PRIVACY STATEMENT
PRIVACY STATEMENT / DATA PROTECTION
Version 1.0 – March 2023
PLEASE READ THIS AGREEMENT CAREFULLY. ONCE ACCEPTED BY YOU, THIS AGREEMENT BECOMES A BINDING AND ENFORCEABLE LEGAL COMMITMENT BETWEEN YOU AND DUST MOBILE.
In this statement « Dust Mobile”, “we” or “us” refers to the Dust Mobile entity that you or your employer has provisioned our services from. In addition, you will see references to the « Dust Mobile Group”, which includes all other Dust Mobile entities globally.
Dust Mobile ideates, develops and supplies innovative communication resources for the commercial market. As a result of our service offerings, Dust Mobile processes personal data about our customers, partners and their end-users.
In this privacy statement, you can read about the personal data we collect, what purposes we use this data for, how we protect your privacy and personal data, how long the data is stored and how you can view and/or correct the personal data we store on you.
Dust Mobile does not share personal information with third parties, unless this is (1) legally required, (2) necessary to supply a service or (3) specifically requested by the customer that has provided the personal information.
CONTACT INFORMATION
You can find our contact information here:
Dust Mobile SA NV
Address: Avenue Louise 523 Louizalaan, 1050 Brussels – Belgium
Email: contact@dustmobile.com
Phone: +32 2 319 49 59
DATA PROTECTION OFFICER
We have a Data Protection Team and a Data Protection Officer (DPO). If you have any questions relating to the processing of your personal data or want to contact our DPO, feel free to contact our Data Protection Team using the details provided below.
Dust Mobile Data Protection Team
Email: dataprotection@dustmobile.com
HOW WE COLLECT YOUR PERSONAL DATA
Dust Mobile is the data controller for the processing of your personal data for the purposes described in this statement. If you choose not to provide the personal data, you might not be able to make use of the desired service / function or technical assistance.
For website users or newsletter subscribers
We always inform you about our processing before collecting your personal data: name, e-mail address, company name, postal address and telephone numbers.
Please note that personal data can be required in order for you to use the features of the website. Additionally, it can be necessary for us to collect and process your personal data in order to provide and optimize our services for you. For example, we need your contact information to be able to book a meeting with you, receive inquiries from you via our contact form, or send you a newsletter if you consented to this.
For end users
The same principles applies to the processing of traffic data and your telephone numbers when we are delivering our telecommunication offerings.
For business customers and partners
Personal data is collected directly or through your employer if you as a business customer or a partner provides us with personal data about others than yourself, for example by making our telecommunication solutions available to your employees. You are obligated to inform your end users about this transfer of personal data to Dust Mobile.
As an employer or partner, you can meet this obligation by linking to this privacy policy.
We use different methods to collect personal data from and about you including through:
Direct interactions
You may give us information about you by filling in forms, engaging in chat on our websites, accessing or utilizing any of our public or private websites and selfceare portal, opening an account with us, requesting support, subscribing to our newsletters, requesting information or materials (e.g. whitepapers), registering for events or webinars, visiting our booth at a trade show or other event, participating in surveys or evaluations, accessing or utilizing any of our websites and communication and cybersecurity services, submitting questions or comments, or by corresponding with us by phone, email, video, or otherwise.
Automated technologies or interactions
As you interact with our public or private websites, communications and cybersecurity services, selfceare portal, we may automatically collect technical data about your equipment, transmissions, and patterns as specified above.
Third parties or publicly available sources
We may receive information about you if you visit websites from third parties including, for example, advertising networks, analytics providers, or through publicly available data, such as social media (like LinkedIn, Facebook, and others) and websites.
Indirectly
As a service provider and mobile operator and carriers we are partnering with in the course of providing voice and messaging and communications services as well as cybersecurity services.
WHAT PERSONAL DATA WE COLLECT
Personal and User Information
When you purchase a service from Dust Mobile or when you contact us, Dust Mobile processes your personal data. Personal data is information that can be linked to an individual and/or your employer.
The information processed by Dust Mobile when you purchase our services can be your: company / organization name, first name, last name, address, telephone numbers, email address and bank account number.
Traffic data
When using our services, traffic data will be processed. This data is required for us to facilitate communication. Traffic data is generated and processed automatically when end user make use of our telecommunication services, Traffic data consists of: the calling and called numbers, the date, the time, the duration, and the fees that were charged for said call.
This data does not concern the contents of the communication. In the case of a data session, we also register the amount of data, and when roaming, we register the network that was used.
We never store the content of communication unless directly instructed to do so by a customer, such as in the case of call recordings.
Location data
When you set up a call or data session, Dust Mobile processes information that can make a very rough determination of your location at that moment. We use this information to determine the location where the call or data session is happening.
Dust Mobile uses other operators mobile network to provide service around the world. These operators could be able to gather some informations such as your location by looking at which transmission tower was used for your call or data session.
Website
dustmobile.com and our customer portals use cookies to optimize the functionality of certain pages on the websites. Cookies are small text files that are placed on the visitor’s computer by a page on the website. In these cookies certain information is stored, such as certain preferences the visitor has. This allows Dust Mobile to serve the visitor even better when they next visit the site. The visitor can decide how cookies should be handled.
Dust Mobile has a separate cookie privacy statement found in the cookie notice.
dustmobile.com and our public websites also use Google Analytics and Social Media cookies (such as LinkedIn) to analyze how users make use of the site. For Google Analytics, the information generated by cookies about your visit to the website (including your IP address) is transferred to and stored on servers in the United States by Google. Google uses this information to monitor the way you use the website, compose reports on the website activity for website operators, and offer other services with regard to website activity and internet use.
Other
When you visit our offices, you can be registered as a guest. We use this registration for safety and security purposes, so that we can quickly evacuate the premises in case of a disaster, without leaving anyone behind.
We also use camera recordings as a security measure in our offices. We do this to protect our guests, personnel and the building. You will be clearly informed about the presence of cameras when on our premises.
We may use the personal data we collect for one or more of the following purposes:
To fulfill or meet the reason you provided the information and to provide our products and services including communication and cyber security services,
To respond to your inquiry about our products and services, including to investigate, to troubleshoot and address your concerns and monitor and improve our responses,
To enable our customers and end users to send and receive communications via our service platform and to bill for those services,
To inform you of additional features, expanded coverage or other products or services offered by us,
To allow you to interact with our systems, including our selfcare portal,
To create, maintain, customize and secure your account with us and the communication services,
To process your requests, order-forms, purchases, transactions and payments,
To bill, collect, and remit taxes, fees and surcharges to the appropriate jurisdictions,
To personalize your customer and end-user experience and to deliver service information relevant to your interests, including communications usage, connectivity, cyber security event, threat detection, targeted offers, marketing communications through our public and private websites, applications, selfcare portal, and via email, SMS or other electronic communications systems,
To maintain the safety, security and integrity of our public or private website, communication and cyber security services, databases and other technology assets and business,
For testing, research, development, and analysis; mitigation of fraud and other threat specific to our services (as applicable per specific product offering), unlawful or abusive activity, or violations of our Acceptable Use Policy; perform quality control; gauge routing effectiveness and deliverability and product development, including developing and improving our public and private websites, selfceare portal and products and services. Specifically, with respect to signalling and SMS messaging, we utilize industry-standard and proprietary protocol-analysis software which utilizes electronic, algorithmic inspection of the originating SS7 / SIGTRAN / DIAMETER / GTP / SIP, telephone number (MSISDN) and/or IMSI and / or IMEI and SMS messages for purposes of best effort attack detection and blocking.
Law enforcement, security, and safety.
To respond to law enforcement requests and as required by applicable law, court order, governmental regulations, or other legal process where we believe in good faith that disclosure protects your safety or the safety of others, or where we need to protect a legitimate business interest such as fighting against fraud that harms our rights.
For security purposes to register visitors to our offices and to manage non-disclosure agreements that visitors may be required to sign, to the extent such processing is necessary for our legitimate interest in protecting our offices and our confidential information against unauthorized access.
Asset transfer and/or M&A Activity.
To evaluate or conduct a financing, merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Dust Mobile’s assets, whether at Dust Mobile’s discretion or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Dust Mobile about you is among the assets transferred except for information registered as classified informations.
Cookies and other tracking technologies
Our websites and private portals including our selfcare portal use cookies (small files placed on your device) and certificates and similar technologies (e.g., web beacons, tags, JavaScript, alone or in conjunction with cookies) to distinguish you from other visitors and compile information about the usage of our websites. This helps us deliver a better and more personalized service when you browse our websites and allows us to improve our websites. We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (known as behavioral tracking). We use both session-based and persistent cookies on our websites. Session-based cookies exist only during one session and disappear from your computer when you close your browser or turn off your computer. Persistent cookies remain on your computer or device after you close your browser or turn off your computer.
We also use web beacons on our websites and in email communications. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to one of our websites. To unsubscribe from our marketing emails, click the link at the bottom of the email marked “Unsubscribe”. Please note that you cannot opt out of receiving transactional emails related to our products and services.
The following describes how we use different categories of cookies and your options:
Strictly Necessary Cookies
Strictly necessary cookies are necessary for our websites to function and cannot be switched off in our systems. Some examples include: session cookies needed to transmit the website, authentication cookies, and security cookies. If you have chosen to identify yourself to us, we may place a cookie on your device that allows us to uniquely identify you when you are logged into our websites and to process your online transactions and requests.
When you visit our websites for the first time, a cookie consent banner may prompt you to customize your cookie preferences in our Paramètres des cookies. We apply the EEA (European Economic Area) GDPR privacy rules so our websites will only serve you strictly necessary cookies unless you consent to additional categories in our cookies parameters.
Functional Cookies
Functional cookies enhance function, performance, and services on our websites. They also allow us to analyze your use of our websites to evaluate and improve your customer experience on this site.
Targeting Cookies
We do not use Targeting cookies on our public websites.
Performance Cookies
These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our websites. They help us to know which pages are the most and least popular.
WHY WE COLLECT YOUR PERSONAL DATA
Legal requirement
Dust Mobile as registered mobile operator is legally obliged to store certain information from customers and their usage for a specific time period for the purposes of legal investigations.
Dust Mobile must cooperate with requests for personal information from the competent authorities or other authorized governmental institutions, as well as with requests for information we process and store as part of our normal business operations.
For example information from your telephone records or about your data usage. When the storage period has elapsed, stored information is destroyed or made anonymous.
Necessary for our service provision
Dust Mobile does not always supply its services itself, but uses, for example, Mobile Network Carriers to supply its services. In such a case, it is necessary that we share the information that is required for the provision of certain services with Carriers. For example, when Dust Mobile shares information with its Carriers, the Carrier must comply with the conditions specified by the GSMA and/or ITU and the same privacy requirements we adhere to also apply to that company.
At the request of the customer
It is also possible that you as the customer purchase certain services for which personal information is required. For example additional telephone numbers. In such cases you can use your telephone or the App to specify whether or not you wish to subscribe to these services, and then give this permission.
WHAT DO WE USE THIS INFORMATION FOR?
Providing services and invoicing
Dust Mobile uses the aforementioned information primarily for the provision and improvement of services purchased by you or your employer. For example the delivery of an order to the specified address, or the setting up of a telephone call.
Based on these services and the use thereof, Dust Mobile creates an invoice. This invoice shows the fees charged for each service, specified by type of use. You can see fees incurred abroad, call costs, data usage and more.
Traffic management, network planning and quality of services
For the sake of the maintenance and the improvement of our platform, we analyze information about the use of our network. We do this so that we can, among other things, redirect traffic in case of potential overloading, but especially so that we can prevent this by planning and implementing targeted improvements. In addition, we can use the information to see when malfunctions occur on the platform.
Security analysis
Based on analyses of call signaling, usage and internet behavior, Dust Mobile can proceed to restrict certain destinations when excessive usage is detected. Higher usage than average call behavior may indicate fraud. A blockade can limit fraud and misuse, and prevent you from receiving a huge bill for fees that you have not incurred yourself. Dust Mobile also uses advanced cyber security techniques to protect against security breaches, signaling and SIM attacks, spoofing, and malware detections.
Caller ID
Dust Mobile always displays your telephone number to the called number. This means that your number will be visible to the call recipient on the display of their telephone. This can be turned off by calling anonymously. However, we are legally obliged to always reveal your number when you call the national emergency number.
Legal requirements
In some cases Dust Mobile is legally required to give your information to third parties. For example, the provision of information in the context of a criminal investigation, to authorities, and – at your request – to other providers for the purposes of shielding the called number in the records.
Training and education of personnel
When you contact our service desk, it is possible that your call will be recorded for training purposes. You will be informed of this prior to the call.
Malicious or annoying contact
If someone is harassing you by telephone or via internet, then you can report this to us and submit a written request to provide information on the person responsible for this malicious or annoying behavior. If we receive such a request, we will follow internal procedures. If that does not help, then Dust Mobile will, as a last resort, provide the complainant with your telephone number, name, address and place of residence.
Number retention and transfer service
Dust Mobile offers you the option of keeping your number when you transfer to a different provider. To do this, we exchange information with your current or next provider. In case of a landline, this information is your current telephone number, your name and your address. For a mobile number, your RIO number, telephone number and name are shared.
WHO WE SHARE DATA WITH
In certain circumstances, for example due to legislation, it may be necessary to pass on information to the authorities or directory inquiries databases.
Disclosure may also take place if necessary to establish or defend legal claims.
Dust Mobile is a group of undertakings all located within the EEA (European Economic Area), as part of our group wide activities we can share aggregated and anonymized data about our customers usage in the form of business intelligence and statistics with members of the group. We do this on the basis of group wide agreements, where we have mapped the transfers and designated the responsibility for compliance with the data protection law, amongst the members.
In order to provide telephony to our business customers, it is necessary for us to transmit traffic data via Carriers Operators Partners. Dust Mobile uses several European and worldwide infrastructure providers and these operators therefore process data on our behalf. These operators are independently data controllers for the processing of data within their respective networks.
We do not pass on your personal and/or employer information to external data processors acting as suppliers for us except for public website related activities such as sending out newsletters and website maintenance notification.
INTERNATIONAL DATA TRANSFERS
Dust Mobile is a global organization, with legal entities, business practices, technical systems and core telecommunication infrastructures that operate across borders. Your personal data may be collected, transferred to, and stored by us in the European Economic Area (“EEA”) by ourself or by our subsidiaries that are in other European Economic Area (“EEA”) countries. Therefore, your personal data may be transferred and processed outside your jurisdiction but in countries that may provide for the same level of data protection as the European Economic Area (“EEA”). Where applicable law requires us to utilize a data transfer mechanism, we rely on adequacy decisions as adopted by the European Commission; standard contractual clauses issued by the European Commission. Data and information transfer will be authorized only on the established relations between the Customer and/or the end-user attachment with the related countries with Enterprise, Professional, Government, International Institutions physical address and phone numbers (MSISDN) in use.
For more information regarding international data transfers among Dust Mobile affiliates, please visit dustmobile.com.
SECURITY
Dust Mobile has implemented generally accepted standards and proprietary technologies and operational security in order to protect personal data from attacks, interception, loss, misuse, alteration, or destruction. Only authorized Dust Mobile personnel are provided access to personal data on need-to-know basis only and these employees are contractually or statutory obliged to ensure confidentiality of this data.
Dust Mobile will implement appropriate technical and organizational measures to ensure that the processing of your personal data is performed in accordance with data protection law, in particular ensuring an appropriate level of security.
YOUR RIGHTS
Under GDPR, you have a number of rights regarding our processing of your personal data. To exercise these rights, please contact us via our contact information.
Right of access
You have the right to access the information we process about you.
Right to rectification
You have the right to have incorrect or outdated information about yourself corrected.
Right to be forgotten
In exceptional cases, you have the right to have information about you deleted before the time of our retention period.
Right to restrict processing
In some cases, you have the right to have the processing of your personal data restricted. If you have the right to have the processing restricted, we may only process your personal data – except for storage – with your consent, or for the purpose of establishing, asserting, defending, protecting, a significant public or private interest.
Right to object
In certain cases, you have the right to object to our otherwise lawful processing of your personal data.
Right to receive your information (data portability)
In certain cases, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to have that personal data transferred from one controller to another without hindrance.
QUESTIONS OR COMPLAINTS
In case you have any questions with respect to the processing of your personal data, you can contact Dust Mobile DPO via our Contact Information..
Please note that you have the right to lodge a complaint with the competent Supervisory Authority for the Dust Mobile entity that is acting as the controller for the processing of your personal data if you are of the opinion that the processing of your personal data by Dust Mobile infringes on the GDPR or other data protection laws.
CHANGES
Dust Mobile reserves the right to modify or amend this statement at any time. The effective date will be displayed below the statement. It is the user’s responsibility to check this document regularly for changes.