N.C. NET-CONNECT (CY) LTD (hereinafter referred to as “NCCY” or “us”), headquartered in Riga Feriou, 2 Limassol Center, Block B, 4th Floor, Flat/Office 406, 3095, Limassol, Cyprus, registered at the Registrar of Companies and Official Receiver Nicosia Cyprus in 2013 under number HE 321879  having VAT number CY 10321879R, introduces you to this Policy on the use of personal data to explain how we process and protect personal data.

​

1. To whom does this policy apply?

 

This policy applies to the processing of personal data of:

• Visitors to www.join-sms.com ("Visitors");

• Our contractual partners such as suppliers, customers ("Business Partners").

 

2. What data do we collect about you?

 

We collect and process your personal data as follows:

• from the information you provide us by filling in the contact and offer form on our website;

• by correspondence with us by telephone, e-mail or in any other way.

 

The information you provide to us may include your name, address, email address and telephone number, as well as other information as appropriate.

 

Through our work on the site, we will not collect or process sensitive personal data about you (ie information about racial or ethnic origin, political opinions, religion or philosophical beliefs, health, sex life or sexual orientation), unless which:

• we are obliged to do so by law; and / or

• if you have given us your explicit consent separately.

 

If you voluntarily provide us with personal data (including sensitive personal data) through your interaction with the site www.join-sms.com  or by correspondence with us by phone, e-mail or any other In this way, of our own free will and not at our request, we will be able to delete such personal data from our systems if we do not consider that their processing is necessary for a legitimate purpose of the NCCY.

 

Every time you visit the site www.join-sms.com , we automatically collect the following data:

• technical data, for example this may include the IP address used to connect your computer to the internet, login information, browser type and version, time zone setting, browser extension types and versions (plug-ins), operating system and platform , device type and mobile device brand; this data is collected and processed on our behalf, through third-party cookies;

• data about your visit, for example this may include data about the URL, sequence of clicks to, through and from the site www.join-sms.com (including date and time), information or services that you have viewed or searched the site.

 

3. What are the purposes of the processing of personal data and what is the legal basis for the processing?

 

We may process your personal data in the following cases:

• for communication purposes when it is necessary to respond to any requests received through the contact and offer forms on the website www.join-sms.com , by phone, e-mail or in any other way;

• for communication purposes when we need to take the necessary steps to conclude a contract with you or the company you represent;

• for communication purposes when we have to execute a contract that we have concluded with you or with the company you represent;

• for legal purposes when we have to comply with a legal obligation (for example: applicable laws in labor relations, accounting, auditing);

• when necessary for our legitimate interests (or those of a third party) and your interests (for example: to detect and prevent fraud or to ensure the security of IT and the computer network), unless your fundamental rights prevail to these interests.

 

When we request personal data in order to comply with legal or contractual obligations, the provision of such personal data by you is mandatory. This means that if such personal data is not provided, we will not be able to manage the contractual relations or comply with the legal obligations imposed on us. In all other cases, the provision of personal data is optional and you are not obliged to provide it.

 

We may process your personal data, such as identification data, contact details and address of residence, for the purpose of possible exercise of our rights in the future. This processing is based on our legitimate interest, and it is necessary to exercise our rights in the event of any disputes.

 

We will use your personal information as follows:

 

Visitors:

 

When it is necessary to respond to any requests received through the contact and offer forms from the site www.join-sms.com  we may use your personal data provided (name, surname, e-mail address or other personal data provided in message body).

 

This processing is based on our legitimate interest in knowing the person to whom the answer should be addressed.

 

Business partners:

 

In order to conclude or execute contractual relations with NCCY's business partners, as administrator or representative of the business partner, we may process your personal data, such as: name, surname, e-mail address, telephone.

This processing is based on:

• execution of a contract to which you, as administrator or representative of the business partner, are a party;

• legal obligations imposed on us;

• our legitimate interest.

 

As a Business Partner, we can provide you with communications about our new products and services. If you no longer wish to receive these communications, you can unsubscribe by sending us an e-mail to sms@join-sms.com .

 

4. To whom do we transmit personal data?

 

NCCY will not pass on (by sale or rental) to third parties your personal information.

 

Within the NCCY, only a limited number of staff members have access to your personal data according to the on a need to know basis. NCCY staff members have the right to manage personal data only on the basis of the instructions communicated by the NCCY, in connection with the responsibilities of the service.

 

Personal data may be disclosed to governmental authorities, tax authorities and / or law enforcement agencies, if required by applicable law or if necessary for the exercise of our rights, including conditions of use, or to protect our legitimate interests. (including the legitimate interests of third parties) in accordance with applicable laws.

 

Your personal data may also be disclosed to third parties as follows:

• To business partners, suppliers and subcontractors for the execution of all contracts we conclude with you, in order to provide the products and services requested by you;

• To service providers providing administrative, professional and technical support to the NCCY for IT support, security and business resources;

• To external consultants (ie lawyers, accountants, auditors), for specific purposes, when necessary.
   

The NCCY performs an appropriate prior assessment in the selection of third party service providers and requires those service providers to maintain adequate technical and organizational security measures to protect personal data and to process personal data only in accordance with the instructions specified by the NCCY. Service providers will have the right to use subcontractors in the provision of services to the NCCY, provided that each subcontractor complies with the same data protection obligations as the service providers.

 

5. What is the retention period of personal data?

 

We will retain your personal data for the period necessary to fulfill the purposes listed in this Policy or for the period required by applicable national law, in accordance with the applicable minimum legal retention periods and / or as long as is necessary to exercise our legitimate rights ( and the legitimate rights of others).

 

If you are a business partner, we will keep your personal data for the duration of the contractual relationship with you.

 

6. Transfer of personal data abroad

 

During storage in the NCCY, your data may be accessible and / or transferred abroad to other companies associated with the Net-Connect group.

 

7. What rights do you have?

 

You have the following rights under the relevant legislation:

• The right to access that personal data to confirm whether or not your personal data are processed by us, and to provide you with a copy of your personal data;

• The right to request the rectification or deletion of personal data;

• The right to request the restriction of the processing of personal data;

• The right to object to the processing of personal data;

• The right to request the portability of personal data;

• The right to withdraw your consent, at any time, without affecting the legality of the processing carried out on the basis of the consent before its withdrawal;

• The right to submit a complaint to the National Authority for the Supervision of Personal Data Processing.

 

Please note that your rights described above may be limited in certain situations and are subject to applicable laws and regulations regarding the protection of personal data.

To exercise one or more of these rights, please contact us at sms@join-sms.com .

 

8. Confidentiality of juvenile data

 

The site www.join-sms.com  does not knowingly collect personally identifiable data from persons under the age of 16. If the parent or legal guardian is aware that the minor in his / her custody has provided his / her personal data to the website www.join-sms.com , he / she must immediately inform NCCY, at the e-mail address sms@join-sms.com . If we discover that a person under the age of 16 has provided personal data through the site www.join-sms.com , then we will destroy this information on our servers immediately, unless in which the parent or guardian gives his / her explicit consent for the processing by the site of the child's personal data for the specified purposes.

 

9. Contact

 

If you have questions or ambiguities regarding the processing of your personal data by NCCY or through the website www.join-sms.com or if you wish to exercise one or more of your rights, you can contact us at by e-mail sms@join-sms.com .

 

Please do not disclose sensitive personal data (for example, information relating to racial or ethnic origin, political opinions, religious or other beliefs, health or trade union membership), social security numbers when contact us.

 

Note: We may periodically update this Policy and we will notify you of any changes by posting the new version on the website www.join-sms.com .

 

Please periodically review the Personal Data Policy page to keep up to date with new changes.

 

Last update: February 9, 2021.