PTCL GROUP’S GENERAL PRIVACY NOTICE

This Notice provides information about:

- Personal information that PTCL Group may collect about you
- How PTCL Group may use your information
- The measure taken by PTCL Group to protect your information
- The retention of your information
- Your rights to your personal information

Personal Information

“Personal Information” may be the information/data that relates to you as a Customer/Subscriber and could be used to reasonably identify or locate subscriber; however, this data when anonymized/pseudonymized or converted in analytical data, which is incapable of identifying you as a person, is not considered the personal information. For the purpose of clarity, personal information may include combination of your name, father/mother name, address, photo,/logo, CNIC Number/Passport Number/Registration Number, CDRs, IP Address details, Social Media Accounts, Phone Number, Webiste, NTN Number, PIN Code, email address and details received from Government entities for SIM sale issuance and activation process; however, this personal information when anonymized/pseudonymized or converted in analytical data, which is incapable of identifying you as a person, is not considered the personal information.

Sensitive Personal Information

For the purposes of this Notice, PTCL Group would treat following information as sensitive personal data in accordance with the applicable regulatory regime and terms of the engagement:
(i) Passwords, (ii) financial data (bank account, credit card, debit card, or other payment instruments), (iii) health data (physical, behavioral, psychological, and mental health conditions or medical record), (iv) computerized national identity card or passport, (v) biometric data, (vi) genetic data, (vii) religious beliefs, (viii) criminal records, (ix) political affiliations, (x) caste or tribe, (xi) individual’s ethnicity, (xii) physical identifiable current location.

Non-Personal Information
In order to provide you quality services, PTCL Group, authorized business partners and third parties including PTCL’s subsidiaries, affiliates and associated companies may also collect, use and share certain information that are not meant to directly identify you as an individual. The non-personal information may include but not limited to connectivity sessions, serving tower location, web beacons, internet protocols (IP), operating system (OS), Web Browsers, aggregate logs and analytical data.

Customer Consent

“By sharing your information and/or subscribing and/or continue using our service(s)/ product(s)”, including (but not limited to) in writing, via click-through agreements, verbally, interactive voice responses, digital engagement’s through App(s) of PTCL Group, PTCL Group brands and PTCL Group presence on social media e.g. PTCL Group WhatsApp number, Facebook page etc., which among others, may be available on PTCL Group Website(s), PTCL Group app(s), or otherwise, pursuant to which we provide you PTCL Group products/services; “You acknowledge and consent (including but not limited to cookies) that PTCL Group may responsibly collect and use your information as well as share/receive your information and analytical data with/from its authorized business partners and third parties including PTCL’s subsidiaries, affiliates & associated companies and cloud-based authorized business partners” for the commercial purpose of understanding, designing innovative products and enhancing your experience as a user of PTCL Group app(s), website(s) and products/services etc.

Collection and Storing of Information

1. To provide you with the best possible services, PTCL Group, authorized business partners and third parties including PTCL Group’s subsidiaries, affiliates, and associated companies (e.g. franchises, managed service providers and authorized data processors and controllers etc.), would responsibly collect and store your information for a number of legal, regulatory and business requirements. The collection may include information pertaining to:

i. Verification of your identity, including your Name, Social Media ID, CNIC, Date of Birth, Address, and other details such as Phone Number and Email when you purchase a PTCL Group’s Mobile SIM card, connection, port-in to PTCL Group network, subscribe and use PTCL Group products/services/websites or otherwise interact with PTCL Group in any manner.
ii. Transactions and usage details, such as logs of voice/data and value-added services, location data, and subscription and billing of our products and services;
iii. Response data related your request for service or assistance; and
iv. Any other information that you have provided to PTCL Group, authorized business partners and third parties including PTCL Group’s subsidiaries, affiliates, and associated companies for subscribing and/or continue using our service(s)/ product(s).

2. Your information will primarily be stored in electronic form. However, certain data can also be stored in physical form. We will ensure to implement adequate organizational and technical measures to protect your information and privacy.

Use of Information

3. PTCL Group, authorized business partners and third parties including PTCL Group Companies subsidiaries, affiliates, and associated companies may use some or all of the above information in-house and/or via cloud-based solutions with or without artificial intelligence capabilities for legitimate commercial purposes such as internal assessment, due diligence, efficient handling, managing, mapping, storing, processing, protecting, transmitting, performing analytics and market research, primarily for improving product and services and operational excellence purposes.

4. PTCL Group, authorized business partners and third parties including PTCL Group Companies subsidiaries, affiliates, and associated companies may transfer/solicit your information to/from any other entity only in case it is necessary for providing services to you. This may include but not limited to sharing of aggregated information with them to test and trial, understand our operational requirements and consequently, optimize services for you.

5. PTCL Group, authorized business partners and third parties including PTCL Group Companies subsidiaries, affiliates, and associated companies will also use your information to ensure compliance to legal and regulatory requirements for (i) detection and prevention of fraud, spamming, grey traffic, non-compliant devices and other such prohibitive activities, including violation of our terms & conditions, and (ii) to ensure compliance with the other applicable laws and orders received from the courts and/or other competent authorities.

Disclosure and Sharing of Information

6. PTCL Group does not sell or rent information to any unauthorized third party that could result in invasion of your privacy.

7. PTCL Group companies ensure implementation of adequate organizational and technical measures to protect your information and privacy; however, your information may be shared/monetized as described in this privacy note e.g., in the following circumstances:

Your request
i. When you request us to share your information with a third-party (e.g., server or website or apps), PTCL Group, authorized business partners and third parties including PTCL Group Companies’ subsidiaries, affiliates, and associated companies may perform verification and charge a reasonable fee before providing such access.

Law enforcement agencies and court orders
ii. PTCL Group, authorized business partners and third parties including PTCL Group Companies’ subsidiaries, affiliates, and associated companies may share your personal information to comply with the court orders and with the competent authorities or Law Enforcement Agencies (LEAs) for the purposes of verification of your identity, detection and investigation of crimes, cyber incidents and prosecution, among other things, as and when required under the relevant law(s).

Business Requirements
iii. PTCL Group, authorized business partners and third parties including PTCL Group Companies' subsidiaries, affiliates, and associated companies may use/share/receive your information, usage data and other non-telecom data (call center records, App logs etc.) in the form of anonymized/pseudonymized data, transcripts, or in the form of analytical data, without identifying you by linking the information with anonymized ID (e.g. MSISDNs or Email or registration ID etc.) to (i) understand how to deliver you improved connectivity and design innovative products & solutions, customer service and complaint handling or (ii) tailor our product and services for you, (iii) to observe patterns and measure traffic on our network, (iv) to provide innovative next generation services e.g. location based services, individually or in collaboration with the authorized local and international business partners, including cloud based solution providers.

iv. PTCL Group companies may transfer user information and CDRs/IPDRs pertaining to foreign subscribers on operator's network while roaming to authorized person/place outside Pakistan.

Emergency Services
v. PTCL Group, authorized business partners and third parties including PTCL Group Companies' subsidiaries, affiliates, and associated companies may share your information for emergency services, including but not limited to your approximate location. We may also be required to disclose your information by the Authorities (such as Pakistan Telecommunication Authority-PTA) or where it is deemed necessary in the interest of public or national security.

Security, Access, and Retention
8. PTCL Group companies have in place appropriate security procedures in line with applicable laws, standards covering technical, operational, managerial and physical security controls to safeguard your information from unauthorized access, breach and disclosure. However, PTCL Group companies will not be liable for any discontinuation of service, loss or data breach for reasons outside PTCL Group’s control such as hacking, social engineering, cyber terrorism, espionage by third parties, or any event of force majeure at the end of PTCL Group companies, authorized business partners and third parties including PTCL Group Companies' subsidiaries, affiliates, and associated companies such as sabotage, fire, flood, explosion, acts of God, civil commotion, strikes and industrial action of any kind, riots, insurrection, war, act of Government etc.

9. Authorized officials of PTCL Group companies, authorized business partners and third parties including PTCL Group Companies' subsidiaries, affiliates, and associated companies can access your information on need-only basis, for the provisioning of services, in accordance with the PTCL Group’s compliance provisions, which obligate them to take adequate measures to protect the privacy of your information.

10. As per the license conditions, PTCL Group companies are required to store subscribers’ information, specifically their call detail record (CDRs) , IP Detail Records (IPDRs) or Event Record for a prescribed period of time to provide optimum telecommunication services within the scope of its license, which comprises the calling and the called number, date, duration, time, IMEI, URL, IP Address, location made on our network as per regulatory requirement.

11. Notwithstanding the above retention procedures, PTCL Group companies, authorized business partners and third parties including PTCL Group Companies' subsidiaries, affiliates, and associated companies may retain your information to process for legitimate purposes, and only for as long as it is necessary to achieve those purposes.

Your Rights
12. Following are your rights related to your data with PTCL Group companies:

i. You have the right to withdraw your consent. You can withdraw your consent to use, process, or share your personal information as stated in this Notice, subject to reasonable processing time, development requirements and the limitation that the information is needed to provide services of PTCL Group companies to you.

ii. You have the right to access your information. If you are Customer/Subscriber of PTCL Group companies, you can request a copy of your personal data that may be made on PTCL Group’s relevant app or by visiting PTCL Group designated customer care centers.

iii. You have the right to correct your information. PTCL Group companies takes adequate measures to ensure that your information we hold is accurately recorded as provided by you. You are responsible for integrity of provided information; and you may request us to correct and/or update your information, if it is not accurate. You can request correction or updating the information held by PTCL Group companies by contacting us in writing.

iv. You have the right to opt out of marketing messages. PTCL Group companies have been offering the business communication services during the authorized timings of the day for the reliable entities after due diligence whereby such entities can send promotional/marketing SMS to you using PTCL Group companies/ partners platform (alphanumeric IDs-usually brand names) or other technical solutions of entities (Numeric Short Codes). If you no longer wish to receive marketing messages on network(s) of PTCL Group companies from such entities, you may choose to opt out. However, PTCL Group companies retain the right to send essential messages for the promotion/information w.r.t. delivery/improvements in products, services and portfolio.

In case of genuine privacy concerns faced by the user or call center agents, PTCL Group may take necessary measures. In the case of Pak Telecom Mobile Limited (“PTML”), you may opt out at any time using the Do Not Call Register (DNCR) facility. The promotional messages from normal cellular number (e.g., 033X-XXXXXXX) cannot be completely blocked but curtailed from the reported numbers, once you report it to PTCL Group by sending the cellular number and messaged to Short Code-9000 for further scrutiny and action.

v. You have the right to request erasure. You have the right to request to erase your personal information that we hold in case you are no longer subscriber of PTCL Group companies; however, authorized entities reserve the right to retain your information for processing as long as it is necessary or as required under the applicable laws. Please note, if your contract with PTCL Group has been terminated, we may still process your personal data.

13. You may note that exercising your above-mentioned rights such as erasure of certain information or withdrawal of consent may lead to cancellation of your subscription or registration with us or affect quality and access to our services.

14. If you would like to exercise any of the above rights:
a. Let us have enough information to identify and verify by you.
b. Let us know the information to which your request relates.

Changes to this Notice

15. The Notice should be read in conjunction with the general terms and conditions (e.g. General Terms and Conditions applicable at the time of SIM Sale/Purchase through BVS) as well as the other products/services and app(s)/website(s) specific terms and conditions and privacy policies. PTCL Group has the discretion to update this Notice at any time based on the changes in business, legal and regulatory requirement and made available to you online. PTCL Group companies will make efforts to communicate about significant changes to this Notice from time to time through any suitable mode such as Web-ticker or In-App notification or SMS or email or social media/digital engagement platforms/Apps.

16. You acknowledge and agree that it is your responsibility to review this Notice periodically and become aware of modifications. Hence, you are requested to visit PTCL Group companies’ relevant Website/Apps on a regular basis for updates and changes in privacy related provisions.

Contact Information

17. If you have a question, concern or complaint about this privacy Notice or handling of your information or how we are processing your personal data, you can access PTCL Group’s relevant Website/Apps for contacting us.