Privacy/ Personal Data Protection
NOTICE

About the Company

Company name: JSC Silknet (hereinafter also referred to as "We", “Our”, “Us” or "the Company")

Identification code: 204566978

Address: 95, Tsinamdzghvrishvili St., Chughureti District, Tbilisi

Additional information about the Company can be found on the website: www.silknet.com

The Privacy Notice may be periodically updated, information about which will be reflected on our website and we will inform you about it. The first page of the document provides the date of the final update of the Notice.

Scope of the Privacy/ Personal Data Protection NOTICE

This Privacy Notice applies to Silk GO (digital television (DTV) and Video on Demand (VOD)) services provided via the mobile application and/or the web-site (Silktv.ge).

If you use/plan to use Silk Go services, we assume that you have read and agree to the terms of the Notice.

This Notice does not apply to - other services and products provided to you by Silknet, including fixed and mobile voice and internet/data services. The notice which covers the confidentiality/personal data protection matters related to Silknet’s basic and additional services/products is available at: https://silknet.com/ge/company/privacy-policy.

Similarly, this Notice does not apply to services or web-sites provided to by third parties, which you may access through Silknet web-site or within the scope of the services provided. Silknet is not responsible for processing of personal data within the scope of the services provided to you by third parties.

Privacy Notice objectives

The purpose of this Notice is to:

  • Explain to you the legal grounds, purposes and principles that we rely on when processing your personal data.
  • Inform you on how we collect and what kind of data we process about you.
  • Inform you how we protect your personal data.
  • Provide information about your rights, as a data subject.

We process personal data in accordance with the rules and norms established by the legislation of Georgia, as well as the conditions specified in this Privacy Notice and in a respective agreement/contract.

Personal data processing principles and warranties

  • Data shall be processed lawfully, fairly, and transparently for the data subject and without violating his/her dignity.
  • Data shall be collected/obtained only for specific, clearly defined and legitimate purposes.
  • Data shall be processed only to the extent necessary to achieve the relevant legitimate purpose. Data should be proportionate to the purpose for which they are processed.
  • Data shall be true, accurate and, if necessary, updated. Taking into account the purposes of data processing, inaccurate data must be corrected, deleted or destroyed without undue delay.
  • Data may be stored only for the period necessary to achieve the relevant legitimate purpose of data processing. After achieving the purpose for which the data is processed, they must be deleted, destroyed or stored in a depersonalized form, unless the processing / storage of data is determined by law and is a proportionate measure to protect superior interests in a democratic society.
  • In order to protect the security of the data, such technical and organizational measures should be taken during the data processing that properly ensure data protection, including against unauthorized or illegal processing, accidental loss, destruction and/or damage.

Silknet declares that it will process personal data in accordance with the legal bases, goals and principles defined in this Privacy Notice.

Personal data security guarantees

We have a dedicated security team that is constantly working to improve security measures to protect your personal data from unauthorized or unlawful access, accidental loss, disclosure or destruction.

Based on policies and procedures related to information security, we have implemented appropriate organizational and technical measures, the effectiveness of which is periodically evaluated within the framework of internal and external audits.

Grounds and purposes of personal data processing

We process your personal data on one or more of the following lawful grounds, namely:

  • Performance of the obligations specified in a contract / agreement concluded between us and/or the consideration of your request/application.
  • Ensuring the protection of our legal/legitimate interests.
  • Fullfilment of the obligations imposed on us by law.
  • Based on your consent.

On the above grounds, we may process your data for one or more of the following lawful purposes:

  • In order to provide you with the service(s) purchased/selected/received by you (DTV and VOD);
  • To identify you and enable you to register in the application/on the web-site;
  • To enter into an agreement and/or manage your account/services, including for provision of remote management services;
  • To provide you with information regarding the service(s) you have purchased, including (i) expected depletion of your balance or volume of services purchased, (ii) your debt and payment due date (iii) expected limitation/discontinuation of service (v) planned preventive works or (vi) changes in terms of service/rates.
  • In order to process your request, claim/complaint, provide you with technical support, detect and eliminate damage or technical error.
  • To ensure quality of service, including for discovery and/or elimination of any technical faults, testing, improving and developing our services / products and applications/web-sites.
  • To monitor, prevent, identify and eliminate / suspend fraudulent activities, fraud and/or cyber attack incidents on our network;
  • To form aggregated and depersonalized data that we use (i) to analyze and further develop our services and products, (ii) to develop new services / products, as well as (ii) to develop managerial, internal corporate and other reports; (data stored in such an aggregated and depersonalized form does not constitute personal data, as it excludes the direct or indirect identification of a person).
  • For direct marketing purposes, namely to provide you with information/notifications regarding our services, as well as products / joint products of our partner companies (to which you have access within our offer);
  • For analyzing your interests, profiling you and developing personalized products tailored to you on the services rendered.
  • To conduct surveys and research on the services rendered;
  • In connection with the provision, correction, processing of personal data, including the termination of processing for direct marketing purposes, in order to record and fulfill your requests;
  • Additionally based on your consent, we may process your data for all other purposes for which you have consented.

Sources of obtaining personal data and data we process

Personal data is collected from one or more sources provided by you to the Company and listed below.

We collect your personal data when you:

  • Contact us or our authorized (including agency and dealer network) representative through various communication channels with a request to purchase our services and/or provide information;
  • You undergo identification, register on our application/website and enter into an agreement/contract with us;
  • Use our services, our application/web-site, including changing, adding or canceling services;
  • User hot-line and online consultation services (online chats) or send us a letter via e-mail or by post;
  • Participate in our survey, action, raffle and/or otherwise communicate with us;
  • Contact us with a claim/complaint, including a request for failure elimination, service quality assurance and/or any other defect correction.
  • Contact us with a request to provide, correct, delete or stop processing your personal data.

Your personal data, within the limits defined by law, may also be obtained from our partner companies whose services you use (for example, roaming operators and interconnected companies) and/or from such organizations as public registers, payment service providers, credit information bureaus, LEPL Public Service Development Agency (PSDA), other financial institutions and public organizations.

Data we Process

The categories of personal data and the scope of processing depend on the services you have purchased /received, the form of communication with us and your request:

The following data may be processed on the basis and for the purposes specified in this Privacy Notice:

  • Your identification and authorization data: first name, last name, personal number, address, phone number, email address and date of birth;
  • Information about your registration data, including the user name, password, account number, one time password and the data regarding their use;
  • Data about the service(s) you have received, including data about received TV content (channel/program), time and duration, as well as data regarding adding, canceling or changing services.
  • Billing data, including data on fees charged for services, date, time and form of service purchase or account payment, as well as information about your debts, unpaid account(s) and deposit(s).
  • Data necessary for payment, including data on credit/debit card and/or a bank account.
  • Your IP address and unique device ID number, including the device manufacturer and the model, operating system version, time zone data, length and width of the screen;
  • Data on the type of connection (mobile data or WiFi) and name of the connected network.
  • Service-related communication data, including written information received by e-mail/mail/online chat) program, audio recording of incoming calls to the Call Center and/or video recording of your visit to our Service Center.
  • Data on the quality of services provided to you and detailed failure data/statistics.
  • Data related to fraud and information security breaches.
  • Data regarding the use of services / products and your interests of us and our partner companies (whose services you have access to within our offer / joint offer), as well as information about marketing offers and messages received regarding the services / products of our and / or our partner companies.
  • Information obtained from the processing of your data, including segment/category and profile.
  • Information on rectification, deletion, disclosure, consent to processing or request to stop processing your personal data.
  • Any other data that you have consented to process and/or that we are required to process by law.

Personal data of minors

The Company concludes agreements/contracts only with adults, i,e. with users who have reached the age of 18. In the event that we learn that that the service user is a minor, we will take appropriate steps to ensure that the minor's best interests are protected.

In order to ensure the safety of minors in the online space, we have introduced a product for our users, additional information of which can be found on our website Parental Control - SILK KIDDO.

Sharing of Personal Data

We may share your data with:

  • Silknet's data processors, i.e. authorised persons/(sub)contractors who process personal data on our behalf/for our benefit and on our behalf for the purpose of providing various services. Our (sub)contractors are not allowed to use the data for any purpose other than the those specified in the relevant agreement between us and/or to disclose the data available to them.
  • In some cases, we may share your data with processors located outside of Georgia, including countries that are not included in the order of the head of the Personal Data Protection Service, which defines the list of countries with adequate guarantees of personal data protection. When processing your personal data by processors, we ensure that data is processed within the scope of the obligations imposed under the contract, including in accordance with the conditions specified in this Notice and the rules established by law.
  • In cases defined by legislation, with the relevant authorized law enforcement bodies and/or state agencies.
  • Other persons, subject to your consent

In all the above-mentioned cases, personal data will be shared only to the minimum extent that is necessary to achieve the respective purpose and/or that is provided/required by law.

Direct marketing

For direct marketing purposes, we process your data based on your consent. Direct marketing on behalf of Silknet takes place when you receive on the phone number(s) provided for in the agreement/contract and/or the contact number provided by you (via short text message, phone call and/or video/audio/image message), as well as by other electronic means of communication (e-mail, online platform, website, application, TV pop-up notices or other) information about our and/or our’s and our partner companies' joint products, services, discounts, promotions, sweepstakes, prizes, customized, personalized products/services and other news. If you opt out of direct marketing of Silknet products, you will not receive information about Silknet discounts, promotions, offers or other news, and you will not be able to take advantage of products/services or discounts tailored to you.

For direct marketing purposes, we may process the following data: your ID and contact data, provided by you to Silknet, data made available to Silknet as a result of the provision of services (including location and electronic communication identity data) and/or data obtained as a result of the processing of such information, including information about your profile/segment.

You may at any time, without any additional cost, ask us to stop processing data for direct marketing purposes (including profiling) and sending you marketing messages (ask for your consent), both through the forms of communications below (see “How to contact us”) and in the manner Silknet sends a marketing message; for example, when receiving a marketing message via Short Message Service (SMS), you can send a request to stop receiving marketing messages to the attached SMS number (NO SMS Silknet - 91131; NO SMS other companies/third parties - 91118).

We have an obligation to stop processing your data for direct marketing purposes within a reasonable time after receiving your relevant request, but no later than 7 working days.

Personal data retention

We retain personal data for the time that is necessary to achieve the relevant legitimate objective and/or is defined by law.

In accordance with the current legislation, we retain your identification and contact data, hardware / device data and data on the provision of services for a period of no more than 4 years after the expiry / termination of the contractual relationship, and information on payments, as well as information on services received or provided (including outgoing /detailed transcript of incoming telephone communication) - no more than 4 years after the service was provided/the communication was made.

Upon the expiration of the period provided for the retention of data, but no later than 30 days, we shall ensure the erasure or destruction of this data.

YOUR RIGHTS

You have the right to:

  • Request information about the data that is being processed about you
  • Review and receive copies of the data we process about you
  • Ask us to correct, update and/or complete any false, inaccurate and/or incomplete data about you
  • Withdraw your consent at any time, without any explanation or justification, if there is no other grounds for data processing
  • Request the termination, blocking, erasure or destruction of your data;
  • Receive the data you provide in a structured, publicly available and machine-readable format or request the transfer of this data to a person responsible for other processing;
  • Be notified of the decision made as a result of automated processing, including profiling, and the logic used to make such a decision, as well as its impact on data processing and the expected / probable result of processing;
  • Receive information about a data security breach incident that is highly likely to cause significant harm and/or pose a significant threat to basic human rights and freedoms.

You have the right to receive the information provided for in this Chapter no later than 10 working days after its request. This term can be extended by no more than 10 working days in special cases and with proper justification, of which you will be notified immediately.

Termination, deletion or destruction of data

You have the right to ask us to stop processing data about you (including profiling), delete or destroy the data.

We shall stop processing your data and/or delete or destroy your data no later than 10 working days after receiving your request (unless otherwise stipulated by the legislation of Georgia).

We may refuse to comply with your request if there is another ground for data processing, for example: the data retention obligation is provided by law and/or the data retention is necessary to achieve the purpose for which the data collection was carried out, including the fulfillment of a contractual financial obligation. In case of refusal, the reason for refusal will be explained to you and you will also be notified of the procedure for appealing said refusal.

Please note that if you request the termination of the processing of such data, which is necessary to provide you with the services defined by the agreement / contract, we will no longer be able to provide you with the corresponding services.

You will receive information about the termination of processig, deletion or destruction of data immediately after taking the relevant action, but no later than 10 working days.

HOW TO CONTACT US

If you have questions and/or wish to make a request regarding this Notice, the processing of your data, please contact us using the following communication channels:

  • Visit our service center(s) during business hours.
  • Contact us on the hotline 24 hours a day 032 2 100100.
  • Email us at dpo@silknet.com or info@silknet.com

Silknet is obliged to correct, update and/or complete the data within 10 (ten) working days from your request and within 10 (ten) working days from correcting the data to notify you about this or to inform you of the reason for refusing to meet your request, if any.

DEFINITIONS

Subscriber/User - a natural or end user legal person, who uses or intends to use the service for his/her own purposes and does not intend to resell it to another user/person and who has entered into a contractual relationship with Silknet.

Company/Silknet/We  - for the purposes of this Notice, data controller, who individually or jointly with others determines the purposes and means of data processing, directly or through an authorized person performs data processing.

Processor - an authorized person who is a contracting party of the Company, acts for it and on its behalf, and who processes the data of the same users in order to provide services to users

Other Company/Third Party - a natural or legal entity engaged in the activities / services included in the categories specified in the appendix.

Other Person - a natural person, legal entity or public institution, except for the data subject, the Personal Data Protection Service, Silknet, an authorized person, a special representative and a person who is authorized to process data on the direct order of Silknet or an authorized person,

Services - any core/additional services and products provided by Silknet, including fixed and mobile telephony, Internet/data transmission, SMS, transit broadcasting (Pay-TV) and video on demand (VOD) services.

Data/Personal Data - any information connected to an identified or identifiable natural person. A person shall be identifiable when he/she may be identified directly or indirectly, in particular by an identification number or by any physical, physiological, psychological, economic, cultural or social features specific to this person.

Depersonalization of Data – the processing of data in such a manner that the data cannot be attributed to the data subject or attributing them to the data subject involves disproportionate effort, expense and/or time.

Partner - any other person with whom the Company offers / implements joint products / services.

Direct Marketing - the direct and immediate delivery of information to the data subject by phone, mail, e-mail or other means of telecommunication for the formation and maintenance of interest in a natural person and/or legal entity, goods, idea, service, work and/or initiative, as well as image and social issues, for sales and/or support purposes.

Profiling - any form of automatic data processing, which involves the use of data to evaluate certain personal characteristics related to a natural person, in particular, the analysis and prediction of those characteristics that concern the quality of work performed by a natural person, his/her economic situation, health, personal interests, reliability, behavior, location or movement.

Authorized Person - a person authorized for processing (natural person, legal entity or public institution) who processes data for or on behalf of the Company.