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Data Protection Policy


Last updated: 01 April 2019

1.     Introduction

1.     We are committed to protecting the privacy of our website visitors, our application visitors ( ), or if you interact with us in any way, including our mobile applications that belong to and by NETT-TEL CO., LTD to be controlled.

2.     This Privacy Policy applies when we act as data controller in relation to the personal data of our website visitors and service users. in other words, when we define the purpose and way of processing this personal data. Therefore, it governs our data collection, processing and use practices. It also describes your decisions regarding the use, access and correction of your personal information. By using our website, our applications, you agree to the data practices described in this Privacy Policy. If you disagree with the data practices described in this Privacy Policy, you should not use our website or our applications.

3.     We may change this privacy policy from time to time. Whenever we make changes to this Privacy Policy, the changes will take effect 30 days after the release of the revised Privacy Policy (as stated by changing the date at the top of our Privacy Policy). We encourage you to read our privacy policy each time you access our services to stay informed about our information practices and how you can help protect your privacy.

4.     We will ask you to agree to the use of cookies in accordance with the terms of this Policy when you visit our website for the first time.

5.     In this policy, "we", "us" and "our" refer to NETT-TEL CO., LTD. More information about us can be found in Section 13.

2.     How do we use your personal information?

1.     This section explains what categories of data we process, the sources we use to obtain data, the purposes for which we process personal information, how we share your personal information, and how we facilitate third-party analysis.

2.     We collect information that you provide to us directly. For example, we collect information when you participate in interactive features of our services, complete a form, request customer support, provide contact or identification information, or otherwise communicate with us. The types of information we may collect include your name, email address, profile photo, phone number, mailing address, credit card information, and any other contact or identification information you provide. The legal basis for this processing is a legitimate interest.

3.     When you access or use our services, we automatically collect information about you. The legal basis for this processing is our legitimate interests, namely the monitoring and improvement of our website and our services. The information we collect includes:

1.     Log information: We record information about your use of our services, including the type of browser used, access times, displayed pages, your IP address and the page you visited before you navigate to our services.

2.     Device Information: We collect information about the computer you use to access our services, including the hardware model, operating system and version.

3.     Location Information: We may collect information about your device's location each time you access, use, or otherwise consent to the collection of any of our mobile applications.

4.     Information Collected by Cookies and Other Tracking Technologies: We use a variety of technologies to collect information. This includes sending cookies to your computer. Cookies are small data files stored on your device's hard drive or memory that help us to improve our services and experience, to see which areas and features of our services are popular, and to count visits. We may also collect information using web beacons (also called "tracking pixels"). Web beacons are electronic images that can be used in our services or emails to track visits or understand usage and campaign effectiveness.

4.     In order to give you access to the service, or to generally provide you with a better service, we may combine information from other sources (such as a third-party service whose application you have authorized or logged in to) and combine this with information we gather about our services. The legal basis for this processing is the consent.

5.     We use information about you for various purposes. The legal basis for this processing is our legitimate interests, namely the monitoring and improvement of our website and our services. The purpose includes:

1.     providing, maintaining and improving our services;

2.     Provide services that you request, process transactions, and send you related information.

3.     Send technical notifications, updates, security alerts, and support and administrative messages.

4.     Answer your comments, questions and requests and offer customer service.

5.     Communicate with you about news and information about our service;

6.     Monitor and analyze trends, usage and activities related to our services. and

7.     Personalize and improve our services.

6.     We may share personal information about you. The legal basis for this processing is our legitimate interests, namely the monitoring and improvement of our website and our services. The information we can give you about is as follows:

1.     With third parties and other service providers who need access to your information to perform work on our behalf, such as: B. e- conomic etc.

2.     If we believe disclosure is appropriate to comply with applicable laws, regulations, legal procedures or regulatory requirements;

3.     enforce applicable user agreements or policies, including our  Terms of Use  ; and to protect us, our users or the public from harmful or illegal activities;

4.     In connection with a merger, sale of NETT-TEL CO., LTD assets, financing or acquisition of all or part of our business to another company; and

5.     When we notify you through our Services (or our Privacy Policy), the information you provide will be disclosed in a specific manner and you will share that information.

6.     We may also pass on collected or anonymised information that you do not identify directly.

7.     We may allow third parties to provide analytical services. These third parties may use cookies, web beacons, and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, clicked links, and information for conversion. This information may be used by us and third parties to, among other things, analyze and track data, identify the popularity of certain content and other sites, and better understand your online activities. The legal basis for this processing is our legitimate interests, namely the monitoring and improvement of our website and our services.

3.     Disclosure of your personal data to third parties

1.     We may provide your personal information to other members of our group of companies, if reasonable.

2.     We may provide your personal information to our professional advisers for advice, as appropriate.

3.     We may provide your personal information to our suppliers and subcontractors where appropriate.

4.     We may enter your personal information to be processed by our payment service providers to process your payment.

4.     International transfer of your personal information

1.     Our office and our employees are located in Germany. According to the European Commission, the free movement of data within the EU / EEA is not restricted or prohibited.

2.     The hosting of our website and the application services are located in European countries. According to the European Commission, the free movement of data within the EU / EEA is not restricted or prohibited.

3.     Our subcontractors and external service providers are located in the following countries for which the European Commission has taken a "decision on adequacy" with respect to that country and the transmission of data to that country is protected by appropriate safeguards:

1.     United States of America

2.     China

3.     Hong Kong

4.     UAE Dubai

5.     Australia


5.     How long do we save your data?

1.     We will not retain personal data for longer than is necessary for the purpose of storing the data.

2.     The personal information we store to comply with our obligations and services to visitors to our website will be stored for at least one month and for a maximum of 24 months. This includes the data that our visitors provide to us through registration forms, registration forms, contact forms and communications via e-mail, telephone or other means of communication.

3.     The personal information we store to comply with our obligations towards users of our applications will be retained for as long as necessary. We will consider it necessary to retain the data when the data to be stored is required to provide the services our users expect from us.

4.     However, we will review the provisions in Section 5 every 6 months to see if the personal information we hold must be stored and kept.

5.     If we have retained personal information for more than 24 months and the personal information has not been used in any way or is not deemed necessary, we will delete the information.

6.     Safety

1.     We take reasonable steps to protect personal information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

2.     We subject personal data to pseudonymisation and encryption

3.     We ensure the constant confidentiality, integrity, availability and reliability of processing systems and services

4.     We ensure that availability and access to personal information can be promptly restored in the event of a physical or technical incident

5.     We have a process for periodically reviewing, evaluating and evaluating the effectiveness of technical and organizational measures to ensure the safety of the processing

6.     We ensure that our databases are accessible only via encryption keys, and we have measures and B. lock all security data. In addition, for security reasons, all credentials are routinely revoked and reissued.

7.     biscuits

1.     Most web browsers accept cookies by default. If you prefer, you can usually set your browser to remove or reject browser cookies. Please note that the removal and rejection of cookies may affect the availability and functionality of our services.

2.     Cookies generally do not contain information that personally identifies a user, but may store personal information about you, and that information may be linked to other information stored about you if the information contains cookies.

3.     We use cookies in the following cases:

1.     Identify you as a visitor to our website to provide you with relevant information.

2.     To determine if you are logged into our application to provide you with our services through our application.

3.     In security cases where cookies may help determine if credentials are used fraudulently and to protect our website and the services provided by our applications.

4.     To identify you as a user who has previously interacted with us online and has chosen to receive advertising communications from us in order to provide you with relevant and necessary information.

5.     Analyze the use and performance of our website and applications to provide our visitors and users with the best possible experience.

6.     Retention of the consent given to us by visitors and users of our website and applications with the aim of providing you with the service and functionality that you require from us as a visitor or user.

8.      Opt-in / Opt- out

1.     When you sign up to our website to learn more about our services, we make sure that you have an easy-to-understand Opt -In solution where you can opt to receive communications.

2.     The opt -in form clearly describes the purpose for which we use the information you provide to us.

3.     If you do not agree to receive communications from us, you will find it easy to unsubscribe by simply telling us that you no longer wish to receive further communications from us.

4.     If you refuse to refuse to receive communications from us, and this will prevent us from providing you with the service you have requested and / or paying us, we will inform you that we can no longer do so To provide you with our services.

5.     If you are a visitor to our site and have chosen to receive promotional emails from us, you also have the option to disable the receipt of promotional emails from us by following the instructions in the emails we send with promotional emails.

6.     You may instruct us not to process your personal information for marketing purposes.

9.     Your rights

1.     You have the right to instruct us to provide you with the information we have about you.

2.     If permitted by law, we may withhold personal information about you if you ask us to provide you with all the information we have about you.

3.     Under the Data Protection Act you have an access right as described here

4.     Under the Data Protection Act, you have the right to rectification as described here

5.     Under the Data Protection Act you have the right to delete, as described here:

6.     Under the Data Protection Act, you have the right to restrict processing, as described here:

7.     Under the Data Protection Act, you have the right to complain to a regulator as described here:

8.     Under the Data Protection Act, you have the right to data portability, as described here:

9.     Under the Data Protection Act you have the right to object as described here

10.  Our details

1.     Our website and applications are the property of NETT-TEL CO., LTD ApS

2.     Our company is registered with the authorities in Germany and Hong Kong and China.

3.     Our company is Hong Kong, which is also our main business, Europe Service ALADIN MARKETING GmbH, China Service YIWU NYNEL NETWORK TECHNOLOGY CO., LTD.

4.     You can contact us in the following ways:

1.     By mail to our address as described in contact on our website.

2.     With our registration, contact or registration form on our website.

3.     By phone: as described in contact on our website.

4.     By email to  or  .

11.  Our data protection officer

1.     The contact details of our data protection officer are as follows: as described in contact on our website.