Friends and Family Privacy Notice

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. We always respect our customers’ privacy and personal information and we take this matter very seriously. We have worked very hard to earn our customers’ trust and keeping it is our top priority. That’s why we comply with the obligations that are laid out under data protection laws.

This privacy notice applies to non-Ding users that receive or request top-up services and other prepaid products from Ding users (such as family and friends). 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, and the top-up services and prepaid products available on the Applications from time to time (“Services”), are provided by, Ezetop Unlimited Company t/a Ding (“Ding”, “we” or “us”). We are registered in Ireland with registered number 422514 and we have our 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?

Personal data is information that identifies a person or can be used to identify a person. For us to deliver the mobile top-up or prepaid 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 mobile top-up or prepaid products to you.

This privacy notice will apply to personal data about you collected by us through the Applications or otherwise. It applies to any personal data about you that you provide to us or is provided to us by your family or friends while using our Services (“Senders”) 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: name; telephone number; email address; name of your mobile operator ;

• Transaction Details: the monetary value of the top up or prepaid product that you receive or request 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;

• Correspondence and complaints: any correspondence that you choose to send to Ding (including complaints); any information you provide to our customer care team; any information you publish about Ding (including on the app stores);

• Application History: details of your visits to the Applications.

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 through the Applications when they top-up your mobile phone or send you a prepaid product.

You also may provide us with your personal data when you choose to register for, or use the “Request Top-Up” option or any other Services.

We may also collect personal data about you from third parties (e.g. through third party direct marketing services). We also collect information about you through your use of our Applications ( “Request Top-Up”), your visits to our Applications, and your interactions with our customer care team. 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. What happens if you do not provide us with your personal data?

If your personal data is not provided to Ding or if you object to the use of certain personal data, we may not be able (i) to deliver the mobile top-up or prepaid products to you; or (ii) facilitate your request for further mobile top-up from Senders through the “Request Top-Up” option or otherwise.

9. Who do we disclose your personal data to?

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

• any Senders you ask us to share it with;

• mobile operators and other service providers (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;

• direct marketing service providers;

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

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

• hosting infrastructure companies based in the EEA;

• legal and financial advisors, and auditors;

• potential purchasers or bidders.

In addition, Senders may be able to view your name or mobile phone number if you request mobile top-up from them using the Request Top-Up option. Senders may also be able to view your name or mobile phone number when you avail of the option to send them a thank you message. You can control whether you wish to share your name with Senders through the account settings in your Ding account here.

Our Applications may, interface with third party services that you have previously interacted with (e.g. Facebook and Google), or contain links to third party content (e.g. service provider content). Please note that Ding is not responsible for such services or content, or the privacy policies associated with those services or content. We recommend that you review any third party’s privacy policy before accessing such services or content.

10. 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 mobile top-up or prepaid 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).

11. 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.

12. 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.

13. 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.

14. 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.

15. Will Ding use your personal data for direct marketing purposes?

Yes, we may use your personal data to send you information by SMS, email or app notifications relating to our products and services which may be of interest to you or similar products and services to those you have previously purchased from Ding with your consent or where otherwise permitted to do so by local law.

16. Can you opt-out/unsubscribe from direct marketing?

You will be provided with an opportunity to opt-in at the point of registration for “Request Top-Up” or any other Services. You can also opt-out at any time, free of charge, by: (i) for SMS by using the unsubscribe facility in the SMS that Ding sends to you; (ii) for push notifications, by following the steps in the guide available at support.ding.com; or (iii) by sending an email to [email protected].

Ding does not sell or share your personal data with subsidiary companies or third parties for marketing or profit purposes.

17. 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 at 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

Canal House

Station Road

Portarlington

County Laois

Telephone: +353 (0)761 104 8000

Telephone: +353 (0)57 868 4800

LoCall Number: 1890 252 231

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 at Ding, 3 Shelbourne Buildings, Crampton Avenue, Shelbourne Road, Ballsbridge, D04C2Y6, Dublin 4, Ireland to exercise any of your rights under this section.

18. Changes to this privacy notice

We may update this privacy notice from time to time. If we make any material changes, we will notify you by posting a notice on our Applications and/or, where appropriate, by sending you a notification.