Telenor Pakistan (Private) Limited Privacy Notice

 

1- Our approach

Privacy matters to us, and we want to be transparent about how we collect and work with your personal information. Please take a moment to read this notice, and if you have any questions, you can contact us  any time.

This privacy notice outlines your rights to your personal information and contains general principles that apply to the handling of your personal information when you use any of Telenor Pakistan’s products or services, websites, and any product or service that we offer in conjunction with our partners. Depending on the product or service, you may also receive service- specific and/or region-specific terms. You will be legally bound by both this notice and the service/region specific term to the extent you have accepted them when signing up to service or product via biometric verification and/or agreement for service, therefore, you should read these terms carefully. In the event of conflict or inconsistency, the service and/or region-specific terms prevail.

 

2- Telenor’s Commitment to Your Privacy

Telenor Pakistan is a subsidiary of Telenor Group ASA. Our companywide commitment to your privacy is reflected in Telenor Group’s

We apply the following key privacy principles while processing your personal information:

I- We will process your personal information in accordance with this privacy notice and all applicable laws.

II- We will do our best to be transparent on how we handle your personal information.

III- We will only process your personal information for legitimate purposes, and only for as long as it is necessary to achieve those purposes. We will dispose of your personal information safely and securely once it is no longer required.

IV- We will enable you to the extent it is possible to exercise choice and control over our processing of your personal information, not only when we are required to do so by the applicable law, but also in other circumstances where we think it is the right thing to do.

V- We will inform you about your privacy rights, respect them and help you to exercise those rights.

VI- We will make sure that your personal information is safe through appropriate security measures.

VII- We will take steps to ensure that your personal information is adequately protected.

VIII- We build privacy and data protection into our products and services by design and by default. This means that we prioritize the privacy of your data, and we will endeavor to build privacy safeguards in everything we develop.

 

3- General processing for telecom services (what, why and how)

What we collect and the way we collect your personal information vary depending on why we collect your information, which in turn depends on which one of our products and services you are using. Generally, we collect and use your personal information where:

. The information is necessary for us to provide the services you use

. The information is needed for us to better improve our service and your user experience

. The information is needed for us to help protect your security

I. Information that is necessary for us to perform the services

There is certain personal information that is necessary for us to perform services you use. These include:

(a) Your name, phone number, email address, postal address, date of birth, and other information provided when you register to use our services;

(b) Payment related information, such as credit or debit card information or other banking and payment information;

We generally use this information to:

(a) perform the relevant service or provide the relevant product;

(b) manage your account;

(c) carry out credit checks;

(d) For better customer services;

(e) request payments; and

(f) Communicate with you.

II. Other information that is needed for us to provide and improve our services

During the course of you using our products, services or websites, we may also collect other information from you. Some examples of such information include:

(a) Information about your account and our communications with you, such as any customer support requests that you make or any feedback that you provide, dates of payments, and date of invoices;

(b) Product usage data, such as your last active use of an application, the duration you spent on an application and how much you spent on a product;

(c) Network data, including mobile calls and SMS data, such as the date and time of the calls and texts you send or receive, and the duration of calls received and made through our network;

(d) Your location data, when:

    1. You use our telecommunications services, such as call, SMS or broadband service
    2. You choose to use our location based service. For example, when you enable direction applications on your mobile phone; and
    3. You signed up to a certain location based promotional activities.

Your browsing data, when you visit our websites and/or use some of our services. Information that we may collect may include:

    1. Information relating to your device, such as IP address, device model and settings;
    2. Network information;
    3. Details and logs of when, where and how you used the service;
    4. Browser information
    5. Information about your visit, including the websites that directed you to us, the pages on our website that you visited, services and products that you viewed or searched for, length of visit, our interaction with you, and the next websites you visit after our website.

Typically, we use the information above and any other information necessary to;

(a) Perform our services upon requests. For example, where you have requested that we link your digital services with third parties such as social networks, we will collect any information necessary to enable us to link and integrate our services;

(b) Improve customer experience, such as for troubleshooting, network management and network optimisation purposes;

(c) Use the recorded communications information for training quality assurance, feedback or for records purposes;

(d) Find ways in which we can better improve our service, such as using personal and/or aggregated statistics or de-identified information about sales, services, customers, network traffic and location patterns to conduct research to help improve our understanding of your behaviours;

(e) Conduct research that create value for the community. You can find out more about Telenor Group and our research activities ;

(f) Create customer profiles about you to offer you personalised content, provide a more relevant user experience or products and services

(g) Analyse use of our network and services to identify general trends and partner with third parties to develop new services for you;

(h) Send you marketing communications about products and services based on your preferences and interests; and/or

(i) Share your information within our affiliate companies, for processing, advertising, service development, cross product marketing and sales, product and service creation, measurement, analytics and research purposes.

You may object to the processing by contacting us unless the information is required for us to perform the services.

 

III. Information needed for us to protect your security

We use the information we have to keep our services and communities safe and secure

(a) We may investigate or take action regarding suspicious and illegal activities that violate our Terms of Services, or the applicable law; and/or

(b) We share your information, in accordance with applicable law/regulations and/or court orders, with the relevant authorities, for example, to protect you or someone else from harm or damage.

IV. Information you consented to provide to us

We may also collect and process information about you when you consent to us collecting and processing this information. Examples are your demographic and other personal information when you participate in one of our competitions, prize draws, research surveys or consumer panels, or health information when you utilise our Tele- health or mobile health products and services.

V. Information that we collect from other sources

We sometimes collect personal information about you from third parties. Examples of the type of information that we collect are:

(a) Your credit information, to help us with customer authentication and credit-related decisions;

(b) If you consented, other information, such as demographic information, to better understand you and your interests and to offer you personalised services. Examples of third parties that we collect the information from include payment and delivery services, advertising networks, analytics providers, search information providers; and

(c) Social media information, such as your interests, “Likes” and friends list, when you use your social media credentials to interact with a Telenor webpage or offer.

You can object to any of the processing above by contacting us , unless the information was required for us to perform the services.

4- Processing for specific applications/products/services

Please click here to see processing of specific applications/products and services.

 

5- How we share your information and other responsible entities

We may share your personal information with an affiliate company or third parties for the purposes listed above. We do our best to ensure that the third party follows the same privacy practices towards your information  in accordance with our key privacy principles, this privacy notice and applicable law.

More detailed examples of the third parties we may share your information with include:

(a) Any of the affiliate companies;

(b) Data processors to process your information on our behalf;

(c) Third party services whom you have asked us to integrate with, such as social networks;

(d) Third /parties who conduct research, analytics or marketing in conjunction with us or on our behalf;

(e) Third party service providers such as debt collection agencies and credit check agencies.

 

6- How we protect your personal information

We ensure that your personal information is safe and secure through the following measures:

(a) When you log into your account to use our services with your phone number or username and password, all of the data is encrypted using cryptographic protocols such as Transport Layer Security (TLS) and Secure Socket Layer (SSL) encryption. We employ such cryptographic protocols on all pages on our websites where we collect personal information. To make purchases from these web pages, you must use a TLS or SSL-enabled browser such as Internet Explorer, Safari, Firefox, or Chrome. This ensures that your personal information remains confidential and is protected white it is transmitted over the Internet;

(b) If you have a username and password to access our services, and have been inactive for some time, we automatically log you out of the account to keep your details secure;

(c) When we use service providers or other data processors to process your personal information on our behalf, we ensure that the relevant providers and processors will implement appropriate technical and organisational measures to protect the information. Such controls include access control to the information and the infrastructure that stores the information, contractual arrangement that requires the third parties to comply with all relevant laws, We apply privacy and data protection by design and by default , and build privacy and data protection into the foundation of our products and services;

(d) We conduct Data Protection/Privacy Impact Assessment where appropriate to measure and reduce the impact of a particular activity to the privacy of your personal information.

7- How long we keep your personal information for

As mentioned in our 3rd Privacy Principle, we will only process your personal information for legitimate purposes which include service provisioning to our customer, and only for as long as it is necessary to achieve those purposes. We will dispose of your personal information safely and securely once it is no longer required subject to applicable laws for retention of data. The customer data is retained as per the regulatory obligations for a minimum period of 01 year stipulated in the license duly granted by Pakistan Telecommunication Authority.

 

8- Your rights

It is important to us that you understand your privacy rights. Therefore, we have listed out below a  list of privacy rights that you could exercise whilst entrusting us with your information:

(a) Right to access your information: You can access and request a copy of the personal information that we hold about you any time by contacting us, or access the information directly through your online account.

(b)The information is no longer needed by us and there is no legal requirement on us to retain the information;

We will do our best in accommodating the request, but please bear in mind that this may result in you being ineligible to receive certain services.

You can contact any time to discuss these privacy rights in more details.

 

9- Handling Children’s Information

As a general rule, we do not process personal information of children under the age of 18, unless we have the consent from their guardians. Where services are designed for use by children under the age of 18, we will seek the consent of the guardians and inform the guardians of their privacy rights.

 

10- Revision of this privacy notice

We commit to reviewing this notice at least once annually, and on an ongoing as needed basis.

 

11- Questions about this privacy notice and contact information

Telenor Pakistan is responsible for the handling of your personal information, and the legal frameworks in which we operate include:

  1. Pakistan Telecommunication (Re-organisation) Act, 1996
  2. Prevention of Electronic Crimes Act, 2016
  3. Investigation for Fair Trial Act, 2013
  4. Telecom Consumer Protection Regulations, 2016
  5. Protection from SPAM, Unsolicited fraudulent and obnoxious communication Regulations 2009
  6. Telecom License

If you have a question, concern or complaint about this privacy notice or our handling of your information, you can contact our Data Protection Officer via the following methods:

Data Protection Officer

Email: privacy@telenor.com.pk

Registered Office:

345 Telenor Pakistan (Private) Limited, 55, River View Avenue, Block B, Gulberg Greens

Islamabad-44000 Tel: +92(51)111-345-700

Web address: www.telenor.com.pk

We will respond to your query as soon as we can and try to resolve it to the best of our capability.

If you lodged a complaint and are unsatisfied with our response, you can refer your complaint to the Pakistan Telecommunications Authority (Consumer Protection Directorate), PTA Head Quarters, F-5/1, Islamabad.

This Privacy Notice is updated on 10th November, 2019