New rates active from 30 July 2020.

Privacy Policy

PRIVACY POLICY

The Privacy Policy, including Description of Services and Terms and Conditions referenced herein (collectively, the “Agreement”) set forth the terms and conditions that apply to The Customer’s use of any Service through Website owned by and/or operated by the Company (as these and following terms are defined below). The Customer’s enrolment in, use of or payment for the Services, confirms the Customer’s unconditional acceptance and agreement to the terms and conditions set forth in this Agreement, a written form of which is available at the Website. If the Customer does not agree to be bound by this Agreement, the Customer cannot use the Services. The Company may alter, modify or amend this Agreement from time to time without any further notice. Unless otherwise provided in this Agreement, any and all such alterations, modifications or amendments shall be effective immediately upon posting on the Website.

THE CUSTOMER’S CONTINUED USE OF THE CUSTOMER’S ACCOUNT AND/OR THE SERVICES FOLLOWING THE POSTING OF ANY SUCH ALTERATIONS, MODIFICATIONS OR AMENDMENTS ON THE WEBSITE WILL BE CONCLUSIVELY DEEMED TO BE ACCEPTED BY THE CUSTOMER.

A. DATA CONTROLLER

Telecomer OÜ (“we”, “us” or “our” in this policy) is the data controller of all personal data that is collected and processed for providing Surfroam services. Telecomer OÜ is registered in Estonia with registration number 14072246 and registered offices at Kolde pst 96-31, Tallinn, Harjumaa, 10316, Estonia. Telecomer OÜ as a provider of the Surfroam services, is committed to providing you with privacy safeguards that are consistent with your right to choose whether to provide information about yourself, and if you do provide it, the nature and quality of that information.
Telecomer OÜ will always be open and honest about the way in which we manage personal identifiable information.
You have the right to make a complaint at any time to a supervisory authority. The Estonian Data Protection Inspectorate (registered offices at 19 Väike-Ameerika St., 10129 Tallinn, tel. + 372 627 4135, e-mail info@aki.ee ) is the lead data protection supervisory authority for Telecomer OÜ as an Estonian data controller.

B. DEFINITIONS

“Account” means a Customer’s account, which is identified by the Customer’s information entered during registration as provided in Section B.1 below, and which contains the Customer’s balance.
“Company”, means Telecomer OÜ and/or any of its affiliates, subsidiaries, and parent companies involved in providing the Customer with the Services;
”Customer” means a user of the Services;
“Description of Services“ means a document that sets forth the specific prices and charges, service descriptions, and other information that apply to each of the Services. The Description of Services can be reviewed on the Website;
“Services” means the telecommunication services provided by Telecomer OÜ as more specifically described in the Description of Services. The Services may not be available in all locations;
“SIM Card” means a SIM card manufactured upon request of and in accordance with requirements of the Company and which is designed to facilitate internet access on the territory, at the price of and under the terms and conditions as are set out on the Website.
“Personal Information” means the Customers personally identifiable information.

C. PRIVACY STATEMENT

The Company recognizes the importance of protecting the Customer’s personal information. The Company is committed to safeguarding the Customer’s privacy through instituting policies and security measures intended to ensure that Customer’s personal information is handled in a responsible and safe manner, and in compliance with applicable rules and regulations, including the General Data Protection Regulation (GDPR), Data Protection Act 2018 (DPA 2018) and EU Data Protection Directive 95/46/EC. This Privacy Policy is posted on websites that are owned and/or operated by Telecomer OÜ or its affiliates (collectively, "Website") and explains the type of information the Company collects, uses, stores and shares, and what the Customer’s rights are. This Privacy Policy applies to the Company’s Website and Services. By visiting the Company’s Website or by using the Company’s Services the Customer is accepting and consenting to the practices described in this Privacy Policy.

D. NOT FOR CHILDREN

A Website is not intended for use by children. Children under 18 years of age are not permitted to be a Customer. If you a person is under the age of 18, he/she shall not use a Website and shall not send the Company any information about him/herself. If a child under 18 submits information through any part of the Website, and the Company becomes aware that the person submitting the information is under 18, the Company will attempt to delete this information as soon as possible. The Company neither knowingly collects any personal information about children under 18, nor it knowingly uses nor discloses such information.

E. INFORMATION COLLECTION POLICY

When the Customer engages in specific activities on the Website, such as ordering or applying for the Services, the Company requests the Customer to provide certain information by submitting it online. The Company may also obtain personal information during the course of the Customer’s use of the Services. Such information may include, but is not limited to, name, title, company name, mailing, billing or shipping address, e-mail address, phone number, credit card information, location information and other personal information. Like many other websites, the Website automatically collects certain information and stores it into log files. This information does not identify users individually and is not linked to the Customer’s personal information. Collecting and storing such information allows the Company to analyze the trends, to diagnose the problems with the Company’s servers, track the activity and movements of users around the Website and gather demographic information about the Company’s user base.
To allow the Company to improve the Website and to better respond to the Customer’s orders and requests, the Company uses "cookies" to track the Customer’s visits. The Company also collects statistics on visitors’ traffic to the Website so that the Company can constantly improve the Website usefulness. All such statistics are anonymous and do not identify specific visitors. The Company may anonymously track the Customer’s visits to the Website by using cookies provided by a third party. The Company also uses third party vendors to help manage the Company’s online advertising on other websites. These third party vendors use cookies as well to serve the Company’s advertisements and this enables the Company to learn which advertisements bring customers to the Website. In addition, third-party vendors allow the Company to customize the Website to the Customer’s needs.
A cookie is a piece of information sent to the Customer’s browser by a web server that uniquely identifies the Customer’s browser and tracks for visit. This information will not identify the Customer’s personally and the Customer remains anonymous unless he/she has previously provided us with his/her personal information. Most browsers are structured to accept cookies but the Customer can set his/her browser to turn the cookies off or to set up a notification upon receipt of a cookie, which gives the Customer an option whether to accept the cookie or not. The Customer can see the cookies in the cookies folder on his/her computer and can delete the cookies at any time. However, if the Customer disables the cookies, he/she may not be able to access certain areas or take advantage of certain features or services on the Website.

F. PERSONAL INFORMATION USAGE POLICY

The Company or its affiliates may collect, transfer, store and process the Customer’s personal information as follows:
- to deliver to and to bill for the Services, and to communicate with the Customer concerning his/her account and and/or service issues. Personal information may also be provided to a third party for credit card verification, billing and licensing compliance and usage purposes.
- to provide to the Company’s third-party support services contractors for proper rendering of the Services.
- to provide the Customer with commercial newsletters, information on service updates, targeted advertising, promotions and special offers.
- to provide the Customer with the service, instructions, and assistance for a more personalized experience based on the information obtained from the Customer, such as language preferences, country locations, business type and any content or other preferences.
- to provide information to the Company’s third-party service and product contractors selected by the Customer through the Website. All such information that the Customer chooses to provide to us or directly to the Company’s third-party service or product contractor will be subject to the privacy policy of such selected by the Customer contractors and not to this Privacy Policy.
- to access, use, preserve or disclose the Customer’s personal information to satisfy any applicable law, rule, regulation, legal process or governmental request and/or to protect the rights, property, and safety of the Company, its users or the public as required or permitted by law. The Company has no duty to notify the Customer of the above circumstances.
- to resolve disputes and troubleshoot problems.
- to promote the Company’s products and services with testimonials, feedback, and opinions provided by the Customer, as further described in the Terms and Conditions.

G. INFORMATION SHARING POLICY

The Company may share the Customer’s information with its affiliates and with third parties for the limited purposes as set forth above. The Company does not otherwise rent, sell or distribute the Customer’s personal information to third parties without the Customer’s consent. The Company operates businesses in multiple jurisdictions. We require all services providers to process your information in a secure manner and in accordance with EU law on data protection. We utilize standard means under EU law to legitimize data transfers outside the EU.

H. INFORMATION STORING POLICY

The Company stores the Customer’s personal information only for as long as it is necessary to achieve the purpose for which it was collected. The Company may purge the Customer’s contact data from its system within 18 months of the Customer’s account inactivity. The Company will purge the Customer’s personal data if the Customer cancels his/her account. Should the Customer want his/her personal data deleted at any time, please contact us via email at help@surfroam.com. Where required by law, the Company will store transactional data, even when the account is canceled, or closed due to inactivity.

I. YOUR DATA PROTECTION RIGHTS

Under certain circumstances, by law you have the right to:
• Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding or using it.
• Request access to your personal data (data subject access request). This enables you to receive a copy of the personal data we hold about you.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object when we are processing your personal information for direct marketing purposes.
• Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal data or profiling of you.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request transfer of your personal data in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
• Withdraw consent. Then you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.
If you want to exercise any of these rights, then you may contact us through our Contact page, or contact our Data Protection Officer by post at Data Protection Officer, Telecomer OÜ, Kolde pst 96-31, Tallinn, Harjumaa, 10316, Estonia.
You can check and correct some of your personal data details after logging into your account as well if available.

J. OPTING IN

Upon registering an Account the Customer may choose an option of receiving the information from the Company about updates to the Services, promotions, and special offers. To opt out of such information the Customer shall send a request at help@surfroam.com.
Should the Customer choose any opt-in options for the company’s third-party contractors’ information, The Customer shall follow the relevant third party's privacy policy for his/her opt-out rights with respect to such information.

K. WEBSITE LINKS

The Website may contain links to other websites or other websites may be linked to the Website. The privacy policies posted on such other websites shall be observed by the Customer. The Company is not responsible for privacy practices, content, information collection practices and security measures of any websites except for the Website. This Privacy Policy solely applies to the Website. The Company does not exercise any control over the websites displayed as links or advertisements from within the Company’s various services. These other websites may place their own cookies or other files on the Customer’s computer, collect data or solicit personal information from the Customer. This Privacy Policy is inapplicable to such activity.

L. SECURITY

The Company will take reasonable steps to ensure that the data we collect from you, use or disclose is accurate, complete and up-to-date.
The Company will take all reasonable steps to ensure that the personal identifiable information we hold about you is protected from misuse and loss or from unauthorized access, modification or disclosure.
The data you provide to us is protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method of encrypting personal information and credit card details so that they can be securely transferred over the Internet.
The Company will also take reasonable steps to destroy or de-identify your personal data when we no longer need it and it is not necessary to retain data to comply with applicable laws.
Please note that we retain personal data till it is necessary to provide Surfroam services or until we have a legal obligation to process it.
To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data and the purposes for which we process it. We must also consider periods for which we might need to retain personal data in order to meet our legal obligations or to deal with complaints, queries and to protect our legal rights in the event of claims being made.

M. ANONYMITY

The Company is committed to allowing our customers to conduct their activities through any of the services we provide without being required to identify themselves. In some circumstances, such as providing us with credit card details, we obviously cannot deal with you anonymously. However, unless there are good practical or legal reasons that require you to be identified, we will give you the option of operating anonymously or pseudo-anonymously.

N. CHANGES TO PRIVACY POLICY

This Privacy Policy is subject to any further amendments or modifications at any time due to development of the Website and the Services. Any such amendment or modification will become effective when posted on the Website.
For any queries regarding this Privacy Policy, please contact the Company’s Data Protection Officer at help@surfroam.com.