Testelium collects Personal Data from its Users, it is necessary for performing services of Testelium listed on the Testelium.com website. You may contact Testelium through email [email protected] or within Contact Form https://testelium.com/contact-form/ at any time if you want to delete, change, transfer or perform any other actions with data that belongs to You.
Data Controller
The Testelium service is operated by two companies under common ownership and control, each a “Testelium Entity”:
TELECOM SOFTWARE OÜ - Pae tn 25-47, Tallinn, Harjumaa 11414, Estonia, Registry code 14393345
TESTELIUM LIMITED - No. 5, 17/F, Strand 50, 50 Bonham Strand, Sheung Wan, Hong Kong, Company / Business Registration No. 80785866
Contact email for all privacy matters: [email protected]
Which entity is the Data Controller of your Personal Data
Testelium Estonia
If you are a visitor of testelium.com, an End User of the Testelium mobile application, or a person who contacts us through the website, TELECOM SOFTWARE OÜ is the Data Controller.
Testelium Estonia or Testelium Hong Kong
If you are a client of Testelium, or a representative of a client, the Data Controller is the Testelium Entity with which your company has entered into an agreement. That entity is identified in your order form, in your account on the Platform and on each invoice. TESTELIUM LIMITED contracts only with clients established outside the Hong Kong Special Administrative Region.
The Testelium Entities apply the same privacy standards, the same security measures and the same retention periods. You may address any request under this policy to [email protected] regardless of which entity is the Data Controller, and it will be routed to the correct entity.
Types of Data collected
Among the types of Personal Data that Testelium collects, by itself or through third parties, there are: Cookies, Usage Data, phone number, email address, SMS permission and name of User.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
The Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Testelium.
All Data requested by Testelium is mandatory and failure to provide this Data may make it impossible for Testelium to provide its services. In cases where Testelium specifically states that some Data is not mandatory, Users are free not to communicate this Data without any consequences on the availability or the functioning of the service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Data Controller identified above.
Any use of Cookies - or of other tracking tools - by Testelium or by Data Controllers of third-party services used by Testelium serves the purpose of providing the service required by the User, in addition to any other purposes described in the present document.
Users are responsible for any third-party Personal Data obtained, published or shared through Testelium and confirm that they have the third party’s consent to provide the Data to the Data Controller.
Mode and place of processing the Data
Methods of processing
The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by Data Controller. The Data may also be accessible to the other Testelium Entity where this is necessary for the operation of the Platform and the provision of support. The updated list of these parties may be requested from the Data Controller at any time.
Place
The Data is processed at the operating offices of the Testelium Entities in Estonia and in the Hong Kong Special Administrative Region, at the locations of our hosting and infrastructure providers, and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.
Transfers outside the European Economic Area
Hong Kong is not covered by a European Commission adequacy decision. Where Personal Data originating in the European Economic Area or the United Kingdom is transferred to TESTELIUM LIMITED in Hong Kong, or to any other recipient in a country without an adequacy decision, the transfer is made under the Standard Contractual Clauses adopted by the European Commission (Implementing Decision (EU) 2021/914), together with the UK International Data Transfer Addendum where applicable.
Transfers between the Testelium Entities are governed by an intra-group data transfer agreement incorporating those clauses. A copy of the clauses applicable to your data may be requested at [email protected].
Retention time
The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data. Account and billing data is retained for the term of the agreement and for 3 years thereafter, as required by accounting and tax legislation in Estonia and in Hong Kong. Usage Data and system logs are retained for 12 months. MSISDNs of End Users are retained for as long as the End User participates in the node community and are deleted on withdrawal of consent.
The use of the collected Data
The Data concerning the User is collected to allow Data Controller to provide its services, as well as for the following purposes: Analytics, Contacting the User, Handling payments, Hosting and backend infrastructure, Interaction with support and feedback platforms, Location-based interactions, Managing contacts and sending messages and Managing support and contact requests.
The Personal Data used for each purpose is outlined in the specific sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Analytics
The services contained in this section enable Data Controller to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Ireland Limited for users in the European Economic Area and the United Kingdom; Google LLC for other users)
Google Analytics is a web analysis service provided by Google. Google utilizes the Data collected to track and examine the use of Testelium, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: Ireland and the United States. Transfers to the United States rely on the EU-U.S. Data Privacy Framework and, where applicable, on Standard Contractual Clauses. – Privacy Policy – Opt Out
We will use cookie files and tracking technologies to store and manage our User’s preferences on our Website and analyse the User’s Data and usage data. You can set your browser to refuse all or part of browser cookies. If you refuse or opt out of cookies, some features or information on our Website may not operate in a proper manner.
Contacting the User
Phone contact (Testelium). Users that provided their phone number might be contacted for commercial or promotional purposes related to Testelium, as well as for fulfilling support requests. Personal Data collected: phone number.
Contact form (Testelium). By filling in the contact form with their Data, the User authorizes Testelium to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header. Personal Data collected: email address, name, company name and any other information the User chooses to provide.
Handling payments
Payment processing services enable Testelium to process payments by credit card, bank transfer or other means. To ensure greater security, Testelium shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction. Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment. Payments are handled by the Testelium Entity that is the Data Controller for your account, through its own banking and payment providers.
Hosting and backend infrastructure
This type of service has the purpose of hosting data and files that enable Testelium to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Testelium. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Managing support and contact requests
This type of service allows Testelium to manage support and contact requests received via email or by other means, such as the contact form. The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address, name, details specified in a message, created by User).
Further information about Personal Data
Legal action
The User’s Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of Testelium or the related services. The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
In addition to the information contained in this privacy policy, Testelium may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, Testelium and any third-party services may collect files that record interaction with Testelium (System logs) or use for this purpose other Personal Data (such as IP address).
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.
The rights of Users
Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.
If your Data Controller is TELECOM SOFTWARE OÜ
The GDPR applies. You have the rights of access, rectification, erasure, restriction of processing, data portability, objection to processing and the right not to be subject to automated individual decision-making. You may lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, aki.ee) or with the supervisory authority of your habitual residence.
If your Data Controller is TESTELIUM LIMITED
The Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong applies in addition to the rights described above. Under the Ordinance you have the right to make a data access request and a data correction request. We will respond to such a request within 40 days of receiving it. A fee may be charged for complying with a data access request, as permitted by section 28 of the Ordinance; any such fee will not be excessive. If we refuse a request, we will give you written reasons. You may complain to the Office of the Privacy Commissioner for Personal Data, Hong Kong (pcpd.org.hk).
Requests under either regime should be sent to [email protected].
Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using Testelium and can request that the Data Controller remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.
Definitions and legal references
SMS. Stands for “Short Message Service.” SMS is used to send text messages to mobile phones. The messages can typically be up to 160 characters in length, though some services use 5-bit mode, which supports 224 characters.
Personal Data (or Data). Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.
Usage Data. Information collected automatically from Testelium (or third-party services employed in Testelium), which can include: the IP addresses or domain names of the computers utilized by the Users who use Testelium, the URI addresses, the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer, the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
User. The individual using Testelium, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.
Data Subject. The legal or natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor). The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.
Data Controller. The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of Testelium. The Data Controller of Testelium is the Testelium Entity identified in the “Data Controller” section above.
Testelium Entity. TELECOM SOFTWARE OÜ or TESTELIUM LIMITED, as described in the “Data Controller” section above.
Testelium. The hardware or software tool by which the Personal Data of the User is collected.
Cookies. Small piece of data stored in the User’s device.
Legal information
Notice to users in the European Economic Area and the United Kingdom: this privacy statement has been prepared in fulfilment of the obligations under Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR) and of the corresponding provisions of the UK GDPR, and under Directive 2002/58/EC as amended by Directive 2009/136/EC on the subject of cookies.
Notice to users in the Hong Kong Special Administrative Region: this privacy statement also serves as a Personal Information Collection Statement for the purposes of the Personal Data (Privacy) Ordinance (Cap. 486) where TESTELIUM LIMITED is the Data Controller.
This privacy policy relates solely to Testelium.
Data Controllers
TELECOM SOFTWARE OÜ - Pae tn 25-47, Tallinn, Harjumaa 11414, Estonia, Registry code 14393345
TESTELIUM LIMITED - No. 5, 17/F, Strand 50, 50 Bonham Strand, Sheung Wan, Hong Kong, Company / Business Registration No. 80785866