Binotel WIRE Privacy Policy
Introduction and Scope

Binotel LLC ("Binotel", "we", "us", "our") understands that your privacy is important. This Privacy Policy ("Policy") is designed to explain how we collect, use, process and store your personally identifiable information ("Personal Data") in connection with your use of our mobile application WIRE ("App").

This Policy explains the collection and use of Personal Data about our users as well as any individual whose Personal Data was supplied to the App by such users.


Controllership

In limited cases where Binotel acts as a data controller (i.e. it decides on the purposes of the processing), it may use certain minimum Personal Data for the following purposes:

  • account registration and administration; and

  • troubleshooting and improving our App.

Most of the processing activities occur through our clients' use of the WIRE App. In the context of such activities, we act as a data processor for your Personal Data and we do not have much control over how your Personal Data is used by our clients.


Categories of Personal Data

We may collect the following categories of Personal Data:

  • biographical information such as your name, email address, phone number;

  • information related to calls: subscriber's name and/or telephone number, subscriber's name and/or number, waiting time, call duration, call time and its recording;

  • any personal information that can be included in call recordings;
  • background location data, if turned on.


How We Receive Personal Data

We may receive your Personal Data:

  • when you provide it directly to our App (e.g., when registering in our system);

  • through the use of our App by its users.


Basis of Processing

In the context of our data processing activities as a data controller, we may rely on one or more of the following legal grounds for processing your Personal Data:

  • the need to perform our obligations under our terms and conditions (i.e., providing you with our services);

  • the need to pursue our legitimate interests, such as to improve our software and its functionality;

  • any other ground, as required or permitted by law in the specific respective context.

In the context of our activities as a data processor, we process your Personal Data on behalf of our clients who rely on various legal grounds to process and share your Personal Data with us.


Purposes of Processing

We process your Personal Data for the purposes of:

  • providing the services to you and our clients;

  • user account registration and administration;

  • managing the relationship with our clients;

  • recording and storing calls in the background;

  • producing analytics of calls;

  • resolving technical issues, detecting and fixing bugs in our App;

  • complying with applicable laws;

  • preventing or detecting fraud, security breaches or illegal activities.

Where we act as a data processor, our use of your Personal Data is quite limited and the purposes of the processing are decided by the respective client (the data controller).


Background location data processing

Some of our clients may need background location turned on for remote employees.

Such data is generally considered sensitive and requires prominent disclosure and explicit consent for use. We provide settings to allow or turn-off background location tracking. If such a setting is turned on, we then provide a notification and request to end users to allow or block location tracking.


Sharing Personal Data with Third Parties

We may share your Personal Data with certain third-party providers for the purposes of facilitating the provision of our services and proper functioning of the App. We will require that all these third-party vendors maintain at least the same level of data protection that we maintain for such Personal Data.

Such third-party vendors may provide:

  • helpdesk software services; and

  • cloud storage services.

Other Disclosure of Your Personal Data

We may disclose your Personal Data:

  • to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders;

  • in connection with a merger, division, restructuring, or other association change; or

  • to our subsidiaries or affiliates only if necessary for operational purposes.

If we must disclose your Personal Data in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your Personal Data will maintain the privacy or security of your Personal Data.

Data Integrity & Security

Binotel takes information security very seriously. We work hard to protect the Personal Data you give us from loss, misuse, or unauthorized access. We utilize a variety of safeguards such as encryption, digital and physical access controls, non-disclosure agreements, and other technical and organizational measures to protect the Personal Data submitted to us, both during transmission and once it is received.

Please note that no electronic transmission, storage, or processing of Personal Data can be entirely secure. We cannot guarantee that the security measures we have in place to safeguard Personal Data will never be defeated or fail, or that those measures will always be sufficient or effective. Therefore, although we are committed to protecting your privacy, we do not promise, and you should not expect that your Personal Data will always remain private or secure.

Data Retention Period

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Some data you can delete whenever you like, some data is deleted automatically, and some data we retain for longer periods of time when necessary. When you delete data, we follow a deletion policy to make sure that your data is safely and completely removed from our servers or retained only in anonymized form.

Sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period of time. For example, when we process a payment for you, or when you make a payment to us, we'll retain this data for longer periods of time as required for tax or accounting purposes. Reasons we might retain some data for longer periods of time include:

  • Security, fraud & abuse prevention.

  • Financial record-keeping.

  • Complying with legal or regulatory requirements.

  • Ensuring the continuity of our services.

  • Direct communications.

Access, Review, Objection to Processing & Portability

As a European resident, the GDPR grants you a number of rights concerning the use, storage, and processing of your Personal Data. In situations when we act as a data processor and our client is a data controller who holds your Personal Data, you must contact this client if you wish to exercise any of the privacy rights mentioned below.

Understand certain circumstances, you may exercise the following privacy rights:

  • right of access – you may ask us whether we are processing your Personal Data and you have the right to request a copy of the information we hold about you.

  • right of rectification – you have the right to correct inaccurate or incomplete Personal Data about you and you the ability to do so yourself in the settings of your Profile.

  • right to be forgotten – you can ask for the information that we hold about you to be erased from our system and we will comply with this request unless we will have a legitimate reason not to do so.

  • right to restriction of processing – where certain conditions apply, you can ask us to 'block' the processing of your Personal Data.

  • right to data portability – you have the right to have the data we hold about you transferred to another organization and to receive Personal Data in a structured, commonly used format.

  • Right to object to automated processing (including profiling) – this right provides you with the ability to object to a decision based on purely automated processing. We are not currently processing your Personal Data for such type of automated decision-making, including profiling, but if we elect to do so in the future we will provide you with notice and choice, in accordance with EU data protection law;

If you wish to learn more about the GDPR and your rights, the Information Commissioner's Office website is a reliable source.

Privacy of Children

Our App is not directed to collect Personal Data from people under the age of 18. We do not knowingly allow anyone under 18 to submit any Personal Data to our Website. If you believe your child may have provided us with their Personal Data, you can contact us using the information in the Contact Us section of this Policy and we will delete the Personal Data.

Changes to this Policy

If we make any material change to this Policy, we will post the revised Policy to this web page and update the "Effective on" date above to reflect the date on which the new Policy became effective. We will also notify you about these changes via email.

Contact Us

If you have any questions about this Policy or the processing of your Personal Data, please contact us at privacy@binotel.com or st. Zdolbunivska, 7-D., Building "Z", office №207, Ukraine, Kyiv, 02081. Binotel has appointed a representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. You may contact our representative at privacy@binotel.com.
Alternatively, the representative in the Union can be contacted at:

Marcin Wrzesiński
Mozartlaan 542
2625CV Delft
The Netherlands

Supervisory Authority Oversight

If you are a data subject whose Personal Data we process, you may also have the right to lodge a complaint with a data protection regulator in one or more of the European Union member states. Here you can find a list of data protection authorities in Europe.


Effective as of 1.10.2019
Last editing: 04.28.2021