Lyca Mobile Privacy Policy

At Lyca Mobile Ukraine (“Lyca Mobile”), we look after data of our Customers (the “Personal Data”) carefully. We adhere strictly to the requirements of the Law of Ukraine “On Protection of Personal Data” dated 1 June 2010, as amended (the “Law”) and other data privacy and data retention regulations.

This Privacy Policy (together with our General Terms and Conditions (the “Terms”) which may be found at our website: www.lycamobile.ua (the “Website”)) describes how we process the Personal Data that you, as a Personal Data owner, provide to us or that is generated or collected when you use our online services and when you use our mobile telephone services.

Please take a moment to read our Privacy Policy so you know what choices you have about your Personal Data. This Privacy Policy may change occasionally so it’s a good idea to come back and read through it again, from time to time.

Please note that by registering or activating an account with Lyca Mobile, by making an agreement in accordance with the Terms or by registering on the Website, you consent to Lyca Mobile to process the Personal Data provided by you or generated in the course of supplying the services to you in accordance with the Law and this Privacy Policy.

The consent is granted for indefinite term and may be withdrawn in accordance with the procedure established by the Law.

Termination of an agreement between Lyca Mobile and a Customer does not constitute a withdrawal of consent to processing of the Personal Data. The withdrawal of consent shall be made separately and in accordance with the procedure established by the Law.

The objective of the Personal Data processing is to provide you with high-quality telecommunication services.

Grounds for processing of the Personal Data are the following:

• Consent of the Personal Data owner;

Making an agreement between Lyca Mobile and the Personal Data owner;

Compliance with statutory requirements by Lyca Mobile; and

Protection of legitimate rights and interests of a Customer and Lyca Mobile.

We may process the following Personal Data about you:

• Your name, address, date of birth, mobile telephone number, call data records including Traffic Data and Location Data, top-up records, credit card or debit card details, billing records, voice mail recordings.

If you contact our Customer Services Department, we may keep a record of that correspondence, including copies of e-mails and your e-mail address. We may also monitor or record any telephone calls made to our Customer Services Department for quality assurance.

Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our products and services, posting material or requesting further products or services. We may also ask you for information when you report a problem with our Website or our mobile telephone services and products.

Details of your visits to our website including, but not limited to, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

We may also ask you to complete surveys that we use for market research purposes, although you do not have to respond to them.

We may also ask you to complete surveys that we use for market research purposes, although you do not have to respond to them.

We may supplement the information that you provide to us with information that we receive from third parties, for example, collected from other members of your household.

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about a user’s browsing actions and patterns, and does not identify any individual.

For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our Website and to deliver a better and more personalised service. Cookies enable us:

• To estimate our audience size and usage pattern.

To store information about your preferences, and so allow us to customise our Website according to your individual interests.

To speed up your searches.

To recognise you when you return to our Website.

You may refuse to accept Cookies by activating the setting on your browser which allows you to refuse the setting of Cookies. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse Cookies, our system will issue Cookies when you log on to our Website.

Please note that our advertisers may also use Cookies, over which we have no control.

Any information sent to us is encrypted (scrambled) using Secure Socket Layer (SSL) technology. This is industry standard encryption technology that protects your Personal Data whilst being sent over the internet from being intercepted and misused by third parties. When it reaches us, we then store it on a secure server so that it can only be read by authorised personnel.

The Personal Data provided by you is processed in the database of subscribers of Lyca Mobile (controller: Lyca Mobile Ukraine, Limited Liability Company, a company incorporated under the laws of Ukraine, with registered number 41317168 having its principal office at 51-B Bogdana Khmelnitskogo Street, Room 32, Kiev, 01030, tel.: +39-091-610-26-26).

The Personal Data could be transferred to any third party without additional consent from you and without further notification about such transfer, as provided by applicable law. Transfer of the Personal Data to a third party can only be where:

• It is necessary under applicable law; or

At request of the Personal Data owner; or

It is necessary for provision of telecommunication services and prevention of any abuse.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We use Personal Data held about you in the following ways:

• Supplying the Products and Services to you,

The administration of your Account by the Customer Services Department,

Providing you with service information, for example about Network faults,

The prevention or detection of fraud,

Market research and profiling your usage and purchase preferences,

Complying with applicable laws and regulations.

Lyca Mobile and other companies of LycaGroup may also use your Personal Data to contact you by post, telephone, e-mail or SMS to let you know about products and services offered by Lyca Mobile, other Lyca group companies and selected companies, including any special offers and promotions, which may interest you. If you do not wish to receive this information or be contacted in this way, you may at any time, free of any charge, opt out of this direct marketing by requesting to be put on a designated list. You may make this request by contacting the Customer Services Department or by sending an e-mail to www.lycamobile.ua.

We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in the City of Kyiv). We may make use of the Personal Data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.

We may disclose your Personal Data to any member of our group of companies in respect of the uses set out above.
We may disclose your personal information to third parties related to a prospective change of control or investment in Lyca Mobile.

Your rights are described in Article 8 of the Law, which you can read at http://zakon2.rada.gov.ua/laws/show/2297-17/print1476093297183676.

At any time you like you’re welcome to ask us what your Personal Data we have and whether such Personal Data is processed. If any of the details are incorrect, let us know and we’ll amend them right away. If you’d like us to send you the information, you can write to our Customer Services Department at the below address.

Any changes we may make to our Privacy Policy in the future will be posted on this page with immediate effect.

Please be aware that our Website provides access to other Websites by linking to them. We are only responsible for the privacy, content or security of the Website.

If you have any comments or queries concerning our Website, please contact us. For queries regarding Lyca Mobile’s products or services, please call our Customer Services Department on +38-091-600-0110 from any telephone. You may also e-mail the Customer Services Department at cs@lycamobile.ua or by completing the online enquiry form at Contact Us.

If you have any questions or concerns about our use of your Personal Data you should write to Lyca Mobile at the address above.

Lyca Mobile Ukraine, Limited Liability Company, a company incorporated under the laws of Ukraine, with registered number 41317168 having its principal office at 51-B Bogdana Khmelnitskogo Street, Room 32, Kiev, 01030, tel.:+38-091-600-0110, +38-091-610-26-26.