text revised in July 2019.
In addition, this Policy also applies to our sub-agents who, as individuals, act in support of sales activities for the Service (sub-agents).
Who we are:
In terms of the applicable data protection laws, we, Solford Trading Limited, a limited liability company, organized under the laws of Cyprus, with its seat at Pamelva Court, Office 101, Griva Digeni 2 & Anastasiou Sioukri, 3105 Limassol, Cyprus represent the data controller providing the Service.
This document contains the following information:
- Types of personal data we process
- Purpose and legal basis for personal data processing
- Data processors
- Data retention period
- Measures created in order to protect personal data
- Your rights regarding your personal data
- Contact information
- Third Party Services
Brief overview of important information
Here you can find information about the personal data we collect and process. These are most often basic personal data that you provided when purchasing the service or that were left to us by our sub-agents when establishing a business relationship with them
Detailed legal explanation
Types of personal data we process
Purpose and legal basis for personal data processing
First of all, we use all your personal data in accordance with our contractual relationship in order to provide you with a service based on your request. The specific purposes for which we use your personal data are listed in the right-hand column.
Based on a legitimate interest, we use only certain information about you for the purposes of promotional activities, for the purpose of preventing fraud or abuse (security), as well as due to potential legal requirements related to the provision of the Service.
We also use the personal data of our sub-agents in order to take steps regarding the establishment of business cooperation, as well as the conclusion and execution of contracts.
Finally, based on a written legal request from government agencies, we may disclose your personal data in a manner prescribed by law or when necessary to meet legal requirements.
All personal data is strictly collected and processed so that we can provide you with a service at your request, i.e. execute the contract (including: free trial period, monthly subscription, subscription for 3, 6, 12 or 24 months or any other payment plan). In accordance with the contract we have with you, we use your personal data for the following purposes:
- We identify and verify the identity of users
- We allow you to access the website and use the NetTV Plus service, as well as to create and manage your account
- We check your credit rating
- We keep records of users
- We provide you with the Service
- We make deliveries
- We respond to your inquiries and requests
- We resolve your complaints
- We provide customer support, which includes all relevant information related to the provision of the Service (sending subscription notifications, etc., as well as recording calls to customer support service)
- We calculate payments (including payments made through a third party)
- We process payments.
The processing of personal data for the above purposes is necessary for the execution of the contract or the steps we take before concluding the contract, based on the User's request. If you refuse to provide this personal data, we will not be able to provide the Service to you. Regarding the processing of your payments which you make through our website, we emphasize that we keep only the first six and last four digits of the payment card number, its expiration date and the name and surname of the owner (this information will be visible on your self-care account), and only to allow you to identify which card you have entered in your account, and to verify the first time you enter this information to prevent any misuse. To process payments through the website, we use the services of our partner who is a world-renowned company in this field and who has ensured the application of the highest security standards in its business.
Based on our legitimate interest, we process personal data in order to detect and identify problems / errors in the provision of the service, as well as to detect and recognize fraud and abuse (prevention of multiple use of free gratis, or prevention and detection of piracy). In order to detect a potential abuse or error, we will contact you based on the information you have provided, while, on the other hand, you can also contact us in the event that you assume that a certain error occurred during this processing due to which you were denied access to the Service.
Based on our legitimate interest, we process your personal data in order to conduct research on our offer and quality of service, as well as to improve your user experience.
Also, based on a legitimate interest, we process your personal data in order to communicate with you about our Service and inform you about promotions, special offers, attractive programs and new features of the Service, and thus make available to you interesting, quality and relevant information about the novelties when using the Service and the benefits you can get when purchasing it. We will communicate with you via email address, text messages (SMS or via OTT platforms such as Viber) and online communication channels. For this purpose, we will process your personal data so that we can adjust the communication we send to you, so that it is particularly interesting and relevant to you. This involves the use of various techniques, including the method of communicating through "identifier matching", which allows us to communicate with you through third-party websites and applications (including social media platforms), by sending a protected identifier to that third party. A secure identifier means that the original personal data (e.g. email address or telephone number) is converted into a numeric value that prevents access to personal data and the disclosure of identity by a third party to whom it is sent or by any other person. A third party compares a protected identifier with the identifiers in its database and the match only occurs if you use an identical identifier (e.g. email address) with us and a third party. Only if a match occurs can we decide to send you a commercial communication that would be relevant to you through a third-party website. For example, by using the "Facebook Custom Audience" service, we share your email address with Facebook, but so that it is completely protected and unrecognizable to Facebook or a third party, so that it can apply the described method of "matching identifiers" based on that information, and in the event of possible matches identified, we include you in our "Facebook Custom Audience" to which we place relevant commercial content related to the Service, or so that it can create a group of other Facebook users based on data within your Facebook profile.
If you do not want to receive our commercial communication, you can send us an email at any time [email protected] or [email protected]. In addition, when receiving the newsletter, you can simply click on the unsubscribe link in the email you received from us, while in the case of commercial communication via online communication channels, you can block any further message immediately upon receipt or later in the "Privacy settings" section on the third-party online platform itself. When you sign out in any of these ways, we will no longer process your personal data for commercial communication purposes.
Based on a legitimate interest, we process personal data due to potential legal requirements related to the Service. Namely, the data of users who have used the Service are kept for two years after the termination of its use, due to potential user disputes or other legal requirements that may arise in connection with the user relationship. Keeping this information is of great importance, because in their absence, the user and Salford would not be able to exercise their rights in relation to user disputes, or would not have the information on which to base their requests and claims.
As for the activities of our sub-agents, we use your personal data only to take the necessary steps before entering into an agreement with you as our sales agent, and to enter into a contractual relationship with you, i.e. to:
- perform the necessary inspections before concluding a contract,
- we use your personal data to keep records of our sub-agents,
- we use your personal data to make payments to you,
- to contact you in regards to the performance of our contractual obligation if we deem it necessary,
- to monitor and check your work with our customers,
- to take any other action necessary to perform the contract.
We do not use automated profiling, nor do we sell personal data to third parties.
Data processors are our business partners with whom we work to provide you with the service, as well as who allow us to cooperate with you if you are our sub-agent.
What you should know is that in most cases we cooperate with companies within the European Economic Area (EEA), but if this is not the case, we apply appropriate measures to protect your personal data. These safeguards are set out in our data processing agreements and the standard contractual clauses we have signed with them.
In order to provide a service, or cooperate with our sub-agents, we need to work with various business partners who help us to provide you with a service in accordance with your request and in the simplest way. We strive to work with partner organizations established within the EEA, however, even when it comes to partners outside the EEA, we always choose those that provide an adequate level of protection of your personal data in accordance with the General Data Protection Regulation on (GDPR) and its technical standards (46.2 (c)). With partners outside the EEA, we have entered into precise agreements which accurately define the purposes for which they may use your personal data, and in accordance with our instructions, they also guarantee that they will not use them for any other purpose. Personal data that we transfer to our processors in countries for which the European Commission (EC) has not issued a decision on adequacy are protected by standard contractual clauses approved by the EC, which we have signed and implemented with the partners in these countries. Additional information is available upon request.
We use data processors in areas that include: a number of agents, i.e. our points of sale and contact, as well as customer support in a particular area, which you can find on our web site. In addition, we work with companies that allow us to provide you with technical and customer support, process your requests to order services through our website, secure your payment transactions on the website and prevent the submission of false requests, as well as provide you with important notices and communicate with you through social media. As for our sub-agents, we rely on the existing sales network and third parties that cooperate with them.
Data retention period
We retain your personal data provided in accordance with the agreement you have entered into with us during the period of providing the service and two years after you cease to use the service. The same applies to our sub-agents.
Certain personal data that we are legally obliged to keep, we may retain for a longer period.
Your personal data is stored with us and / or our data processors, only for as long as it takes us to fulfil our obligations. In addition, we retain some of your personal data for two years from the date you cease to use our Service (i.e. when your Service Agreement or free trial period is terminated) due to potential legal requirements regarding the provision of our Service, as well as for the purpose of preventing abuse.
Regarding our sub-agents, we store your personal data as long as you are our sub-agents. If you do not enter into a subagent relationship with us, we will delete your data immediately. After the expiration of our business relationship, we keep your data for two years for the purpose of exercising our and your rights in that period.
After the expiration of this period, we will take steps to make the data anonymous in an appropriate manner so that you can no longer be identified based on it, except in the case of personal data which the applicable law requires to be retained for an extended period.
Measures created in order to protect personal data
Detailed information on the technical measures we apply to protect your personal data can be obtained on the basis of a written request sent to our Personal Data Protection Officer (DPO) (at: [email protected]).
All personal data you provide will be fully protected in accordance with the latest standards of this industry, as prescribed by the General Data Protection Regulation. We take adequate measures to protect personal data from misuse, loss and unauthorized access. Personal data is stored on our servers and is protected within secure networks that can only be accessed by authorized employees. You can receive more information about the security measures we apply in our systems by request sent to our personal data protection officer (to the email address: [email protected] ).
Your rights regarding your personal data
You have the right to see what personal data we hold, as well as to correct personal data that is inaccurate. You can do this yourself on our website on your account, or you can send us a form with this request as stated in this procedure.
You may ask us to discontinue the processing of your personal data (while we decide on your requests listed in the right-hand column).
When processing is based on our legitimate interest or is for direct marketing purposes, you have the right to object to such processing.
You have the right to request the deletion of data. When a certain period of data retention expires and there are no other legal reasons for storing your personal data, we will delete it. However, if you believe that we did not do so for any reason, you have the right to know what personal data we hold about you and you can request that this information be deleted.
If you wish to transfer your personal data to another entity, we will provide you with an overview of all your personal data in order to do so.
We will respond to each of the above requests within one month at the latest. You can find a detailed procedure for exercising all these rights at the following link.
These rights apply accordingly to our sub-agents, where they can be exercised.
At any time, you may ask us to provide any personal data we hold about you, as well as to correct personal data that you believe is incorrect. You can do this yourself on your account or you can exercise your right to information and corrections (as well as all other rights) in accordance with this procedure and we will respond to your request within a month.
In addition, you have the right to ask us to restrict access to your personal data in the following cases:
- If during the verification of the accuracy of personal data you find that personal data is incorrect, we will not process it;
- If you believe that your personal data has not been processed in accordance with the law, you have the right to object to the deletion and request restriction;
- If we no longer need your personal data, but you need it to file, exercise or justify a legal claim regarding the protection or defence of your rights (in court or otherwise);
- Also, processing will be limited if you have objected to processing based on a legitimate interest during the period required to decide on your claim.
In addition to submitting a restriction request, you need to explain the reasons for submitting such a request. We will keep your personal data during the limitation period, but we will not process it.
You also have the right to object to the processing if your personal data is processed on the basis of a legitimate interest, including in cases where this is done for direct marketing purposes. In cases where you exercise the right to object, it will be examined whether the objection is well-founded and we will continue processing if we deem that there is a predominant interest in it, while we will suspend any further processing of your personal data for a specific purpose. Therefore, when you file a complaint, we will stop processing personal data for a specific purpose, unless our legitimate interests for processing outweigh your interests, rights and freedoms, or if the processing is necessary to establish, enforce or defend a legal claim. Please note that we have the right to refuse to act on unfounded or inappropriate requests. Exceptionally, if your personal data is processed for the purpose of placing direct marketing, we will suspend such processing upon receipt of your complaint without any examination of its merits.
In addition, you have the right to request that your personal data be deleted when it is no longer necessary for the purpose for which we originally collected or processed it. This right does not apply to personal data that we must keep in accordance with applicable law or due to potential legal requirements regarding the use of our service (for a period of 2 years after the termination of the service, as defined in this Policy). Personal data provided to us by consent may be deleted immediately if you have withdrawn your consent, or if it is direct marketing. The same applies when you have provided us with personal data on the basis of a legitimate interest, but you oppose this type of processing and there is no overriding legitimate interest in continuing this processing.
Finally, you can exercise your right to transfer personal data by asking us to provide you with all your personal data in electronic form, which you can then pass on to any other entity. We are unable to transfer your personal data directly to another entity.
These rights apply accordingly to our sub-agents, where they can be exercised. For more information on exercising your rights, you can contact our personal data protection officer electronically at: [email protected]
For all questions, you can contact our personal data protection officer electronically at: [email protected].
You can submit a complaint with the National Data Protection Authority in your country.
For more information on exercising your rights, you can contact our personal data protection officer electronically at: [email protected]
At any time, you can submit a complaint with the National Data Protection Authority in Cyprus (our country of residence) at the following address: Office of the Data Protection Commissioner ("Commissioner"), Office of the 1, iasonos Str. 2nd Floor, 1082 Nicosia, Cyprus, P.O. BOX 23378, 1682 Nicosia, or electronically at the following address: [email protected]
You can also submit a complaint with the data protection authority in your country.
Third Party Services
When you visit our website, you will be informed about the cookies we use, as well as the type of personal data they collect. You decide whether to accept the use of these cookies (unless their use is necessary for the proper functioning of the website).
These General Terms and Conditions shall be governed by and construed in accordance with the laws of Cyprus. These General Terms and Conditions shall not limit any consumer protection rights to which you may be entitled in accordance with the applicable laws of the Subscriber's country of residence.