluded.

Liability for links

Our website includes links to other web pages on whose contents NAKA has no influence. Therefore we cannot assume responsibility for any of these foreign contents. The respective providers or operators are solely responsible for the content of the linked pages. At the time of including the links, the linked pages have been verified for eventual infringements and illegal contents and none was noticeable. NAKA has no influence on the current and future content of the linked pages. Permanent monitoring of the content of the linked pages is not reasonable, if there is no clear evidence for an infringement. In case infringements emerge, the corresponding links will immediately be removed.

Contractual relationship

The utilisation of the website of NAKA does not constitute any contractual relationship between the operator and the user. Thus, no contractual or other claim results against NAKA or any of its subsidiaries.

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