PRIVACY POLICY

Introduction

We are MTEL Global Group, including the following companies: MTEL Global d.o.o. Belgrade, registration number 21020958, having its registered office in Franše D’Eperea 88, Belgrade, Serbia, LINK2YU Network LLC, 340 S Lemon Ave #8618 Walnut, California, 91789, State of California, USA, and Link2YU Network GmbH, registration number FN 497831 f, having its registered office in Bockhgasse 9, Office 7, 1120 Vienna, Austria.

Each company operating as part of MTEL Global Group (hereinafter collectively referred to as MTEL GLOBAL) recognizes the crucial importance of adequate and proper protection of information and, consequently, this document lays down the basic principles of privacy policy to protect the privacy of personal data of individuals and ensure compliance with the law and the regulations adopted to protect personal data handled by all Group member companies in their business activity. If an MTEL Global member company adopts a separate privacy policy document, it will be forwarded to you, while this Privacy Policy will constitute a framework for the adoption of a separate privacy policy by individual member companies, so please get informed about these documents as well (if applicable).

Depending on the territory you reside on and whether you are a visitor to our www.mtel.global website or a user of our services or someone interested in using our services (hereinafter collectively referred to as the customer), each company is either individually or collectively, as part of MTEL GLOBAL, the controller of your personal data, provided to, or collected by or for, or processed in connection with our services, depending on the type of service you use on the relevant territory or when accessing our website.

Unless otherwise specified, the terms “We” or “MTEL GLOBAL” will refer in this Privacy Policy to MTEL Global Group member companies collectively, if applicable, or individually, depending on the conditions referred to in the previous paragraph of this Privacy Policy.

Unless otherwise specified, the common term “Services” will refer in this Privacy Policy to all services provided by MTEL GLOBAL, including the use of the website, visits to our companies’ pages/profiles on social media, online chat communication, blogs, forums etc.

As our customer, the collection, use and sharing of your personal data are subject to this Privacy Policy (which includes our Cookie Policy and/or other documents referred to in this Privacy Policy) and all updates, if any. The provisions contained herein supersede all previous statements or notices regarding our privacy practices.

MTEL GLOBAL generally does not provide services in the Balkans (Slovenia, Croatia, Serbia, Bosnia-Herzegovina, Macedonia). If you reside in the Balkans, this Privacy Policy applies to you only as a visitor to our website.

Protection of Personal Data

MTEL GLOBAL takes very seriously the protection of your personal data. This Privacy Policy describes our policies and practices regarding the collection and use of your personal data and sets forth your privacy rights. MTEL GLOBAL uses up-to-date technical and organizational arrangements to protect your data from being accessed or misused by unauthorized persons. The Privacy Policy defines the following:

Personal data may only be processed and transferred as part of a specific task and solely for the purposes for which it was originally obtained. Personal data will only be transferred to third parties in line with the legal framework and/or with explicit consent. It will be deleted or rendered anonymous as soon as the purpose for which it has been obtained is fulfilled.

This Privacy Policy does not cover all links to other websites posted on our website. For this reason, you are recommended to read all privacy statements on other websites that you visit.

Protection of Children

We deliberately do not attempt to solicit or receive any information from children. If a visitor to our website is a child, certain types of data are collected but are not personally identifiable, while the use of the website is considered approved by the holder of parental responsibility for the child. If a child uses our Services, the use will be considered approved/authorized by the holder of the parental responsibility for the child (parents, guardians), since our Services are not intended to be bought/used by children unsupervised by adults.

Parents/guardians are encouraged to spend some time online with their children and get informed about the types of content available via our website or Services, or on the Internet in general. We advise parents/guardians to supervise on a regular basis their children’s use of e-mail or other online communications and transactions. Control tools ensuring a safe online environment for children are available through online services and software manufacturers. If your child has used a credit card in connection with our Services without your permission, please contact our Customer Support Service immediately.

Right to Access and Control Your Personal Data

You can access or delete your personal data. This document helps you learn more about the ways in which your data is collected, used and shared. We have ensured numerous options in connection with that, from deleting or correcting the data you have provided to controlling advertising and communications opt-outs. We offer you different settings to manage and control the personal data We have about you.

If the stored data is inaccurate, you can report it to our Customer Support Service at any time, by phone or via the e-mail address support@mtel.global or the e-mail address used for data protection purposes dpo@mtel.global .

You can request at any time free-of-charge information about the type of data stored about you, the origin of the data and the purpose of its processing. You also have the right to transfer or delete your data. If there is ever any reason to complain about the way in which your data is processed, you can contact us at any time.

If you have any questions this Privacy Policy has failed to answer or if you would like more in-depth information about the above, please contact our Customer Support Service (e-mail support@mtel.global ) or e-mail us at dpo@mtel.global . Residents of specific countries have the additional right to file a complaint with the data protection authorities on their territory of residence, if applicable under the relevant legislation.

As regards our data about you, you have the right to do the following:

Security Standards and Data Loss

MTEL GLOBAL protects the data stored on its servers. In the event of a loss of data at MTEL GLOBAL despite the highest security requirements, specific escalation measures, which will immediately identify and deal with any flaws, will be put in place, i.e. appropriate protective countermeasures will be taken. Depending on the severity or the relevant persons’ interests at risk, these persons will be informed about it together with the competent authorities (regulatory agency, data protection authorities, if applicable under the relevant legislation).

Personal Data

Personal data is any information that relates to an identified or identifiable natural person. An identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, phone number, address, e-mail address etc.

If you are a visitor to our website, we collect some data automatically, such as IP address, region or general location where your computer or device has accessed the Internet, browser type, operating system or other information about the use of our website, including the history of the web pages that you have visited.

Data is not personal if it does not relate to a specific person, such as the data about the gender or number of persons visiting the website per day. The statistics collected include, for example, the data about your visits to specific pages on the website and this data cannot be directly associated with you as a person, such as the statistics about the most popular pages on our website etc.

Processing

MTEL GLOBAL identifies and processes specific personal data and metadata, as well as other data that you provide as part of the contractual relationship and/or when granted the right to a free-of-charge promotional period for our services or when it is necessary to verify the buyer’s/customer’s identity.

Master Data

The personal data that you provide to MTEL GLOBAL when concluding the contractual relationship is considered to be master data. This includes your name, home address, phone number, contact details such as your e-mail address, and the information about the nature and content of the contractual relationship. In the case of legal entities, the master data includes also name, address and company registration number. MTEL GLOBAL deletes customer master data not later than seven years after the completion of all claims arising from the contractual relationship.

Metadata

Metadata refers to all data processed to forward a message to a communications network or to bill the process. It includes, for example, active and passive subscriber numbers, type of device, charge code, number of units to be charged for the billing period, type, date, time and duration of a connection or other use, routes, the protocol used, the network from which the message originates or to which it is sent.

Telephony – To fulfill the contractual obligations related to telephony (calls and SMS), master data and metadata are processed for the purpose of establishing, controlling and charging telecommunications services. On our website, section User Account (“My Account”), you have password-protected access to your account, enabling you to track the consumption of telephony services and check the listing/history of your calls and sent SMS.

Operational Purposes

Only insofar personal data is strictly necessary for operational purposes (in particular troubleshooting of connection problems, network needs analysis, performance analysis, development and planning of network deployment, analysis and prevention of fraudulent practice against MTEL GLOBAL, optimization of offers etc.), it is processed by means of MTEL GLOBAL metadata. The metadata stored for these purposes will be deleted or anonymized after six months at the latest.

To ensure communication, MTEL GLOBAL works with different service providers, also having access to technical systems and data for troubleshooting purposes. Some of these service providers are located outside the European Union. In such cases, MTEL GLOBAL will ensure, by obtaining appropriate guarantees from the providers, that the EU’s high data protection level is complied with, as well as that their service providers and partners comply with the same standards.

We operate globally and rely on others to help us provide services and ensure the use of our website (e.g. maintenance, analysis, audit, payments, misuse prevention, marketing and development). They will have access to your information only insofar as it is necessary for them to perform their tasks or work on our behalf and they are under an obligation not to disclose it or use it for any other purposes. Whenever We transfer, store or process your personal data, We will take all reasonable steps to safeguard the privacy of your personal data in line with applicable laws.

Contract-/Order-Related Processing
Billing

For accounting, business or legal reasons, the master data and metadata of customers and suppliers of MTEL GLOBAL are processed, analyzed and stored. All tax-related data is retained for seven years.

Accounting

We send invoices for services/goods to the e-mail address you have provided for the purpose. Master data and metadata are used for billing purposes. The master data and the product/service information can be found directly on the invoice. Also, you can find all invoices in “My Account”, your user zone on the website, including the listing of used services. For billing purposes, the metadata and, consequently, individual records are kept until the time limit for filing a complaint or until the final decision on a complaint against the consumption-based bill. Invoices are stored for the statutory retention period of seven years.

Payment

If you want to pay your prepaid invoice via our website, the payment method you have opted for (credit card) can be used for automatic payment collection, if you have selected this option. MTEL GLOBAL works with banks and credit card companies to collect payments, while data is transferred in an encrypted form to service providers. The payment of prepaid invoices using the website user zone is made via PayUnity (European Union) and Authorize.Net (USA and Canada) as the service providers.

You may revoke your consent for automatic payment collection at any time, for any reason whatsoever, with effect for the future, by accessing your user account on our website (“My Account”) and turning off this function.

If you transfer the invoice amount to MTEL GLOBAL directly (bank order), the payment will be allocated to your customer account on MTEL GLOBAL by means of your master data that banks provide. If you purchase a product in connection with a service/tariff at an authorized MTEL GLOBAL retail outlet, the information about purchased products will be saved in the customer database, while your customer data will be printed on the invoice issued by the relevant outlet.

When purchasing services/tariffs directly via the MTEL GLOBAL application, you have the option to make the purchase via the Apple or Google system (the so-called “in-app purchase”). MTEL GLOBAL has no access to the data you enter during the purchase process. We suggest that you read the Apple and Google privacy policy.

Claims and Disputes

In claims and disputes cases, MTEL GLOBAL accesses the master data, metadata and payment, profile and customer interaction data saved in databases, needed to review claims.

If you contact an arbitration board, an interest representative (e.g. consumer information association) or an agent/lawyer, and an objection has been filed on your behalf, MTEL GLOBAL will forward the above personal data, needed to clarify the subject of the claim, to the arbitration board, the interest representative or the lawyer. As long as the procedure is in progress, the personal data described above will not be deleted. After that, general provisions on data retention and deletion apply.

Termination of the Contract

If you terminate the contract, your master data and saved customer interactions will be deleted after 3.5 years (after the expiry of the time limits for bringing actions arising from the contractual relations).

Extraordinary Termination – Handling of Special Cases

If there is an extraordinary reason for termination, such as the awarded guardianship or death, all the necessary master data and metadata, as well as notifications and documents, will be transferred to third parties, such as notaries, lawyers or specific administrative staff, if necessary.

Legal Obligations regarding Abuses and Emergencies

You are hereby informed and agree that our telephony services cannot be used to make calls to emergency services (rescue, firefighters, police etc.) and, consequently, We cannot provide information about your master and location data to any of them.

You can contact MTEL GLOBAL if you are being harassed by a specific caller and, if possible, We will take appropriate steps to protect you and will inform you about it.

Transfer to Third Parties

Your data will be used solely to provide our services and, naturally, will not be disclosed to third parties without your explicit consent. Our employees and partners, who may acquire information about your personal data during maintenance and service, are bound by contract to non-disclosure. We do not reveal your personal data to third parties for their independent use unless: (1) you request so or authorize them for the purpose; (2) the information is provided to comply with the law, the contract that we have concluded with you has to be enforced or our rights, property and safety protected; (3) the information is provided to our agents, suppliers or service providers performing tasks on our behalf; (4) emergencies have to be addressed; or (5) disputes, claims and requests have to be dealt with or data forwarded to parties legally authorized to act on your behalf. Your data cannot be sold or marketed.

In accepting this Privacy Policy, the customer agrees that the basic customer and traffic data will be submitted to MTEL GLOBAL.

Transfer to Third Countries

The data We collect from you will be processed in the EU, the US and Serbia, depending on your residence or type of user (website visitor and/or user of a specific service that We provide), in line with the applicable legislation pertaining to MTEL GLOBAL business operation. MTEL GLOBAL collects and transfers personal data to third countries only: with your consent; to perform the contract closed with you; or to pursue a compelling legitimate interest in such a way as not to outweigh your rights and freedoms. MTEL GLOBAL seeks to apply appropriate safeguards to protect the privacy and security of your personal data, used only in accordance with your relationship with MTEL GLOBAL and the procedures described in this Privacy Policy. MTEL GLOBAL also minimizes the risk to your rights and freedoms by not collecting or storing sensitive information about you.

Customer Support Service

To deal with your requests and complaints, having to do, for example, with invoices, customer-related products and services or technical issues, MTEL GLOBAL processes master data and metadata stored in the systems, as well as customer interaction data, needed to reply to a request or solve the existing issue. Such a request may involve, for example, address updates, setting locks or enabling/disabling packages. In order to identify you as a customer, the information requested first includes, for example, your name, the device’s MAC address, or your phone or personal number, if you use our telephony services. For each customer contact, an entry will be made in our Customer Management System.

MTEL GLOBAL employees and/or authorized persons can access your user account exclusively with your consent and at your request, in order to make changes in it directly, as per the requested order. Each time the account is accessed, the data about it is stored in the Customer Management System.

In order to reply to all your queries, MTEL GLOBAL works with partners granted the same access to master data and metadata as its employees within their respective duties. Naturally, the same strict data protection regulations apply to the partners as well.

MTEL GLOBAL Apps and Services
Communication
Websites and Social Media
Analysis of the Website Use

We use different types of software to analyze the use of our website so as to gain valuable insight into the needs of our website visitors. These insights help us to constantly improve the quality of our offerings and customer interface.

Cookies Policy

We collect non-personally identifiable information through technologies, such as cookies, web beacons and pixel tags. Cookies are small text files stored on your computer’s (PC, laptop) hard drive, smartphone, tablet or any other device connected to the Internet by a website. Cookies allow an analysis of your user behavior, but also allow you to be recognized as a visitor to our website so you do not have to log in again if you previously logged in to our website. For this purpose, our server accesses your cookies and processes the stored information.

Cookies are used both to improve the quality of service, including the storage of user settings and preferences, and to track visitor trends, such as which products you have viewed and ordered. If the cookies function is activated in your browser settings on your computer/device, MTEL GLOBAL can recognize the browser of the local computer and offer you the advanced cookie functions. In principle, the cookies used to analyze user behavior are automatically deleted after 30-90 days.

The so-called session cookies are automatically deleted after 30 minutes if you close your browser or use the logout function. They contain only a randomly generated identifier that allows a visitor to be recognized during a session while using the website. Permanent cookies are only set if you allow them in your browser settings and you additionally agree; for example, if you allow the "remember me/stay signed in" feature on our website. Such cookies are stored for a period of one year and extended for the same period every time you log in.

You can easily manage cookies yourself: enable and disable cookies. You can manage cookies by following the procedure for the browser you use:

However, disabling the cookie feature may prevent you from using certain benefits or features when visiting our website. Therefore, we recommend that you enable the cookie feature.

Your Rights (Addition)

As stated elsewhere in this document, depending on your place of residence, you may have some additional privacy protection rights. This Privacy Policy does not limit your rights granted in compliance with the applicable laws of the territory where you have your residence. For example:

If you seek to exercise any of the aforementioned rights or have any further questions, you can reach us at support@mtel.global or dpo@mtel.global

Dispute Resolution

If you reside in the territory of USA or Canada and use the Services of LINK2YU Network LLC, you and LINK2YU Network LLC (collectively “the Parties”) agree that any dispute relating to this Privacy Policy or any other binding document that you have with LINK2YU Network LLC will be exclusively governed by the laws of the State of California, USA, excluding the conflict of laws rules. In the event of any misunderstanding or dispute in connection with this Privacy Policy, the Parties will attempt to resolve it amicably, by mutual agreement. All disputes which cannot be settled as previously envisaged shall be finally settled by the court of competent jurisdiction in California, USA.

If you reside in the territory of the European Union and use the Services of Link2YU Network LLC, you and Link2YU Network GmbH (collectively “the Parties”) agree that any dispute relating to this Privacy Policy or any other binding document that you have with Link2YU Network GmbH will be exclusively governed by the laws of Austria, excluding the conflict of laws rules. In the event of any misunderstanding or dispute in connection with this Privacy Policy, the Parties will attempt to resolve it amicably, by mutual agreement. All disputes which cannot be settled as previously envisaged shall be finally settled by the court of competent jurisdiction in Vienna, Austria.

If you are a visitor to our website or a user of Services of MTEL Global d.o.o. Beograd, you and MTEL Global d.o.o. Beograd (collectively “the Parties”) agree that any dispute relating to this Privacy Policy or any other binding document that you have with MTEL Global d.o.o. Beograd will be exclusively governed by the laws of Serbia, excluding the conflict of law rules. In the event of any misunderstanding or dispute in connection with this Privacy Policy, the Parties will attempt to resolve it amicably, by mutual agreement. All disputes which cannot be settled as previously envisaged shall be finally settled by the court of competent jurisdiction in Belgrade, Serbia.

Modifications, Effective Date

This Privacy Policy applies to your use of our website and Services as of the “Effective Date.”

We may from time to time update all or parts of this Privacy Policy, at any time and without individual notice to you, but we will always publish a new version through our website or our Services. We encourage you to periodically review this Privacy Policy to stay informed about MTEL GLOBAL information practices. If you object to any changes, please stop using our website and/or close your account (if applicable) or contact us without delay.

You acknowledge that your continued use of our website and our services after we publish or send a notice about our modifications to this Privacy Policy, if applicable, will mean that the collection, use and sharing of your personal data is subject to the modified version of Privacy Policy and will be deemed as your acceptance of those modifications.

Latest version: Effective Date October 10, 2020