Friends and Family Privacy Notice

This privacy notice applies to those people who receive Products from family and friends who use Ding (Senders).

We recognise that protecting personal information is very important to you and that you have an interest in how we collect, use, store and share such information.

This privacy notice sets out how we, as a data controller, will use and protect your information. We will use your personal information only for the purposes and in the manner set out in this privacy notice. We recommend that you read this privacy notice carefully.

Please note: you have the right to object to the processing of your personal data where that processing is carried out for our legitimate interests or for direct marketing purposes.

1. About us

www.ding.com and its subsidiary sites (including www.ezetop.com and www.recargasacuba.com) and any associated Ding mobile applications, present or future (each the “Applications”), are operated by Ezetop Unlimited Company t/a Ding (“Ding”, “we” or “us”). Ding makes available prepaid mobile and/or data airtime products and prepaid vouchers (“Products”) for purchase on the Applications.

Ding is registered in Ireland with registered number 422514 and has its registered office at 3 Shelbourne Buildings, Crampton Avenue, Shelbourne Road, Ballsbridge, Dublin 4, D04C2Y6, Ireland. Our VAT number is 9576713i. Ding is a registered business name of Ezetop Unlimited Company.

All correspondence in relation to any Ding company should be sent to 3 Shelbourne Buildings, Crampton Avenue, Shelbourne Road, Ballsbridge, Dublin 4, D04C2Y6, Ireland.

2. How can you get in contact with Ding?

If you have any questions about this privacy notice or any other queries or complaints, our customer care team is here to help – please contact us using one of the following options:

Email us: [email protected]

Live chat: https://support.ding.com

3. Scope of this privacy notice?

This privacy notice applies to you if you receive Products from Senders.

If you become a user of Ding, we will process your personal data under Ding’s Privacy Notice.

Personal data is information that identifies a person or can be used to identify a person. For us to deliver the Products to you, and to confirm such delivery, we need to collect and process personal data about you. Without this information, we may not be able to deliver the Products to you.

This privacy notice will apply to personal data in respect of which we are a data controller.

4. What data does Ding collect?

We may collect and process the following data about you:

• Contact Details:

  telephone number; name of your mobile operator;

• Transaction Details:

  the monetary value of the top up or prepaid product that you receive and currency of same;

• Electronic Identifying Details: where you visit our Applications, IP address; SMS content; cookies; pixels; activity logs (e.g. user session recordings); online identifiers; device identifiers (e.g. the mobile device and/or the internet browser that you use) and geolocation data.

For more information on the cookies we use, please see our Cookie Policy.

5. How does Ding collect your personal data?

Your personal data (and in particular, your mobile phone number) is provided to us by Senders when they purchase a Product for you or, may be collected by us through the Applications

We may also collect personal data about you from third parties (e.g. through third party direct marketing services). When you visit our Applications, your device and/or browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connection to an Application or other technical communications information), some of which may constitute personal data

6. Why do we process your personal data and what is our legal basis for doing so?

We will inform you in advance if we intend to further process your personal data for a purpose other than as set out above. We will also seek your specific consent if we carry out any processing of personal data that legally requires us to obtain such consent. You will have the right to withdraw such consent at any time.

7. Do we carry out any automated processing of your personal data?

We use automated statistical analysis of the personal data we collect about you in order to comply with our legal obligations to detect and prevent fraud, dishonesty and other crimes. We may use automated processing to screen for suspicious transactions, or to identify transactions that may be subject to international sanctions.

8. Who do we disclose your personal data to?

We share your personal data, where necessary, with the following recipients:

• mobile operators and other service providers of Products (directly or via third parties);

• governmental, legal, regulatory, or similar authorities, on request or, where required, including for the purposes of reporting any actual or suspected breach of applicable law or regulation;

• law enforcement authorities, where responding to valid requests to assist in the prevention, detection, investigation or prosecution of a criminal offence;

• data analytics service providers (e.g. Google Analytics);

• third party service providers used for the delivery of some aspects of the Products (e.g. SMS delivery, messaging app (e.g. WhatsApp) delivery and phone number lookup);

• hosting infrastructure companies based in the EEA;

• legal and financial advisors, and auditors;

• potential purchasers or bidders.

9. Does Ding transfer your personal data outside the EEA?

Ding may be required to transfer your personal data outside the EEA for the purposes of delivering the Products to you. To ensure that your personal data receives an adequate level of protection and is treated securely, and where a specific derogation does not apply, we put the appropriate safeguards in place to protect the privacy and integrity of such personal data when being transferred outside the EEA (e.g. EU-approved standard contractual clauses / binding corporate rules).

10. What if Ding is bought by another company?

We reserve the right to transfer information (including your personal data) to a third party in the event of a merger, liquidation, receivership or transfer of all or substantially all of the assets of our company. The third party must only use your personal data for the purposes that you provided it to us in the first place and as set out in this privacy notice. You will be notified in the event of any such transfer.

11. Data Security

We have implemented appropriate technical and organisational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with data protection laws.

You are responsible for ensuring that any personal data that is sent to us is sent securely.

12. How long do we keep your personal data?

We will keep your personal data only for so long as is necessary to carry out the purposes set out above and to comply with any legal obligations. The criteria for determining the duration for which we retain your personal data are whether it is necessary:

• to maintain an ongoing relationship with you (e.g. to deliver the mobile top-up or prepaid products to you or where you are lawfully included in our direct marketing lists and have not unsubscribed);

• in connection with the purposes set out in this privacy notice, and where we have a valid legal basis; or

• to comply with any applicable limitation period under applicable law, and a reasonable amount thereafter.

Once the periods above have concluded, we will either:

• permanently delete or destroy the relevant personal data;

• archive your personal data so that it is beyond use; or

• anonymise the relevant personal data.

13. Where does Ding hold your personal data?

Your personal data is held by us on secure servers which are hosted by Ding or by a third-party hosting infrastructure company located within the EEA.

14. Your Rights

You have a right to obtain a copy of, and the right to rectify any inaccuracies in, the personal data we hold about you by making a request to us in writing. You also have the right to request erasure, restriction, portability, or object to the processing, of your personal data or not to be subject to a decision based on automated processing, including profiling. You should inform us of any changes to your personal data.

Any requests made under this section can be made using the contact details set out below. We will respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than one (1) month after receipt of your request. In each case, these rights are subject to restrictions as laid down by law.

If you are unhappy with any aspect of processing or your data protection rights, please contact Ding in the first instance and we will be happy to listen to your concerns. We can be contacted as follows: [email protected] or Data Protection Officer, Ding, 3 Shelbourne Buildings, Crampton Avenue, Shelbourne Road, Ballsbridge, D04C2Y6, Dublin 4, Ireland

At all times, you have the right to lodge a complaint with the Office of the Data Protection Commission if you are unhappy with how your personal data is being handled by us. Their contact details are as follows:

Data Protection Commission 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland

Telephone: +353 (01) 765 0100

LoCall Number: 1800 437 737

Email: [email protected]

If we are relying on your consent to allow us to process your information, you can withdraw your consent at any time. From that point on we would no longer be able to carry out the processing we were carrying out with your consent. Any processing we carried out before you withdrew your consent would remain valid. We do not generally rely on consent for processing personal data.

Please contact us at [email protected] or Data Protection Officer, Ding, 3 Shelbourne Buildings, Crampton Avenue, Shelbourne Road, Ballsbridge, D04C2Y6, Dublin 4, Ireland to exercise any of your rights under this section.

15. Changes to this privacy notice

We may update this privacy notice from time to time. If we make any material changes, we will post a notice on our Applications.