Privacy Notice
Privacy Notice and
processing of Personal Data at Icetrak Limited
Icetrak Limited
(“Icetrak”) is responsible for storing and processing Personal Data on behalf
of individuals and organisations. Icetrak shall process Personal Data within
applicable laws and regulations. This privacy notice provides information about
Icetrak’s processing of personal data.
Terminology
·
Data
Subject is an identifiable
natural person.
·
Data
Controller is the
organisation that defines the purpose(s) for the processing of Personal data
and has an agreement with the registered Data Subject.
·
Data
Processor processes Personal
Data on behalf of a Data Controller
·
Personal
Data is any data that
directly or indirectly is linked to an individual (Data Subject).
·
Traffic
Data is data generated
through the use of a network. As an example, when an individual is using the
mobile network, information about who is sending and receiving a message or a
phone call, start and end time, and the location of the mobile phone is
generated. If traffic data directly or indirectly can be linked to you as an
individual, these are classified as Personal Data. Icetrak for example uses some
Traffic Data for billing purposes.
·
Anonymous
Data is data where all identifying
items have been removed making it impossible to associate the data with an
individual. Icetrak for example removes all sms message content from message
logs after seven days leaving only the mobile number as Anonymous Data.
·
The
Processing of Personal Data
is any use of Personal Data, including collecting, storing, modifying,
transferring or deleting.
Icetrak as a Data
Processor
The data about an
individual (Data Subject) that we process as a Data Processor depends on which
of our services are used by the Data Controller.
Icetrak will only
process Personal Data to provide services to the customer, and in accordance
with the customer’s instructions. Upon termination of the agreement or
instructions from the customer, we will delete or return the Personal Data
processed under the agreement, unless otherwise required by law.
Examples of Icetrak
data processing
·
Sending of messages
like SMS or email from our customer (Data Controller) to the end user (Data
Subject).
·
Producing customer
usage reports of messages sent and received
·
Monitoring of traffic
to ensure message delivery and system stability but not monitoring of personal
data.
·
Manage Data
Subject consents.
Depending on the
service and the customer’s use of the service in question, Icetrak may as a Data
Processor process Personal Data within the following categories
·
Basic Personal
Data – name, contact details (such as email or phone number).
·
Special categories
of Personal Data, such as data revealing racial or ethnic origin, political
opinions, religious or philosophical beliefs, trade union membership or health
data.
·
Location Data,
such as GPS, Wi-Fi location data and location data derived from Processor’s
network (that is not traffic data as defined below).
·
Traffic Data: Personal
Data processed in relation to the conveyance of communication on an electronic
communications network or billing thereof.
·
Data related to
content of communication, such as e-mails, voice mails, SMS/MMS, etc.
In some cases, Icetrak
will be able to link Personal Data collected by several different services, as
long as the data is collected for the same purpose.
Icetrak as a Data
Controller
The data about the
end user (Icetrak’s direct customer) that we process as a Data Controller
depends on which of our messaging services that are used.
Examples of
processing activities
·
Manage end user
profile.
·
Manage end user
consents.
·
Execute individual
rights.
·
Notify end user of
changes to services, terms and conditions or this privacy notice.
·
Respond to
enquiries or questions related to services, terms and conditions or this
privacy notice.
·
Mediate
information and membership offers.
Depending on the
service and the end user’s use of the service in question, we may as Data
Controller process Personal Data within the following categories
·
Basic Personal
Data – name, contact details (such as email or phone number).
·
Special categories
of Personal Data, such as data revealing racial or ethnic origin, political
opinions, religious or philosophical beliefs, trade union membership or health
data.
·
Location Data,
such as GPS, Wi-Fi location data and location data derived from Processor’s
network (that is not traffic data as defined below).
·
Traffic Data:
Personal Data processed in relation to the conveyance of communication on an
electronic communications network or billing thereof.
·
Data related to
content of communication, such as e-mails, voice mails, SMS/MMS, etc.
In some cases, Icetrak
will be able to link Personal Data collected by several different services, as
long as the data is collected for the same purpose.
Legal basis for Icetrak’s
processing are:
·
To fulfil the
agreement for use of a service provided by Icetrak to the end user, e.g. in
relation to management of the user profile or memberships and to notify end users
of changes to, or respond to enquiries related to services, terms and
conditions or this privacy notice.
·
To pursue Icetrak’s
legitimate interests (provided always that the interests of the data subjects
do not override such interests), e.g. in relation to improve the services or
the user experience, to establish, exercise or defend a legal claim, to prevent
loss or damages to Icetrak or any third parties or to prevent any actions that
may compromise Icetrak or a third party’s property or the personal data of the
other users of the services.
·
Consent, e.g. in
relation to marketing of Icetrak’s services.
·
To comply with a
legal obligation to which Icetrak is subject, e.g. continued storage due to
statutory rules of storage for accounting purposes.
The end user can by
requesting in writing at any time
·
Withdraw consent
to processing activities based on consent.
·
Access Personal
Data.
·
Amend Personal
Data.
·
Request deletion
of Personal Data.
·
Request
restriction of, or object to, processing.
·
Request export of Personal
Data.
·
Terminate the
agreement.
Icetrak will
retain your Personal Data for as long as it is necessary to fulfil the purposes
for processing as defined in the terms and conditions in the agreement between Icetrak
and our end user and will as a main rule retain Personal Data until
cancellation of the agreement or until end users request deletion. Please note
that legal obligations, e.g. statutory rules related to storage for accounting
purposes, may make it necessary to store Personal Data after cancellation of
the agreement. Continued storage may also occur where such storage is necessary
for the purposes of legitimate interests pursued by Icetrak, including, but not
limited to, the establishment, exercise or defence of legal claims.
With whom do we share
data?
By the nature of
the networked messaging services delivered by Icetrak, Icetrak may disclose subsets
of personal data to third party vendors and hosting partners who perform
services for Icetrak, in order to be able to deliver the services. These third
party vendors will only use the Personal Data for the purposes they were
collected, and in order to perform their services towards Icetrak. The
relationship to such third party vendors will be governed
by a Data Processing Agreement.
The disclosure of
Personal Data to public bodies may occur if and to the extent required by law
and current regulations.
How do we use
cookies?
Icetrak uses
cookies and similar technologies on our websites. Cookies help us to determine
the most popular parts of our websites, which pages are visited and for how
long. The data is used for development and analysis of services but not for
marketing or promotional purposes.
How do we protect
Personal Data?
Safeguarding Personal
Data is of the utmost importance to Icetrak. We therefore continuously work to
protect Personal Data. Our security policy embraces protection for personnel,
data, IT infrastructure, internal and public networks, as well as office
buildings and technical facilities. Special attention is given to information
such as Personal Data.
Our security work
aims to balance risk exposure, business value, available technology,
vulnerabilities, and threats in order to comply with applicable laws,
regulations as well as with contractual demands. Icetrak strives to implement
security measures by setting appropriate levels of protection for Personal Data
and by so preventing disclosure of Personal Data to unauthorised parties,
externally and internally.
Right to lodge a complaint
with a supervisory authority
If you believe
that Icetrak’s processing of personal data infringes relevant data protection
regulations, you are entitled to lodge a complaint with the supervisory
authority of your habitual residence, place of work or place of the alleged
infringement, or other relevant supervisory authority.
Modifications to
this privacy notice
Icetrak reserves
the right to modify this privacy notice from time to time. The most recent
revision shall supersede any earlier versions. The current version of the
privacy notice will be available at Icetrak’s website or at request at all
times. We advise that you check the privacy notice from time to time, to keep
up to date with the current notice. We will notify you of any changes to the privacy
notice that you are entitled to receive information about or which requires
your consent.
Contact
information
If you are a
direct customer of Icetrak, please contact our Customer Support: