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What is the purpose of this Privacy Statement / Policy
This Privacy Statement / Policy is intended to provide you, with information on how epic collects, uses, discloses and processes your Personal Data when you use epic services, products, websites and applications, and also to inform you about your rights under the national data protection law and Regulation (EU) 2016/679 on the Protection of Natural Persons with Regard to the Processing of Personal Data and on the Free Movement of Such Data [General Data Protection Regulation (“GDPR”)].
Who we are
Epic Ltd is a private company registered under the laws of the Republic of Cyprus with registration number HE 141156 having its registered address at 16 Kyriakou Matsi Avenue, Eagle House, 10th floor, 1082 Agioi Omologites, Nicosia and its headquarters at 87 Kennedy Avenue, 1077 Nicosia, Cyprus.
Epic uses third parties (agents and partners) who act on its behalf in:
• promoting and selling epic products and services;
• concluding the contracts with the customers, including on premises contacts, distance contracts (via telephone), and off - premises contracts (door -to- door);
• contacting the customer and providing support.
Epic Ltd has appointed a Data Protection Officer and the contact details are as follows: 87 Kennedy Avenue, 1077 Nicosia, Cyprus, P.O Box 20683 – CY 1662, email address email@example.com, fax number 96969151.
What Personal Data are processed and where we collect it from
The Personal Data processed by epic or its agents vary according to the interaction we have with you and the services / products we offer you. Personal Data may include amongst other:
a. Customer Data - your name, surname, national identification number / passport number, email address, residence and billing address, contact number(s), payment records, invoices issued per service per month, details of authorised representatives per contract, direct debit details (where needed), debit or credit card details (where needed), any customer preferences (where needed), voice recordings and complaints filed through epic call center or through any other support channels of epic;
b. Telecommunication / traffic and Billing data – location data, called subscriber number, date, starting time and duration of the calls made and/or the data volume transmitted, IP address, internet browsing, number of identification of subscriber devices, details of modem data, TV traffic data, Set Top Box data, TV channels and programs watched, Video on Demand (VOD) data, billing records;
c. CCTV data - Closed Circuit Surveillance System processing in epic stores and other premises where needed for security purposes.
We process Personal Data which we receive from you, in our stores, via our website, call center and eStore or via our agents and partners and through alternative sales channels such as Telesales and Door-to- Door.
We may also collect and process Personal Data which we lawfully obtain not only from you but from third parties such as credit reference agencies, or companies that process card payments.
What security measures are taken
The security of your Personal Data is important to us. Epic takes technical, contractual, administrative, and physical security actions to protect your Personal Data. Employees of epic with access to your Personal Data process those data in adherence with the principles set forth in this Privacy Statement / Policy and according to all applicable legislation.
What is the Purpose of Processing Personal Data and the Legal Basis of such processing
Your Personal Data shall be processed by epic, its agents and partners, solely for the purposes of:
a) providing you the services according to the subscription agreement you have signed with us;
b) subscriber billing and interconnection payments;
c) managing your account and help you manage your account;
d) getting in touch with you (e.g. if we need to tell you about any problems with a service);
e) recovering any money, you might owe us;
f) maintaining our client relationship management systems;
g) client support;
h) checking your creditworthiness, credibility and payment integrity so we can assess and decide on whether we can provide products and services by installments;
i) resolving client complaints and handling requests and enquiries;
j) initiating or participating in litigation procedures;
k) performing customer satisfaction surveys;
l) conducting investigations relating to disputes, billing, suspected illegal activities or fraud;
m) processing of payment instructions, through direct debit facilities or through any other way of payment chosen by you and/or credit facilities requested by you;
n) analyzing your use of the epic products and services to help us improve, review, develop and efficiently manage the products and/or services offered to you;
o) managing epic network;
p) helping you issue an insurance coverage for your device;
q) your Personal Data may be shared with other network operators, to enable the making and receiving of calls, and/or to investigate fraud. Epic may also need to give your Personal Data to emergency services.
The above purposes of processing fall under one of the following legal basis:
(I) for the performance of a contract; processing of Personal Data is necessary in order for epic to proceed in providing you with the products and services that you have requested.
(II) for compliance with a legal obligation; processing of Personal Data is necessary in order to comply with a provision contained in legislation to which epic is subject.
(III) for the purposes of safeguarding legitimate interests; a legitimate interest is when we have a business or commercial reason to use your information by respecting fundamental rights and freedoms.
(IV) when you have provided to epic your consent; in such a case the lawfulness of the processing is based on the specific consent you have provided. You have the right to withdraw your consent at any time, without affecting, however, processing already performed prior to the receipt of your revocation.
Who are the recipients of your Personal Data
All recipients of Personal Data, act under strict contractual obligations which they have undertaken after signing relative agreements with epic, requiring them to maintain the confidentiality of all Personal Data and to use such data solely for purposes related to the provision of epic services and products.
Recipients of Personal Data include the following:
a) our agents, partners and suppliers, enabling epic to provide you with the products and services that you have requested timely and efficiently;
b) other network operators;
c) authorized service centers for the repairing of devices sold by epic;
d) consulting, technical and support service providers;
e) commercial and credit information providers;
f) companies providing credit risk management, debt recovery and call center services;
g) companies for the storing, managing and protecting information as well as cloud storage companies;
h) banking institutions and card payment processing companies;
i) insurance companies;
j) our external legal advisors;
k) our accountants;
l) any court, supervisory, or public authority as required by law;
m) an acquiring entity, in connection with an epic corporate re-organization, merger or amalgamation, or a sale of all or a substantial portion of the assets of epic provided that the Personal Data disclosed continues to be processed only for the purposes permitted by this Privacy Statement / Policy and according to applicable legislation, by the entity acquiring the data;
n) people or entities to which you have instructed us to disclose your Personal Data.
How do we transfer data about you
If there is a need for epic to send your data to a country that is not in the EEA, such transfer will only take place if the European Data Protection Standards are complied with, and appropriate safeguards are put in place in accordance with GDPR.
How long we keep your Personal Data
Epic stores your Personal Data for the duration of the contract and/or for as long as we are required to perform the contract and/or as long permitted by law. Upon expiration or termination of your contract with our Company and in the absence of any outstanding balances, legal disputes, claims or complaints on your behalf, your Personal Data may be retained for satisfying the requirement of the below laws:
• The Retention of Telecommunication Data for the Purpose of the Investigation of Serious Criminal Offenses Law of 2007 (Law 183 (I) / 2007) for the purpose of criminal offenses;
• The Limitation of Conduct Rights Law 2012 (Law 66 (I) / 2012) for the purpose of Court claims;
• The Value Added Tax Law of 2000 (95 (I) / 2000) and the Taxation and Collection of Taxes Act of 1978 (Law 4/1978) for the purpose of taxation;
• The Provision and Use of Payment Services and Access to Payment Systems Act of 2018 (Law 31 (I) / 2018) for the purpose of payments.
Otherwise, your data will be deleted in a way that is not technically recoverable.
How we treat your Personal Data for marketing activities
We may process your Personal Data to inform you about epic products, services and offers that may be of interest to you or your business.
The Personal Data that we process for this purpose consists of information you provided to us and data we collect when you use our services e.g. from the use of your mobile plans. We study such information to form a view on what products may be of interest to you. We process your data automatically with the aim of evaluating certain personal aspects in order to provide you with targeted marketing information on epic products and services.
We only use your Personal Data for the above purposes if you have provided your explicit consent or if it is in our legitimate interest to do so. You have the right to object at any time to the processing of your Personal Data for marketing purposes, by contacting epic at 136 or by sending an email to firstname.lastname@example.org or by visiting an epic store and completing the Data Subject Request Form.
Withdrawal of consent
Unless processing is necessary in order for epic to proceed in providing you with the products and services that you have requested, you may withdraw you consent for data processing at any time. Possible withdrawal does not affect the lawfulness of processing based on consent before such withdrawal.
In order to exercise this right you may contact us or send an email to email@example.com or visit an epic store and complete the Data Subject Request Form.
What are your rights
According to GDPR, you have the following rights that you can exercise free of charge:
a) right of access – You have a right to request a copy of the Personal Data we hold, and be informed on how it has been processed.
b) right to rectification - If you believe any of the Personal Data, we hold about you is incorrect or inaccurate, you can request that we update it.
c) right to erasure - In some circumstances, such as where we no longer have a justifiable reason to continue to process your data, you can request we delete it.
d) right to restriction of processing – You have the right to request the restriction of processing of your Personal Data where the accuracy of the data is contested, when you consider the processing as unlawful but you do not wish the erasure of your data, when data are no longer needed for the purpose of processing but they are required by you for possible legal claims or when you have objected the processing pursuant to article 21(1) of GDPR.
e) right to data portability - You have the right to receive the Personal Data which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party.
f) right to object - Where we are processing your Personal Data for the purposes of direct marketing, or any legitimate interests that epic is reliant upon, you can object at any time to this processing.
Please note that if your Personal Data has been provided to epic by a third party you should contact that organization or individual to make such queries and/or complaints.
If you would like to discuss or exercise any of your rights or for any further information on how epic uses your Personal Data, you may contact our DPO’s office by email at firstname.lastname@example.org. Your rights can also be exercised by visiting one of our stores and completing the Data Subject Request Form.
Lodging of complaints
If you have a complaint, you can contact us. We will do our best to help but if you’re not satisfied with our response, you have the right to lodge a complaint with the supervisory authority, the Office of the Commissioner for Personal Data Protection, Iasonos 1, 1082 Nicosia, Cyprus, P.O. Box 23378, 1682 Nicosia, Cyprus, tel: +357 22818456, fax: +357 22304565, email: email@example.com.
Changes to this Privacy Statement / Policy
Epic may from time to time change its Privacy Statement / Policy as new epic services are added or old ones changed. Changes will be effective when notice of those changes is posted on epic website (www.epic.com.cy). Please check this Privacy Statement / Policy regularly for updates.
Last updated: 2/07/2020