TELOKA PTY LTD., operating under the name Teloka (www.TELOKA.com), acknowledges the significance of your privacy. This Privacy Policy outlines the methods by which we gather, utilize, share, and safeguard your personal information, commonly referred to as personal data. Additionally, this Privacy Policy informs you of your rights and options regarding your personal information and how you can reach us to get answers to your questions.
By registering an account or by utilizing or accessing any Teloka website, application, product, software, tool, data feed, and/or service (collectively referred to as the “Service”), you understand and agree with the terms outlined in this policy.
This Privacy Policy details the methods by which we gather, utilize, retain, and safeguard your personal information. Please read this Privacy Policy carefully.
Table of Contents:
1. Applicability of this Privacy Policy
2. Methods of Collecting, Disclosing, and Utilizing Personal Information
3. Types of Information Collected
4. Retention of Data
5. How We Use Information
6. Sharing of Personal Information
7. Your Rights
8. Data Transfer & International Data Transfer
9. Security Measures
10. Changes to This Policy
11. Children
12. Contact Information
1. Applicability of this Privacy Policy
This Privacy Policy is applicable to users of Teloka’s services worldwide, encompassing users of Teloka’s mobile applications, Partner Platform, websites, features, and other services, interactions (both online and offline) with Teloka, its employees, and job applicants (collectively referred to as the “Services”).
The Privacy Policy describes how Teloka gathers and utilizes data and is relevant to all Teloka users globally, except for those using a service governed by a distinct privacy notice. This Privacy Policy pertains explicitly to:
End Users: Individuals who engage with the Services through their Teloka account for personal purposes.
Business Users: Teloka provides services to entities (“Business Users”) who directly and indirectly provide us with End Customer’s personal information in connection with those Business Users’ own business and activities.
End Customers: Individuals who benefit from services requested by other Teloka account holders, such as when engaging in transactions with a Business User.
Job Applicants: Individuals who apply for a position at Teloka.
2. Methods of Collecting and Utilizing Personal Information
We gather information about you through various methods based on your interactions with us and our Services, which include:
Information you provide directly, such as when you create an account, subscribe to our communications, place an order, make a purchase, or contact us via phone, email, or other means.
Automatically using cookies, server logs, and similar technologies when you engage with us via our Services and/or through emails, under legal permissions or your consent.
From additional sources, including our affiliates, business partners, service providers, online social media platforms, and other third parties, as well as publicly accessible information. For instance, we may perform a background check if you apply for a job or become an employee.
Teloka categorizes data and information systems based on legal obligations, sensitivity, and business importance to ensure that information receives appropriate protection. The "data controller" refers to the entity that determines the purposes and methods of data processing. The "data processor" is an entity that processes personal information on behalf of and under the direction of the controller.
Teloka in its capacity as a data controller:
Teloka functions as a data controller by defining the objectives and methods for processing personal data. In this capacity, Teloka is accountable for ensuring that the processing of personal data adheres to relevant data protection regulations. The responsibilities associated with Teloka's role as a data controller encompass:
Direct Registrations: Teloka acts as the data controller when individuals register directly for the service. This is relevant in both contexts:
B2C Context: End users who register directly for Teloka's services.
B2B Context: Business Users or End Customers who sign up directly with Teloka.
Key activities:
Service Provision: Utilizing data to deliver Teloka's products and services.
Fraud Detection: Monitoring and identifying fraudulent transactions and activities.
Legal Compliance: Adhering to applicable financial, legal, and regulatory obligations.
Service Improvement: Enhancing and refining products and services through data analysis.
Job Application Management: Processing personal information from job applications.
Teloka functions as a data processor:
Teloka operates as a data processor in instances where it delivers services on behalf of and under the instructions of a Business User. This encompasses circumstances such as:
B2B Context for End Customers: Teloka functions as a data processor for information about the End Customers of Business Users within a B2B framework.
Service Execution for Business Users: In accordance with Business Users' directives, Teloka facilitates the creation of accounts and the distribution of eSIMs to End Customers.
In its role as a data processor, we recommend that users review the privacy policy of the relevant data controller (the Business User) to understand how their data is managed and safeguarded. Teloka strictly follows the instructions provided by the data controller and is dedicated to maintaining the confidentiality and security of the processed data in compliance with applicable data protection regulations and contractual commitments.
3. Types of Information Collected
The following provides various examples of the information we gather across different contexts and how we utilize that information.
Context | Types of Data | Primary Purpose for Collection and Use of Data |
Account Registration | When you create an account, we gather your name and contact details, including your email address. Additionally, we collect information regarding your activities while logged into your account. | We possess a valid interest in offering account-related features to our users. Accounts facilitate a streamlined checkout process and allow the storing of preferences and transaction history. Additionally, we may utilize this information to meet our contractual obligations to you. |
Biometric information | Biometric identifiers from photo IDs and selfies. | As legal requirements mandate, we collect and utilize biometric information with your explicit consent to verify your identity through eKYC. |
Business Users | We gather employees' names and contact details from our Business Users with whom we may interact, including email addresses, phone numbers, and physical addresses. | We want to communicate with our clients and discuss normal business operations, including projects, services, and billing matters. |
Necessary Online Tracking Technologies | We utilize cookies and clear GIFs. During website viewing, cookies are small data files transmitted from a website to a computer's hard drive. Clear GIFs are pixels that your browser retrieves when you visit a website. Tracking technologies may gather data regarding your browser type, operating system, Internet Protocol (IP) address (a unique number assigned to a computer when accessing the internet), domain name, click-activity, referring website, and/or a date and time stamp for visitors. | We possess a valid interest in making our website operate efficiently. |
Non-Essential Tracking Technologies | We may implement tracking technologies on our website, such as cookies or pixels, which gather analytics, monitor your interactions with our site, and enable us to engage in behavior-based advertising. These technologies can collect data regarding your browser type, operating system, Internet Protocol (IP) address (a unique number assigned to a computer when accessing the internet), domain name, click-activity, referring website, and/or a date and time stamp for visitors. Additionally, we or a third party may collect information over time and across various websites to deliver advertisements on our site or on other platforms. | Where required by law, we rely on consent to utilize third-party cookies. |
Demographic Information | We gather personal information, such as your age or geographical location. | We possess a valid interest in comprehending our users and delivering customized services. |
Job Applicants | When you submit an application for a job posting or become an employee, we gather the information required to evaluate your application or retain you. This includes your contact details, educational background, and job history. | We possess a valid interest in assessing candidates for potential roles within our workforce. In certain situations, the law also requires us to collect information about employees or applicants. Additionally, we have a legitimate interest in utilizing your information for adequate staffing and operational management of our workforce. |
Feedback/Support | When you offer feedback or contact us for assistance, we will gather your name and email address, along with any additional information you provide, to reply. | We possess a valid interest in obtaining and addressing your feedback or issues. |
Mobile Devices | We collect information from your mobile device, including unique identification information transmitted when visiting our website. | We want to recognize unique visitors and track their interactions with our website. |
Order Placement | When you place an order, we collect your name, billing address, shipping address, email address, phone number, and payment card number. | We utilize your information to fulfill our contract in delivering our Services to you. |
Partner Promotion | We collect information you provide as part of a co-branded promotion with another company. | We possess a valid interest in executing our promotional activities. |
Surveys | When you participate in a survey, we gather the information you provide. If the survey is provided by a third-party service provider, that provider's privacy policy applies to the collection, utilization, and sharing of your information. | We want to comprehend your perspectives and gather information pertinent to our organization. |
4. Retention of Data
We keep your personal information only for the duration necessary to fulfill the objectives specified in this Privacy Policy. This includes fulfilling any legal, accounting, or reporting obligations unless a longer retention period is mandated or allowed by law. In assessing the suitable retention period for personal information, we take into account factors such as the volume, nature, and sensitivity of the information, the potential risks associated with unauthorized use or disclosure, the purposes for which the data was collected, and whether those purposes can be met through alternative methods, along with relevant legal obligations.
5. How We Use Information
In addition to the purposes above and applications, we utilize information in the following manners:
To recognize you during your visits to our websites.
To deliver products and services or to facilitate returns.
To enhance our services and product offerings.
To optimize the checkout experience.
To perform analytics.
To communicate with you, including responding to and/or following up on your requests, inquiries, concerns, or feedback.
To distribute marketing and promotional materials, which may include information about our products, services, sales, or promotions, as well as those of our business partners.
To identify and safeguard against malicious, deceptive, fraudulent, or unlawful activities, including breaches of our policies and terms and conditions, security incidents, and threats to the rights, property, or safety of our company, users, employees, or others.
To troubleshoot, identify, and rectify errors that hinder the intended functionality of our website and services.
To fulfill our legal or regulatory responsibilities, to assert or exercise our rights, and to defend against legal claims.
For internal administrative functions and to facilitate the management of our relationships.
For any additional purposes to which you may agree from time to time.
While the sections above outline our primary reasons for gathering your information, it is essential to note that we often have multiple purposes. For instance, when you make an online purchase, we collect your information to fulfill our contractual obligations to you. Additionally, we retain your information due to our legitimate interest in being able to promptly and effectively address any inquiries regarding your order after the transaction has been completed. Consequently, your information is collected and processed in various contexts based on your consent, our contractual requirements, legal obligations, and/or our legitimate business interests.
6. Sharing of Personal Information
We may also reveal personal information in the following circumstances, in addition to the specific scenarios outlined in other sections of this Privacy Policy.
Affiliates and Acquisitions: We may share information with our corporate affiliates, which include our parent company, sister companies, subsidiaries, joint ventures, or any other companies under common control. If another company plans to acquire our organization, business, or assets, we will also share information with that company, including during the negotiation phase.
Other Disclosures without your consent: We may reveal information without your consent in response to subpoenas, warrants, or court orders or as part of any legal proceedings to adhere to applicable laws. Additionally, we may share your information to assert or protect our rights, respond to legal claims, and investigate, prevent, or address potential illegal activities, suspected fraud, threats to personal or property safety, or breaches of our policies. Furthermore, we may disclose your information to fulfill your request for product shipments or services provided by a third-party intermediary.
Partner promotion: Promotions may be available in collaboration with third-party partners. Should you choose to participate in a promotion sponsored by a third-party partner, the information you provide will be shared with us and the partner. This privacy policy does not regulate the partner's handling of your information.
Service providers: We may share your information with service providers. These providers assist us in managing our website and delivering services essential for the efficient operation of our business. Their roles include offering technical support, processing payments, and aiding in the fulfillment of orders.
Other disclosures with your consent: We may disclose your information with other third parties when we have received your consent or instruction to proceed.
7. Your Rights
Depending on your location and subject to applicable law, you may have the following rights:
You have the right to request disclosure of the personal information we collect, utilize, or share about you and details about our data handling practices. In specific limited situations, you may also request access to your personal information in a portable, machine-readable format.
Ensure accuracy and request corrections: You can ask us to correct any inaccurate personal information we hold about you. We depend on you to keep your personal information current and accurate. Our website provides the functionality to edit or remove your account profile. Should our website not allow you to update or correct specific information, please contact us at the address provided below to request modifications to your information. Please know that we may retain historical data in our backup files as the law allows.
You have the right to request the deletion or removal of the personal information we have gathered about you.
You may revoke your consent at any time: This refers to your entitlement to retract consent you previously provided for processing your data.
You have the right to object to processing your personal information when such processing is conducted legally and not based on your consent.
Online tracking: We do not acknowledge the “Do Not Track” signal. It is essential to understand that not all rights mentioned above are absolute and may not be applicable in every situation. In certain instances, we may restrict or refuse your request if permitted or mandated by law or if we cannot sufficiently verify your identity. We will not discriminate against individuals who choose to exercise their privacy rights as outlined by applicable law.
This section provides detailed information regarding specific rights. If you wish to submit a request to exercise any of the rights above or contest a decision we made concerning a data subject rights request, please contact us using the information provided below or our Contact Us page.
It is important to understand that, in compliance with legal requirements, we must verify your identity. Depending on the nature of your request, we may ask for details such as your name, the most recent item you purchased from us, or the date of your last transaction. Additionally, we may require you to provide a signed statement affirming your identity. Upon receiving a request, we will make reasonable efforts to provide, amend, or remove your personal information from our records.
In certain situations, you can appoint an authorized agent to submit requests to exercise specific privacy rights on your behalf. Suppose you are acting as an authorized agent for another individual. In that case, it is necessary to include a copy of a signed document that confirms your authority to act on their behalf.
What steps should I take to unsubscribe from marketing email lists?
The unsubscribe feature in your Profile Settings allows you to unsubscribe from marketing emails. To adjust your preferences, please log into your account and proceed to your Profile Settings. You can toggle the “I'd like to receive promotional emails” option to enable or disable it, ensuring your changes are saved. Your email address will be removed from marketing communications as soon as possible.
Should you have any inquiries about opting out of Teloka's marketing communications, do not hesitate to contact us at [email protected].
What is the procedure for deleting my account?
Please use the “Delete Account” option in your Profile Settings to delete your account. First, log into your account and proceed to your Profile settings. Select the “Delete Account” button and confirm your decision. We will process your request promptly or within one month if specific requirements are involved.
Additionally, please be aware that we may need to verify your identity and association with us before proceeding with your request.
At what point does Teloka resume data processing after receiving a deletion request or an objection to the processing?
In specific situations, Teloka may be legally obligated to retain and process your Personal Data even following a request for deletion or an objection to processing. For example, Teloka must retain certain personal information to comply with legal requirements related to Know Your Customer (KYC) regulations and payment transaction details.
8. Data Transfer & International Data Transfer
Teloka owns the Service, and is accessible both in Europe and internationally. (ASIA) Consequently, your information may be processed in a foreign jurisdiction where privacy regulations may not be as rigorous as those in your home country. However, whenever feasible, we strive to handle personal information using the same privacy principles mandated by the laws of the country where we initially received your information. By providing your personal information to us, you consent to the transfer, storage, and processing of your data in a country other than your country of residence, which may include but is not limited to, the United States. Should you require further details regarding our efforts to apply the privacy principles from one jurisdiction to data transferred to another, please contact us using the contact information below.
9. Security Measures
We adhere to widely recognized industry standards to safeguard your personal information. However, it is essential to note that no method of transmission via the Internet, mobile technology, or electronic storage can be deemed entirely secure. Consequently, while we strive to implement physical, electronic, and procedural measures to ensure the confidentiality of the information we gather online, we cannot assure its complete security.
Teloka users are responsible for maintaining the security of their passwords and credentials. Should you suspect that your interaction with us is no longer secure—for example, if you believe that the security of any account you hold with us has been compromised—please promptly inform us of the issue by contacting [email protected].
10. Changes to This Policy
We maintain the authority to modify the terms of this Privacy Policy at any time. In the event of significant changes to this statement or alterations in how we utilize your personal information, we will inform you by prominently displaying a notice of such changes on this page or our homepage or by sending you an email. We recommend that you review this policy each time you access one of our websites or applications. Our privacy policy includes an "effective" date and a "last updated" date. The effective date indicates when the current version became applicable, while the last updated date signifies when the current version was last meaningfully revised.
11. Children
Our services are not designed for individuals under the age of 13, and we do not intentionally gather personal information from unemancipated minors who are under 16 years of age without obtaining parental consent. Children under 13 are advised against submitting their personal information to us.
12. Contact Information
Should you have any inquiries, remarks, requests, or grievances regarding our privacy practices, or if you require this Privacy Policy in a different format due to a disability, please contact us using the contact information below. We will address your requests and provide you with further privacy information.
Email: [email protected]
