Privacy Notice

This is the Privacy Notice of Tensormobile Telecom d.o.o and its subsidiaries and affiliates.

At Tensormobile we aim to do privacy the right way – wherever we operate. We believe that the responsible use of personal datasupports business growth and builds strong relationships between partners,consumers, and brands. As a business, we are committed to respecting andprotecting the privacy of all individuals with whom we interact.  

It is very important to us to be transparent about thepersonal data we collect about you, how we use such data, and with whom weshare it. That is exactly what this Privacy Notice contains. We divided it intoseveral sections for easier navigation. 

This Notice describes our general privacy practices. Inaddition to this Privacy Notice, we will also sometimes provide you withadditional privacy information where appropriate. 

This Notice does not apply to the personal data we processin relation to job applicants.

We use the following definitions in this notice:

• The term “Tensormobile” or “us” or “we” or “our” refers to the company Tensormobile Telecom d.o.o as well as to     its subsidiaries and affiliates. Occasionally, we might also use the term “Tensormobile Telecom” to     refer to Tensormobile Telecom d.o.o and its subsidiaries and affiliates.  
• The term “you” refers to a natural person (an individual) whose personal data Tensormobile collects and processes. 
• The term “end-user” means a subscriber of a mobile network operator with whom Tensormobile’s customers communicate using the  Services. 
• The term “account user” means an individual authorized by the Tensormobile’s     customer to log into their account and utilize the Services. 
• The term “business contact” means a customer’s representative or any other individual acting as a contact point between the customer and Tensormobile. The term “Services” means Tensormobile’s cloud-based communication (CPaaS – Communications Platform-as-a-Service and SaaS – Software-as-a-Service) and other products and services. 
• The term “personal data” means any information about you from     which you can be identified, directly or indirectly. 
• The term “controller” means the organization which determines     the purposes and means of the data processing and is responsible for     processing such data in a manner consistent with the applicable privacy     law. 
• The term “processor” means an organization who processes     personal data on behalf of the controller. 
• The term “applicable privacy law” means all laws and     regulations applicable to the processing of given personal data (e.g. the     General Data Protection Regulation (EU) 2016/679). Please see the  country-specific addenda for more information. 

Tensormobile is a Communications Platform-as-a-Service(CPaaS) and Software-as-a-Service (SaaS) provider. While providing Services toour customers, we act either as the controller or the processor, depending on the situation.  

Our activities as processor

Our customers are mainly companies that integrate ourServices into their business operations through their own software applications(via API) or by using Tensormobile Portal, our web interface. By using our cloud communications platform, our customers can send or exchange their communications with their end-users using different communication channels (SMS, WhatsApp, Viber, email, voice etc.). Moreover, we offer a comprehensivesuite of SaaS products, including contact center management, AI-powered chatbotcreation, marketing automation, and a unified customer data platform thatprovides insights into our customers’ end-users and their needs.

We are not in a direct relationship with our customers’end-users, so we distribute these communications through telecom operators andother communications providers. When we do this, we act as the processor on behalf of our customers and process the relevant data for the sole purpose ofproviding our Services to them. We do that within limits and according to customers’ instructions and in line with the Services terms and conditions,agreement for Services, or data processing or similar agreement concluded withour customer.  

For example, when you, as an end-user of our customer,receive a communication sent via our platform (such as an SMS or WhatsApp message), we process that communication on behalf of our customer. That meansthat the customer is the controller, and Tensormobile is the processor. Anyrequest we may receive from customers’ end-users regarding their rights relatedto our activities taken on behalf of our customers will be forwarded tocustomers, or the end-users will be asked to contact them directly.  

Our activities as controller

This Privacy Notice describes the activities which Tensormobile undertakes as controller. Tensormobile is a controller when we process personaldata for our own purposes and do not act on behalf of our customer or anyoneelse. We are committed to processing that data as described in this PrivacyNotice and respecting all obligations arising from the applicable privacy law. 

The main entity responsible for processing of personal data as described in this Privacy Notice – the controller – is Tensormobile Telecom d.o.o., Slavonska avenija 1C 10000 Zagreb, Croatia. For the purposes of EU data protection laws, Tensormobile Telecom d.o.o has appointed its EU-based Data Protection Officer (DPO) as our EU Representative.  Please note that depending on the specific contractual agreement applicable to you and the given processing activity, another Tensormobile subsidiary or affiliate may be a controller for your personal data. If you have any questions regarding this Privacy Notice or our privacy practices, you may contact our Privacy team and Data Protection Officer via the email address data-protection-officer@tensormobile.com.

Most of the personal data we process is provided to us directly by you when you for example use our Services, visit our website, fill out our online forms, communicate with our APIs, register for an event, participate in our research initiatives, submit application forms, visit our premises, or otherwise communicate with us.  

We also receive personal information from other sources, such as in the following situations: 

• If you are an end-user of one of our customers, they may provide us with certain     information to use our Services 
• If you are employed by or represent one of our customers or suppliers, they may     provide us with certain information necessary to use our Services 
• If you are an individual whose contact details have been shared with us by one of     our partners for the purpose of exploring new business opportunities      
• If you participate in our market research, we may receive information from our     third-party provider related to that research 
• If you visit our website or use our Services, we automatically collect certain     information, such as your Internet protocol (IP) address, user settings,     cookie identifiers, and other unique identifiers, browser or device     information, and location information (including approximate location     derived from IP address).
• If you are an individual whose personal data is shared with us in the event of a     merger, acquisition, sale, or other asset transfer. Your information may be transferred as part of such a transaction, as permitted by law or contract.  

5.1 When we provide Services to our customers

In this section, you will find information on the processing of personal data when we provide Services to our customers. It provides details on how we are processing your data if you are: 

• an  end-user, 

• an account user, 

• a business contact, 

• an individual using our services for yourself as a free trial or self-service     customer.  

An “account user” is an individual authorized bythe customer to log into their account and utilize Tensormobile Services, a “business contact” is a customer’s representative or anyother individual acting as a contact point between the customer and Tensormobile, and an “end-user” is an individual that receives communications from or sends it to our customers

5.1.1. To enter into an agreement, create the customer’s account, and provide the necessary support to enable the customer to use our Services

5.1.2 To enable customers to exchange their communications through our Services, ensure the security of our network and compliancewith our Service Use Policy, and handle billing and payments

5.1.3. To improve our products and Services

5.2. When we engage suppliers

5.3. When you contact us about our products and services, schedule a demo, or when we reach out to explore new business opportunities

5.4. When we send you our email or other marketing communications

5.5. When you register for, attend, or speak at our webinar,business breakfast, developer meetup, or other events

5.6. When we perform research activities
5.6.1. When we perform anonymous market research activities

5.6.2 When we perform in-depth market research interviews

5.6.3. When we perform user experience research

5.7. When you visit our website

5.8. When you reach out to us regarding our social impactinitiatives or when we collaborate on such initiatives

5.9. When you visit our offices or premises

We may engage suppliers (also known as vendors or serviceproviders) to help us in the processing of your personal data for theactivities that we conduct as a controller and that we describe in this Privacy Notice. Since we are a global company, we may also share your personal data with our subsidiaries and affiliates as part of our daily operations.

Any such sharing within the Tensormobile Telecom isregulated by intercompany agreements on personal data processing andtransfer.  Before engaging any new supplier, we perform a security and privacy assessment.

Where such supplier acts as our processor we ensure that the processing of personal data is governed by a written data processing agreement.  Notwithstanding the foregoing, as a rule, we do not share personal data with third parties except when strictly necessary and on a need-to-know basis, such as with: 

• Telecom operators and other communications service providers when necessary for     the set-up of proper routing and connectivity. We are able to deliver messages that our customers send to their end-users, independent of where they are located, through our connections with telecoms and other communications providers (such as WhatsApp, Viber, Facebook). 
• Service and technology providers to the extent strictly necessary for them to     perform specific actions on our behalf. These might be related both to our     Services (e.g. as part of the functionality of our Services) and to our other processes (e.g. utilizing a software provider to manage our job application process). 
• Third parties when required to comply with our legal obligations. We may share     your personal data with authorized legal authorities due to relevant legislation, such as a judicial proceeding, court order, or legal process served on us (e.g. for criminal procedures) or because of threats to public security, regulatory requirement, or in the context of investigations or bankruptcy. As a communications provider, we are     required to retain certain communications-related data for law enforcement     purposes and will be required to share that data with authorized law  enforcement authorities upon their request. Also, if we are under an obligation to demonstrate compliance with relevant accounting, financial and tax legislation, your data can be shared with auditors and tax authorities for those purposes.
• Business partners to whom we may give your business details for the purpose of exploring new business opportunities and marketing our products and services. 
• Advertising partners that we might use as part of our marketing activities. More     information is listed in our Cookie Policy along with an explanation of how to adjust your cookie settings when visiting our website.  
• Merger and acquisition stakeholders as part of disclosure in the event of a merger, sale, or other asset transfer. Your information may be transferred as part of such a transaction, as permitted by law or contract. 

We conduct our business operations globally, and sometimes we need to carry out international transfers of your personal data by providing your personal data to the parties specified in the section above. All international transfers are carried out while ensuring the confidentiality and security of your personal data and in line with the applicable privacy law. This might include specific technical, organizational, and contractual measures. For example, in relation to transfers of personal data outside the European Economic Area, we will complete and execute standard contractual clauses for data transfers where required.

At Tensormobile, we believe that security and privacy go hand in hand. In order to protect personal data collected and processed by us, we have therefore invested in the development, implementation, and constant improvement of a wide range of technical and organizational security measures. These measures have been implemented in accordance with ISO 27001:2022 standard requirements. The list of our current and up-to-date certificates can be found on our website. We take care to train all our staff in the field of privacy and security, starting from their first day in Tensormobile through the onboarding process and continuously throughout their stay at Tensormobile. Before we engage a supplier, we check their security practices and alignment with the applicable privacy law. Once engaged, we continue to assess them on a regular basis.

Depending on the applicable privacy law, you may have certain rights with respect to your personal data. Where granted by the applicable privacy law, you have the right to:

• Withdraw your consent to our processing of your personal data (to the extent such processing is based on your consent and consent is the only     permissible basis for processing), without affecting the lawfulness of processing based on consent before its withdrawal 
• Request from us to access your personal data, which means requesting a copy of the personal data we hold about you 
• Ask to rectify (correct) your personal data that you think is inaccurate and to complete your personal data that you think is incomplete
• Ask us to erase your personal data in certain circumstances 
• Ask us to restrict the processing of your personal data in certain circumstances 
• If we process your personal data by automated means based on your consent or     upon a contractual relation with you, you can exercise the right of data portability
• If we process your personal data upon our legitimate interest, you have the right to object to the processing.
• If you want to object to the processing of your data for marketing purposes, you     can do it at any time by using the unsubscribe link provided in our marketing communications
• You may also have specific rights in exceptional cases when we may carry out     automated decision-making operations, including profiling.

You can exercise your rights or submit a complaint bycontacting our Data Protection Officer. If you have any questions about how weare using your personal data or resolving your complaint, you can contact ourdata protection officer by emailing: data-protection-officer@tensormobile.com. WhenTensormobile acts as a processor and you submit a request to exercise yourprivacy rights, we will forward your request to the relevant customer (thecontroller) and follow their instructions. 

If applicable to you, you can lodge a complaint with thesupervisory authority of the EU member state of your habitual residence, place of work, or place of the alleged infringement. If you want to file a complaintor contact the relevant data protection authority for any other reason, you mayfind contact details of EEA data protection authorities at https://edpb.europa.eu/about-edpb/board/members_en. 

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We at Tensormobile do not conduct any activity which isbased solely on automated processing, and which produces legal effects concerning you or that in any other way significantly affects you. Eventually we may take partially automated measurements that include human intervention in order to analyze the way users of our platform use thefeatures and tools available (e.g. by tracking usage activities inside our web interface) to give you recommendations to improve your performance (e.g. how to better access certain features).

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Your personal data that has been collected based on your consent will be kept for a period specified in the consent. If you wish to withdraw your consent for the processing of your personal data for any purpose and to delete your data, you can do that at any time by sending an email to data-protection-officer(at)Tensormobile.com. Regarding your personal data, that is not subject to your consent, we will only keep it for as long as necessary to fulfill the purposes for which it was collected before making it non-identifiable (anonymous) or deleting it, as required by law.  Specific retention periods are listed under the respective activities in section 5 of this Privacy Notice. The retention periods listed are the standard default periods. In some cases, exceptions apply due to local laws related to law enforcement, tax, or other purposes. Additionally, if legal matters such as litigation, law enforcement requests, or government investigations require us to preserve records, including those containing personal information, for longer periods than listed in section 5, then we will delete the records in question when we are no longer legally obligated to retain them.

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Where appropriate, we implement measures to anonymize the personal data we process, which may include data aggregation. These anonymization activities may apply to any category of data we collect as data controllers, including traffic data. We ensure that, as a result of our anonymization efforts, individuals cannot be directly or indirectly identified by any reasonably likely means, such as singling out. Once anonymized, the data may be further used for analytics, business insights, and product development. Although we process special categories of personal data (sensitive data) in very specific cases, such data is not subject to anonymization and is not used for any additional purposes.

The most current version of this Privacy Notice will govern our practices for collecting, processing, and disclosing personal data. We will provide notice of any modifications on this page. You can always check the date of the last update at the beginning of this Privacy Notice.