GDPR
2018-05-23 10:49
PRIVACY POLICY FOR HAMSPHERE

We recently updated our Privacy Policy to clarify how we protect your personal information in keeping with the EU’s new General Data Protection Regulation (GDPR).

This privacy policy describes how RingJoeBing Holdings Ltd (”we” or ”us”) collects and processes your personal data. Your integrity is important to us and we want to make sure that you always feel safe when you are sharing your personal data to us. In this privacy policy, we describe which personal data we process about you when you are visiting our website, using the HamSphere product, entering into a contract with us or otherwise have shown your interest for our services and offerings.


1. DATA CONTROLLER
The legal person responsible for the processing of your personal data is:

RingJoeBing Holdings Ltd
4 Naxou Street, 101
CY-1070 NICOSIA
CYPRUS
Phone: +357-22 768 555
Email: contact@hamsphere.com
Reg No: HE-186279
VAT No: 10186279Z


2. USE OF PERSONAL DATA
We use your personal data for the following purposes:

a) Provision of services: Personal data is used to enable RingJoeBing Holdings Ltd's provision of requested services, to provide you with optimized support and to communicate with you and inform about the services.

b) Marketing: Personal data is used for marketing purposes, such as adapting our communication with you based on your areas of interest and focus and to provide you with a relevant, straightforward and inspiring experience in relation to our communication with you, for example through newsletters.

c) Optimizing the user experience on our digital platforms: Personal data is collected through your use of our digital platforms. This data is used by us to optimize the user experience through customized content, and to develop and improve our digital platforms. This is described more in detail in our cookie policy. Furthermore, personal data is used to uphold the IT security.

d) Statistics and analyzes: Personal data is used to compile statistics and analyzes regarding the use of our services, use of our digital platsforms, customer satisfaction and traffic data to enable us to develop and further improve our services.

e) Surveillance: We are monitoring the HamSphere product and our other facilities in order to avoid and prevent outages in services, support emergency operations, document incidents, enable control of the servers, get an overview of potential server congestions on the servers, and to secure the quality of the automated payment methods (e.g. PayPal and DIBS).


3. CATEGORIES OF PERSONAL DATA
We may collect and process the following data about you for the following purposes:

a) Provision of services: Personal data: name, location coordinates lat/long, location name, Licensed callsign, e-mail address, customer number, contract number, receipt number, order number.

b) Marketing: Personal data: name, location coordinates lat/long, location name, Licensed callsign, e-mail address, customer number, contract number, receipt number, order number.

c) Optimizing the user experience on our digital platforms: Personal data: name, location coordinates lat/long, location name, Licensed callsign, e-mail address, customer number, contract number, receipt number, order number.

d) Statistics and analyzes: Personal data: name, location coordinates lat/long, location name, Licensed callsign, e-mail address, customer number, contract number, receipt number, order number.

e) Surveillance:
Personal data: name, location coordinates lat/long, location name, Licensed callsign, Customer number.


4. SOURCE
When we are collecting personal data from other sources than from you personally, such sources may be:

a) Online sources, for example social media or providers of information which is publicly available.

b) Authorities, providers of address directory assistance, providers of credit assessments, dept collection companies and partners, such as PayPal and DIBS.

The personal data collected about you may be derived from other parts of the EU/EEA.


5. LEGAL GROUND FOR THE PROCESSING OF PERSONAL DATA
Our processing of your personal data pursuant to the description above is based upon the folllowing legal grounds in relation to each of the below mentioned purposes:

a) Provision of our services

The processing of your personal data is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into such contract.

b) Marketing

Processing of your personal data to adapt our marketing communication to you is based on your consent.

c) Optimizing the user experience on our digital platforms

Processing of your personal data to optimize your experience on our website is based on your consent. Please see our cookie policy

d) Statistics and service development

Processing of your personal data is based on our legitimate interest to compile statistics and to perform surveys and analyzes for the purpose of ensuring the functionality and quality of our services.

e) Surveillance

Processing of your personal data is based on our legitimate interest to prevent accidents, assist in relation to emergency operations, ensure that our automated payment methods work correctly and to ensure identification in relation to recovery of debts.



6. DISCLOSURE OF YOUR PERSONAL DATA
We may disclose your personal data to the following categories of recipients:

a) Public authorities, such as the Police and the Tax Agency if they have a legal ground to be granted access to the personal data.



7. TRANSFER TO COUNTRIES OUTSIDE THE EU/EEA
RingJoeBing Holdings Ltd does not transfer your personal data outside the EU/EEA



8. STORAGE AND RETENTION OF YOUR PERSONAL DATA
We will store and retain your personal data that consists of:

i. Basic data about you: during up to 1 year from when your relationship with HamSphere has been cancelled by you.

ii. Transactions information and verifications: during up to 7 years from the date of the transaction in accordance with applicable legislation.

iii. Data for the purpose of handling an ongoing case, for example a claim or an incident: during up to 3 years after completion in accordance with applicable rules.



9. YOUR RIGHTS
You are always entitled to:

• Request rectification of your personal data;

• Request access to your personal data;

• Object to processing of your personal data for direct marketing purposes; and

• Withdraw your consent in case our processing of your personal data is based on your consent. However, the withdrawal of your consent will not affect the legality of the processing of personal data that has been performed prior to your withdrawal of your consent.

Under certain circumstances, which are set out more in detail in applicable data protection legislation, you are also entitled to:

• Object to processing of personal data and to obtain restriction of the processing of your personal data;

• Request that we delete your personal data; and • Receive the personal data concerning you and which you have provided in a structured, commonly used and machine-readable format (data portability).

You may exercise your rights by: Contacting our support: http://www.hamsphere.com/support


10. QUESTIONS AND POTENTIAL COMPLIANTS
If you have any questions regarding this privacy policy or our processing of your personal data, please contact our support: http://www.hamsphere.com/support

Should you be dissatisfied with our processing of your personal data, please let us know, and we will do our best to meet your complaints. Your integrity is very important to us, and we always strive to protect and secure your personal data in the best possible way. However, should you feel that we fail in this ambition, please note that you are also entitled to lodge a complaint with the Cyprus Data Protection Authority.



Last update: May 2018