Privacy Policy

Last Updated: ___________ __, 2024

Introduction

Société de Développement des Télécommunications du Liban (Sodetel) S.A.L, referred to as "SODETEL" or "us," "we," and "our," recognize the significance of safeguarding your personal data and value the trust you place in us to handle it securely and responsibly.

This Privacy Policy outlines the information we gather and details our policies and procedures concerning the collection, use, disclosure, and protection of the personal data we collect. Please carefully review this Privacy Policy to comprehend your rights and our practices regarding personal data.

Personal data encompasses any information that identifies you as an individual or is related to you as an identifiable person ("Personal Data").

I- HOW YOUR PERSONAL DATA IS COLLECTED

We gather your Personal Data when you browse or visit our website:

• We collect non-personal information, encompassing session durations, accessed content on the website, the frequency and extent of your website usage, and details about your computer and internet connection, including your operating system and browser type.
• Additionally, we may gather information through cookies and analytic tools for essential analytics purposes.
• Our legal basis for collecting this information is your consent and/or our legitimate interest, particularly when utilizing essential cookies.
• We gather your Personal Data when you utilize or engage with our website or other SODETEL platforms:
• We collect personally identifiable information, such as your name, email address, telephone number, company, date of birth, and any other details you willingly share with us. Personal Data is acquired only if provided voluntarily by you, such as when joining our mailing list (if available) or requesting us to contact you. It also includes information you provide in surveys (if available). 
• Your Personal Data is collected to address your specific requests or inquiries and to deliver the services you desire. This Personal Data enables us to offer technical and professional assistance.
• If you opt to subscribe to our mailing list (if available), we will utilize your data to send newsletters, updates, and inform you about marketing events, including those organized in collaboration with third parties. You can unsubscribe from our mailing list anytime by clicking the "unsubscribe" link in the relevant communication.
• Our legal basis for collecting your Personal Data is that processing is necessary to fulfil your request before entering into a contract and/or aligns with our legitimate interest, such as responding to your requests.
• We may share this Personal Data with third party platforms, such as email platforms and/or hosting provider.
• We gather your Personal Data during the processing of job applications:
• The information collected includes your full name, email address, phone number, CV or LinkedIn link, and any additional details you opt to provide.
• This data is collected to facilitate the processing of your job application and to evaluate your suitability as a candidate.
• Our legal basis for collecting this information is that processing is necessary for the performance of a contract to which you will be a party or is required prior to entering into a contract, as well as our legitimate interest, such as assessing your candidacy.
• We may share this Personal Data with third-party platforms, including recruitment software, email platforms, and/or hosting providers.
• We seek your knowledge and consent before collecting, using, or disclosing Personal Data, except when mandated or allowed by law. Supplying your Personal Data is entirely voluntary, as you have the discretion to refrain from providing it when requested.

II- USE OF YOUR PERSONAL DATA

We rely on the information we collect to support our business functions, power our services, and improve your experience. Your Personal Data may be employed for various purposes, including:

• Facilitating the provision and maintenance of the Website.
• Personalizing our website to enhance your experience.
• Enabling your participation in interactive features of our services.
• Providing analysis or valuable information for service improvement.
• Monitoring the usage patterns of our Website.
• Detecting, preventing, and addressing technical issues.
• Ensuring the security of our Website and preventing fraud.
• Delivering customer care and support, addressing inquiries and complaints from you.
• Offering news, special offers, and general information about other goods, services, and events we provide.
• Sending email notifications that you have specifically requested.
• Furnishing third parties with statistical information about our users (with no ability to identify individual users from that information).
• Prevent and investigate security issues, illegal activities and verifying compliance with the terms and conditions governing the use of our Website.
• Billing, collection, and protection of our property and legal rights. 
• Improve and protect our network.
• Detect and prevent fraud.

III- DISCLOSURE OF YOUR PERSONAL DATA

Preserving your trust is paramount to us, and we want to clarify when and with whom we might share the Personal Data we collect:

Sharing with Third Parties: We may share your Personal Data for the purposes outlined in this Privacy Policy. Additionally, we may share aggregated or anonymized information that does not directly identify you. Third parties receiving personal data are contractually obligated to implement suitable data protection and security measures, using the data solely for the specified purpose.

Links to Other Sites: Our website might include links to third-party sites not covered by this Privacy Policy. Once you leave our site, our Privacy Policy no longer applies. We are not responsible for the privacy practices of these third-party sites, so we recommend reviewing their privacy statements to understand how they handle information.

Corporate Affiliates: Your information may be shared with our corporate affiliates adhering to this policy. Personal Data may also be shared with business partners, suppliers, and local distributors collaborating with us to provide products or services.

Business Transactions: In the event of a merger, acquisition, or asset sale involving SODETEL, your Personal Data may be transferred. Notice will be provided before the transfer, subjecting the data to a different Privacy Policy.

To protect you, others or us: This includes protecting our rights, property or the safety of our customers or employees; in cases involving danger of death or serious physical injury to any person or other emergencies; to protect against fraudulent malicious, abusive, unauthorized or unlawful use of our products and services (including providing a risk score to help deter fraud) and to protect our network, services, and users from such use. 

Disclosure for Legal Requirements: SODETEL may disclose your Personal Data under certain circumstances, such as when legally mandated or responding to valid requests by public authorities, such as a court or government agency.

With Your Consent or at Your Direction: We may share information for any other purposes disclosed during collection, pursuant to your consent, or as directed by you.

IV- Analytic Tools

Google Analytics: The Website may utilize a tool known as "Google Analytics" to gather data on Website usage. This tool records details like the frequency of user visits, the specific pages they navigate, and the websites they visited before arriving at our Website. The insights from Google Analytics aid in the upkeep and enhancement of the Website. It is important to note that the information obtained through Google Analytics is not merged with the Personal Data we collect.

V- Personal Data Transfers

Internal Transfers: Transfers within SODETEL are governed by an internal processing arrangement, guaranteeing that your Personal Data maintains an appropriate and consistent level of protection, regardless of the recipient.

External Transfers: In cases where your Personal Data is transferred outside of Lebanon, such as to third parties providing us with services.

We will generally take all reasonably necessary measures to ensure secure treatment in line with this Privacy Policy. No transfer of your Personal Data will occur to an organization or country unless adequate controls are in place, ensuring the security of your data and other personal information.

VI- Data Security

The security of your Personal Data will be ensured through safeguards suitable for the sensitivity level of the information. We implement all reasonable measures to prevent any loss or unauthorized use, access, or disclosure of your Personal Data.

It is important to note that transmitting and transferring data over the internet is not entirely secure. Despite our efforts to protect your personal information, we cannot guarantee its absolute security, particularly in instances of piracy, hacking, or theft.

VII- Data Retention Period

We will keep your Personal Data for the duration necessary or permissible based on the purpose(s) for which it was acquired. Our criteria for determining retention periods encompass: (i) the duration of our ongoing relationship with you; (ii) any legal obligations we are bound by; and (iii) the advisability of retention considering our legal position, including relevant statutes of limitations, ongoing litigation, or regulatory investigations.

VIII- Customer Access

Upon your request, we will provide information about the existence, utilization, and disclosure of your Personal Data and grant you access to it. You have the right to verify the accuracy and completeness of your Personal Data and can request amendments if necessary. However, there may be instances, as permitted by law, where certain information cannot be disclosed to you.

IX- Updates to this Privacy Policy

The Privacy Policy may undergo updates periodically, at our sole discretion, through the publication of a new privacy policy and the modification of the date at the top of this Privacy Policy page. We recommend checking for revisions to this Privacy Policy regularly. Changes will become effective upon their posting on this page.

X- Inquiries

For any inquiries regarding this Privacy Policy, please reach out to us by visiting the designated page on our website.