1. What information about you is collected, how will we use it and how is it legal for us to do so?
We collect personal data in a variety of ways, such as when you visit any of our websites, download our app, interact with electronic advertisement, use the services in the app or on our websites, make a purchase, contact us and use our customer portal.
Categories of personal data we may collect and process:
Registration and account information: e.g. your phone number, name, email, profile picture, address and, password, time zone, language, currency, EU VAT number.
Device and connection information: We collect device and connection-specific information when you install, access, or use our services. This includes information like hardware model, operating system information, app version, browser information, and mobile network, connection information including phone number, mobile/phone operator or internet service provider, language and time zone, and IP, device operations information, and identifiers like device identifiers. When you install the UltraTone app, you’ll also be asked to allow us access to your mobile device’s address book. A copy of the phone numbers, names and, if applicable, account identifiers for services, of all your contacts (whether they are a UltraTone customer or not – but only name, phone number and UltraTone account identifier) will be collected in order for us to provide functionality and administer our services.
Activity and usage information: e.g. information about your use of our services and the services of our Partners (as defined in the UltraTone Terms of Service) and other activities in relation to UltraTone and/or our Partners, such as information about when you registered to use the services, how you use our services, items you purchase, transaction amounts, the features you use, your services settings, the time, frequency, and duration of your activities and interactions (e.g. the phone numbers and/or other identification details of the originating and receiving party, the start time, call duration, messages, mobile money top-ups, money transfers, delivery notices), log files, and diagnostic, crash, website, and performance logs and reports.
Location Information: We collect device location information if you use our location features.
Customer support and social media: If you use our Customer Support service, interacts with us on our social media channels or in any other way, we may keep a record of that interaction, including the correspondence such as copies of emails and your email address.
Behavioral and tracking details: e.g. location data, behavioral patterns, personal preferences, IP-number, cookie identifiers, unique identifier of devices you use to access and use the services and our websites.
Payment information: We collect billing details, name, address, email address, bank details, card information and other financial information corresponding to your selected method of payment. However we will only store name, address, email and issuing bank (i.e. UltraTone do not store full payment card details).
The data that collected is used for the purposes set out below. In short, we process 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 UltraTone
To conduct payment for services. Fulfil our contractual obligations towards you, to comply with applicable laws and to pursue the legitimate interests of UltraTone
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 UltraTone
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 UltraTone
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 UltraTone
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 UltraTone
To comply with applicable laws and regulations (for example bookkeeping, lawful intercept). Comply with applicable laws and to pursue the legitimate interests of UltraTone
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 UltraTone
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 UltraTone
2. Security measures for personal data
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 email@example.com.
3. Sharing Information
We work with carefully selected third-party service providers and Partners to operate, provide, improve, understand, customize, support, and market the services. For example, we work with companies to distribute our apps, provide infrastructure, delivery, supply location, prevent fraud or other criminal behavior, 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 Partners 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 UltraTone or a group company or corporate restructuring or as a result of a change of control of UltraTone 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.
Transfer of data to third countries
In some cases, UltraTone may transfer your personal data outside the EU / EEA, mainly in cases where we use service providers and/or Partners that process personal data outside the EU / EEA. This will only be done after adequate protection measures have been taken to ensure an adequate level of data protection, e.g. by including the European Commission’s standard contractual clauses for the transfer of personal data and, where necessary, by implementation of supplementary safeguarding measures.
4. Communications and notifications
UltraTone 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.
UltraTone 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 UltraTone and the services, including new products, campaigns, promotions and payment methods.
If you don’t want to receive promotional messages from UltraTone you can unsubscribe by following the instructions in the promotional message you have received or by contacting our customer support at firstname.lastname@example.org.
Promotional SMS messages to US Customers
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 email@example.com 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 UltraTone and from you to UltraTone.
5. Third Party Sites
7. Data retention
Your personal data is stored only as long as is necessary in order to fulfil the purposes for which your personal data was collected, however the personal data may be retained for a longer period if it is required by law (for example to fulfill book keeping requirements or requirements to keep records of phone calls for lawful intercept) or it is reasonably necessary to safeguard our legal interests.
8. Your rights in respect of your personal data
Under applicable data protection legislation you have the following rights in relation to personal data.
Right to access – You have the right to obtain information from UltraTone about any personal data being processed about you and access to such data, if any.
Right to rectification – You have the right to obtain the rectification of inaccurate personal data about yourself.
Right to erasure (“the right to be forgotten”) – You have the right to obtain the erasure of data about you if the data is no longer necessary for the purpose it was collected for. There might be legal obligations for UltraTone to keep the data anyway, that stops UltraTone from immediately erasing the data. In that case we can block the data we are required to keep, from being used for other purposes than the fulfilment of the legal requirements or anonymize the data.