Privacy Policy

Telna collects some personal data from its users. 

Owner and Data Controller

Telna (Telecom North America Ltd.)

Your privacy matters. Telna is committed to providing secure and reliable global connectivity. We value your privacy and as part of our commitment, we want to be transparent about the data we collect and how it is used. 
This Privacy Policy applies when you purchase a Telna product and/or use Telna Services. Owner contact email: [email protected]

Types of Data collected

Among the types of Personal Data that Telna collects, by itself or through third parties, there are: Cookies, Usage Data, email address and various types of Data.

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.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Telna.
Unless specified otherwise, all Data requested by Telna is mandatory and failure to provide this Data may make it impossible for Telna to provide its services. In cases where Telna specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by Telna or by the owners of third-party services used by Telna serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through Telna and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing
The Owner takes 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 Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Telna (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 the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner 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 authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Content commenting, Interaction with external social networks and platforms, Interaction with live chat platforms, Analytics, Remarketing, and behavioral targeting, Handling payments, Managing support and contact requests, Platform services and hosting and Data transfer outside the EU.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective 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:

Analitycs
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of Telna, 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: US – Privacy PolicyOpt Out.

Data transfer outside the EU
The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Users can inquire with the Owner to learn which legal basis applies to which specific service.

Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield (Telna)

If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU – U.S. and Swiss – U.S. Privacy Shield.
In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List. Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce.
Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal
grounds. Users can ask the Owner to learn about such legal grounds.

Personal Data collected: various types of Data.

Data transfer abroad based on standard contractual clauses (Telna)

If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

Personal Data collected: various types of Data.

Interaction with external social networks and platforms
This type of services allow interaction with social networks or other external platforms directly from the pages of Telna.
The interaction and information obtained through Telna are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

Facebook Like button and social widgets (Facebook, Inc.)

The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.

Twitter Tweet button and social widgets (Twitter)

The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.

Google+ +1 button and social widgets (Google Inc.)

The Google+ +1 button and social widgets are services allowing interaction with the Google+ social network provided by Google Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.

Managing support and contact requests
This type of service allows Telna 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).

Freshdesk (Freshworks, Inc.)

Freshdesk is a support and contact request management service provided by Freshworks, Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

Remarketing and behavioral targeting
This type of service allows Telna and its partners to inform, optimize and serve advertising based on past use of Telna by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
In addition to any opt-out offered by any of the services below, the User may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.

AdRoll (AdRoll, Inc.)

AdRoll is an advertising service provided by AdRoll, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy PolicyOpt Out.

Facebook Custom Audience (Facebook, Inc.)

Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of Telna with the Facebook advertising network.
Personal Data collected: Cookies and email address.
Place of processing: United States – Privacy PolicyOpt Out. Privacy Shield participant.

Content commenting
Content commenting services allow Users to make and publish their comments on the contents of Telna.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

Facebook Comments (Facebook, Inc.)
Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User to leave comments and share them on the Facebook platform.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.

Disqus (Disqus)
Disqus is a content commenting service provided by Big Heads Labs Inc.
Personal Data collected: Cookies, Usage Data and various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy – Opt out.

Handling payments
Payment processing services enable Telna to process payments by credit card, bank transfer or other means. To ensure greater security, Telna 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.

PayPal (PayPal Inc.)

PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: See the PayPal privacy policy – Privacy Policy.

Stripe (Stripe Inc)

Stripe is a payment service provided by Stripe Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

2Checkout (2Checkout.com, Inc.)

2Checkout is a payment service provided by 2Checkout.com, Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.

Interaction with live chat platforms
This type of services allows Users to interact with third party live chat platforms directly from the pages of Telna, for contacting and being contacted by Telna support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

Zopim Widget (Zopim Technologies Pte Ltd)

The Zopim Widget is a service for interacting with the Zopim live chat platform provided by Zopim Technologies Pte Ltd.
Personal Data collected: Cookies and Usage Data.
Place of processing: Singapore – Privacy Policy.

Platform services and hosting
These services have the purpose of hosting and running key components of Telna, therefore allowing the provision of Telna from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

WordPress.com (Automattic Inc.)

WordPress.com is a platform provided by Automattic Inc. that allows the Owner to build, run and host Telna.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.

Shopify (Shopify Inc.)

Shopify is a platform provided by Shopify Inc. that allows the Owner to build, run and host an e-commerce website.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: Canada – Privacy Policy. Privacy Shield participant.

Further information about Personal Data

Service use & device and location
Service use

The Owner (Telna) or third-party services employed by the Owner collects information automatically when the User uses or engages with Telna Products & Services, such as the Telna website and platform technology. The information collected includes the User usage data, purchases made and how the User engages with content or ads. Telna uses login information, cookies, device information, and internet protocol (“IP”) addresses in order to identify Users, log API calls, and provide User support.

Telna Customer Support accesses User data to troubleshoot and resolve User complaints and service issues. Additional information may be requested from the User to investigate further. User data may be shared with third party vendors in order to address service issues beyond Telna’s control.

Device and location

In order to offer services, Telna automatically collects User information pertaining to device location, operating system, IP address, device identifier, ISP and/or mobile carrier connection, cell id, and Telna app version.

Advertising
Telna uses User Data in order to communicate news, special offers, and promote growth and engagement. Telna targets and analyzes ads displayed to Users and visitors on Telna.com and other partners’ sites, using Data from advertising technologies (e.g. pixels, cookies, and ad tags), information provided by the user (e.g. home country), and Data from roaming service usage (e.g. amount of data used, countries visited).

Personal Data collected: the amount of data used, home country, countries visited, cookies, pixels and ad tags.

Communications
Telna provides Users with email, text messages, and push notifications to communicate the following, but is not limited to, availability of Services, policy changes, network disruptions, order confirmations, rate changes, account information details, and personalized offers. By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive commercial or promotional email messages. Users may opt out of receiving promotional marketing emails at any time by clicking the unsubscribe link located at the bottom of every email. However, Users cannot opt-out of receiving communications related to service and account updates, including security and legal notices. If a user wishes to stop receiving all account-related communication, they must cancel their account by reaching out to [email protected]

Personal Data collected: email address, first name, last name, home country, and country located.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to the processing

Where Personal Data is processed for the public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookies Policy

Telna uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Telna or the related Services.
The User declares to be aware that the Owner 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, Telna 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, Telna and any third-party services may collect files that record interaction with Telna (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled
Telna does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within Telna and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.