Privacy Notice

BACKGROUND:

TONAVE SERVICES LIMITED understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients, customers and partners and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About Us

1.1 Tonave Services Limited, trading under the brand name TonMobile is a limited company registered in the Republic of Cyprus under number HE435321, whose registered address is at Souliou, 18 Strovolos, 2018, Nicosia, Cyprus.

1.2 We are reseller of services provided by Amtel Corporation (https://pondmobile.com).

1.3 We ARE NOT mobile provider or mobile network operator. Data service are provided by their respected network provider in their country. Althoght we are not the network provider, we will provide support to end-users who purchase services we resell.

1.4 WE DO NOT ASSUME ANY RESPONSIBILITY AND MAY NOT BE HELD RESPONSIBLE OR LIABLE FOR CONNECTIVITY AS SUCH, ITS QUALITY, QUANTITY, DIVERSITY, COVERAGE, SECURITY OR/AND ANY OTHER FEATURE OR OPTION A CONSUMER MAY EXPECT FROM A MOBILE OPERATOR OR PROVIDER.

1.5 We provide our services via Telegram bot @mobile. Our web-site contains link to @mobile. Telegram is NOT owned or controlled by Us. PLEASE NOTE that Telegram operates according to its own privacy policy available on https://telegram.org/privacy as may be amended from time to time. IF YOU DISAGREE WITH TELEGRAM PRIVACY POLICY, TERMS OF USE OR ANY OTHER POLICY PLEASE DON’T USE OUR SERVICES. Please check inter alia here how you can manage your privacy setting with bots: https://telegram.org/faq#q-are-bots-safe

1.6 Contact details:

Email: support@tonmobile.com

Telegram: @tonmobilesupport

2. What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) or “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

4. What Personal Data Do You Collect and How?

We may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table.

Data Collected	How We Collect the Data
Name, surname	Telegram bot API
Email address	Directly from you via email or Telegram account @tonmobilesupport
Business information including business name, business address, contact details	Directly from you via email
Payment information including card details, account number, bank name and address	Telegram bot API
Profile public information including Telegram user name, screen name and picture(s)	Telegram bot API

PLEASE NOTE that we get access to and may collect Your personal data via Telegram bot @mobile. @mobile is operated by Telegram under its own privacy policy available on https://telegram.org/privacy as may be amended from time to time. Please check inter alia here how you can manage your privacy setting with bots: https://telegram.org/faq#q-are-bots-safe

5. How Do You Use My Personal Data?

We may use your personal data for doing the following:

Administering our business;
Supplying our services and support to you;
Managing payments for our services;
Personalising and tailoring our services for you;
Communicating with you and supplying you with information on our services.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and text message with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and you will always have the opportunity to opt-out.

We use the following automated system for carrying out certain kinds of decision-making. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), please contact us to find out more using the details in Part 10.

The following automated decision-making method(s) may be used:
- @mobile is a Telegram bot we use to provide our services.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

6. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. We will keep your personal data to comply with our legal obligations, resolve disputes, and enforce our agreements unless a longer retention period is required or permitted by law

7. How and Where Do You Store or Transfer My Personal Data?

Personal data we have access to in Telegram bot @mobile is stored by Telegram according to its privacy policy available on https://telegram.org/privacy as may be amended from time to time. Notwithstanding anything to the contrary in this Notice we do not copy, collect, backup or otherwise operate this kind of personal data outside of Telegram.

Generally we store your persona data electronically in EU member state. However, We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within EEA. By agreeing to use our services you expressly agree and consent to Us transferring your personal data and storing it in abovementioned countries.

8. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:

Amtel Corporation DBA Pond Mobile

We may share your details with credit card processor which you will be notified separately.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EEA.

9. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held).

All subject access requests should be made in writing and sent to the email in Part 10.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will do our best to respond to your subject access request within 20 calendar days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

10. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: support@tonmobile.com

Telegram: @tonmobilesupport

11. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on https://tonmobile.com/en/privacy.

This Privacy Policy was last updated on 01 July 2022.