Teways Privacy Policy

The applicable Teways legal entity responsible for processing your personal data will depend on the services you use, the contractual relationship with you, and the jurisdiction involved.

For privacy-related questions, requests or concerns, please contact: legal@teways.com.

Where applicable, Teways will identify the relevant data controller, data processor, representative or Data Protection Officer in the applicable contractual documentation or privacy notice.

This Privacy Policy applies to personal data collected or processed through:

• Teways websites and online services;
• Contact, enquiry and registration forms;
• Customer and partner communications;
• Teways products, platforms and services, where applicable;
• Customer support and service communications;
• Business and commercial relationships;
• Marketing and communications activities; and
• Other interactions between you and Teways.

Where Teways processes personal data on behalf of a customer as a data processor, Teways will process that data in accordance with the customer's documented instructions and the applicable data processing agreement.

Depending on how you interact with Teways, we may collect the following categories of personal data:

Where Teways processes message content on behalf of a customer, the applicable customer generally determines the purposes and means of that processing and Teways may act as a processor or service provider.

We may retain information contained in communications with our teams, including support requests, enquiries, technical issues, complaints, feedback and other correspondence.

We may collect personal data:

• Directly from you;
• From your employer or organization;
• From our customers, partners and service providers;
• Through your use of our websites, platforms or services;
• Through cookies and similar technologies;
• From publicly available sources; or
• From other lawful sources.

Where required by applicable law, we will provide appropriate privacy information when personal data is obtained from sources other than the individual concerned.

Teways may process personal data for the following purposes:

• Providing, operating and supporting our services;
• Managing customer and partner relationships;
• Customer onboarding and account administration;
• Processing orders and contractual arrangements;
• Billing, invoicing, accounting and financial administration;
• Providing customer and technical support;
• Monitoring service performance and reliability;
• Service development and improvement;
• Website operation and administration;
• Business analytics and reporting;
• Security, fraud prevention and abuse detection;
• Network and communications security;
• Regulatory and legal compliance;
• Responding to enquiries and requests;
• Managing disputes and enforcing contractual rights;
• Business communications and marketing where permitted by law; and
• Other purposes disclosed at the time personal data is collected or otherwise permitted by applicable law.

Where GDPR, UK GDPR or another law requiring a lawful basis applies, Teways may rely on one or more of the following lawful bases:

• Contract: where processing is necessary to enter into or perform a contract with you or your organization;
• Legal obligation: where processing is necessary to comply with applicable law or regulatory requirements;
• Legitimate interests: where processing is necessary for legitimate business interests, security, service improvement, fraud prevention or other legitimate purposes, provided those interests are not overridden by applicable rights and interests;
• Consent: where consent is required and has been obtained; and
• Other lawful grounds: where permitted by applicable legislation.

Where processing is based on consent, you may withdraw that consent at any time, subject to applicable legal limitations and the consequences explained when consent was obtained.

Teways may disclose personal data where necessary and permitted by applicable law to:

• Customers and authorised business users;
• Telecommunications operators and carriers;
• Messaging platforms and communication providers;
• Cloud, hosting and infrastructure providers;
• Technology and software providers;
• Payment, billing and financial service providers;
• Professional advisers, auditors and insurers;
• Security, fraud prevention and risk management providers;
• Regulatory, governmental, judicial or law enforcement authorities where legally required;
• Business partners and service providers supporting the delivery of our services; and
• Other parties where disclosure is authorised by you or otherwise permitted by applicable law.

Teways does not sell personal data for monetary consideration.

Where Teways processes personal data on behalf of a customer, we may engage third-party processors and sub-processors to support the delivery of our services.

Such parties may provide services including:

• Cloud hosting;
• Infrastructure;
• Messaging and telecommunications;
• Security;
• Monitoring;
• Customer support;
• Analytics;
• Data storage; and
• Other technology services.

Teways requires applicable processors and sub-processors to maintain appropriate contractual, technical and organisational safeguards for personal data.

Where required by contract or applicable law, Teways may maintain and provide information regarding relevant sub-processors.

Teways operates in an international telecommunications and technology environment. Personal data may therefore be processed or transferred across borders.

Where applicable law requires safeguards for international transfers, Teways will implement appropriate lawful transfer mechanisms, which may include:

• Adequacy decisions or recognized adequate protection mechanisms;
• Standard Contractual Clauses ("SCCs");
• Appropriate contractual safeguards;
• Other legally recognized transfer mechanisms; or
• Applicable derogations where legally permitted.

The applicable safeguards will depend on the jurisdiction, nature of the transfer and applicable law.

Teways retains personal data only for as long as reasonably necessary for the purposes for which it was collected, including to:

• Provide and support services;
• Maintain business and contractual records;
• Meet legal, regulatory, tax and accounting obligations;
• Resolve disputes;
• Prevent fraud and security incidents;
• Enforce contractual rights; and
• Protect Teways' legitimate business interests.

Retention periods vary according to the type of personal data and the purpose of processing.

When personal data is no longer required, Teways will securely delete, anonymize or otherwise dispose of it in accordance with applicable requirements.

Teways implements appropriate technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, loss, misuse or destruction.

These measures may include access controls, authentication, encryption where appropriate, network and system security, monitoring, backups, incident management, personnel controls and other information security measures appropriate to the nature and risk of the processing.

Teways aligns its information security and privacy practices with recognised industry standards and applicable legal requirements.

Where Teways holds a specific certification or assurance report, such certification or report may be identified separately.

Teways may use cookies and similar technologies to operate, secure, analyse and improve our websites and online services.

Where required by applicable law, Teways will obtain consent before placing non-essential cookies or similar technologies on your device.

For more information about the cookies we use and how you can manage your preferences, please see our Cookie Policy.

Where permitted by applicable law, Teways may use personal data to communicate with existing or prospective customers, partners and business contacts regarding products, services, events, updates and other relevant business information.

Where consent is required, Teways will obtain it before sending relevant marketing communications.

You may opt out of marketing communications at any time by using the unsubscribe mechanism provided in the communication or by contacting us at legal@teways.com.

Opting out of marketing communications will not affect transactional, service, security or other communications that are necessary for the provision or administration of our services.

Depending on applicable law and the circumstances of processing, individuals may have the right to:

• Request access to personal data;
• Request correction of inaccurate or incomplete personal data;
• Request deletion or erasure of personal data;
• Request restriction of processing;
• Object to certain processing;
• Request portability of personal data where applicable;
• Withdraw consent where processing is based on consent;
• Object to direct marketing;
• Request information about automated decision-making or profiling where applicable; and
• Lodge a complaint with the relevant data protection or supervisory authority.

Certain rights may be subject to legal limitations or exemptions.

To submit a privacy or data protection request, please contact legal@teways.com.

Please provide sufficient information to allow us to understand and process your request.

Teways may take reasonable steps to verify the identity of the person making a request where necessary to protect personal data and prevent unauthorized disclosure.

We will respond within the timeframe required by applicable law.

Teways does not generally make decisions producing legal or similarly significant effects on individuals solely through automated processing.

Where automated decision-making or profiling is introduced in a manner that triggers additional obligations under applicable law, Teways will provide the information and safeguards required by that law.

Teways' business services are primarily intended for businesses, organisations and professional users and are not directed at children under the age of 18.

Teways does not knowingly collect personal data directly from children through its business websites or services without appropriate legal authorisation.

Teways maintains procedures for identifying, assessing, managing and responding to personal data breaches and security incidents.

Where required by applicable law, Teways will notify relevant regulators, customers and/or affected individuals within the applicable statutory timeframes.

Our websites or communications may contain links to third-party websites, applications or services.

Teways is not responsible for the privacy practices of third parties that operate those websites or services. We recommend reviewing the applicable privacy notices before providing personal data to third parties.

If you have concerns about how Teways processes your personal data, we encourage you to contact us first at legal@teways.com.

Where applicable, you may also have the right to lodge a complaint with the competent data protection or supervisory authority in the jurisdiction applicable to you.

Teways may update this Privacy Policy from time to time to reflect changes in our services, technology, legal requirements or privacy practices.

The latest version will be published on this page together with the date of the most recent update.

Where required by applicable law, Teways will provide additional notice of material changes.

For questions, requests or concerns relating to privacy and personal data, please contact Teways at legal@teways.com.

For contractual customers, additional privacy requirements, data processing terms, security controls and sub-processor information may be addressed through the applicable agreement, Data Processing Agreement ("DPA") or other contractual documentation.