DATA PRIVACY NOTICE CONCERNING THE PROCESSING OF YOUR PERSONAL DATA BY THE FROG APPLICATION
The OTE Group attaches particular importance to protecting your personal data and complies with the transparency principle regarding data processing. If you would like general information about how OTE and COSMOTE process your personal data, please read the General Data Privacy Notice which can be found here.
This text provides more specific information about how your personal data from using the Frog Application (hereinafter, the Application) is processed. Note that this document is a specific notice about the processing of your personal data for the purpose of providing the Service. This document shall be interpreted at all times in conjunction with the text of the General Data Privacy Notice.
1. Who is the Data Controller and how can I contact it?
The data controller is COSMOTE MOBILE TELECOMMUNICATIONS S.A. (COSMOTE) whose registered offices are at 99, Kifissias Ave., Marousi, Attica, tel. 13888 for household customers and 13818 for business customers.
2. Who can I contact about data privacy issues?
For information about your data privacy you can call the household customer care on 13888 or the business customer care on 13818 or you can fill out the online contact form at www.cosmote.gr/contact_us.
To exercise any of your rights you can send an email to customerprivacy@cosmote.gr or a fax to 2102511888 or a letter to COSMOTE Customer Care, 99, Kifissias, Ave., Marousi, GR-15124 putting “Exercise of personal data rights” in the subject line, accompanied by a copy of your ID Card, and stating your name-surname, mobile or landline number.
3. What categories of personal data do you process using the Application and for what purpose?
The Application enables users to manage their Frog tariff plan, by checking the balance on their pre-paid number, activating services or topping up airtime, for example.
To enable the Application to be used we process:
• Data you fill out for user authentication purposes. To authenticate you on the application, only your mobile number (msisdn) is required.
• Data needed to top up airtime by credit card, such as email address, mobile number, name-surname, password, alternative email address and/or mobile number.
• Data needed to use the application (such as the user’s connection number (msisdn)).
• Data resulting from the use of the application (such as error logs, information relating to navigation on the application). That information is sent in pseudonym form to Google which analyses it to help improve the functionality of the Application and resolve any technical bugs affecting its operations.
Note that pseudonym data means data from which a specific natural person (you) can no longer be identified without using additional information about you.
• Your contact details (e.g. mobile phone) for the purpose of sending updates via the Application relating to changes, news or special offers on fixed and/or mobile telephony products that are activated on the OTE and COSMOTE networks respectively, provided you have given consent for this as stated in section 7.
• Data relating to Frog services and/or requests and orders placed via the Application. Examples of such data are the phone number (msisdn), the mobile telephony subscriber ID (imsi), the prepaid connection balance, the prepaid number airtime expiry date, the last top-up date, and the available MB/SMS/Minutes balance.
• Data needed to personalize the application. Examples of such data are Favorite International Destinations, or Preferred Display Language stored in the Application.
• Data you provide to take part in competitions using the COSMOTE DEALS for YOU program.
• Data needed to use the Calling Tunes service (user registration, profile login, purchases and settings/options for the service): Mobile phone number, email, COSMOTE ID, date and time of purchase, Calling Tunes and Calling Tunes Unlimited subscription, Calling Tunes you have added to your Collection, contact numbers set to Calling Tunes, dates and times your Calling Tunes are heard.
4. Application permissions
Depending on the operating system installed, the Application may need to request additional permissions to access the following data on the subscriber handset on which it has been installed and operates:
• Contact data to use your contact’s photo as an Avatar Image, and to let you know which of your contacts are FROG subscribers.
• Location data (telecommunication network and/or GPS) to show your position on the map and to let you know about DEALS for YOU at nearby stores.
• SMS: Automatically read the code sent by COSMOTE via SMS to automatically login into the Application.
• Camera: Use the camera to take a photo that will be used as an Avatar Image in your profile.
• Internet: The Application requires internet access to contact COSMOTE’s systems and show information relevant to you (such as balance, balance expiry date, etc.).
• SIM Card details: Identification of your mobile telephony identification number (msisdn) and international mobile subscriber ID (imsi) used by your handset to automatically fill out your number in the login field.
• External memory: Access is needed to choose a photograph from your handset’s photo album, to change the Avatar Image, and to store your photograph if the Application is used to take a photo.
5. Push notifications
The Application sends notifications to your handset to let you know about Application functionality issues.
Moreover, if you have given your consent to create a personalized profile as described in point 7, you may receive personalized deals and/or advertising in the form of notifications.
If you don’t want to receive notifications, you can disable this feature in your handset’s settings.
6. How long do you retain my personal data?
COSMOTE retains your personal data, mentioned in paragraph 3 above, for as long as you have an active COSMOTE prepaid connection and for a period of 14 months after your Frog connection is deactivated. Any information regarding transactions entered into via the Application, such as airtime purchases, is retained for a period of 14 months from deactivation of your COSMOTE prepaid mobile connection.
Data generated while using the Application is retained for 14 months.
7. Will COSMOTE process my personal data for other purposes?
COSMOTE will not process your personal data for purposes other than the ones stated above. If COSMOTE wishes to use your personal data for other purposes, it will only do so after informing you and obtaining your express consent.
If you have given consent, COSMOTE may collect your data via the Application, to create a subscriber and user profile, so it can send you personalized offers and products based on your personal needs and preferences. The form you can use to give consent is available here.
In addition, COSMOTE uses application user behavioral analysis mechanisms by analyzing your pseudonym data. That allows us to ensure that your identity is not disclosed at any stage of the process. To be more specific, using Google’s Firebase (Google Analytics for Firebase) and Fabric tools, pseudonym data about use of the Application is collected, from which we draw useful conclusions about its operation (such as crash reporting, application user transaction statistics, etc.).
8. Who are the recipients of my personal data and for what purpose is it sent?
Your personal data may be sent to:
• Financial institutions via which your airtime balance is topped up.
• Third party companies we collaborate with to provide and support the Application namely:
o Desquared S.A. which supports the service. It is based in Greece. The data transmitted only relates to cases of technical support (such as to resolve technical problems).
o UPSTREAM TELECOMMUNICATION AND SOFTWARE SYSTEMS S.A. based in Greece. Data is sent to assist with the development, support and provision of the COSMOTE DEAL FOR YOU Program.
o MoEngage Inc. based in India, which follows the processing rules and security requirements specified by COSMOTE. Data is only transmitted for the purpose of providing personalized deals and advertising.
Those third party companies are sub-processors acting on COSMOTE’s behalf, which is to say associates of COSMOTE which have undertaken to perform a certain task by following our instructions and by implementing the OTE Group’s strict personal data processing procedures. In these cases OTE continues to be responsible for the processing of your personal data as Data Processor.
Your personal data is primarily processed by our associates for those purposes in Greece and the European Union (EU). If we collaborate with companies outside the EU, they will process your data only on our instructions and only if there is an adequacy decision from the European Commission or if they agree to appropriate terms which ensure a high level of safety when your personal data is being processed.
Other than processing via Desquared S.A., UPSTREAM TELECOMMUNICATIONS AND SOFTWARE SYSTEMS S.A. and MoEngage Inc., COSMOTE does not process or make public your personal data to third parties, save for cases where notification/dispatch is required by the applicable legislation.
9. What are my personal data protection rights as a user of the Application?
The rights you can exercise include:
Right of access: You are entitled to receive information about your personal data which we process (such as the purposes of the processing, the data types, the recipients it is sent to, the retention period) and to obtain copies of that data.
Right of rectification: You can ask for your data to be corrected (to have a wrong address or wrong contact details or ID Card No. corrected, for example).
Right of erasure: You can ask for your personal data to be erased if it is no longer needed in relation to the purpose for which it processed or where you withdraw the consent which was the basis for us collecting and processing it.
Right to restrict processing: You are entitled to limit the processing to a specific purpose (for example you can say “I don’t want to receive email updates for marketing purposes”).
Right to data portability: You are entitled to obtain the personal data you have provided to the company, in a structured, commonly used, readable format (for example you can request data held in the cloud).
Right to object to processing of your personal data in cases where you do not want your personal data to be processed.
To exercise your rights you can:
• Send an email to customerprivacy@cosmote.gr or
• Fax to 2102511888 or
• Letter to COSMOTE Customer Care, 99, Kifissias, Ave., Marousi, GR-15124, marked "Exercise of personal data rights"
accompanied by a copy of your ID Card and stating your name-surname and mobile or landline number.
You also retain the right to submit a written complaint to the competent supervisory body for data protection matters, namely the Hellenic Data Protection Authority (1-3, Kifissias Ave., Athens, GR-11523, +30 210 6475600, email: contact@dpa.gr).
COSMOTE will promptly respond to your requests free of charge, within one month of receiving the request. In exceptional cases, that deadline may be extended by 2 months if necessitated by the complexity of your request. In all events, we will let you know about the extension and the reason for the delay.
If we consider that your request is manifestly unfounded or excessive we reserve the right to ask you to pay a reasonable fee to have it examined, taking into account the administrative costs of doing so, or even to refuse to pursue the matter further.
10. What type of measures are taken to protect my personal data?
COSMOTE implements appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction or accidental loss and against unauthorized alteration, disclosure or access, and against all other unlawful forms of processing.
More information about this issue can be found in the General Data Privacy Notice.