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Information memorandum

Processing of personal data - GDPR

On 25 May 2018, Regulation (EU) No 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data, on the free movement of these data and repealing Directive 95/46/EC (General Data Protection Regulation) came into force ( hereinafter referred to as "GDPR"). This document contains information related to the processing of personal data within RocketConnect.

Who manages your personal data or who is their administrator?
The administrator of your personal data is the company RocketConnect OÜ, Rau tn 36, City Centre District, 10120, Tallinn, registration code 16662996 (hereinafter referred to as "Administrator", "RocketConnect", "we/us").
Who will be the contact person for privacy issues and what are his/her contact details?
The contact person for personal data protection is a person appointed by the administrator or processor of personal data on the basis of his/her professional qualities, who performs statutory tasks, in particular serves as a contact for you, our client, in all cases related to the processing of your personal data and the implementation your rights under the law.

You can email us your questions regarding personal data protaction at gdpr [аt] rocketservers [dot] cc
What are the purposes of processing your personal data and the legal basis for their processing (reasons for personal data processing)?
The purpose of processing your personal data is to offer products and services provided by the Company, as a company engaged in providing telecommunications services, managing data centers, hosting, hosting servers and providing other services, to the Company's customers. Processing means analysis and segmentation in order to tailor the offer to your needs as much as possible. We don't want to bore our clients with unnecessary communication. We use the personal data in order to better understand your needs and to be able to offer you a suitable solution in the form of product offers, service communication, satisfaction surveys, etc. Communication takes place through all channels, including electronic ones (e-mail, SMS, web-interface).

The Company is obliged to process data for the purposes of preventing the legalization of proceeds from crime and the financing of terrorism.
What personal data do we use?
We only use the personal data that is necessary for the purposes listed above. For example:
- identification data (e.g. first name, last name, date of birth)
- contact details (e.g. address, phone number, email)
- registration and payment data
- call details, authorization protocols
What sources does this information come from?
The data processed within the Company originates primarily from you, from contracts concluded between you and the Company, from public sources and from cooperating third parties.
For what purposes of using personal data can I express optional consent? Who gives consent?
Specifically, the purpose of your consent may be:
- the opportunity to contact you with a commercial offer of the Company within a maximum of five years after the end of the last contract,
- the ability to transfer your personal data to other companies in order to offer their services and products,
- the opportunity to contact you with our offer in electronic form.
You may give the Company your consent to the processing of the above categories of your personal data, and you also authorize the transfer of your personal data and contact details to other companies. Obtaining consent is currently irrelevant, detailed information, if consent is necessary, will be published on the Company's website.
Who can process personal data?
The legal regulation of the protection of personal data gives the administrator the opportunity to entrust the processing to the processor. A personal data processor is any individual or legal entity that processes personal data on the basis of a legal order or an administrator's permission. The Company applies this procedure to the processing of your personal data, only if the personal data protection standards of a particular processor are contractually guaranteed at least to the same level as in the Company, and that such processor complies with the conditions, established by law.

Only trusted and trained employees of the Company may process personal data in the Company. The Company also transfers selected data to third-party counterparties in cases where it is required by applicable law for the provision of DID in certain countries.
How long is your personal data stored for?
Personal data received by the Company is stored for the entire period of validity of the contract with the client/partner and for the next three years after its expiration, unless the law establishes a longer storage period. CDRs, by law, are retained for a period of at least 6 months. Payment processing information is retained for a period of at least 10 years.

At the end of this period or the validity of your consent to the processing of personal data, your personal data will be erased, anonymized or processed solely for purposes for which your consent is not required.
What rights do you have when processing your personal data?
When it comes to your personal data, you have the following rights:
- Right of Access – You can request the Company to access personal data relating to you; The Company will provide you with a copy of the processed personal data. For the second and subsequent copies, the Company may charge a reasonable fee based on administrative costs.
- Right to Correction. You can ask the Company to correct inaccurate or incomplete personal data that concerns you.
- Right to Deletion – you can ask the Company in writing to delete your personal data in the following cases:
  - the personal data are no longer needed for the purposes for which they were collected or otherwise processed;
  - the consent on the basis of which your personal data was processed was withdrawn, while there is no other basis for their processing;
  - an objection has been made to being the subject of decision-making based on automated processing of your personal data and there are no overriding legitimate reasons for such processing, or an objection has been made to the processing of your personal data for direct marketing purposes;
  - Your personal data has been processed unlawfully;
  - Your personal data must be deleted by the date of compliance with a legal obligation under Union or State Member law to which the administrator belongs;
  - Your personal data was collected with the offer of the Company's services.
- The right to restriction of processing - you can ask the Company to restrict the processing of your personal data in the following situations:
  - You have disputed the accuracy of personal data - for the time necessary for the company to verify its accuracy.
  - The processing of your personal data is unlawful, but you object to the deletion of this data and instead request the restriction of its use.
  - The company no longer needs your personal data for the purposes of processing, but you wish to retain it for the determination, exercise or defense of legal claims.
  - You have objected to the processing of your personal data pursuant to Art. 21 paragraph 1 of the GDPR until it has been verified that the legitimate grounds of the Company outweigh your legitimate grounds.
- Right to data portability – you have the right to receive the personal data concerning you that you have provided to the company in a structured, commonly used, machine-readable format, without prejudice to the rights and freedoms of others.
- The right to withdraw consent - you have the right to withdraw your consent to the processing of personal data, for the purposes for which you have given your consent, at any time; Withdrawal of your consent does not affect the processing of personal data prior to its withdrawal.
- Right to object – you can object to the processing of your personal data by the Company for direct marketing purposes at any time.
- The right to file a complaint - you have the right to file a complaint with the Company at: RocketConnect OÜ, Rau tn 36, City Centre District, 10120, Tallinn.
Is your consent to the processing of personal data voluntary or necessary?
Giving consent to the processing of your personal data for sending commercial offers is completely voluntary.

Last revised April 01, 2023

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