- "User Data" means Personal Data relating to a legal or natural person that is necessary to subscribe to our Platform (as defined below) and that are authorized by us to access and use the Platform (collectively, "User", "you" or"your").
- "Visitor Data" means Personal Data relating to visitors of the website www.telemetryapp.io (hereinafter the "Website"), and any other prospective user who visits or otherwise interacts with our Website, or receives emails or communications under our control (collectively, "Visitor", "you" or"your").
Telemetry is a software that provides Users with advanced search capabilities and analytics for Telegram©. It allows Users to search for content, such as messages, files, and contacts across public Telegram© channels and messages, and to track their usage patterns over time (hereinafter "Platform").
While you are accessing, browsing, navigating and using the Website and the Platform, you communicate your Personal Data to Telemetry, as a data controller.
WHAT PERSONAL DATA DO WE PROCESS ABOUT YOU?
Collection Of Personal Data - General Provisions
We hereby inform you, and you hereby acknowledge that you have no legal obligation to provide us with any Personal Data when you use the Website and the Platform, and the provision of it is solely based on your free will.
Personal Data That You Provide Us With
We process the following categories of personal data directly from you through the Website:
- User Data
- Identification data (first name, last name)
- Contact details (email address)
- Visitor Data
- Contact details (email address)
- Data related to your exchange with Telemetry for contact requests (e.g., date and subject of your contact requests, exchanges with our services)
- User Data
Personal Data That We Collect Automatically From You
Each time you visit our Website or use our Platform we may automatically collect the following data through cookies and other tracking technologies:
- Electronic network activity information, (e.g., connectivity; date and time of the use; time and length of the use; location, device data (like type, OS, device id, browser version, locale and language settings used, operating system); activity log; session recordings; log-in credentials to the Platform).
FOR WHAT PURPOSES DO WE USE YOUR PERSONAL DATA?
We may process the following categories of Personal Data through the Website and the Platform for the following purposes:
Purposes Example of use of User Data Legal Basis Creating and managing your account
- to create your personal account;
- to provide and manage authentication;
- to authenticate yourself on the Website and access our Platform;
- to update your account.
Performance of the contract Managing your subscription to our Platform
- to pay our Platform or use the free trial;
- to manage your subscription including contacting you;
- to provide you with our services;
- to provide support and technical assistance.
Necessary for the performance of the contract concluded between Telemetry and User
Purposes Example of use of User Data Legal Basis Managing contact requests
- to answer your questions;
- to contact you if necessary;
Legitimate interest of Telemetry to manage its contact requests
All types of Personal Data:
Purposes Example of use of User Data and Visitor Data Legal Basis Marketing and promotional purposes
- to send you marketing communications;
- to receive newsletters.
Your consent Improving the Website, the Platform
- to evaluate, develop, enhance, analyze and improve the Website and the Platform;
- to facilitate your navigation of the Website.
Legitimate interest of Telemetry to improve its Website, its Platform and User’s and Visitor’s experience Supporting and enhancing our data security measures
- to monitor, investigate bugs, and improve our Website and Platform;
- to prevent and mitigate the risks of fraud, error or any illegal, criminal or prohibited activity.
Legitimate interest of Telemetry to secure its Website, its Platform and User’s and Visitor’s experience Pre-litigation or litigation management
- to take action against any identified security breach;
- to manage any dispute or litigation.
Legitimate interest of Telemetry in defending its rights and interests Compliance with legal and regulatory obligations
- to perform any reporting and notifications obligations we may be subject to, to competent governmental agencies and authorities;
- to process your requests to exercise your rights.
Legal and regulatory obligations to which Telemetry is subject
WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
We may share your Personal Data with the following recipients:
Recipients Purposes Service providers and sub-contractors
(including hosting, data security services, billing and payment processing services, fraud detection and prevention services, product analytics, session or activity recording services, remote access services, content transcription and analysis services, performance measurement, content and data enrichment providers, insurers)
To perform services on our behalf or complementary to our own. Depending on each of their specific roles and purposes in facilitating and enhancing our Website and/or Platform, and may only use the Personal Data as determined in our agreements with them. Governmental, administrative or judiciary authorities In case of a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations.
Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
Lawyers and all interested parties In the case of the management of possible disputes and other legal matters where appropriate Other third parties In connection with any proposed or actual reorganization, restructuration, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Telemetry business, assets or stock (including in connection with any bankruptcy, insolvency or similar proceedings)
HOW IS YOUR PERSONAL DATA TRANSFERRED OUTSIDE OF THE EUROPEAN UNION/ECONOMIC AREA/UNITED KINGDOM AND ISRAEL?
How Is Your Personal Data Transferred Outside Of Israel?
When we transfer Personal Data from the State of Israel to a third country outside Israel, the transfer takes place on the basis of:
- To a country declared as offering equivalent level of protection by the Israeli Privacy Protection Authority; or
- you consent to transfer your Personal Data to other jurisdictions, understanding that in some countries the level of protection may be lower than the level under Israeli law.
How Is Your Personal Data Transferred Outside Of The European Union ("EU")/ European Economic Area ("EEA")/United Kingdom ("UK")?
When we transfer Personal Data from within the EU/EEA/UK to countries or international organizations that are based outside the EU/EEA/UK, the transfer takes place on the basis of:
- an adequacy decision by the European Commission or the Information Commissioner’s Office ("ICO"), as applicable; or
- in the absence of an adequacy decision other legally permitted safeguards such as standard contractual clauses ("SCCs") for the transfer of Personal Data to third countries or UK addendum, as applicable and supplementary measures, if required.
HOW LONG DO WE STORE YOUR PERSONAL DATA FOR?
We retain Personal Data for as long as we deem it as reasonably necessary in order to maintain and expand our relationship and provide you with our Website and Platform, as required by applicable laws and/or to fulfill our legitimate interests; or to protect ourselves from any potential disputes and/or as permitted by applicable laws.
If you have questions or concerns regarding retention period, please contact us at firstname.lastname@example.org.
HOW DO WE KEEP YOUR PERSONAL DATA SECURE?
Telemetry has implemented technical and organizational measures to protect Personal Data, in particular against potential data breaches, either by accident or unlawfully, and against the destruction, loss, modification, unauthorized access or divulgation. However, we do not promise or guarantee that any Personal Data will be absolutely protected from unauthorized disclosure or use.
We restrict (and require our service providers to restrict) access to Personal Data to personnel who need to know that Personal Data to facilitate the operation of the Website and/or provide our Platform. If you have found a vulnerability or would like to report a security incident, you may send an email to email@example.com.
WHAT RIGHTS DO YOU HAVE REGARDING YOUR PERSONAL DATA?
Individuals have rights concerning their Personal Data. At any time, you may contact us at: firstname.lastname@example.org. and request to know what Personal Data we process about you. We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by applicable laws).When you ask us to exercise any of your rights under this Policy and the applicable laws, we may need to ask you to provide us with certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Data which is related to others that you are not authorized to receive, and to ask you questions to understand better the nature and scope of data that you request to access.
We may redact from the data we will make available to you any Personal Data related to others.
Information For Israeli Data Subjects
- review your Personal Data that we process
- update, amendment, and deletion of Personal Data which is incomplete or outdated.
Information For EU/EEA/UK Data Subject
If you are based in the EU/EEA/UK, you are entitled to request us to:
- access your Personal Data in order to obtain clear, transparent and understandable information on how we process your Personal Data and on your rights (as provided in this Policy), as well as a copy of your Personal Data;
- rectify your Personal Data in case your Personal Data are obsolete, inaccurate or incomplete;
- object the processing of your Personal Data when the processing is based on Telemetry’s legitimate interest. Telemetry will no longer process your Personal Data unless Telemetry demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, such as the respect of a legal obligation (e.g. legal obligation involving the retention of documents), or for the establishment, exercise or defense of legal claims; in certain circumstances under applicable laws, restrict the processing of some of your Personal Data during a limited period of time;
- withdraw your consent when it has been obtained and processing is based on consent;
- in certain circumstances under applicable laws, request data portability, meaning that you can receive the Personal Data originally provided by you in a structured and commonly used format or that the data subject can request the transfer of the Personal Data provided by him or her to another data controller;
- in certain circumstances under applicable laws, delete your Personal Data (also known as the right to be forgotten);
- lodge a complaint with your national data protection authority.
If you have a complaint about how we use your Personal Data, we would always prefer you to contact us first. However, you may also make a complaint to your local data protection authority in the EU/EEA/UK. If you are unsure which data protection authority to contact, please contact us at email@example.com..
WHAT IS OUR POLICY REGARDING MINORS?
The Website and our Platform are not intended for persons under 18 and we do not knowingly collect and process Personal Data relating to minors under 18, except any mentions of minors under 18 included in Telegram©. If these age requirements are not met, you are required to avoid using the Website and/or the Platform.