Agreement/Contract

IPKO uses the data to conclude agreements / contracts and to fulfill contractual obligations from contractual relations with users. The purpose of personal data processing is also clear from the agreement/contract and/or other documents, which regulate the relevant contractual relationship. When processing personal data for the needs of the implementation of an agreement / contract, IPKO will process only the data required for the conclusion and implementation of the agreement / contract and/or for the fulfillment of contractual obligations.

During the provision of specific services, IPKO will process personal data only for the purposes stipulated in the agreements/contracts and terms of use for the respective service. In case of changes to existing services or the introduction of new services, IPKO will update this Privacy Policy or change existing agreements / contracts and terms and conditions, and/or enter into or adopt new terms and conditions.

Law

In addition to processing personal data, which is required to conclude or implement the agreement/contract, IPKO also processes personal data in cases defined by law.

Personal data and categories of personal data, processed by IPKO in accordance with the law, are defined in the agreements/contracts and in the terms and conditions for the use of the relevant service. In case of changes to existing services or the introduction of new services, if necessary and in accordance with the law, IPKO will update this Privacy Policy or change existing agreements / contracts and terms and conditions, and/or connect or approve new terms and conditions.

CONSENT

In case of user’s consent, IPKO will process personal data only for the purposes for which the user has given consent. In cases where the processing of personal data is based on consent, the user can withdraw his given consent at any time.

When processing personal data based on consent, IPKO will properly assess which data is required for a specific purpose, and will only use those data which are necessary to achieve the purpose. When processing personal data, IPKO will properly protect such data and implement relevant data protection activities.

By giving his consent, the user agrees that IPKO can process personal data or categories of personal data, available to the user, which are indicated in the consent. This may include data, which the user submits to IPKO when entering into and implementing contractual relationships (eg including, but not limited to: data from applications, agreements/contracts, questionnaires, surveys and other documents, including data on the desired subscribed services or devices), information on the purchase of goods and the use of IPKO services (eg, including but not limited to information on the services used and/or billed, including the quantity and their type, as well as information on the use of IPKO’s website and applications), and traffic and location data (eg, including but not limited to: link information and related location data, data on the location of devices).

Personalized offers include general offers of IPKO, which IPKOua delivers to users when it assesses that they may be interesting for a specific user, as well as offers, specially tailored for each user. IPKO will process data for automated decision-making whether a specific offer is interesting for a specific user, as well as for their profiling/segmentation (e.g. based on demographic, socio-graphic and behavioral data and criteria and factors others, such as gender, age, location of residence, frequency of use of the service, type and time of use of services, websites and applications, past purchase habits, location or online identification), on the basis of which IPKO will present offers to the user.

Based on the consent, IPKO can present the user with information and offers through all the communication channels listed in the consent, for which the data are available within the scope of the contractual relationship, which is subject to the users’ consent.

When processing data for the development and direct marketing of goods and services to IPKO’s business users and partners, personal data will only be processed by IPKO or by an entity authorized by IPKO.

In the event that a customer gives his consent to the processing of data for a specific purpose and has not withdrawn such consent, IPKO may – within the scope in accordance with the regulations – process personal data for such a purpose for two other years after the end of the contractual relationship, for which consent was given.

IPKO may also receive data and consent from individuals, who are not subscribers or users of IPKO’s services, and process this data in accordance with their consent. In case the subscriber enables the use of the services to another person, they will authorize such person to give consent within the scope of the enabled services.

Users can withdraw their consent by sending a written request to: IPKO TELECOMUNICATIONS LLC, Street “Zija Shemsiu” No. 34, Lagjia Ulpiana, Pristina, info@ipko.com; by submitting a written request to IPKO’s sales points; by sending their request by e-mail to: info@ipko.com or by calling +38349/43/700700.

In cases where consent is obtained through electronic communication services or information services (eg by SMS message, applications) and where appropriate, users may also withdraw their consent through these communication channels.

In the event that a consent is withdrawn, IPKO will stop processing data, collected based on the relevant consent, and/or will no longer process them for the purpose that was the object of the consent.

Processing based on legitimate interest

IPKO also processes personal data of users for the legitimate interest of the company (IPKO) or third parties for the purposes listed here or in the agreement/contract, as well as in the terms and conditions or in other documents, which regulate a contractual relationship specific.

In case of processing users’ personal data based on a legitimate interest, IPKO will take into account the possible effects of this processing on users (both positive and negative), as well as the rights of users in relation to such processing. In such a case, IPKO’s legitimate interest does not automatically prevail over the interests, fundamental rights and freedoms of users. IPKO will not process data in cases where the interests of the user (e.g. when the user is a child) prevail over the interests of IPKO, if it does not have the consent of the user, or if such processing is not required by regulations and/or when the processing such is not allowed according to the law.

When personal data is processed based on a legitimate interest, IPKO will process only the data necessary to achieve the purpose, in accordance with the consent given, and will apply all relevant personal data protection measures.

IPKO will process users’ personal data based on its legitimate interest in accordance with this policy, in the case and for the purposes listed below. Additional examples of processing based on a legitimate interest can also be listed in the agreement/contract, terms and conditions, and other documents governing any contractual relationship.

Fraud prevention

As part of caring for its users, as well as efforts to ensure its business continuity, IPKO makes efforts to prevent fraud and provide security, stability and continuous operation of IPKO’s networks and services. When you enter into contractual relationships and purchase goods or services, and during the implementation of contractual relationships and the use of services, IPKO will implement procedures and measures to prevent fraud and to ensure the security of its services, networks and business. When processing data for the purposes specified above, IPKO will process information about users and the use of IPKO services, including traffic and location data. As a rule, IPKO’s legitimate interest in preventing fraud always prevails over the interests, fundamental rights and freedoms of users. On the basis of data processing, IPKO may adopt anti-fraud measures, which may include preventing or limiting access to IPKO services and networks, limiting rights from contractual relationships, severing contractual relationships, required activities for the identification of users and/or offenders, the initiation of relevant civil, inspection or criminal procedures for the prevention or limitation of fraud, as well as other measures, permitted by law or regulation.

Marketing analysis

In accordance with the Personal Data Protection Act, legal bases for direct marketing may also serve as a legitimate interest. In accordance with its legitimate interest and for direct marketing purposes, IPKO also processes data for the segmentation and profiling of its users. In this case IPKO processes data related to the user and the use of IPKO services, its websites and applications, social networks and the Loyalty Program. However, in this case IPKO does not process traffic data, including information about connections or location data, unless it has obtained the prior consent of the respective user. Such data processing does not affect users’ rights arising from contractual relations.

Since IPKO offers a wide range of services subject to various regulations and rules, the processing of personal data for direct marketing in accordance with a legitimate interest may be additionally defined in contracts, terms and conditions, as well as in documents others applicable to a particular service.

Polls

User feedback is sought and helps a lot in providing high quality services that meet the needs of users. IPKO wants to collect the most important information about users’ satisfaction with IPKO’s services and offers. From time to time and when in contact with its users, IPKO may also send these users an invitation to complete a survey questionnaire and/or submit their feedback and opinions about IPKO’s services and offers. In such cases IPKO processes the users’ contact information (phone number, e-mail) and information related to the contact. Completing surveys is voluntary, while (not) failing to complete the survey will not affect users’ rights.

Hazard/risk management

When doing business with its users, IPKO will act with due diligence, including prudent risk management. In order to manage risks, IPKO may monitor the implementation of contractual relations with its users, including the processing of data about users and their use of IPKO’s services, while this data is used for user segmentation and profiling .. However, in this case IPKO will not process traffic data, including information about links or location data, unless it has obtained the prior consent of the respective user. If doing business with a specific user may pose a risk to IPKO, IPKO may adopt appropriate measures to mitigate such risk, including limiting access to services. Furthermore, IPKO’s specific offers may be available only to specific groups of users who meet the requirements set out in the offer, which may involve a certain level of risk.

Analysis

IPKO strives for personalization and continuous improvement of its services and offers. Therefore, it maintains a legitimate interest in monitoring contractual relations and analyzing the use of services by its users, i.e. for the planning and development of services and applications, for market evaluation and for measuring the success of sales, marketing activities and activities aimed at improving the user experience and the quality of services. In this case IPKO will only process the data related to the user and the use of IPKO’ services, its websites and applications, social networks and the Loyalty Program, while also applying the relevant protection measures that may include anonymization and / or pseudonymization. However, when doing so, IPKO will not process traffic data, including information about links or location data, unless it has obtained the prior consent of the relevant user, or if such data has been anonymized beforehand. The processing of data for analysis does not affect the rights of users arising from contractual relations.

Obtaining consents

When offering goods or services, IPKO wants to provide its users with relevant information and process personal data as much as possible in accordance with users’ wishes and expectations. Thus, when exercising contractual relations with users, IPKO has a legitimate interest in seeking their consent. In this process, IPKO will process your phone number(s), email address, first name, last name and postal address, username, TV interface/app identifiers and consent information, which may then be used to asking users to provide their consent.

Data about network devices/devices

When installing network equipment for broadband services, the equipment is used to set and maintain settings that match the user’s needs. In case of interventions for repair purposes, when settings need to be reset or devices/devices need to be replaced, or when support is required to properly place the relevant devices/devices, ensuring a high quality and fast service is possible only if IPKO maintains these settings. In this process, data from network devices/devices is processed (user network settings, i.e. including but not limited to: DHCP server, modem LAN, DHCP MAC-IP reservations, PortForWarding, DMZ settings, information about user devices and their interconnections – physical MAC address, assigned IP address and device name). IPKO uses this information to provide support and assistance to users, and during interventions to repair network devices/equipment.

The right to object

The user will have the right to object and has the possibility, at any time, to object to the processing of data for the purposes specified above. In this case IPKO – if this is possible and if the interests of IPKO do not prevail over the interests, rights and freedoms of the user – will stop processing the data for these purposes. A user can submit his objection by sending a written request to IPKO, or via e-mail to: info@ipko.com; by regular mail to IPKO Telecommunications LLC, Street “Zija Shemsiu” No. 34, Pristina; or by submitting their request in writing at IPKO’s sales points.

Data types

The types and/or categories of personal data processed by IPKO depend on the respective service and are listed or described in the agreement/contract and/or in the terms and conditions for the use of the respective service. IPKO can provide personal data either directly from the user, or indirectly through the use of a specific service by the user. IPKO may also receive personal data from third parties – in this case IPKO will receive and process the same types and/or categories of personal data as if such data had been received directly from the user. IPKO may also receive personal data of the user from a third party, which enters into or wishes to enter into a contractual relationship with IPKO (eg the user’s employer or another user of IPKO, contractual partners who list individuals as contact persons, etc.). In such a case, the third party must provide the relevant permission for the transmission of personal data to IPKO and will regularly inform and notify the user about this.

In order to check the accuracy of the data and obtain accurate data, IPKO may also receive data from third parties itself. In these cases, IPKO will receive the same types of data as if such data had been presented or should have been submitted by the user when entering into the contractual relationship (eg new/correct address when entering into the relationship their subscription, etc.)

Users of personal data

Users of personal data include IPKO, IPKO’s suppliers, IPKO’s contracting partners and state bodies.

Before IPKO allows its suppliers or business partners to have access to personal data, IPKO will first verify whether they comply with IPKO’s requirements regarding the processing and protection of personal data. Unless explicitly stated otherwise in the contract for specific contractual relationships for the processing of personal data by suppliers and business partners, IPKO will be responsible to the users for the processing of the users’ personal data. IPKO’s suppliers and business partners may be allowed access to personal data to the extent and within the relevant scope, as necessary for the supply/distribution of goods and/or the provision of services.

PKO may submit subscriber/user information to contractual partners to whom IPKO has assigned its claims against the subscriber/user.
Official bodies can receive personal data from IPKO only in cases and in accordance with the procedures defined by law.

Co-controllers of personal data

IPKO sells or offers specific services in cooperation with partners, who also enter into a contractual relationship with the customer and are – in these cases – also data controllers with their requests for the processing of personal data, including requests for the transmission of them to third countries. In these cases, IPKO’s business partner will be directly responsible to users for the processing of user data (and IPKO will not bear any responsibility for such processing by its contractual partner).