PRIVACY POLICY 

Effective as of ​13.12.2022 

We respect and value your privacy, so we have taken the protection of Personal data seriously. With this Privacy Policy, we aim to explain to you in a transparent and understandable way how we collect, share, and use your data, as well as how you can exercise the rights you have as a Data subject. 

This Privacy Policy applies to all personal data that is collected and processed by us, TelQ Telecom GmbH, with the seat at the address Neuer Wall 71, 20354, Hamburg, Germany, as a data controller, in relation to the use of the App Money SMS.  

If you do not agree to this Privacy Policy, please do not access, or otherwise use the App Money SMS.  

In case you have any inquiries regarding this Privacy Policy, you can contact us at ​[email protected]. ​ 

  1. Definitions 
  1. TelQ as a data controller  
  1. What personal data do we collect and how? 
  1. Personal data security  
  1. Who do we share your personal data with? 
  1. How long do we keep your data? 
  1. Your rights  
  1. Changes to our Privacy Policy 
  1. Contact us 
  1. DEFINITIONS 
When we say…   We mean…  
 “App Money SMS” or “Application” or “App” 
Money SMS 
 Mobile application in the ownership of TelQ. Free android app that enables you to make money online automatically by receiving or sending test SMS generated by our system and our customers. 
 “Consent” 
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 Your explicit consent to the processing of personal data. Persons who are 18 years of age or older may give free consent to the processing of their Personal data.    
 “Controller  or “data controller” 
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 The entity that alone or jointly with others, determines the purposes and means of the processing of personal data. For the purpose of this Privacy Policy, TelQ is the controller. 
 “Cookies” 
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 Small pieces of code stored on your device. Based on their type, they may be used to provide you with certain functions of the App Money SMS, collect data on your device and configuration, or compile statistical reports of the App Money SMS usage. 
 “Data processor” 
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 Any natural or legal subject who processes Personal data on our behalf. We may use the services of various service providers to process your Personal data more effectively.  
 “Data subject” or “you”  
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 Any natural person who shares their Personal data with TelQ through App Money SMS. 
GDPR” 
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 General Data Protection Regulation 2016/679.  
 “Personal data” or “data”  
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 Any information relating to an identified or identifiable natural person (Data subject);   An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, identification number, location data, online identifier or to one or multiple factors specific to its physical, physiological, genetic, mental, economic, cultural, or social identity. Data about a company or any legal entity is not considered to be personal data but registering on behalf of a legal entity may include sharing personal data.   However, the information related to one-person companies may constitute Personal data when it allows the identification of a natural person. The privacy rules also apply to all personal data relating to natural persons in the course of professional activity, such as the employees of a company or organization, and business e-mail addresses like “[email protected]”.   
 “Processing”  <div>Icons made by <a href="https://www.flaticon.com/authors/noomtah" title="noomtah">noomtah</a> from <a href="https://www.flaticon.com/" title="Flaticon">www.flaticon.com</a></div>   Any activity or set of activities performed on Personal data or sets of Personal data, whether by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.  
 “We or TelQ”    TelQ Telecom GmbH, HRB: 144036, with the seat at the address Neuer Wall 71,  20354,Hamburg, Germany. 
“Usage Data”  Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), 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 (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) 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 this Application who, unless otherwise specified, coincides with the Data Subject. 

Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Definitions section of the Terms of Use

  1. TELQ AS DATA CONTROLLER  

Regarding your personal data processed via the App Money SMS, TelQ acts in the capacity of a data controller. That means that we are responsible for determining the purposes and means of the processing of your personal data. In the table of Section 3a. of the Privacy Policy, you can access the listed cases when TelQ acts as a data controller. There you can also read about the purpose and legal basis for each specific data processing. 

  1. WHAT PERSONAL DATA DO WE COLLECT AND HOW? 

We may collect and receive information about you in two ways: 

  1. Information you voluntary provide 

All personal data that you provide to us needs to be true, complete, and accurate, and you are obliged to notify us of any changes to such personal data.  

  1. Information we collect automatically when you use App Money SMS 

Please note that Money SMS App can read your private messages in order to determine which messages are our test messages and which are not. Once it’s determined, we save our test messages on our server and user’s messages are not saved anywhere. Please note that Money SMS App does not use any other data, unless specifically stipulated in this Privacy Policy.  

Additionally, we only store those messages that contain our code and that turn out to be our tests. All other messages are discarded and are not stored anywhere in our system. 

Money SMS App is not intended to be used for the processing of the special categories of Personal Data, and we do not analyse any such Personal Data. Special categories include the information on your racial or ethnic origin, religious and/or philosophical beliefs, health data, sex life or sexual orientation data, information on your political opinions, trade union membership, and genetic or biometric data.  

Not processing personal data of data subjects under the age of 18 

App Money SMS is not intended for minors, and we do not knowingly collect data relating to a person younger than 18. If you are under the age of 18, please do not provide any personal information about yourself to us. If we detect that we have collected personal information from a person under the age of 18, such information will be deleted promptly. If you believe we have collected personal information regarding a child under the age of 18, please contact us at [email protected]

  1.  PROCESSING – WHAT, WHY, ON WHAT GROUNDS, AND FOR HOW LONG? 

In the table below, you can read about the collection of your personal data in detail. 

DATA WE COLLECT
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PURPOSE
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LEGAL BASIS
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    Your email address, country, password, and phone number. Once you register, we will also collect your preferred method of payment (BitCoin, Ethereum, Litecoin, PayPal), the address linked to that payment account, and the income that you have received from us, including the registration bonus.  Registration and  Maintenance of Your Account
We collect this data to create your account, send to you or send from your phone number the test SMS, and pay you a certain amount to your preferred account. 
    Processing is necessary for the performance of the Agreement (as defined in the Terms of Use) or to enter into such an Agreement with you. Failure to provide this Data may make it impossible for TelQ to provide its services.  
  In case you are participating in our referral program, we will collect information about your referral code, and information about the income from the referral program.  Referral program  
Money SMS referral program enables you and your friends to earn more money through the App. You can get your referral code from the App and ask your friends to use it during registration. 
  Processing is necessary for the performance of the Agreement (as defined in the Terms of Use) and providing the Services. 
   Your phone number, content, and other information about the test SMS that we have sent to your phone or you’re your phone number (which contains our code) and the number of SMSs received/sent from us in the last 30 days.  Sending/Receiving Test SMS i.e. providing the Service  
We are sending test SMS in order to provide you the Service and perform the Agreement we have concluded with you. We are sending, processing, and saving only the SMSs that we have sent you or sent from your phone number, to check if they have been delivered to your mobile phone and, if so, in what form or for the tests sent from your phone number to check two-way delivery of SMS. All other messages are dismissed and not saved anywhere in our system.   Please note that Money SMS App can read your private messages in order to determine which messages are our test messages and which are not.   Once your balance is updated, please feel free to delete the messages. 
   Processing is necessary for the performance of the Agreement (as defined in the Terms of Use) or to enter into such an Agreement with you. Failure to provide this Data may make it impossible for TelQ to provide its services.   
   Your email address, or social media account, and any additional information that you share with us.  Responding to your inquiries  
We collect your personal data in order to respond to the inquiries or comments that you sent us via email or social media, and to provide and improve the App Money SMS. 
   Processing is necessary for the performance of the Agreement (as defined in the Terms of Use) or to enter into such an Agreement with you, but it is also based on your consent. You can withdraw your consent at any time, but this will not affect the lawfulness of processing based on your consent that was carried out before you withdrew your consent.  
   Your email address, phone number, and any additional information that you share with us.  Managing support and contact requests  
We collect your personal data in order to manage support and contact requests you send us. 
   Processing of personal data is either necessary to provide a Service or part thereof, or the processing is based on your consent. 
   Technical data and data related to your device.  Technical data and Usage Data  
Automatically collected data is used for:  • managing and improving the App Money SMS, • analysis of the use of the App Money SMS; • providing the most efficient configuration of the App Moneys SMS according to a user’s device. 
   Except for the necessary technical data (which is processed based on the performance of the agreement), the processing is based on your consent. Also, you can withdraw your consent at any time, but this will not affect the lawfulness of processing based on your consent that was carried out before you withdrew your consent. If you want to withdraw your consent and manage sharing information about Technical data and data related to your device please go to Settings menu of the App. 
    Your phone number and test results  Providing services to our clients  
In order to be able to provide the services to our clients, we will keep all the test results we received from your mobile phone number since we are contractually obliged to present these tests to our clients. Please note that these test results will be saved even after the deletion of your account.  Additionally, we will keep your phone number for the purposes of maintaining test results correct. Namely, we have algorithms that depend on number of tests received by a user and if the old phone number looks like a new one, our test results will be affected by it. 
    Processing of your personal data is based on our legitimate interest. This data will be stored only for the duration determined by our client that is necessary to fulfill their purposes. TelQ has documented a legitimate interest assessment for greater transparency. 
     Your phone number  Preventing registration of previous users with the same phone numbers  We want to prevent any abuse of App’s benefits by the users, such as a benefit of the sign-up bonus. Therefore, we will keep your phone number after the deletion of your account for these purposes in an anonymized form.       Processing of your personal data is based on our legitimate interest. However, since the data is kept in an anonymized form, we will not be able to identify you or connect your phone number with you. 

We do not process data outside the specified purposes, and, especially, we do not: 

Device permissions for Personal Data access 

Depending on the User’s specific device, this Application may request certain permissions that allow it to access the User’s device Data as described below. 

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact TelQ for support at ​[email protected]​.  

The exact procedure for controlling app permissions may be dependent on the User’s device and software. 

Please note that the revoking of such permissions might impact the proper functioning of this Application. 

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this App as explained in Section 3a of this Privacy Policy. 

SMS permission 

Used for accessing features related to the User’s messaging including the sending, receiving and reading of SMS. 

  1. PERSONAL DATA SECURITY 

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.  

TelQ has implemented appropriate technical and organizational measures to protect the personal data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data.  

However, please note that no method of transmission over the Internet or method of electronic storage is absolutely secure. For that reason, we cannot guarantee its 100% security or confidentiality.  

If you have any questions about security in the App Money SMS, please contact us at [email protected]

  1. WHO DO WE SHARE YOUR PERSONAL DATA WITH? 

To be able to perform some processing activities, we may require additional support from external processors. In such situations, TelQ uses information audits to identify, categorize and make records of all personal data that is processed outside of the TelQ – that way, all the information, processing activity, processor, and legal basis are recorded, reviewed, and easily accessible.  

Such external processing may include (but is not limited to): 

We may be legally required to share certain information, including your personal data, with e.g. public authorities or governmental bodies; in such cases, we will not require your further consent in order to share your personal data in such circumstances. 

Please be aware that your phone number can be shared with third parties (i.e. TelQ’s clients), in order to perform testing of their SMS gateways, check delivery of SMS messages, SMSC, Sender ID, and content of messages. In these cases, TelQ acts as a data processor and TelQ’s client as a data controller. Therefore, please check TelQ’s client’s privacy policies for more information. 

This is the list of processors with whom we share your personal data: 

PROCESSOR 
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ROLE
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SEAT 
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PayPal Inc.  Handling payments  USA 
The Rocket Science Group, LLC (MailChimp)  Managing contacts and sending messages  USA 
Freshdesk  Managing support and contact requests  USA 
TelQ Telecom doo  Software development  Serbia 
Amazon Inc.  Web and Cloud computing Services  USA 
Cloudflare Inc.  Web application security and performance  USA 
Datadog  Cloud Monitoring Services  USA 

We may transfer your personal data to countries other than the one you reside in. In these cases, we will transfer your personal data only: 

  1. To the countries within the EEA; 
  1. To the countries which do not form the EEA but are considered to ensure an adequate level of protection; 
  1. To the countries which do not belong to those specified under items 1. and 2, but only by applying the appropriate safeguard measure in accordance with the GDPR (for example, applying EU standard contractual clauses).  

If you require further information about these protective measures, please contact us at [email protected] 

Your personal data is stored on servers located in Germany. The server will be persisting only SMS messages for which it is proven to be our test results. All other SMS messages will be dismissed from our server. 

  1. HOW LONG DO WE KEEP YOUR DATA? 

TelQ does not keep your personal data longer than the time necessary to fulfil the purpose for which the data is collected, and if in some cases we process your data on the basis of your consent – no longer than the time for which we have your consent.  

Personal Data collected for purposes related to the performance of a contract between TelQ and you shall be retained until such contract has been fully performed. 

Additionally, TelQ may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. 

When determining data retention periods, we take into consideration local laws, contractual obligations, and the expectations and requirements of data subjects, our customers, and suppliers. When we no longer need personal data, or when you legitimately request from us to delete your information, we will securely delete or destroy it. 

  1. YOUR RIGHTS 

Given that data security and transparency are our cornerstone principles, we want you to be aware of the rights that you have as a data subjects. These rights may be exercised by Data Subject when TelQ operates as a Data Controller. 

If your inquiry or exercise of any of the Data Subject’s rights relates to the data processed by third parties, i.e. TelQ’s clients, please contact TelQ’s clients. 

In the event TelQ receives a request for exercising any of these rights directly from a Data Subject, we are obliged to notify the client before responding to such a request. 

 Right to withdraw the Consent 
<div>Icons made by <a href="" title="Cuputo">Cuputo</a> from <a href="https://www.flaticon.com/" title="Flaticon">www.flaticon.com</a></div>Article 13(2)c of the GDPR  
 If you have provided your consent to the collection, processing, and transfer of your Personal data, you have the right to withdraw your consent – fully or partly.   Once we have received a notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented, unless there is another legal ground for the processing.   
 Right to access  
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 You can send us a request for a copy of the Personal data we hold about you.  We have ensured that appropriate measures have been taken to provide such a copy in a transparent and easily accessible form, using clear and plain language.   Such information is provided in writing free of charge. It may be provided by other means when authorized by the Data subject and with prior verification as to the subject’s identity.  Information will be provided to the Data subject at the earliest convenience, but at a maximum of 30 days from the date the request was received. Where the retrieval or provision of information is particularly complex or is subject to a valid delay, the period may be extended by two further months where necessary.  
 Right to correction of your Personal data  
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 Article 16 of the GDPR  
 If the Personal data we have about you is incorrect, you have the right to request that we correct those data. In such a case, we will rectify the error within 30 days and inform any third party of the rectification if we have disclosed the Personal data in question to them.  
 Right to be forgotten  
<div>Icons made by <a href="" title="berkahicon">berkahicon</a> from <a href="https://www.flaticon.com/" title="Flaticon">www.flaticon.com</a></div>Article 17 of the GDPR  
 You have the right to request from us that your Personal data be deleted in these situations: The personal data are no longer needed for the purpose for which they were collected; You have withdrawn your consent (where the processing was based on consent); You have objected to the processing and no overriding legitimate grounds are justifying us processing the personal data;  the Personal data was being unlawfully processed; or the Personal data has to be erased for compliance with a legal obligation.  However, this right does not apply where, for example, the processing is necessary to comply with a legal obligation, or for the establishment, exercise, or defence of legal claims.  
 Right to the restriction of processing 
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 You can exercise your right to the restriction of processing if:  the accuracy of the Personal data is contested,  the processing is unlawful, but you do not want the data erased, we no longer need the Personal data but you require the data for the establishment, exercise, or defence of legal claims, you have objected to the processing, but the verification of whether the legitimate reasons of the data controller override those of the Data subject is pending.   
 Right to data portability  
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 In case you have provided your Personal Data to us, and that data is processed using automated means, you have the right to ask us for a copy of such Personal Data, as well as to have those data transmitted to a third-party data controller. 
 Right to object  
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 You have the right to object to using your Personal Data in case processing is based on our legitimate interest, as well as if the processing is performed with a purpose of direct marketing, which includes profiling. 
 Right to Lodge a Complaint 
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 If you have any concerns or requests in relation to your Personal data, please contact us at [email protected] and we will respond within 30 days.  If you are unsatisfied with how we process your data, you may also contact the competent supervisory authority.  In case you believe that we are processing your personal data in violation of the GDPR, you have the right to lodge a complaint with the supervisory authority located in the EEA where you reside or work or where the alleged infringement took place.   
  1. CHANGES TO OUR PRIVACY POLICY   

TelQ reserves the right to change and update this Privacy Policy periodically at its sole discretion. If we find it appropriate, we may send you the notice regarding the upcoming changes via email or through a pop-up notice. Any change shall enter into force after being published, thus, please review our Privacy Policy from time to time. 

You can access the current version of our Privacy Policy at any time. Please go to Settings > Privacy Rules. In case you do not agree to our Privacy Policy, please stop using the App Money SMS immediately.  

  1. CONTACT US 

If you want to exercise any of the rights that you have as a data subject, or you have a question for us regarding this Privacy Policy, please contact us at [email protected].