Last Update published on the 22nd of July 2019.
We want to explain to you how doctorSIM obtains and processes personal data according to the new regulation. Not only do we wish to comply with the General Data Protection Regulation, but also help you understand in a clear and transparent way how we collect, use, and share information about you, and give you the opportunity to decide how your data is handled.
1. Who are we?
doctorSIM is an Internet-based technology company that provides a wide range of services for the cell phone industry worldwide. We are responsible for handling the personal data transferred between our customers (the “Customers” or “Users”) and doctorSIM. Our corporate name is DOCTORSIM MOBILE S.L., registered in Spain with VAT ID number B-84987056 and located at Avenida de Brasil 17, Floor 17A, 28020 Madrid. We can be contacted via the mailing address above, by e-mail email@example.com or any other method listed here.
- Users of doctorSIM SERVICES, (for example, cell phone unlocking services, IMEI checks, top-ups or other services related to cell phones).
- Users browsing the doctorSIM website searching for products and services of interest to them, looking for the best deals or comparing current market prices.
- Users wishing to contact doctorSIM via Chat or any other method listed here.
- doctorSIM Users that sign up and provide personal information by completing an online form and thereby creating a User Account. A registered user is anyone who can access and manage all aspects of their profile with the use of a username and password, as well as interact with the doctorSIM website.
3. What data do we collect?
doctorSIM can obtain data from its Users coming from:
- Information requested using our online registration or checkout form, basically, identifying data related to your cell phone (including, but not limited to, the IMEI number or original operator) and the SERVICE you are interested in purchasing. The SERVICES offered by doctorSIM are listed and defined in our Terms & Conditions.
- Information we need to receive proving you have granted us permission to collect the information outlined in the previous point (at the very least, identification, IP address, date and time).
- Information you wish to provide voluntarily while browsing the doctorSIM website, such as clicks, comments, or by selecting specific content. We also have access to collection data, payments, invoices and other information allowing us to charge for the SERVICES.
- Information through interactions with the doctorSIM website (such as purchases, phone unlockings, phone checks, top-ups, refunds, questions or comments) related to doctorSIM’s SERVICES.
- Contact information provided to doctorSIM through different communication channels, or information requests regarding a SERVICE.
- Browsing data obtained from our website which is used for technical purposes, performance enhancements and for analyzing commercial transactions.
4. Do we handle personal data required to purchase your products and services?
You will often need to purchase products and SERVICES offered by doctorSIM. In these cases, we will only process the data necessary to render the SERVICE and/or contract diligently.
5. Why do we ask for your permission?
Your express permission is vital for us to obtain your personal data in order to give you full access to doctorSIM’s features, products and services.
In doctorSIM’s case, you provide your consent by:
- Pressing the button to submit the online form with your personal information.
6. Why do we need your personal information?
The reasons why we need your personal information are as follows:
- Allow you to enjoy, place orders and make use of the SERVICES offered by doctorSIM and so doctorSIM can charge for them.
- Allow invoices to be processed, verify payments and resolve any issues with the payment method selected.
- Allow the delivery and provision of products and/or SERVICES.
- Allow User claims to be handled accordingly.
- Allow handling of the Account and Profile of the User.
- Sending you, through any communication channel, including electronic (email and text messages), advertising, newsletters and commercial information related to all doctorSIM activities (direct marketing).
- So we can include your personal data in customer profile segments allowing us to display information which is relevant to you (e.g. services that you can access from where you are located or in your preferred language).
We will only ask you for the personal information strictly required to carry out these functions. And in all cases, the only information used will be that which you have given prior consent.
7. Do you share my personal data with third parties?
We may share your personal data with specific providers when necessary for the fulfillment of the SERVICE, to unlock or top up a device, to deliver items purchased through doctorSIM, to repair a cell phone including pick up and delivery, for consultancy, management, and provision of mobile phone services or to process your complaints and disputes related to the service.
Keeping in mind that doctorSIM offers a wide variety of online payment methods, operating at all times within a safe and secure environment to minimize possible fraud, we may also allow the financial institutions that fulfill these payments access to your personal data as well as other organizations dedicated to the detection, prevention, and control of online criminal activities.
We may share some of your information, as data processors, with payment service providers, payment method validators, data and payment processors or for fraud prevention purposes.
Attached for your reference, is the Data Protection and Crime Prevention Manual published on May 10, 2018, by the Spanish Agency for Data Protection which helps companies collaborate with the prevention of cyber crime and online fraud.
8. Can I receive promotional materials from doctorSIM?
Of course. We would like to provide you with regular updates and inform you of any additional SERVICES, however, we guarantee you can opt out immediately from any e-mail you receive from doctorSIM by clicking on the unsubscribe button in EACH AND EVERY e-mail.
9. How long do you store my data?
The length of time we store your data is determined by different factors:
- Your profile information and other data collected while interacting with doctorSIM will be kept while you continue to interact with us (e.g. if you access your Profile, if you open or click on any of the e-mails we send you, purchase one of our products/services, etc.).
- As data collected relating to the purchase of products and services is subject to different storage and documentation regulations by public, fiscal and/or other institutions, doctorSIM may be obliged to store the data for a certain length of time in each case according to the applicable law.
- If at any time in the future the Regulation changes requiring us to keep your data for a longer period of time, we will do so in order to fully comply with the Regulation.
10. What are my rights regarding personal data?
The rights you have with regards to your personal information are as follows:
- The Right of Access: The right to request access to and obtain free of charge any personal information we have stored on you and to use for your own purposes.
- The Right to Rectification: The right to update any personal information which is incorrect or incomplete.
- The Right to Erasure: The right to ask us to delete all personal information on you from our records.
- The Right to Object: The right to object to the processing of your personal data in certain circumstances.
- The right to revoke consent: You have the right to withdraw your consent at any time.
- The right to restrict processing: You have the right to restrict the processing of your personal data in certain circumstances.
- The Right to Data Portability: The right to request that your personal information is sent to another company, institution, organization or yourself.
11. How can I exercise my rights?
You can exercise each and every one of your rights by contacting us either:
- By sending a letter to “Data Protection Rights” at DOCTORSIM MOBILE S.L., Avenida de Brasil 17, Floor 17, 28020 Madrid, Spain; or
- By sending an e-mail to firstname.lastname@example.org with “Data Protection Rights” in the subject header.
12. What if I’m not in agreement with something?
If you have any concerns, a complaint, suggestion or any other question regarding how your personal information is handled, please contact the doctorSIM Data Protection Officer (DPO) at email@example.com.
And in any case, you have the right to file a complaint if you consider it appropriate with the Spanish Data Protection Authority, using this link: Spanish Agency of Data Protection.
We include, for your reference, the Data protection: Guide for the citizen prepared by the Spanish Agency for data protection.
13. What happens to my browsing data?
14. What is expected of me?
Our only wish is that you are responsible with the information you share. We can neither control nor review the legality of the information you provide and, therefore, under no circumstances will be held liable for any consequences resulting from the incorrect, illegitimate, illicit or misuse of the information you have provided. With this in mind, we understand that you guarantee that any data you provide to us is legal and accurate.