Privacy Policy

Privacy Policy

Last update 20/04/2020.

General information

This privacy policy applies to all online services of Xsltel OÜ

The controller is:
Xsltel OÜ

Harju maakond, Tallinn, Kesklinna linnaosa, Tartu mnt 67/1-13b, 10115 , Estonia. (Postmail only).
Phone: +372 668-2763
Email: info@xsl.tel
Reg no: 14881702
VAT Reg no: EE102230561

Introduction

It is Xsltel OÜ’s policy to respect your privacy regarding any information we may collect while operating our website. This Privacy Policy applies to xsl.tel (hereinafter, “us”, “we”, or “xsl.tel”). We respect your privacy and are committed to protecting personally identifiable information you may provide us through the Website. We have adopted this privacy policy (“Privacy Policy”) to explain what information may be collected on our Website, how we use this information, and under what circumstances we may disclose the information to third parties. This Privacy Policy applies only to information we collect through the Website and does not apply to our collection of information from other sources.
This Privacy Policy, together with the Terms and conditions posted on our Website, set forth the general rules and policies governing your use of our Website. Depending on your activities when visiting our Website, you may be required to agree to additional terms and conditions.

What data we collect

In particular, we save the following data from you.

Registration data

When you register an account with us, we collect and process certain personal data from you as your registration data. For example, we need your name, address information, telephone number, payment information and your email address to process your order. If you pay using a credit card, we do not collect and store any payment information such as credit card numbers or verification codes. You disclose this information only to the respective payment service provider. One exception with credit card payments is what is known as the pseudo card number: in order for you not to have to enter your credit card information for every payment, a pseudo card number is saved for your account. The pseudo card number only enables payment for products on our website that you order using your customer account. A pseudo card number is not identical to the credit card number. We delete all your registration data either: within 24 months, as soon as you delete your user account with us, or once the statutory retention period expires. You can delete your user account with us by sending an email to data-protection@xsl.tel with your deletion request. The legal basis for this data processing is Art. 6 (1) lit. b GDPR.

Email addresses

If you subscribe to our mailing list, we also store your email address. We delete your email address once you delete your user account or if you unsubscribe from our mailing list.

We use the double opt-in method to ensure that you actually want to receive the newsletter. If you go through this process, you agree to receive the newsletter and to be added to the mailing list for it, and then you will receive a confirmation email that will allow you to legally confirm that you have registered for the newsletter. We will only add your name to the mailing list if you actually complete the confirmation.

We use these data exclusively for sending information that you request including information about our new offers.

You can revoke your consent at any time to the storage of your personal data (including your email address) and to the use of your data. You can do this, for example, by clicking on the “Unsubscribe” link in the newsletter. The legal basis for processing your data for the above purpose is Art. 6 (1) lit. a or Art. 6 (1) lit. b GDPR.

Server log files

Whenever you visit our websites, we automatically store certain data. This includes your IP address, type and version of the browser you use, time, date, website from which you come to our site. Your IP address is saved anonymized. You can then no longer be identified. The legal basis for this data process is Art. 6 (1) lit. f GDPR.

Who we share your data with

External service providers may have access to your data while they assist us in providing our services. In some cases, third parties such as government authorities, external consultants, or our business partners may receive your data.

In particular, this may occur in the following cases:

Payment via credit card

When paying via credit card, the payment is processed by an external service provider. For credit card payments, your information such as full name, address, email and your credit card  is collected directly by Stripe at the address
Stripe, 510 Townsend Street, San Francisco, CA 94103, USA

Phone verification

New customers are required to verify their phone number . We use Google Firebase to process your phone number SMS verification. We use this service to prevent fraud and abusive orders.

Third countries

Data is transferred to third countries in adherence to the legally regulated admissibility requirements. We will not transfer your data to a third country if it does serve the purpose of performing our contract with you; we have no consent from you; the transfer is not necessary to assert, exercise or defend legal claims; and there are no other exceptions. We will only transfer your data to a third country if there is an adequacy decision in accordance with Art. 45 GDPR or appropriate safeguards in accordance with Art. 46 GDPR. Once such adequacy decision (regarding an adequate level of protection) is the “Privacy Shield” for the USA. For transfers to a company certified under the Privacy Shield, the data privacy level is considered essentially as adequate within the meaning of Art. 45 GDPR. However, we usually do not rely on the Privacy Shield, but rather create appropriate privacy guarantees and complete the EU standard data privacy clauses issued by the European Commission with the receiving party. Together these actions establish appropriate safeguards in accordance with Art. 46 GDPR and provide an adequate level of protection.

Other categories of recipients

State authorities and courts

Where do we process your data?

We process your data exclusively on our highly encrypted servers located in different datacenters.

Cookies

“Cookies” are small files that are stored on a user’s computer. Cookies can store different kinds of data. Cookies are primarily used to store information about users. They are stored on the users’ devices during and/or after users visit a website or online store. “Temporary cookies”, “session cookies”, or “transient cookies” are cookies that are deleted after users leave an online store and close their browsers. With such cookies, for example, the content of a shopping basket can be stored in an online shop or a login bottleneck. However, other cookies are referred to as “permanent” or “persistent” and remain stored even after the browser is closed. For example, users’ login status can be saved when they visit a shop after several days. Likewise, permanent cookies can measure the “range” of a website (where the users are geographically located) or information on the users’ interests. This information is used for marketing purposes. “Third-party cookies” are cookies that are offered by the original providers (who operate the online store or website) to other parties. (If the original provider is the one using the cookies, they are often called “first-party cookies”). It is useful to know the above terms so that you understand our cookie policies and data protection agreement. If, as a Xsltel OÜ customer or as a visitor to our websites or interfaces, you do not wish cookies to be stored on your computer, we ask you to deactivate the corresponding option in the system settings of your browser. You can also delete stored cookies in the system settings of your browser. However, if you do these things, it will likely lead to problems when you try to use Xsltel OÜ websites and interfaces. If you would like to “opt out” of the use of cookies for online marketing and tracking purposes, you may be interested these two sites to help you:
1) the US site http://www.aboutads.info/choices/
2) the EU site http://www.youronlinechoices.com/.
Furthermore, you can deactivate cookies from being stored on your computer or device by changing your browser settings. However, if you do this, it will likely lead to problems when you try to use Xsltel OÜ websites, interfaces, and features on the interfaces.

LiveZilla

We use the chat system from LiveZilla GmbH, Ekkehardstrasse 10, 78224 Singen, Germany, to provide technical support for our customers. Every time that a customer accesses this chat support service from our website, we collect and store data from the chat for web analysis and to actually operate the live chat system itself. This allows us to create user profiles with pseudonyms so that we can operate the chat and analyze visitor behavior. We can also improve our support systems, online shop, and user experience. We run Livezilla from our own servers and do not transfer your data to third parties.

If you activate live translation while using this live chat, it will integrate Google Translator. The translations generated by Google Translate should not be regarded as exact, and can sometimes contain incorrect or even offensive expressions. We do not guarantee the accuracy, reliability or currentness of the information translated by this system. Xsltel OÜ does not accept liability for any issues or damages that may result from possible translation errors. Furthermore, it may not be possible to translate some applications, files or elements including graphics, photos or PDFs.

Google collects, stores and processes information in order to provide users with better services. This includes, for example, not only the language used in the translation, but also the user’s entire surfing behavior.

For more information, please see Google‘s privacy policy.

Voluntary nature of data provision

There is no statutory obligation for you to provide your data to Xsltel OÜ. However, you cannot use some of our services if you do not provide your data to us. Your decision to provide us with your personal data is completely voluntary.

Privacy policy changes

Although most changes are likely to be minor, Xsltel OÜ may change its Privacy Policy from time to time, and in Xsltel OÜ’s sole discretion. Xsltel OÜ encourages visitors to frequently check this page for any changes to its Privacy Policy. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change.