10TEL, LLC. is committed to protecting your personal data and respecting your privacy. In this Privacy Policy, we describe how we collect and process your personal data. The Privacy Policy also describes your rights towards us and how to exercise them. 

Please contact us at sales@10tel.com should you have any questions about this Privacy Policy or in general regarding your personal data. 

THIS PRIVACY POLICY IS RELEVANT FOR ANYONE VISITING OUR WEBSITE, USING OUR SERVICES, PRODUCTS OR OTHERWISE INTERACTING WITH US. IT IS IMPORTANT THAT YOU READ AND UNDERSTAND OUR PRIVACY POLICY BEFORE USING OUR SERVICES AND PRODUCTS. 

10TEL, LLC. is part of the portfolio of companies held by Identidad Group. Notwithstanding that portfolio relationship, 10TEL, LLC. is an independent legal entity, maintains its own corporate documentation, and acts autonomously in providing its services and in processing the personal information described in this Privacy Policy. Accordingly, all references in this document to “10TEL” refer exclusively to 10TEL, LLC., in its capacity as data controller and/or processor, and not to Identidad Group or to any other company in its portfolio. 

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 our website, download our app, interact with electronic advertisement, use our services, make a purchase, contact us and use our customer portal. 

Categories of personal data we may collect and process: 

Registration and account information: your phone number, name, email, profile picture, address, password, time zone, language and currency. 

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 10TEL 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 Nauta services, of all your contacts (whether they are a 10TEL customer or not – but only name, phone number and Nauta 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 other activities in relation to 10TEL, such as information about when you registered to use our services, how you use our services, items you purchase, 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 calling and receiving party, the start time, call duration, messages, mobile money top-ups, delivery notices), log files, and diagnostic, crash, website, and performance logs and reports. 

Location Information: We collect device location information. 

Customer support and social media: If you use our Customer Support service, interact with us on our social media channels, or communicate with us 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 and other financial information corresponding to your selected method of payment. 

The data that is collected we use for different purposes in accordance with the list below. Basically, we use the data to provide, perform and improve our services. 

How do we use it? 

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. 

To conduct payment for services. 

Marketing, product and customer analysis to improve our services and to optimize our offer to customers. 

Product and customer analysis for internal operations, including troubleshooting, data analysis, testing, research and statistical purposes. 

To carry out risk analysis, fraud detection and risk management, to prevent misuse of the services to keep the services safe and secure. 

To improve our services and for general business development purposes, such as developing new products and features and explore new business opportunities. 

To comply with applicable laws and regulations (for example bookkeeping, lawful intercept). 

To communicate with you in relation to our services and to provide customer support. 

To establish, exercise or defend a legal claim or collection procedure 

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 sales@10tel.com. 

10TEL also implements reasonable technical, administrative, and organizational measures to protect the credentials used in its integrations with the LinkedIn and Meta APIs. Such measures may include encryption of information in transit and at rest, role-based access controls, secure authentication mechanisms, protection of API credentials and tokens, access monitoring, and security procedures designed to prevent unauthorized access, alteration, disclosure, or destruction of information. Access to such credentials is limited to authorized personnel and systems responsible for operating 10TEL’s services. 

3 – Sharing Information 

We work with carefully selected third-party service providers (or group companies) to operate, provide, improve, understand, customize, support, and market our 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, 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 10TEL or a group company or corporate restructuring or as a result of a change of control of 10TEL 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. 

3A – Integration with the LinkedIn and Meta APIs 

10TEL uses an internal social media management tool (OneSocial) that connects, through the official LinkedIn and Meta (Facebook and Instagram) APIs, exclusively to social media accounts and pages owned by 10TEL, LLC. This tool is used to publish content, view engagement metrics (analytics), and manage 10TEL’s presence on those social networks. 

This functionality is for 10TEL’s internal use only. 10TEL does not offer, sell, license, or distribute this tool to third parties, clients, or external users, and does not use it to manage social media accounts owned by third parties. 

Access to 10TEL’s LinkedIn and Meta accounts occurs solely through the official authentication and authorization (OAuth) mechanisms provided by each platform, and under the permissions (“scopes”) expressly granted by 10TEL, LLC. as the holder of those accounts. 

10TEL, LLC. may revoke that authorization at any time from the settings of the corresponding account or from the tool’s own settings. 

Information obtained through these APIs — including profile information for the managed pages, analytics metrics, publications, and engagement statistics — will be used by 10TEL exclusively to manage its own social media presence, in accordance with the policies, terms, and conditions of each platform and applicable data protection regulations. 

10TEL does not sell, redistribute, or share with unauthorized third parties any information obtained through the LinkedIn or Meta APIs. 

Information obtained through those APIs will not be used for unauthorized profiling, advertising directed at third parties, or any purpose other than managing 10TEL’s own accounts as expressly authorized by each platform. 

4 – Communications and notifications 

10TEL may use your personal data to communicate 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 and improving our services. 

10TEL 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 10TEL and the services, including new products, campaigns, promotions and payment methods. 

If you don’t want to receive promotional messages from 10TEL you can unsubscribe by following the instructions in the promotional message you have received or by contacting our customer support at sales@10tel.com. 

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 sales@10tel.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 10TEL and from you to 10TEL. 

5 – Changes to the Privacy Policy 

We are constantly innovating and looking for new ways to improve our services. We therefore reserve the right to update or modify this Privacy Policy at any time, with or without notice, to reflect such improvements or any other changes to our business or in order to comply with applicable data protection legislation. 

Our Privacy Policy is always available on our website so that users, at all times, can be aware of what personal data we collect, how and for what purpose the data is processed and under what circumstances such information may be shared. You are advised to review the Privacy Policy periodically so that you are aware of any modifications. If you do not agree with the terms of the Policy, you should not use the services. 

6 – Data retention 

Collected personal data is kept for as long as it’s needed for us (however no longer than two years and 10 months after your account was closed) unless we are legally required to keep the data in our records for a longer period. When 10TEL saves data for other purposes than contractual obligations (for example to fulfill book keeping requirements or requirements to keep records of phone calls for lawful intercept) we only keep the data for as long as it’s necessary and legal for each purpose. 

6A – Retention of LinkedIn and Meta Credentials 

Authentication credentials and access tokens issued by LinkedIn and Meta for 10TEL’s own accounts are stored securely, are protected using appropriate technical and organizational security measures, and are retained only for as long as the corresponding integration remains active. 

If 10TEL deactivates or revokes an integration, or it is no longer needed, the associated credentials will be securely deleted in accordance with 10TEL’s internal security procedures. 

Data obtained through these integrations will be retained only for as long as necessary to manage 10TEL’s social media accounts, and will be deleted or anonymized once the integration is revoked or the data is no longer needed. To request the deletion of any data obtained through these integrations, data subjects may contact 10TEL at sales@10tel.com. 

10TEL implements reasonable technical and organizational procedures to ensure the secure deletion of information and to prevent unauthorized access during storage or destruction processes, limiting access to such credentials to authorized personnel and systems only. 

7 – Your rights to access, rectification and erasure 

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 10TEL 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 10TEL to keep the data anyway, that stops 10TEL 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. 

If you would like to exercise the rights to your personal data or should you have any other questions in connection with this Privacy Policy, please contact us at sales@10tel.com.