1.1 We, Telenor Myanmar Limited (“Telenor Myanmar”), value your privacy and take the protection of your personal information seriously. Therefore, it is important to us that you understand how we collect and process personal information about you.
2.1 Telenor Myanmar collects personal information about you, and we will process it in accordance with the following key principles:
4.1 We collect personal information about you in three ways:
4.1.1 information that you provide to us, for instance when you subscribe for our services;
4.1.2 information that we collect automatically when you use our services;
4.1.3 information that we may obtain about you from third parties.
We explain below what personal information we typically collect about you in these three ways.
4.1.1 Information that you provide to us, for instance when you subscribe for our services
(a) When you sign up for one of our services or when you receive one of our services, you may provide us with certain personal information. The types of such information may include:
4.1.2 Information that we collect automatically when you use our services
(a) When you use our services, we will automatically collect certain information about you and your device. The information that we collect automatically will vary depending on the service and the device that you are using to access and/or benefit from our service.
(b) We will collect information about the type of device and software that you use to access our services, for instance whether you use an iPhone or Samsung phone, and what operating system is running on your device.
(c) When you use our telecommunication services, we automatically collect information about your communications, including:
(d) When you visit one of our websites and/or use one of our online services, we collect information concerning your terminal equipment or device and your use of our online services. Such information usually includes:
(e) When you visit one of our websites and/or use one of our online services we may also collect the following information:
(f) The information that we collect automatically when you use our websites and/or online services is collected through cookies and similar technologies.
4.1.3 Information that we may obtain about you from third parties
(a) We collect information when we link our digital services with the services of third parties, for instance when you have given us your consent and/or where otherwise lawfully permitted and we integrate our service with social networks such as Facebook, Instagram or Twitter. Such information usually includes:
4.2 For some of our services, for example financial, music or astrology services, it may be necessary to collect additional personal information about you, and/or collect personal information in other ways and/or for purposes that are specific to that service. In such cases, our relevant Terms of Service explain the service-specific personal information processing activities. When you subscribe for one of our services, you will have the opportunity to review the Terms of Service and will be asked to indicate that you accept them.
5.1 We collect information about your location in the following circumstances:
6.1 We sometimes collect personal information about you from third parties, in connection with services that we provide to you. We will do this only when you have given us your consent or when we are required or allowed to do so under applicable law.
6.2 For instance, when we integrate our digital services with third-party services. We also work closely with third parties (including, for example, business partners, sub-contractors, payment and delivery services, advertising networks, analytics providers, search information providers) and may receive information about you from them.
6.3 When you use your social media credentials to login to or otherwise interact with a Telenor Myanmar webpage or offer, we may collect information about your social media profile, such as your interests, “likes” and friends list. You can control this data collection via the options made available by your social media service provider in your social media account.
6.4 We may combine the personal information that we receive from such other sources with personal information you give to us and information we automatically collect about you.
7.1 We use your personal information to provide our services to you, support and improve our services, to provide more personalised and relevant services and to send you communications about the services we provide to you.
7.2 We may also process your personal information to contact you from time to time with exciting news and offers, as further explained in the section on How we use your personal information for marketing purposes below.
7.3 We also use your personal information to:
7.4 In many cases we aggregate and/or anonymize your personal information to an extent that it no longer identifies you. We process such aggregated and/or anonymized data for various purposes, including for research purposes and to help us understand our customers, their requirements and how they use our services so that we can improve our services to provide a better customer experience or create new services.
8.2 We use partners and service providers for a variety of business purposes such as to help us offer, provide, bill, repair, and improve our services. In such cases it may be necessary to disclose your personal information to third parties for these purposes. We will typically share your personal information with third parties when:
8.3 When we share your personal information, we will take steps to ensure that the recipient will protect your privacy, keep your personal information secure under our instruction and process it in accordance with applicable law. Such measures may include entering into appropriate contracts with third parties. Your personal information may be stored in our data centers, or in servers and locations outside of Myanmar.
8.4 We will not sell the personal information that we process about you to third parties without your consent.
9.1 We would like to increase the value you get from being a Telenor customer and provide you with more relevant information about products and services. Therefore, with your permission, we and selected third parties may use your personal information to send you marketing communications, information about products and services based on your preferences, subscribe and interests. You have choice and can control how we use your personal information for marketing purposes. This means that we will obtain your consent before using your personal information for marketing purposes, when we are required by law to do this. You may at any time opt-out of receiving such marketing messages from us. Please contact our call center (dial 979 for Telenor Myanmar customers) or visit our Telenor website www.telenor.com.mm for more information.
9.2 Please note that if you opt out, we will stop sending you marketing communications, but we will continue sending you communications that relate to the services we provide to you.
(a) A cookie is a text file containing small amounts of information that a website can send to your browser, which may then be stored on your computer as an anonymous tag that identifies your computer but not you.
(c) For most types of cookies, including those we use for advertising purposes, you have the right to tell us that you do not want us to use them when you visit our websites. If you opt out of cookies that we use for advertising purposes, we will stop using cookies, but please note that this does not mean that you will not see ads when you visit our websites, it only means that the ads that you will see will not be tailored to your interests.
(d) If you want to know more about cookies, check out www.aboutcookies.org.
10.3 Pixel tags
(a) A pixel tag, also known as a clear gif or web beacon, is an invisible tag which we may place on certain pages of our website. When you access these pages, pixel tags generate a generic notice of that visit. Usually, they work in conjunction with cookies and record when a computer visits a page. If you turn off cookies the pixel tag will simply detect an anonymous website visit.
(b) A ‘smart pixel’ is a tiny graphics file containing a unique identifier that is embedded within an e-mail. We may use smart pixels in our email campaigns or newsletters. They allow us to track whether the e-mail was opened successfully and to record certain information about the activities of the recipient(s). Users who have set their e-mail client software to refuse automatic downloads of images within the e-mails they receive will not be served our smart pixel unless they actively choose to download the images within the e-mail (and many e-mail clients are set by default to refuse automatic image downloads).
11.1 We will normally not keep your personal information for longer than is necessary for the purposes for which we collect and process it, except when we are required by applicable law and our obligation under Operation License to keep it for longer than that.
12.2 We will put in place appropriate technical and organisational security measures to protect your personal information from unauthorised access, collection, use, disclosure, copying, modification or disposal. Our specialist security teams review these security measures regularly.
12.3 When we use service providers or other data processors to process personal information on our behalf, we require them to follow our instructions and apply appropriate security measures to protect the personal information they process on our behalf.
13.1 For the purpose of develop and extend our telecommunication services, we may transfer your personal information to countries outside Myanmar. We may transfer customer information as permitted by applicable Laws and other regulatory framework. Every time when we export the Personal information to outside of Myanmar, we ensure that our Partner or Telenor Group will implement appropriate measures to protect the personal information that they receive, and only process such information in accordance with our instructions.
13.2 We also take the appropriate measures and cover with contract obligation to comply with applicable laws for such data exports.
14.1 You have certain rights in relation to the personal information that we hold about you. We have in place measures and processes to enable you to exercise your rights and ensure that we can fulfil your requests concerning the personal information that we hold about you.
14.2 We have listed below a list of your privacy rights: -
(a) Right to access your information: You can request a copy of the personal information that we hold about you any time by contacting us at firstname.lastname@example.org, or access most of the information directly through your online account. Before we are able to respond to your request, we may ask you some security questions to prove your identity, conduct verification exercise and to provide further details about your request. We will respond to your request within an appropriate timeframe and, in any event, within the timescales and subject to payment of the fees prescribed by applicable laws;
(b) Right to correct personal data: You can request to correct or amend your personal information that is inaccurate by contacting us, or by accessing your online account to correct personal information relating to billing address and email address. However, it is your responsibility to ensure that you provide us true, accurate and complete information, and that you keep information on your online account up to date;
(c) It is your responsibility to provide us with accurate and complete information, and to update us when such information changes, so that we can continue to provide you with the best possible customer experience.
15.1 As a general rule, our services are not aimed at children under the age of 13, and generally we do not intentionally collect personal information about them. If we become aware that we have collected information about children under the age of 13 which we should not have been collecting, we will take steps to delete the information as soon as possible, except where we are required by law to keep it.
15.2 However, some services may be designed for use by children under the age of 13. We will let you know in these services and the applicable Terms of Service exactly how we are protecting the relevant data and will make sure each of these services complies with our guiding principles.
16.1 Our websites may contain links to third party websites, and some of our digital services provide you with access to third party services (such as social networks).
16.2 We have no control over how third-party websites and services process your personal information. We do not review third party websites and services, and we are not responsible for such third-party websites and services or their privacy practices. Please read the privacy policies of any third-party websites or services that you access from our websites or services.