PERSONAL DATA PROTECTION POLICY INTRO
Yuboto LTD as Processor or Processor asks for and processes the minimum necessary data needed to acquire in order use our Services as well as browsing our Site.
YUBOTO, with a commitment to legality and transparency, manages with absolute respect the personal data communicated to it and the processing operations are limited to the minimum possible and only for the fulfillment of their purposes.
Any processing is done in accordance with the General Data Protection Regulation (2016/679/EU )and in general the current national and European legal and regulatory framework for the protection of personal data.
Katsantoni & Olympias, Metamorfosi Athens, 14452
(+30) 211 114 4111
For any clarification as well as for related requests regarding Personal Data, we have designated a "Data Protection Officer" and you can contact us directly at firstname.lastname@example.org
PURPOSE OF PROCESSING
The purpose of data processing is the smooth execution of telecommunication and subscription services in accordance with the law and service during the contract. This purpose includes:
Provide the relevant Service you obtained.
Provision of Technical Support and Customer Service.
Provision of Pricing and Information Services.
Provision of Access and Complaint Requests,
Provision of Information, Balance, Payments and Settlements.
Compliance with regulatory requirements, including legislation on the protection of communications secrecy and the identification of crimes in cases of requests by public authorities.
Protect the legitimate interest and function of YUBOTO, your privacy, your security, and effectively address the problems that arise.
For direct marketing purposes, YUBOTO can make decisions or profile, based on automated data processing, if you give your consent.
CATEGORIES OF DATA
For the above reasons, YUBOTO could possibly collect and process:
User IDs: * Name * Surname * Address * Birth Date
Unique User IDs: * VAT * ID Number
User Billing Elements: * Name * Billing Address * Bank Account
Connection Details: * Address to install the connection
User Contact Details: * Phone * Email
Items that can be imported/created by the user: * End User / Recipient Telephone Numbers * Messages History * Messages Statistics
User IDs when browsing: * Address of the connection provider (IP) * Cookie
Data generated during use: * Communication Data * End User Actions
More about the Cookies and Data we process while browsing our Websites can be found here
The transfer of personal data to legal and/or natural persons cooperating with YUBOTO takes place only when it becomes absolutely necessary for the implementation of the services provided to the users or when the applicable legislation requires so.
Data Recipients may be the following:
YUBOTO and its employees in the framework of their responsibilities.
Its agents and / or subcontractors for the purpose of supporting, promoting and performing the contract.
Relevant Public Authorities, including the National Telecommunications Commission, the Communications Integrity Authority and the Judicial Authorities.
The providers with which we have interconnected the networks to serve the traffic.
YUBOTO partners have agreed and contractually agreed in writing that:
Keep confidential, like their employees, of personal information they may know.
Not to transfer data to third parties without the written permission of YUBOTO.
To take organizational and technical data security measures that protect their logic and physical security.
Design their systems so that by design and by definition they can be assured that they will be able to fulfill these obligations.
Promptly inform YUBOTO of any incident relating to the violation of CUSTOM personal data, comply with the legal framework for the protection of personal data and in particular the General Data Protection Act (GDPR) as processors.
YUBOTO undertakes not to sell, rent or otherwise publish or / and disclose visitor / user personal data to any third party for purposes other than the contractual relationship.
DATA RETENTION / DELETION
YUBOTO keeps the data in a physical / electronic file for the entire duration of the contract.
Data for dormant contracts are held for a necessary period for winding-up purposes 14 months after expiry of the telecommunication contract and 2 years for other services unless, under the law, they have been complied with until the final settlement of cases or if it is defined by other legislation period (eg tax provisions). They are then completely deleted without the chance recovery.
TECHNICAL AND ORGANIZATIONAL SECURITY MEASURES
Any data processing in any way is only allowed to authorized persons, employees and partners solely for the purposes mentioned above.
YUBOTO has taken the necessary and appropriate organizational and technical measures for the security and protection of your Data in the context of the Information, Communications and Personal Data Security Policy, in accordance with the ADAE Regulatory Framework, on a standard comparable to a minimum level of protection during concept of the ISO 27001 standard of protection. Furthermore, it holds ISO 9001/2001 quality assurance certification.
These measures shall be reviewed and amended as necessary.
DATA SUBJECT RIGHTS
In any case, the CUSTOMER has the right to information, at the stage of collecting the identity data of YUBOTO, the purposes of the processing, the recipients of the data, any third parties to whom the data is transmitted.
The CUSTOMER has the right to have full access to his / her data. This means that the CUSTOMER has the right to update how and if it is processed in his / her data. The CUSTOMER may request information, in writing or electronically, of the above, has the right to correct inaccurate personal data, the right to delete it (if it is no longer necessary for the above mentioned processing purposes or in case of withdrawal of consent, where applicable) data in mechanically readable form, right to restrict processing (for as long as your processing objections are pending), the right to recall / oppose the processing of the data.
In the event of any objection to processing, YUBOTO will cease processing the data if there are no compelling and legitimate reasons that prevail over the CUSTOMER's right or are no longer necessary for the above mentioned processing purposes.
The CUSTOMER's request is received free of charge without delay, and in any case within (1) one month from the date of receipt. However, if the request is complex or there are a large number of requests, YUBOTO will inform if another two (2) months are to be extended. If the claims are manifestly unfounded or excessive in particular because of their recurrence, YUBOTO may impose a reasonable fee, taking into account the administrative costs of providing the information or executing the requested action, or refusing to respond to the request by giving reasons its answer.
AMENDMENT OF THE PERSONAL DATA PROTECTION POLICY
REQUESTS - QUESTIONS - COMPLAINTS
For any request and exercise of a right, in relation to your personal data and for the provision of specialized information, the CUSTOMER may contact the Service Department electronically by sending it to mail: email@example.com.
The CUSTOMER has the right to file a complaint with the Personal Data Protection Authority (Kifisias 1-3, PC 115 23, Athens, tel. 210 6475600, firstname.lastname@example.org) if he considers that the processing of Personal Data violates the current national and regulatory framework for the protection of personal data.
General Terms and Conditions of Use
C. Minors are not allowed to register and use yuboto.com web pages and services, which by law are meant exclusively for adults. If minors voluntarily visit web pages or use services that could be deemed inappropriate, Yuboto Ltd. bears no responsibility whatsoever.
D. All who visit/use yuboto.com do so under the currently valid Terms and Conditions of Use; the latter may not be modified or otherwise interfered with. Acting in good faith, conforming to the principles of Art and Science and according to business ethics, Yuboto Ltd. provides a safe environment of use at yuboto.com, as well as accurate, comprehensive, valid, reliable and up-to-date information. However, users acknowledge and accept that in any case, given the nature of the services provided, Yuboto Ltd. may be unable to control entirely the content and safety of yuboto.com web pages and services. For that reason, Yuboto Ltd. offers no assurance or guarantee, and takes no responsibility as to the safety and content of the website. Therefore, users accept that they ought to evaluate content and that they bear responsibility for any risk, threat, or damage resulting from the use of the website or its content, including their decision to rely on the accuracy, comprehensiveness, validity, or usefulness of any yuboto.com content.
II. USER OBLIGATIONS
With the exception of any third-party rights, all of the original content on yuboto.com, such as any patented and protected trademarks, brand and company names, logos, photographs, designs, texts, and files in general, are part of the intellectual and industrial property of their beneficiary, Yuboto Ltd., and fall under the protection of the relevant legislative provisions. The aforementioned content, in whole or in part, cannot be sold, copied, modified, reproduced, broadcast, transmitted, traded, or distributed in any way by any user without a written permission to do so.
Any third-party products and/or services appearing on yuboto.com are part of the intellectual and industrial property of said third parties, who also bear responsibility for their content and their services and/or products.
Users accept and agree to comply and conform to the lawful and proper use of yuboto.com, subject to the provisions on data transmission and on the rendering and use of telecommunications services from Greece to EU member countries and third countries. Therefore, users agree on such terms as, but not limited to, the following:
They shall not cause harm to a minor, transmit, trade, or promote in any way content that is subject to legal and moral codes, especially illegally acquired material, wiretap records, terrorist material, child pornography, etc.
They shall not transmit or access content that: i) violates any third party rights, ii) violates fundamental human rights recognized by national law and by the European Convention on Human Rights (e.g. the right to confidentiality, the prohibition of discrimination based on any factor, including sex, race, skin color, language, religion, political views or other beliefs, nationality or social position), iii) is contrary to the law, and deviates from moral codes and business ethics, iv) violates in any manner third party privacy or their individual and social rights.
They shall not provide anyone with false information regarding the origin of the website content, damage in any way the reputation of Yuboto Ltd., prevent any user from accessing yuboto.com, or override the identity check performed by Yuboto Ltd.
They shall not in any way install or promote any sort of unsolicited or unauthorized advertisement or unasked electronic messages (spam), chain letters, pyramid systems, or any other kind of unwelcome content promotion, nor shall they install and promote advertisements without the written authorization of Yuboto Ltd.
They shall not install, promote, and/or make available any content containing digital viruses, or any other kind of code, files or programs designed to interfere with, destroy or limit the functionality of any software or telecommunications equipment, or prevent other users from using yuboto.com.
They shall not disclose personal or third-party information containing user or third party personal data, either during real-time conversations (chats, message boards) or while using any yuboto.com service with a multi-user communication feature.
They shall not use the service to inform and contact third parties or the competent Authorities in case of emergency as we cannot guarantee that a call will be successfully made and received during such a critical occasion. Yuboto Ltd. bears no responsibility whatsoever if a call or data transfer fails or if a call is unexpectedly disconnected.
Yuboto Ltd. bears no responsibility should the domestic peace of the called party be disturbed during quiet hours; therefore, users are required to respect the quiet hours, privacy, confidential communications, and moral codes of the called party. In addition, Yuboto Ltd. bears no responsibility whatsoever for malicious calls or call content that is offending, illegal and/or immoral, since the company exerts no control over calls and is unable to intervene. However, if complaints are filed, Yuboto Ltd. may immediately suspend any service rendered until the issue is resolved.
In case visitors/users use the website in an illegal or contrary to these Terms and Conditions manner, they are required to compensate Yuboto Ltd. for any direct or indirect, compensatory or consequential damage. Even if the rights defined in these Terms and Conditions are not exercised by Yuboto Ltd. , it does not mean they are relinquished.
III. ACCESS CODES
In order to gain access to certain website services or connect to certain web pages, Yuboto Ltd. may ask users for identification data so as to issue a relevant Access Code. The data provided by users must always be true, accurate, valid and comprehensive. Users bear responsibility for all actions taken using the Access Code; if the latter is used in any unauthorized way or there is any kind of security breach (or even the possibility of one occurring), then users are obligated to immediately contact Yuboto Ltd. . Yuboto Ltd. does not share such data with third parties. Yuboto Ltd. bears no responsibility for any harm or damage incurred from the arbitrary or illegal use of the Access Code by third parties, obtained via a data breach or any other way, and reserves the right to ask users for compensation if the company suffers any kind of damage due to the arbitrary or illegal use of an Access Code. Yuboto Ltd. has the right to refuse to issue an Access Code, cancel an issued code, and terminate the services provided to users, as well as deny them current or future use of yuboto.com in case the Terms and Conditions of Use are violated. Users must be prudent and diligent as needed on the matter of Access Code safety, and refrain from sharing the Access Codes with any third parties.
Codes issued by Yuboto Ltd. are meant strictly for personal use, and the user, for whom codes are issued for, bears sole responsibility should they be lost or stolen. It is assumed that all activities connected to the name and code of a user have been carried out by that user, who also bears full responsibility for the content and use of the services used.
VI. APPLICABLE LAW - JURISDICTION
These Terms and Conditions of Use and any modification thereof are governed by Greek Law. Any dispute arising from this contract shall be brought before the competent court of law in Athens.
VII. CONTACT DETAILS
Users may contact the Customer Service Department of Yuboto Ltd. by phone: +30 211 11 44 111, or by email: info[at]yuboto[dot]com.
SPECIFIC TERMS OF OCTAPUSH by Yuboto
I. OCTAPUSH Terms and Conditions
II. CONTENT - LIABILITY
OCTAPUSH service is a web-based service that allows Viber messages to be edited, written and sent to mobile phones. This way, the users may access the web interface to send either bulk personal messages or in a business context, with the purpose of contacting consumers (CRM and Direct Marketing) sending corporate news, announcements, news, election issues, reminders, wishes, invitations, announcements of offers, announcement of new products and services, discount coupons. Through this online application and easy-to-use user interface, the registered users may send messages to a list of recipients at the touch of a button, enter new recipients (individually or even through data files), group the recipients, create / store templates, customize and schedule the time, frequency, and rate of messages sent.
Yuboto Ltd. provides mediation services and does not interfere in any way with the content of messages neither takes any other action on the information that may be produced by them.
Yuboto Ltd. collects and processes only the data entered by the registered user as Processing Manager, as well as security data for user browsing and activity.
The personal data that Yuboto Ltd. may collect from the user and / or end users when using the service are related to the following categories:
User ID (Phone number, Username, Password, Email)
User Billing Details (Company name, professional activity, registered address, VAT number id, tax office)
End User / Recipients; Telephone Numbers
Message log history and Service Usage
User IDs when browsing (IP, Cookie)
III. NETWORK AVAILABILITY & SECURITY
YUBOTO Ltd. undertakes the task of delivering Viber messages sent by OCTAPUSH users that hold an approved by Viber Sender id to users holding active viber accounts and/or SMS to mobile networks and is not responsible if some of them fail to deliver are delayed or distorted.
The successful and timely delivery depends on whether:
The end user’s viber account is online and active.
The geographic area where the user is located and whether the area is covered by the mobile network.
The end user’s device is active.
The weather conditions allow the proper operation of mobile networks
The networks are overloaded.
As a result, Yuboto Ltd. is not responsible for any delays or failure in delivering the messages. On message delivery, a relative report is available to the sender, while a detailed log is maintained, according to the conditions for the protection of personal data and the legislation in force.
Yuboto Ltd. will take comprehensive, timely and proper action to maintain and ensure the availability of yuboto.com. Nevertheless, users accept that Yuboto Ltd. may modify and/or temporarily or permanently take the website off line, in whole or in part, with or without prior notification, considering that availability may be affected by user equipment, network provider activity, the number of users on the website at any given time, or other causes. Therefore, Yuboto Ltd. bears no responsibility for any kind of damage (compensatory, consequential, due to negligence, contractual, etc.) resulting from the use of the website or user inability to access it, from part or the whole of the website being off line, from the services being delayed, undelivered, interrupted or experiencing poor reception, from content loss, and from any kind or error. In any case, Yuboto Ltd. reserves the right to temporarily or permanently take the website off line, in whole or in part, at any time for maintenance or updates or any other reason.
IV. TERMS OF TEMPORARY OR DEFINITIVE SENDER ID DEACTIVATION
a) Temporary Account Deactivation Right (without monthly charge)
For the months when the user’s business does not send message campaigns, Viber allows the users to temporarily disable their account. For example, if the users know that they will not send campaigns during August, they must notify us in writing by the 15th of the previous month (July) in writing sot that Viber temporarily disables the account and does not charge this month. The Temporary Disable feature can be used for up to 3 months within a year and through the end users’ OCTAPUSH account. Temporary shutdown on July 16 will temporarily disable in September, and in this case, August will be charged as normal.
b) Permanent Account/Sender id Deactivation
The permanent Account/Sender id deactivation requests for the sender id that the user wishes to disable the 1st day of the following month, must have been made through the user’s OCTAPUSH account until the 15th of the previous month of the month. In this case, the user’s account will be deactivated from the 1st of the following month and the monthly minimum fee will not be charged. If the deactivation request is made after the 15th of the month, according to Viber's policy, the user will be billed for minimum monthly consumption and the next month as well.