Privacy Policy

 

Privacy Notice

ANAM’s care about your personal data. It is very important to us to be transparent about the data we collect about you, how we use such data and with whom we share it. Therefore, we advise you to read the following Privacy Notice to be informed about the processing of your personal data.

 

  1. ABOUT US

The term “ANAM” or “us” or “we” or “our” refers to the company Anam Technologies Ltd, with its business office at the 3 Custom House Plaza, Dublin, D01 VY76, Ireland, and registration number 512215, as well as to its subsidiaries and affiliates.

 

Our parent company is INFOBIP LIMITED, with its registered office at the United Kingdom, as well as to its subsidiaries and affiliates (the full list can be found at: https://www.infobip.com/offices) – Infobip Group of Companies (hereinafter jointly: Group Companies)

 

 

  1. ABOUT ANAM SERVICES

ANAM is the world’s leading SMS Firewall and A2P Monetisation service provider, filtering billions of messages for Mobile Operators.

 

While providing Services to our customers and processing personal data, we act as the processor regarding Services that we provide to customers.

 

  1. ANAM CONTACT DETAILS

ANAM Technologies Ltd, with its registered office at the 3 Custom House Plaza, Dublin, D01 VY76, Ireland.

 

If you have questions regarding this Privacy Notice or about the ANAM’s privacy practices, you may reach our Data Protection Officer via the email address dpo@anam.com

  1. HOW DO WE COLLECT DATA?

You explicitly choose to provide us with the data we collect. Most of the personal data we process is provided to us directly by you for one of the following reasons:

 

  • When we provide the Services to our customers
  • When you contact us with a question about our Services and when we are looking for new business opportunities
  • When you register to attend our events
  • You accepted to participate in our market research activities
  • You visited our webpage
  • You applied for a job or internship with us.

 

 

  1. WHAT PERSONAL DATA DO WE COLLECT, WHY AND ON WHICH LEGAL BASIS, HOW DO WE USE IT AND FOR HOW LONG DO WE KEEP IT?

 

 

  • When we provide the Services to our customers

We collect customer’s account data which is data that relates to the customer’s relationship with ANAM. If you sign up for our Services we ask for your name, contact details (e.g., phone number, email address, country), and information such as your company’s name, industry and your business role, as well as your login details (e.g. username and password). We also collect names, contact details of customer’s personnel. We also collect billing information (such as billing address). We collect personal data (such as name, business contact details, position in the company) related to customer representatives and other personnel that will be our contact points.

 

 

Collecting your name, contact details, login details, and billing information is necessary for us in order to enter into an agreement for Services with you, to create your account and enable you to access and use our Services, to keep your account secure, to provide you with customer care and technical support, to share relevant information about our products and services and to exercise our rights and fulfil our obligations arising from the business relationship that we may have with you or with your organisation. Conducting these activities is our legitimate interest according to GDPR article 6.1.(f) in the sense of providing our Services.

 

 

We collect and process traffic data to provide customers with our Services. Traffic data is data that is processed for the conveyance of a communication exchanged by using our Services or for billing related to that communication, and it includes data on the routing, type, duration, and time of the SMS communication. We also process traffic data to prevent spam and fraud. The carrying out of these activities is our legitimate interest in the sense of GDPR article 6.1.(f). In order to comply with our legal obligations (article 6.1.(c) GDPR).

 

 

We collect logs on your activities created during your use of our Services and connect this information with the customer’s account details in order to secure customer’s account, to prevent or detect fraudulent activities. For these activities we rely on our legitimate interest and on the legitimate interest of our customers (GDPR article 6.1.(f)) to maintain and improve the security of our network and Services.

 

 

All personal data collected within the customer’s account will be kept in a form that can identify an individual (such as names and contact details of customer’s personnel contact points obtained from the customer) for 12 months after the end of the provision of the Services.

 

Your requests and other communication exchanged with our support team via our help desk (support ticketing) system may be kept for three years after the end of the provision of the Services.

 

Traffic data will be kept in accordance with the applicable national legislation regulating retention of data in electronic communications for law enforcement purposes. As we may need to keep traffic data in order to calculate charges, we will keep them for billing and to settle our payments until payments are settled, the longest until the end of the period during which the bill may lawfully be challenged or payment pursued. In case that a bill remains unpaid or has been challenged before being paid, we will keep data to establish, exercise or defend our legal rights, the longest until the court or other legal procedure is finally closed.

 

In case that legal matters such as litigation, law enforcement requests or government investigations acquire us to preserve records, including those containing personal information, we will delete the impacted records when no longer legally obligated to retain them.

 

5.2. When you contact us with a question about our Services and when we are looking for new business opportunities

 

 

We may collect your name, surname and basic contact and business information such as your email address, phone number, country, company, industry, and business role. We will also collect any other information you choose to send us, depending on the nature of our communication. We may collect this information from forms available on our website.

 

We are constantly searching for new business opportunities. Therefore, we may collect your contact and business information indirectly, through business and professional networks and databases (such as LinkedIn) or we may employ third parties that supply us with information collected from publicly available sources and data enrichment providers. We only retain the information that will help us reach potential customers that could benefit from our services, or if we are interested in their products and services.

 

We collect this information to contact you, answer your questions, and to find out if you or your organisation are interested in further cooperation with us.

 

We use your personal data to provide you with the requested information about our Services and to see if you are interested in using them, or if we can benefit from using your Services, as well as to provide you with all the necessary information and support required to ensure the mutually beneficial and satisfying cooperation if you become our customer. Any further processing of your personal data will be based on the business relationship established with you or your organisation and on the lawful processing ground.

 

Such activities represent our legitimate interest in accordance with GDPR article 6.1.(f).

 

If we do not enter into an agreement, we will delete your personal data collected for this purpose within six months after our last communication.

 

In any case, if you no longer wish to be contacted by our sales or procurement team, you can always object by sending an email to optout@anam.com

 

 

5.3. When you register to attend our events

 

 

When you register to attend a webinar or any other event, you will be asked to provide your name and contact details (email, phone number, country), as well as your company’s name, industry, and your business role. We may also ask you information about the time and place of your arrival as well as accommodation details and dietary requirements you may have. We may collect photos, audio, and video material from our events.

 

We collect your personal data directly from you when you fill in our registration forms.

 

If you register for a webinar, we will use your contact details to provide you with the webinar details in advance, to remind you of the webinar and email you the recording of the webinar subsequently.

 

If you register to attend our event, we will use gathered information to ensure your place at the event, to be in touch with you, to provide you (via email or by SMS on the phone number you provided in the registration form) all relevant information before your arrival and during the event, to facilitate the event and ensure all organisational support that you may need (e.g. help you with information about the location of our event, accommodation, travel or any logistic details related to the event).

 

The legal basis we rely on is your consent under article 6(1)(a) of the GDPR, provided when you submit your details through our registration forms. When we collect any information about dietary requirements, we also rely on your consent (under article 9(2)(a)) as this type of information is classified as a special category of personal data.

 

In order to be able to facilitate the event, we rely on your consent to process your personal data and this means you have the right to withdraw your consent at any time by sending an email to optout@anam.com

 

 

5.4. When we perform market research activities

 

 

We collect your name and contact information (email address). The idea of the researches we conduct is to gather anonymous information. Therefore, our intention is to collect only your personal data necessary to send you a questionnaire but not to link the anonymous answers with you in any way. We collect your name and contact data (email address) from business and professional networks (for example LinkedIn), or from our databases if you or your organisation are our customers, suppliers or business contacts.

 

We conduct market research activities in order to receive anonymous information and feedback for improving our products and services and targeting potential. Firstly, we invite you to take a survey sending a generic untraceable URL to a survey questionnaire. If you decide to participate and answer our questions, we will not ask you to unveil any personal data, and our intention is to keep the answers anonymous.

 

When searching for your email address, we rely on our legitimate interest in accordance with GDPR Art. 6.1.(f). Our intention is to collect anonymous information. However, if you disclose any information about you in your answers, we will rely on your consent in accordance with GDPR Art. 6.1.(a).

 

We will process the answers you provided in order to have general feedback on our products and services.

 

5.5. When you visit our webpage

 

 

We use third-party services such as Google Analytics when you visit www.anam.com  in order to collect standard internet log information and details on visitor behaviour patterns. We do this to find out information such as the number of visitors to various parts of the site. This information is only processed in a way that does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of visitors to our website. We also use LinkedIn Analytics. For more information, please consult the relevant privacy notice. When you browse our website, we automatically place necessary cookies on your browser. You can opt in to accept advertising or analytical cookies. The information we collect helps us maintain and improve our website and business. It usually includes your IP address, browser type, the pages you’ve visited and the order you visited them, as well as whether you’re a new or returning visitor. For more information please read our cookie policy – ANAM – The A2P SMS Revenue Experts | Cookie Policy

 

 

5.6. When you apply for a job or internship with us

 

 

We collect your first and last name, contact information (email address and telephone number) and location/place of residence as well as information about your education, previous work experience, and any other information you choose to share with us in your resume (CV) or application when expressing interest in joining our team. When permitted by applicable law, we may also collect professional information about you from the business networking sites you use (such as LinkedIn) and we may search their content in order to find out more professional information about you if your resume or application contains links to other sources (e.g. web pages).

 

If we arrange an interview and you go through our selection process, we may collect further information gathered from you during the interviews, results of conducted evaluation tests, interview notes and reviews of our colleagues who interviewed you. We may also collect information about your professional experience from your referees, if you indicated them.

 

We collect your personal data directly from you when you submit your resume and/or application directly into our recruitment software.

 

We may collect your personal data from recruitment agencies and background check agencies we have engaged in order to help us find potential candidates for open positions or from business networking sites you use, such as LinkedIn.

 

We may collect further information about you during the selection process. This information will be generated by you and by us.

 

You can find information on open positions and internships in our offices on our Careers web page hr@anam.com, where you can submit your resume and/or application if you are interested in joining us. When submitting your resume, you will be asked to provide us your consent to store and process your personal data for recruitment purposes for the period of time specified in the consent form. We rely on your consent to collect and process your personal data in accordance with article 6.1(a) GDPR. We use your personal data for recruitment purposes, e.g. in order to contact you and check if you are interested in open positions or internships, and if you are, to conduct the selection process and assess your suitability.

 

If you do not submit your resume directly into our recruitment software (e.g. when we receive it from a recruitment agency, or we find your professional details on business networking sites you use), we will send you an email with a link to our recruitment software and you will be asked to provide us your consent to keep your personal data for recruitment purposes. In such cases, we collect your personal data and contact you with an email based on the legal grounds of our legitimate interest pursuant to GDPR article 6.1(f), in order to find potential job candidates. However, we need your consent for any further processing of your personal data. If you do not provide us with the consent within thirty days following the receipt of the email, we will erase your personal data from our database.

 

During the selection process we collect further information in order to review your professional qualifications and interests and be able to choose the best candidate. We also conduct the relevant background checks, to the extent permitted by applicable data protection laws, which include identity verification, right of work verification, education, professional license and previous employment checks, verification of recommendations, checks of company registers and criminal checks. Moreover, for executive roles we will also carry out a reputational check from publicly available sources. For the processing of this information, we rely on our legitimate interest (article 6.1(f) GDPR), your consent (article 6.1(a) GDPR) or legal obligation article 6.1(c) GDPR.

 

If you have been selected as the most suitable candidate for a job position or internship, you will be presented an offer. If you accept it, we will collect further information so as to be able to conclude and execute an agreement with you. We rely on article 6.1(b) of the GDPR for the further collection and processing of your personal data because the processing is necessary in order to conclude an employment or internship agreement with you or in order to take certain steps, at your request, prior to entering into that agreement.

 

As we rely on your consent for recruitment purposes, we only keep your personal data for the consented time.

 

Your personal data will be erased from our database after the expiration of the period for which you have provided us with your consent or earlier if you withdraw it.

 

You have the right to withdraw your consent at any time and you can do it by sending the email optout@anam.com

 

  1. SHARING YOUR PERSONAL DATA

 

We may engage processors to facilitate us in the processing of your personal data or to assist us in providing you with our Services.

 

Before engaging a new processor, we perform security & privacy assessment of the processor, and we ensure that the processing of personal data is always regulated with written data processing agreements. If the personal data during the provision of the services of our processor is being transferred outside the European Economic Area (EEA), ANAM will always ensure that the transfer is in line with applicable data protection laws, including the GDPR.

 

We may share your personal data within ANAM and Group companies. Since we are a global company, we may share your personal data with our subsidiaries and affiliates to complete internal procedures within our offices, to perform certain processing activities on a global scale or to support you in the use of our products and services.

 

  1. TRANSFER YOUR PERSONAL DATA OUTSIDE THE EEA

 

Your personal data may be processed both inside and outside of the European Economic Area by the parties specified in the section above, subject always to contractual restrictions regarding confidentiality and security in line with applicable data protection laws and regulations.

 

In any case, any activity that involves access to the personal data from outside the EEA (with or without re-locating the personal data) is done in accordance with the high EU data protection standards, either by implementing EU standard contractual clauses, by transferring personal data in accordance with the EU data protection adequacy decisions or by implementing another adequate GDPR transfer mechanism.

 

  1. KEEPING YOUR PERSONAL DATA SECURE

 

We have a specialized security team who constantly review and improve our measures to protect your personal data from unauthorized access, accidental loss, disclosure or destruction.

 

The list of our current and up-to-date certificates can be found

 

We take care to train all our staff in the field of privacy and security, starting from their first day in ANAM  through the onboarding process and continuously throughout their stay at ANAM.

 

Before we engage any third-party vendor and service provider, we check their security practices and alignment with the GDPR, and regularly conduct our vendors’ and service providers’ security and privacy assessments.

 

  1. YOUR PRIVACY RIGHTS

 

Where permitted by applicable data protection law or regulation, you have the right to:

  • withdraw your consent to our processing of your personal data, without affecting the lawfulness of processing based on consent before its withdrawal,
  • request from us to access your personal data, which means request a copy of the personal data we hold about you,
  • ask us to rectify (correct) your personal data that you think is inaccurate and to complete your personal data that you think is incomplete,
  • ask us to erase your personal data in certain circumstances,
  • ask us to restrict the processing of your personal data in certain circumstances,
  • if we process your personal data by automated means based on your consent or upon a contractual relation with you, you can exercise the right of data portability,
  • if we process your personal data upon our legitimate interest, you have the right to object to the processing, and we will reassess the legitimacy of the processing,
  • you may also have specific rights in exceptional cases when we may carry out automated decision-making operations, including profiling,
  • you also have a right to file a complaint with us and/or the relevant data protection authority.

 

If you have any questions on how we use your personal data or if you wish to exercise a certain right or resolve a complaint regarding the processing of your personal data, you can contact our Data Protection Officer by sending an email to the following email address: dpo@anam.com

 

If you want to file a complaint or contact the relevant data protection authority for any other reason, you may find contact details of EEA data protection authorities at: https://edpb.europa.eu/about-edpb/board/members_en.

 

 

  1. CHANGES TO THE PRIVACY NOTICE

 

 

We will provide notice of any modifications by posting a written notice on our website.

 

 

 

Dublin, August 2021