Privacy Policy Bottom of Form

At SIMFONY and IBASIS, the privacy of our stakeholders is very important to us. We take privacy very seriously and make our best efforts to ensure your personal data is protected.Bottom of Form

Please read our Privacy Policy and find out how we collect, use, share and retain your personal data, what rights you have with respect to your personal data, and how we keep it secure.

# WHO ARE WE

The personal data that you provide on this platform will be processed by Simfony B.V. (Simfony) and IBASIS IOT US, LLC. (IBASIS IOT), as joint controllers, as defined by the Regulation (EU) 2016/679, of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (General Data Protection Regulation or GDPR).

Reference to "we", "our", "us" in this Policy refer either to Simfony or IBASIS IOT, indistinctively.

# HOW WE COLLECT DATA

We need to process personal data necessary to comply with our contractual obligations or to perform enhancements in our platform to improve the service based in our legitimate interest.

We collect your personal data when you register on our platform, place an order or enter information, depending of your interaction with our platform. Furthermore, information will be collected when you use our services and/or products, regarding usage and log information, as described above.

Furthermore, usage and log information will be collected automatically when you use our services and/or products. This includes information about the devices' activity, log information, data traffic, duration of activity, diagnostic and crash logs, performance logs and reports. While this information is not considered personal data, it will be collected as part of our services.

# TYPE OF DATA PROCESSED AND FOR WHAT PURPOSES

In the table below, you can find what sort of data and for what purposes we use it:

Type of data | Purpose | Legal basis
Name, e-mail address for technical and business contact, address, phone number | Commercial and operational contacts with customer Authorities requests | Contractual obligation, legitimate interest Legal obligation

# SHARING YOUR PERSONAL DATA

We may provide your personal data to:

- Other IBASIS legal entities where necessary and within the limits of applicable laws for the provision of services;

- Service providers, who process data on behalf of us;

- Competent authorities, to comply with applicable laws or court orders in connection with judicial proceedings or other legal process;

- Third parties such as Google for the provision of Google Maps service;

- Other companies in the process of a business transfer if we are acquired by or merged with another company.

When sharing your personal data with service providers, we take the appropriate steps to assure your data is processed only for the provision of services and ensure compliance with data protection applicable regulations, by signing with them data processing agreements.

# GOOGLE SERVICES

#

We use Google Maps API in our platform to improve the service we provide. This feature is provided by Google LLC, address 1600 Amphitheatre Parkway, Mountain View, California 94043, United States who acts as a data controller for the provision of this specific feature.

To know more about how your data is used by Google and the additional terms applicable, please check the current versions of Google Maps/Google Earth Additional Terms of Service and Google Privacy Policy .

# COOKIES

Our platform uses cookies to provide an enhanced user experience and services tailored to the needs and interests of each user. For more information on how we use cookies, please check our Cookies Policy here [link to Cookie Policy]

# DATA SECURITY

Your personal information is stored on the servers of of service providers based in Frankfurt, Germany. Their services are ISO 270001, ISO 27017 and ISO 27018 certified with a systematic and ongoing approach to managing information security risks that affect the confidentiality, integrity, and availability of company and customer information, including personal data. Furthermore, the servers are hosted in highly secure data centers that utilize state-of-the art electronic surveillance and multi-factor access control systems. Data centers are also staffed 24x7 by trained security guards, and access is authorized strictly on a least privileged basis. Regarding the information you provide to us, it is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential.

Furthermore, our platform is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.

We use regular Malware Scanning.

We implement a variety of security measures when a user places an order, enters, submits, or accesses their information to maintain the safety of your personal information.

All transactions are processed through a gateway provider and are not stored or processed on the servers we have access to. In addition, all credit card information you supply is encrypted via Secure Socket Layer (SSL) technology.

# INTERNATIONAL DATA TRANSFERS

Your personal data may be transferred to, accessed from and otherwise processed in other countries outside EEA, in which IBASIS legal entities and third-party service providers operate. When we transfer your information internationally, we ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as required by the applicable law, by using Standard Contractual Clauses and Data Processing Agreements to meet the adequacy and security requirements for our Customers that operate in the EU.

# FOR HOW LONG DO WE KEEP YOUR DATA

We retain personal data for as long as it is necessary to provide our services or to comply with the applicable law, regulation, tax or accounting practice or the terms of any governmental telecommunications licenses or authorizations to which we may be subject.

These might include retention periods:

i. mandated by law, contract or similar obligations that apply to our business operations;

ii. for preserving, resolving (customer support), defending or enforcing our legal/contractual rights; or

iii. as needed to maintain adequate and accurate business and financial records (billing purposes).

Once we no longer need your personal data, we take the necessary procedures to destroy it.

# YOUR PRIVACY RIGHTS

We guarantee you:

Right of Access: allows you to obtain information on whether or not we are processing personal data concerning you, if so, the right to obtain information on the personal data being processed.

Rectification: allows for the correction of errors and the modification of inaccurate or incomplete data.

Erasure: allows data to be erased and not processed by us, unless there is a legal obligation to retain them. For example, where personal data are no longer necessary for the purposes for which they were collected, the data subject may request that we delete such data without undue delay.

Restrict data processing: under the conditions established by law, it allows the processing of data to be stopped, in such a way as to avoid future processing by us. We will only keep data for the exercise or defense of claims.

Right to object: in certain circumstances and for reasons related to their particular situation, you may object to the processing of your data. We will cease processing the data, except for compelling legitimate reasons, or the exercise or defense of any claims.

Portability: it allows you to receive your personal data and be able to transmit those data to another controller in a structured, commonly used and machine-readable format.

Should you need to exercise one of your rights or any additional information, you can contact our Data Protection Officer to the following address: dpo@ibasis.net or the Data Protection Authority https://www.autoriteitpersoonsgegevens.nl/en

# HOW TO CONTACT US

You can send an e-mail to our DPO to dpo@ibasis.net or you can write us to:

IBASIS IOT US, LLC. SIMFONY, B.V.

10 Maguire Road, Building 3, Lexington Hornweg, 7

02421 MA 1432 GD

United States of America Aalsmeer

The Netherlands

# UPDATES TO OUR PRIVACY POLICY

This Privacy Policy may be changed from time to time, considering the evolution of our business and technology. We recommend you to regularly review this Privacy Policy to make sure you are up-to-date with how we are using your personal data.

January 23, 2023

Version 1.0

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