Privacy Policy

Primonet Inc. provides and operates a video intercom telecommunication service, called “PrimoDoor” (“the Service”), and distributes an application for mobile platforms, called PrimoDoor (“the Application”), to any individual user, whether for personal or professional purposes.

This Service and Application, as well as other associated support, maintenance or development services, and more generally all products and services provided by Primonet Inc., are fully described on PrimoDoor’s website, available at primodoor.com.ua (“the Site”).

This Privacy Policy describes, as required by art.13 of GDPR, how Users‘ personal data are collected and processed by Primonet Inc. when Users visit the Site, contact the company, as well as their rights and ways to exercise them.

This Policy, as well as any amendment thereof, is published on the Site.

1. DEFINITIONS

As used in this Policy, the following terms shall be defined as follows:

Application: the PrimoDoor application for Android; downloadable on the User's Terminal; published by Primonet Inc.;
Personal Data (or “Data”): personal data of the User, processed by Primonet Inc. for the purposes set forth in this Policy;
Service: Primonet’s video intercom service, using the open protocol SIP (Session Initiation Protocol);
Site: primodoor.com.ua website, published and operated by Primonet Inc., describing and updating the features and requirements of the Application and the Service;
Device: a mobile or fix telecommunication device with Internet access, such as a smartphone or tablet, which allows the Application to be downloaded and the Service to be used, in accordance with the prerequisites indicated at the time of download;
User: natural person visiting the Site, having downloaded and using the Application for personal or professional purposes, or having created an account on the Service.

2. WHO IS THE DATA CONTROLLER?

The Data Controller is Primonet Inc., whose head office is located at Ukraine, 79019, Lviv, Lypyns'kogo st. 36.

All requests regarding this Policy and GDPR may be sent, by mail to its postal address: Ukraine, Lviv, 79010, PO box 5312, or by email at: privacy@primonet.com.ua.

3. WHO ARE THE DATA SUBJECT?

The Data Subject, as defined under art.4 of GDPR, and concerned by this Privacy Policy, are the Users, as defined under Section I.

4. WHAT KIND OF PERSONAL DATA ARE PROCESSED?

For the purposes of providing the Service, the Application, and related services, the following Personal Data are processed by Primonet Inc.:

4.1. Primonet Inc. video intercom service:

4.1.a. User subscription data:

User's login name
User's password stored as a MD5 or SHA256 hash, used for SIP digest authentication.

4.1.b. User activity data:

Calls logs. They comprise: caller's SIP address, callee's SIP address, date, time, status (completed or not), duration.
Registration logs: these logs represent the instants when a user apps connects to the service through the network. They contain: date, time, status, IP address.

4.1.c. Debug logs:

For the sole purpose of troubleshooting, Primonet Inc. reserves the right to activate the debug logs in the Application and in the software used to provide the Service. Such debug logs contain full protocol information for the calls and other protocol events generated by the Users.

4.2. Visiting the website:

IP address
Cookies

5. WHAT ARE THE PURPOSES OF DATA PROCESSING?

We decided to list processing purposes, for each type of Data processed under Section IV.

Primonet Inc. video intercom service data	User subscription Data: User’s operation of the Service; User activity Data: Ability to proceed with requests from legal or regulatory authorities, regarding use of the Service; Statistical analysis on use of the Service by Users; such as call peaks; based on fully anonymized data of Users; in order to improve the Service’s operation and functionalities; Debug Logs: Support and troubleshooting services; Correct operation of the Service.
Visiting the Site	Audience and statistical purposes

Primonet Inc. video intercom service data

User subscription Data:
- User’s operation of the Service;
User activity Data:
- Ability to proceed with requests from legal or regulatory authorities, regarding use of the Service;
- Statistical analysis on use of the Service by Users; such as call peaks; based on fully anonymized data of Users; in order to improve the Service’s operation and functionalities;
Debug Logs:
- Support and troubleshooting services;
- Correct operation of the Service.

Visiting the Site

Audience and statistical purposes

6. WHAT ARE THE LEGAL BASIS FOR SUCH PROCESSING?

Once again, we thought it would be clearer to present such legal basis for each kind of Data processing.

Primonet Inc. video intercom service data	User subscription Data: User consented to the processing; Processing is necessary to operate the Service, and therefore for the performance of the agreement with the User; User activity Data: Processing is necessary to comply with our legal obligations; Debug Logs: Processing is necessary to perform the Service or support agreement with the User; Processing of the Data is in accordance with our legitimate interest since it enables us to improves performance of the Service.
Visiting the Site	Processing of the Data is in accordance with our legitimate interest since it enables us to measure the audience of our Site;

Primonet Inc. video intercom service data

User subscription Data:
- User consented to the processing;
- Processing is necessary to operate the Service, and therefore for the performance of the agreement with the User;
User activity Data:
- Processing is necessary to comply with our legal obligations;
Debug Logs:
- Processing is necessary to perform the Service or support agreement with the User;
- Processing of the Data is in accordance with our legitimate interest since it enables us to improves performance of the Service.

Visiting the Site

Processing of the Data is in accordance with our legitimate interest since it enables us to measure the audience of our Site;

7. HOW ARE MY DATA PROTECTED?

Primonet Inc. runs the video intercom service on machines hosted by Primonet Inc., in Ukraine.

The machines are secured, only Primonet Inc. workers are entitled to login.

8. HOW LONG ARE MY DATA PROCESSED?

Primonet Inc. video intercom service data	a. User subscription Data: - Until closing or deletion of User’s account; b. User activity Data: - 12 months after collection; i.e. call logs are retained for 12 months from their registration in Primonet’s systems; c. Debug Logs: - 1 month.
Visiting the Site	13 months, from the first date of collection;

9. DO WE DISCLOSE ANY INFORMATION TO THIRD PARTIES?

We do not sell, trade, or otherwise transfer to outside parties your Personal Data, unless specifically requested by legally competent authorities, under a judicial or administrative order (see IV.1 and V).

10. DO WE USE COOKIES?

We only use audience cookies, i.e. Google Analytics.

11. WHAT ARE MY RIGHTS AND REMEDIES?

11.1. User’s rights on Personal Data

As a User, you have the right to obtain from us:

confirmation that personal data concerning you are or are not being processed, and if necessary, to have access to them;
the correction of personal data concerning you that are inaccurate or incomplete;
the deletion of your personal data, under the conditions set forth in art.17 of GDPR; you may, for instance, delete your user account directly via the Service online, which will stop processing of all Personal Data, subject to the exceptions set forth in Section VIII;
to oppose, under certain conditions, the processing of your personal data.

11.2. How to exercise them

You may delete your account upon request sent via email.

For all other requests, please send us an email to: privacy@primonet.com.ua,

indicating the subject of your request, your name(s) and first name(s);
enclosing a photocopy of both sides of your identity card or passport, to enable us to verify your identity and any information that would be useful in processing your application.

We will get back to you as soon as possible, at the latest within one month of receiving your application.