Privacy Policy

At LIFETIMESMS PRIVATE LIMITED, we care about your personal data. It is very important to us to be transparent about the data we collect about you, how we use such data and with whom we share it. Therefore, we advise you to read the following Privacy Notice to be informed about the processing of your personal data.

Through our worldwide network of over 600 direct carrier connections, we reach more than 7 billion people and things. Our local presence, of more than 10 offices across Pakistan, enables us to react faster, support better, engage more, and offer tailor-made solutions creating communications solutions of the future with our clients. We believe that the responsible use of data supports business growth and builds strong relationships between partners, consumers, and brands. As a business, we are committed to respecting and protecting the privacy of all individuals with whom we interact.

1. Definitions
2. About LIFETIMESMS PRIVATE LIMITED MARKETING PRIVATE LIMITED Services
3. Controller’s contact details
4. How do we obtain your personal data?
5. What personal data do we collect, why and on which legal basis
  5.1. When we provide the Services to our customers
  5.2. When you provide your products or services to us (suppliers)
  5.3. When you contact us with a question about our products and services
  5.4. When we send you our email marketing communications
  5.5. When you register to attend our webinar, business breakfast or other events
  5.6. When we perform market research activities
  5.7. When you visit our website
  5.8. When you apply for a job or internship with us
6. How and with whom do we share your personal data?
7. How do we transfer your personal data outside the EEA?
8. How do we secure your personal data?
9. What are your rights in respect of your personal data?
10. How can you object to the processing of your personal data?
11. How can you exercise your rights?
12. Do we conduct automated decision-making that significantly affects you?
13. How long do we keep your personal data?
14. How often do we update this Privacy Notice?

1. DEFINITIONS

In the text, we use specific data protection terms, and their definitions are the following:

The term “LIFETIMESMS PRIVATE LIMITED” or “us” or “we” or “our” refers to the company LIFETIMESMS PRIVATE LIMITED, with its registered office at the H#:2 , St #:4 ,Ghulaam Bhatti Colony , Near Bhatti Flats 1KM Chandrai Road , Chungi Amer Sidhu Lahore and registration number of SECP is 0139467, NTN : 6396773-5 as well as to its affiliates (the full list of LIFETIMESMS PRIVATE LIMITED affiliates with contact details can be found at: https://Lifetimesms.com/contact-us).

The term “GDPR” means the EU General Data Protection Regulation (the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC).

The term “personal data” means any information about you by which you can be identified, directly or indirectly.

The term “controller” means the natural or legal person which determines the purposes and means of the data processing and is responsible for processing such data in a manner consistent with the GDPR and other applicable European and national regulations on personal data protection.

The term “processor“ means a natural or legal person who processes personal data on behalf of the controller.

The term “Services” means LIFETIMESMS PRIVATE LIMITED’s cloud-based communication products and services (CPaaS – Communications Platform as a Services and CCaaS – Contact Centre as a Services).

The term “you” refers to a natural person (an individual) whose personal data LIFETIMESMS PRIVATE LIMITED collects and processes.

2. ABOUT LIFETIMESMS PRIVATE LIMITED SERVICES

LIFETIMESMS PRIVATE LIMITED is a Communications Platform as a Services (CPaaS) and Contact Centre as a Services (CCaaS) provider. While providing Services to our customers and processing personal data, we act either as the controller or the processor, depending on the situation.

Our customers are mainly companies that integrate our Services into their business operations through their own software applications (via API) or using LIFETIMESMS PRIVATE LIMITED Portal (CUP), our website interface. By using our cloud communications platform, our customers are able to send or exchange their communications with their end users using different communication channels (for example, SMS, email, Voice). We are not in direct relationship with our customers’ end users, so we will distribute these communications through telecom operators and other communications providers.

We act as the processor when processing personal data of individuals on behalf of our customers, and for the sole purpose of providing our Services to them. We do that within limits and according to customers’ instructions and in line with the Service terms and conditions, agreement for Services and/or data processing agreement concluded with the customer.

For example, when you, as an end user of our customer are the recipient of communication that our customer sent you by using our platform (such as an SMS message), we send that customer’s communications acting on behalf of our customer. That means that the customer is the controller, and LIFETIMESMS PRIVATE LIMITED is the processor.

Any request we may receive from customers’ end users regarding their rights related to our activities taken on behalf of our customers will be forwarded to customers, or the end users will be asked to contact them directly.

In situations when we process personal data for our own purposes and do not act on behalf of someone else, we act as the controller and we are committed to processing that data as described in this Privacy Notice and respecting all obligations arising from the GDPR and other applicable data protection legislation.

3. CONTROLLER’S CONTACT DETAILS

LIFETIMESMS PRIVATE LIMITED, H#:2 , St #:4 ,Ghulaam Bhatti Colony , Near Bhatti Flats 1KM Chandrai Road , Chungi Amer Sidhu Lahore

Contact details of all LIFETIMESMS PRIVATE LIMITED affiliates (LIFETIMESMS PRIVATE LIMITED group companies) are available at: https://Lifetimesms.com/contact-us

If you have questions regarding this Privacy Notice or about the LIFETIMESMS PRIVATE LIMITED Group’s privacy practices, you may reach our Privacy team and Data Protection Officer via the email address [email protected].

4. HOW DO WE OBTAIN PERSONAL DATA?

Most of the personal data we process is provided to us directly by you for one of the following reasons:

• You created an account and started using our Services
• You visited our website, registered for more information on a specific Service, and/or you initiated communication with us
• You registered to attend or have attended an event organised by LIFETIMESMS PRIVATE LIMITED
• You subscribed to our e-newsletter, blog or a webinar
• You accepted to participate in our market research activities
• You applied for a job or internship with us.

We also receive personal information indirectly, such as in the situations where:

• Our customer or supplier provided us with the contact details of its representatives and personnel who will be our business contact points
• Our customer provided us with the contact details of individuals authorized to use its account to access our Services,
• Our customer provided us with the contact details of its personnel who will attend our event
• Our customer provided us with contact details of its end users (such as telephone number or email address) when using our Services
• An employee of ours gave us your contact details when naming you as a referee
• We have collected your information from LinkedIn or other publicly available sources or from data enrichment providers.

5. WHAT PERSONAL DATA DO WE COLLECT, WHY AND ON WHICH LEGAL BASIS, HOW DO WE USE IT AND FOR HOW LONG DO WE KEEP IT?

5.1. When we provide the Services to our customers
5.2. When you provide your products or services to us
5.3. When you contact us with a question about our products and services and when we are looking for new business opportunities
5.4. When we send you our email marketing communications
5.5. When you register to attend our webinar, business breakfast or other events
5.6. When we perform market research activities
5.7. When you visit our website
5.8. When you apply for a job position with us

5.1. When we provide the Services to our customers

5.1.1. To create the customer’s account and enable the customer to start using our Services:

What personal data do we collect?

We collect customer’s “account data”, which is data that relates to the customer’s relationship with LIFETIMESMS PRIVATE LIMITED.

If you sign up for our Services, in order to create a customer’s “account” we ask for your name, contact details (e.g., phone number, email address, country), and certain related information such as your company’s name, industry and your business role, as well as your login details (e.g., username and password, or API key).

We also collect names, contact details and login details of customer’s personnel or any other individual authorised by the customer to log into and utilise our Services connected with the customer’s account (a “user” of the customer’s account).

Within the customer’s account we also collect billing information (such as billing address, information on whether the customer is a legal entity or an individual, prepaid or postpaid subscriber, and further information if we are legally required to, and depending on each country’s legislation).

When doing business with legal persons, we may collect personal data (such as name, business contact details, position in the company) related to their representatives and other personnel that will be our contact points.

Collecting your name, contact details, login details, and billing information is necessary for us in order to enter into an agreement for Services with you. Therefore, we will not be able to provide you with our Services without collecting this basic information. If you sign up for a free trial account, you are not required to enter your billing information unless and until you decide to continue with a paid subscription to our Services.

How do we collect personal data?

If you are our customer as an individual, we obtain this data directly from you. If your organisation is our customer, we may obtain your personal data either directly from you or via your organisation.

Why do we collect personal data, under which legal basis, and how do we use it?

We collect and use collected data for agreement signing and agreement administration purposes, to create your account and enable you to access and use our Services, to keep your account secure, to provide you with customer care and technical support, to share relevant information about our products and services and to exercise our rights and fulfil our obligations arising from the business relationship that we may have with you or with your organisation.

Conducting these activities is our legitimate interest according to GDPR article 6.1.(f) in the sense of providing our Services to your organisation. However, if you personally are our contractual counterpart, we process your data because it is necessary for the performance of an agreement for Services, or in order to take steps, at your request, prior to entering into the agreement in accordance with GDPR article 6.1.(b).

5.1.2. To enable customers to exchange their communications by the use of our Services and to ensure the security of our network and Services:

What data do we collect?

We collect traffic data. Traffic data is data that is processed for the conveyance of a communication exchanged by using our Services or for billing related to that communication, and it includes data on the routing, type, duration, and time of the communication. So, this data encompasses data used to trace and identify the source and destination of a communication (including customer end user’s telephone number or email address, depending on the Service provided).

We also collect the commands your application communicates to LIFETIMESMS PRIVATE LIMITED (such as your IP addresses, information on your usage, routing information), as well as logs on your activities created during your use of our tools and Services and we connect this information with your account details.

How do we collect this data?

We receive the customer’s end user’s telephone number or email addresses from our customer, while other traffic data are automatically generated or unveiled during the process of conveyance of a communication.

We collect data related to your activities on our platform directly from you when you use our Services.

Why do we collect this data, under which legal basis, and how do we use it?

We collect and process traffic data to provide customers with our Services, that is, to manage traffic with the purpose of transmitting customer’s communications toward or from telecom operators and other communication networks, in order to handle customer’s enquiries and to calculate charges.

If you, as our customer, are an individual, we rely on GDPR article 6.1. (b) for these processing activities, since it is necessary for the performance of our agreement for Services. If our customer is a legal person, we rely on our legitimate interest (GDPR article 6.1.(f)).

We also process traffic data to prevent spam and fraud, for troubleshooting and detecting problems with the network, and to settle interconnection payments with telecom operators and other communications providers. Should we have a billing dispute with our customer or with telecoms or other communications providers, we may need to use traffic data related to routing (including the end user’s telephone number or email address, as well as the customer’s IP address) in order to resolve it. The carrying out of these activities is our legitimate interest in the sense of GDPR article 6.1.(f).

In order to comply with our legal obligations (article 6.1.(c) GDPR), we may be obliged to retain records containing communications related data as stipulated in the relevant national data retention provisions regulating the law enforcement matter, and to share them upon government request.

We collect logs on your activities created during your use of our Services and connect this information with the customer’s account details in order to secure customer’s account, to prevent or detect fraudulent activities, and to ensure the security of the LIFETIMESMS PRIVATE LIMITED network. This information is necessary to construct the timeframe of user’s activities in the case of security-related incidents, and to be able to take adequate steps for mitigation. IT security is crucial for us, so for these activities we rely on our legitimate interest and on the legitimate interest of our customers (GDPR article 6.1.(f)) to maintain and improve the security of our network and Services.

5.1.3. To improve our products and Services

What data do we collect?

We collect the data you generate during your activity on our platform (e.g. your behaviour records inside our web interface, such as time spent, pages visited, history of your visits and features used).

How do we collect this data?

We obtain this data directly from you. When you browse our website and use our Services, we automatically collect data by placing cookies and trusted tracking technologies on your browser.

Why do we collect this data, under which legal basis, and how do we use it?

The information we collect helps us maintain and improve our website and business. It usually includes your IP address, browser type, the pages you have visited and the order you visited them in as well as whether you are a new or a returning visitor.

If you are already our customer, we’ll use the data collected from your account to gain insight into the way you use our platform and Services, what your business needs are, past support issues, and so on. This information makes it possible for us to tailor our assistance and product offers and provide the best possible support.

We analyse your activities on our platform and collect data that is useful for the improvement of our products and Services, relying on our legitimate interest in accordance with GDPR Article 6.1.(f). We take partially automated measurements that include human intervention in order to analyse the way you use the features and tools available on our platform (e.g., by tracking and recording your behaviour inside our web interface, including time spent, pages visited and features used) in order to give you recommendations to improve your performance (e.g. how to better access some feature). Also, we create statistics on the use of our tools to understand which tools have a user-friendly design and which should be enhanced. The general goal of such activities is to enhance your and your company’s messaging execution when communicating with your end users.

How long do we keep your personal data?

If you as our customer are an individual, we will erase all personal information collected about you within 12 months after the end of the provision of our Services, except the data that we need to keep to comply with our legal obligations arising from financial and tax laws and regulations. For that reason, personal data related to your account such as your name and contact details, billing details as well as an agreement for Services and billing documentation will be kept for a period defined by applicable tax and financial legislation.

In the case our customer is a legal person, all personal data collected within the customer’s account will be kept in a form that can identify an individual (such as names and contact details of customer’s personnel contact points obtained from the customer) for 12 months after the end of the provision of the Services.

Your requests and other communication exchanged with our support team via our help desk (support ticketing) system may be kept for three years after the end of the provision of the Services.

Traffic data will be kept in accordance with the applicable national legislation regulating retention of data in electronic communications for law enforcement purposes. As we may need to keep traffic data in order to calculate charges, we will keep them for billing and to settle our payments towards telecoms and other communications providers until payments are settled, the longest until the end of the period during which the bill may lawfully be challenged or payment pursued. In case that a bill remains unpaid or has been challenged before being paid, we will keep data to establish, exercise or defend our legal rights, the longest until the court or other legal procedure is finally closed.

Behaviour analytics i.e. data generated during your activity on our platform are kept for twenty- five months.

In case that legal matters such as litigation, law enforcement requests or government investigations acquire us to preserve records, including those containing personal information, we will delete the impacted records when no longer legally obligated to retain them.

5.2. When you provide your products or services to us

What personal data do we collect?

If you as our supplier are an individual, we collect your name, contact details (such as address, phone number, email address), certain related information such as your company’s name, industry and your business role, and your billing information (e.g., billing address, information on whether you are a business or an individual, your VAT number, bank account details, and further information if we are legally required to and in accordance with applicable national legislation).

Collecting this data is necessary for us in order to enter into an agreement with you. Therefore, we will not be able to purchase your products or services without collecting this personal data.

When doing business with legal entities, we collect personal data related to their representatives and other personnel that will be our contact points (such as their name, business contact details, position in the company).

How do we collect personal data?

If you as an individual are our supplier, we obtain this data directly from you. If your organisation is our supplier, we may obtain your personal data either directly from you or via your organisation.

Why do we collect personal data, under which legal basis, and how do we use it?

We collect and will use this data for agreement signing and agreement administration purposes, to maintain and improve our business relationship, to get relevant information about our supplier’s product or services, or to share relevant information about our business and services with you, as well as to exercise our rights and fulfil our obligations arising from the business relationship that we may have with you or your organisation.

Conducting these activities is our legitimate interest according to GDPR article 6.1.(f) in the sense of purchasing products or services from a supplier that is a legal person. However, if you personally are our contractual counterpart, we process your personal data because it is necessary for the performance of an agreement or in order to take steps, at your request, prior to entering into an agreement in accordance with GDPR article 6.1.(b).

How long do we keep your personal data?

If you as our supplier are an individual, we will keep your personal data collected when entering into an agreement (such as your name, contact details, billing details, as well as the agreement concluded with you and billing documentation) for a period defined by applicable tax and financial legislation.

Your requests and other communication exchanged with our support team via our help desk (support ticketing) system will be kept for three years after the end of the agreement.

If our supplier is a legal person, personal data of the supplier’s personnel that were our contact points during the business relationship we had obtained from our supplier will be deleted or made anonymous within 12 months after the end of the provision of the Services.

If legal matters such as litigation, law enforcement requests or government investigations require us to preserve records, including those containing personal information, we will delete the records in question when we are no longer legally obligated to retain them.

5.3. When you contact us with a question about our products and services and when we are looking for new business opportunities

What personal data do we collect?

We may collect your name and basic contact and business information such as your email address, phone number, country, company, industry, and business role. We will also collect any other information you choose to send us, depending on the nature of our communication.

How do we collect your personal data?

We may collect this information directly from you through our “Contact Sales” or other forms available on our website. After submitting your details, we will send you an email to confirm that our sales team will contact you.

We may also collect your information directly from you when you register on our website to learn more about our business and services, start chatting with us via our chat channel, and when you provide us your contact information when requesting further information.

We are constantly searching for new business opportunities. Therefore, we may collect your contact and business information indirectly, through business and professional networks and databases (such as LinkedIn) or we may employ third parties that supply us with information collected from publicly available sources and data enrichment providers. We only retain the information that will help us reach potential customers and suppliers that could benefit from our services and products, or if we are interested in their products and services.

Why do we collect personal data, under which legal basis, and how do we use it?

We collect this information to contact you, answer your questions, and to find out if you or your organisation are interested in further cooperation with us.

We use your personal data to provide you with the requested information about our products and services and to see if you are interested in using them, or if we can benefit from using your products and services, as well as to provide you with all the necessary information and support required to ensure the mutually beneficial and satisfying cooperation if you become our customer or supplier. Any further processing of your personal data will be based on the business relationship established with you or your organisation and on the lawful processing ground.

Such activities represent our legitimate interest in accordance with GDPR article 6.1.(f).

If there will be a mutual interest in entering into an agreement, we will process your personal data within the presales and purchasing process to ensure adequate technical and administrative support (tender procedures, negotiating, and concluding agreements). In accordance with GDPR article 6.1.(f), it is our legitimate interest to conduct this process properly. If you personally are our contractual counterpart (as an individual), we process your data because it is necessary for the performance of a contract or in order to take steps, at your request, prior to entering into a contract in accordance with GDPR article 6.1.(b).

How long do we keep your personal data?

If we do not enter into an agreement, we will delete your personal data collected for this purpose within six months after our last communication.

In any case, if you no longer wish to be contacted by our sales or procurement team, you can always object by sending an email to [email protected].

5.4. When we send you our email marketing communications

What personal data do we collect?

We collect your name and email address.

How do we collect personal data?

We collect this information directly from you if you subscribe to receive our newsletters, blogs or our other email marketing communication by which we provide the information about our business and services. This data is collected through the webforms available on our website.

For business to business (B2B) marketing, if we have an existing business relationship (our customers, suppliers and their staff), we may use data collected from you or your organisation when entering into an agreement or during our business relationship.

Why do we collect personal data, under which legal basis, and how do we use it?

Our purpose for collecting the information is the provision of the services to you and informing you about news, webinars and upcoming events.

We use your details only to provide these services. We also gather statistics around email opening and clicks using industry standard technologies, including clear gifs to help us improve our e-newsletter.

If you subscribe to our email marketing communication, we rely on your consent (Article 6.1.(a) GDPR) provided to us when submitting such webforms. You will receive a confirmation email once you have submitted your details.

For B2B (business to business) direct marketing, we may rely on our legitimate interest in accordance with GDPR article 6.1.(f). For the purpose of maintaining and improving our business relationship, it is our legitimate interest to inform our existing business partners (customers and suppliers, including their staff) about our products and services, news, webinars, and upcoming events via email newsletters, blogs or other forms of email communication.

In any case, you may proactively manage your preferences or opt-out of communications (unsubscribe) with LIFETIMESMS PRIVATE LIMITED at any time using the unsubscribe link provided in all LIFETIMESMS PRIVATE LIMITED’s email marketing communications. In case that you have unsubscribed from our marketing communications (i.e. withdraw your consent or object to the processing) we will stop sending you any marketing materials.

However, we maintain a so-called “suppression list” that contains only your email address just to be sure that we will not contact you with unwanted content in the future. We retain this information relying on our legitimate interest (article 6.1(f) GDPR).

How long do we keep your personal data?

If we send you marketing communications based on our legitimate interest (B2B) we will do so only during the business relationship with you or your organisation (existing agreement for products or services is in place), or until you object to the processing of your personal data for this purpose. We will keep a suppression that contains email addresses of individuals that objected to receiving our marketing communications until the end of the business relationship with you or your organisation.

If you subscribed to receive our email marketing communications, we will provide you this service until you unsubscribe, i.e. withdraw your consent. The suppression list with email addresses of individuals that withdraw their consent is kept for five years following the year when they unsubscribed.

5.5. When you register to attend our webinar, business breakfast, or other events

What personal data do we collect?

When you register for our webinar, we collect your name, email address, and company information as necessary information.

When you register to attend a business breakfast or any other event (hereinafter: event), you will be asked to provide your name and contact details (email, phone number, country), as well as your company’s name, industry, and your business role.

We may also ask you information about the time and place of your arrival as well as accommodation details and dietary requirements you may have.

If you require us to provide you with an invitation or support letter, or you need to get letter of guarantee to be able to get a visa, we will collect the necessary information required by applicable law (such as your name, address, date of birth, passport details).

We may collect photos, audio, and video material from our events.

How do we collect your personal data?

We collect your personal data directly from you when you fill in our registration forms.

Sometimes your organisation will send us your contact details to attend our event on their behalf, and we will send you an invitation with the link for registration.

Why do we collect personal data, under which legal basis, and how do we use it?

If you register for a webinar, we will use your contact details to provide you with the webinar details in advance, to remind you of the webinar and email you the recording of the webinar subsequently.

If you register to attend our event, we will use gathered information to ensure your place at the event, to be in touch with you to provide you (via email address or by SMS provided in registration form) all relevant information before your arrival and during the event, to facilitate the event and ensure all organisational support that you may need. For example, help you with information about the location of our event, accommodation, travel or any logistic details related to the event.

The legal basis we rely on for processing your personal data is your consent under article 6(1)(a) of the GDPR, provided when you submit your details through our registration forms. When we collect any information about dietary requirements, we also rely on your consent (under article 9(2)(a)) as this type of information is classified as a special category of personal data.

If you will need an invitation or support letter or letter of guarantee to be able to get a visa, we have to collect the necessary information about you as defined by the applicable legislation. We collect this information just to respond to your request and support you with the necessary documentation and we rely on your consent (article 6(1)(a) of the GDPR) provided when you submit us your personal data for this purpose. Such information will not be processed for any other purpose than issuing such a document upon your request. However, we may be legally obliged to share such a document with government authorities and to keep it for a certain period of time, as defined by applicable legislation and for these processing activities we rely on article 6.1(c) of the GDPR.

In order to be able to facilitate the event, we rely on your consent to process your personal data and this means you have the right to withdraw your consent at any time by sending an email to [email protected].

We also keep events’ inviting lists containing only your name, contact details, your company’s name, industry and your business role. In this case, the processing purpose is to maintain a list of former participants in order to invite them to future events we consider they might be interested in. To be able to stay in touch with you and invite you to our other events, we rely on our legitimate interest in accordance with GDPR article 6.1.(f). You may object to these communications at any by time using the unsubscribe link provided in all LIFETIMESMS PRIVATE LIMITED’s emails and we will stop sending you event invitations.

We also conduct promotion activities of the events we held. In this case, the processing purpose is to promote our events, and it consists of publishing photos, videos, audios, and texts in online and offline media. These activities represent our legitimate interest in the sense of GDPR article 6.1.(f).

How long do we keep your personal data?

Personal data collected when you register for our webinar will be erased within 30 days after the webinar.

We keep events’ inviting lists for three years after the event day.

Invitation or support letter or letter of guarantee will be kept for a period of time determined by the applicable legislation.

All other personal data collected will be kept only for the duration of the event and will be erased within 30 days after the event day.

5.6. When we perform market research activities

What personal data do we collect?

We collect your name and contact information (email address). The idea of the researches we conduct is to gather anonymous information. Therefore, our intention is to collect only your personal data necessary to send you a questionnaire but not to link the anonymous answers with you in any way.

How do we collect your personal data?

We collect your name and contact data (email address) from business and professional networks (for example LinkedIn), or from our databases if you or your organisation are our customers, suppliers or business contacts.

Why do we collect your personal data, under which legal basis, and how do we use it?

We conduct market research activities in order to receive anonymous information and feedback for improving our products and services and targeting potential.

Firstly, we invite you to take a survey sending a generic untraceable URL to a survey questionnaire. If you decide to participate and answer our questions, we will not ask you to unveil any personal data, and our intention is to keep the answers anonymous.

When searching for your email address, we rely on our legitimate interest in accordance with GDPR Art. 6.1.(f). Our intention is to collect anonymous information. However, if you disclose any information about you in your answers, we will rely on your consent in accordance with GDPR Art. 6.1.(a).

Keep in mind that we respect your privacy rights, so we do not carry out any activity to link the answers provided with you, and we do not inform other organisations (e.g. your employer) on the answers you provided in any way.

How long do we keep your personal data?

We will process the answers you provided in order to have general feedback on our products and services. However, we will never ask you to reveal any personal data in your answers, our intention is not to collect personal data within this activity, and if you reveal any personal data in your answers, it will be promptly deleted.

5.7. When you visit our webpage

We use third-party services such as Google Analytics when you visit www.LifetimeSMS.com in order to collect standard internet log information and details on visitor behaviour patterns. We do this to find out information such as the number of visitors to various parts of the site. This information is only processed in a way that does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of visitors to our website.

When you browse our website, we automatically place functional cookies on your browser. You can opt in to accept advertising or analytical cookies. The information we collect helps us maintain and improve our website and business. It usually includes your IP address, browser type, the pages you’ve visited and the order you visited them, as well as whether you’re a new or returning visitor. For more information please read our Cookie Policy.

5.8. When you apply for a job or internship with us

What personal data do we collect?

We collect your first and last name, contact information (email address and telephone number) and location/place of residence as well as information about your education, previous work experience, and any other information you choose to share with us in your resume (CV) or application when expressing interest in joining our team.

We may also collect professional information about you from the business networking sites you use (such as LinkedIn) and we may search their content in order to find out more professional information about you if your resume or application contains links to other sources (e.g. web pages).

If we arrange an interview and you go through our selection process, we may collect further information gathered from you during the interviews, results of conducted evaluation tests, interview notes and reviews of our colleagues who interviewed you. We may also collect information about your professional experience from your referees, if you indicated them.

How do we collect your personal data?

We collect your personal data directly from you when you submit your resume and/or application directly into our recruitment software.

If you choose to send your resume to a staff member who will be your referee, it will be passed on to authorized employees on our recruitment team and entered into the recruitment software by us. We recommend you submit your resume directly into our recruitment software (a link is available at https://Lifetimesms.com/contact-us).

We may collect your personal data indirectly from recruitment agencies we have engaged in order to help us find potential candidates for open positions or from business networking sites you use, such as LinkedIn.

We may collect further information about you during the selection process. This information will be generated by you and by us. For example, you might complete an evaluation test or we might take interview notes or contact your referees.

Why do we collect personal data, under which legal basis, and how do we use it?

As we are a young and growing company, we are in constant need of new, talented individuals who will become part of our global team.

You can find information on open positions and internships in our offices all around the world on our Careers web page (https://Lifetimesms.com/contact-us), where you can follow the link to our recruitment software and submit your resume and/or application if you are interested in joining us. When submitting your resume, you will be asked to provide us your consent to store and process your personal data for recruitment purposes for the period of time specified in the consent form.

We rely on your consent to collect and process your personal data in accordance with article 6.1(a) GDPR. We use your personal data for recruitment purposes, e.g. in order to contact you and check if you are interested in open positions or internships, and if you are, to conduct the selection process and assess your suitability.

If you do not submit your resume directly into our recruitment software (e.g. when you send it to a staff member who is your referee, when we receive it from a recruitment agency, or we find your professional details on business networking sites you use), we will send you an email with a link to our recruitment software and you will be asked to provide us your consent to keep your personal data for recruitment purposes. In such cases, we collect your personal data and contact you with an email based on the legal grounds of our legitimate interest pursuant to GDPR article 6.1(f), in order to find potential job candidates. However, we need your consent for any further processing of your personal data. If you do not provide us with the consent within thirty days following the receipt of the email, we will erase your personal data from our database.

During the selection process we collect further information in order to review your professional qualifications and interests and be able to choose the best candidate. For the collection of this information, we rely on our legitimate interest (article 6.1(f) GDPR).

If you have been selected as the most suitable candidate for a job position or internship, you will be presented an offer. If you accept it, we will collect further information so as to be able to conclude and execute an agreement with you. We rely on article 6.1(b) of the GDPR for the further collection and processing of your personal data because the processing is necessary in order to conclude an employment or internship agreement with you or in order to take certain steps, at your request, prior to entering into that agreement. You will be presented with an LIFETIMESMS PRIVATE LIMITED privacy notice that applies to our staff where you can find relevant privacy information.

We collect and process your personal data through the recruitment platform of our processor, SmartRecruiters Inc.

Your personal data are collected and stored on servers maintained by Amazon Web Services in a data center located in the European Union.

Your personal data will be processed by authorized members of the LIFETIMESMS PRIVATE LIMITED recruitment team. However, if there is a problem with the platform, the SmartRecruiters support team may also have access to your personal data in order to help us resolve the problem. SmartRecruiters is a USA-based company with which we have concluded a data processing agreement and EC Standard Contractual Clauses. Additionally, SmartRecruiters Inc. is compliant with the EU-US and Swiss-US Privacy Shield Framework.

If you want to know more details about SmartRecruiters’ privacy practices, you can refer to the SmartRecruiters’ Privacy Policy.

We may share your personal data within LIFETIMESMS PRIVATE LIMITED group companies (contact-us). Since we are a global company, we may engage our affiliates in which we have employed members of our recruitment team in order to complete the recruitment process.

How long do we keep your personal data?

As we rely on your consent for recruitment purposes, we only keep your personal data for the consented time.

Your personal data will be erased from our database after the expiration of the period for which you have provided us with your consent or earlier if you withdraw it.

Please note that you have the right to withdraw your consent at any time. If you want to withdraw your consent or to edit your profile, you can do so yourself by accessing your profile in our recruitment software. Otherwise, you can always withdraw your consent as well as exercise your other rights by contacting our Data Protection Officer.

6. HOW AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

We may engage processors to facilitate us in the processing of your personal data through CRM (Customer Relationship Management), marketing, recruitment and other tools necessary for conduct our business activities or to assist us in providing you with our Services.

We maintain an up-to-date list of them, including reference to the special safeguards on which we rely on when transferring your personal data outside the EEA.

Before engaging a new processor, we perform security & privacy assessment of the processor, and we ensure that the processing of personal data is always regulated with written data processing agreements. If the personal data during the provision of the services of our processor is being transferred outside the European Economic Area (EEA), LIFETIMESMS PRIVATE LIMITED will always ensure that the transfer is in line with applicable data protection laws, including the GDPR.

We may share your personal data within LIFETIMESMS PRIVATE LIMITED Group companies (contact-us). Since we are a global company, we may share your personal data with our affiliates to complete internal procedures within our offices, to perform certain processing activities on a global scale or to support you in the use of our products and services. LIFETIMESMS PRIVATE LIMITED affiliates can be engaged as processors or in certain situations can act as joint controllers.

All LIFETIMESMS PRIVATE LIMITED affiliates will only use the personal data as described in this Privacy Notice. All intercompany processing of personal data is regulated by the LIFETIMESMS PRIVATE LIMITED Group intercompany agreements on personal data processing and transfer and where applicable with European Commission standard contractual clauses.

Notwithstanding the foregoing, as a rule, we do not share personal data with third parties except when necessary, 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 operating all over the world, especially OTT ones such as Whatsapp, Viber, Facebook, Kakaotalk, Line, Telegram, Vkontakte.
• With third-party service and technology providers, to the extent strictly necessary for them to perform specific actions on our behalf. We may share personal information with our trusted and verified third-party service providers, for example, in order to enable them to process payments for us or to prevent fraud.
• Due to relevant legislation. If we are presented with the legal obligation, we will share the data with third parties that are legally entitled and authorized to request it, such as for criminal procedures or because of threats to public security. 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.
• Targeted Advertising. We do not and will not sell, rent, or share in any other shape or form any information to a third party for advertising or similar marketing purposes. We do, however, use direct marketing through Google Adwords for our own purposes. You can visit our Cookie Policy or adjust the advertising settings in your browser. There you will be able to find out more about how to manage your advertising preferences to suit your needs.

7. HOW DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE THE EEA?

Your personal data may be processed both inside and outside of the European Economic Area by the parties specified in the section above, subject always to contractual restrictions regarding confidentiality and security in line with applicable data protection laws and regulations.

In any case, any activity that involves access to the personal data from outside the EEA (with or without re-locating the personal data) is done in accordance with the high EU data protection standards, either by implementing EU standard contractual clauses, by transferring personal data in accordance with the EU data protection adequacy decisions or by implementing another adequate GDPR transfer mechanism.

8. HOW DO WE SECURE YOUR PERSONAL DATA?

LIFETIMESMS PRIVATE LIMITED values your privacy. In order to protect personal data collected and processed by LIFETIMESMS PRIVATE LIMITED we have invested in development, implementation, and constant improvement of a wide range of technical and organisational measures. Our technical and organisational measures have been implemented in accordance with ISO 27001:2013 standard requirements.

We take care to train all our staff in the field of privacy and security, starting from their first day in LIFETIMESMS PRIVATE LIMITED through the onboarding process and continuously throughout their stay at LIFETIMESMS PRIVATE LIMITED.

Before we engage any third-party vendor and service provider, we check their security practices and alignment with the GDPR, and regularly conduct our vendors’ and service providers’ security and privacy assessments.

9. WHAT ARE YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA?

Under GDPR and/or other applicable data protection law, you have rights we need to make you aware of.

Where permitted by applicable data protection law or regulation, 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 request a copy of the personal data we hold about you,
• ask us 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, and we will reassess the legitimacy of the processing,
• you may also have specific rights in exceptional cases when we may carry out automated decision-making operations, including profiling,
• you also have a right to file a complaint with us and/or the relevant data protection authority.

You can exercise these rights within limits stipulated by the applicable data protection legislation.

10. HOW CAN YOU OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA?

If we process your personal data upon our legitimate interest, you have the right to object to the processing. In such a case we will reassess its legitimacy and will no longer process your personal data unless we are able to demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or for the establishment, exercise or defence of legal claims.

However, when we process your personal data for direct marketing purposes, you have the right to object at any time to such processing of your personal data, and in this case, your personal data will no longer be processed for marketing purposes. You can exercise this right by using the unsubscribe link provided in all LIFETIMESMS PRIVATE LIMITED’s email marketing communications.

11. HOW CAN YOU EXERCISE YOUR RIGHTS?

If you have any questions on how we use your personal data or if you wish to exercise a certain right (as specified under 10 and 11 of this Notice) or resolve a complaint regarding the processing of your personal data, you can contact our Data Protection Officer by sending an email to the following email address: [email protected] or by sending a written request via the postal address: LIFETIMESMS PRIVATE LIMITED d.o.o., attn. Data Protection Officer, Istarska 157, 52 215 Vodnjan, Croatia.

If you want to file a complaint or contact the relevant data protection authority for any other reason, you may find contact details of EEA data protection authorities at: https://edpb.europa.eu/about-edpb/board/members_en.

In particular, you can lodge a complaint with the supervisory authority of the EU member state of your habitual residence, place of work, or place of the alleged infringement.

12. DO WE CONDUCT AUTOMATED DECISION-MAKING, INCLUDING PROFILING, THAT SIGNIFICANTLY AFFECTS YOU?

No. We do not conduct any operation under which you would be subject to a decision based solely on automated processing that has legal or similarly significant effects for you, including profiling.

13. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

Your personal data that has been collected and saved in our database in accordance with your consent and will be saved in our database 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 from our database, you can do that at any time by sending an email to [email protected].

Regarding your personal data that is not subject to your consent, we will process it for the period necessary to fulfil the purposes outlined in this Privacy Notice, unless a longer period for the processing of such personal data is required or permitted by law. We have provided relevant information under section 5 of this Privacy Notice. Any storage of data beyond the deletion deadlines will encompass only non-personal data (aggregated or anonymized data).

14. HOW OFTEN DO WE UPDATE THIS PRIVACY NOTICE?

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 by posting a written notice on our website.