Privacy Notice – Start IoT
Our Privacy position
We value your privacy and take protection of your personal information very seriously. Therefore it is important for us that you understand how we collect data and process your personal information.
This privacy notice explains the information that is collected by Telenor Research through our ‘Start IoT’ offering. Telenor Research is Telenor ASA’s division for scientific research. It plays a key role in providing insight and competence that enable Telenor to become a software and data-driven company. The unit conducts research within key areas, including customer insight, data analytics, machine learning, innovation, digital services, new technologies and market dynamics.
Telenor Start IoT is set to stimulate innovation in Low-Power Wide-Area (LPWA) IoT in Norway, by providing startups, developers, students, hobbyists and tech enthusiasts an easy access to a limited, non-commercial Start IoT offering including developer kits, platform, and use of Telenor Norway’s mobile network (NB-IoT or LTE-M).
Data we collect and how we collect it
When you register as a user of Start IoT and order a devkit we will collect the following information directly from yourself:
- Your full name, email address, street address, city, postal code, company or organization you are linked to, your main area for IoT visions and objectives, the type of application you plan to implement, the development kit you wish to receive, your planned managed IoT cloud platform, your planned transfer protocol, your professional category, and eventual commercializing plans.
When your IoT device is connected to our network and you are using our services, we will also automatically collect the following:
- Information about the quality and use of your connectivity services. Usage data will typically be data volumes and data frequency transmitted over the NB-IoT or the LTE–M networks, and the use of the data enabler platform (MIC).
How and for what purposes we use your personal information
The majority of our processing is an integral part of our service and is essential to provide the functionality you have requested. We have outlined below how we use your personal information, as well as the legal basis under which it is processed.
To provide you with your service
We process your registration information as it is necessary for the performance of a contract. Without such information, we would not be able to register you as a participant in the research programme and provide you with the development kit for testing and experimentation.
To improve our connectivity service
We process data from your IoT device to our IoT platforms in order to manage our network and understand its usage. In this way, we can seek to review and improve the network and ensure we develop the service in a way that meets the expectations of our research participants. This processing is necessary for the delivery of the communication that Telenor is providing.
Research – individual analytics
Some supporting data processing, such as information regarding your intentions with the Start IoT research project, or your responses to our survey, are used for research purposes to help inform how we can continuously improve our service, as well as understand the needs and expectations of the participants. We process this data as it is necessary for the performance of the contract, in this case the agreement that you will participate in the research project.
We also process the data generated by your devices for the purposes of this research project to gather insights as to how IoT devices can be used and are being developed. This data is valuable in enabling us to understand user expectations and aims in the realm of IoT. We process this data as part of our legitimate interest.
Research – aggregated analytics
Telenor Research also collects and analyses aggregate data regarding the use of the Start IoT devices to gain insights to overall usage and create statistical management reports. When doing so, we will never display your identity in reports or presentations that are produced. We process this data as part of our legitimate interest, as it also enables us to review how the Start IoT project is successful in its aims.
Fraud prevention and security
We process your personal and traffic data in order to protect against and detect fraud and to protect against misuse of our networks. This may be, for example, letting you know when you are approaching the end of the 50MB of data traffic in Telenor Norway’s mobile network, following Start IoT Terms and Conditions.
How we share your personal data
There are three basic setups in which Telenor Research transfer personal data to third parties.
- Telenor Group – as a service provider in the Telenor Group, we collaborate with other Telenor companies.
- Telenor Mobile Network Operators – our Telenor mobile network operators provide the connectivity between your device and our IoT platforms.
- External vendors– we use external vendors to host services such as our registration portal, IoT forum and survey capabilities. These vendors are external processors to Telenor ASA, which means they are legally and contractually obligated to follow our instructions, maintain the data securely, delete data upon request, and so forth. We do not authorise them to use or disclose your personal information except in connection with providing their services.
Transfers to third countries
If applicable, any data transfers to a third-country, not pre-approved by the EU as having an adequate level of protection, must enter into standard data protection clauses adopted by the European Commission (“EU Model Clauses”).
How long we will store your personal data for
We’ll store and process your information for as long as we need to be able to deliver you the services you have requested, and in addition for as long as we are required to by law. If you finish using the service or are unwilling to continue it, we’ll keep some personal information for a reasonable period to allow us conducting research on how Start IoT is used and to improve it. We will also retain your registration information in case you decide to use the service again. As this is a research project, we expect to retain your personal data until the research project is closed.
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. The rights available to you depend on the legal basis for which we are processing your information.
If you wish to exercise a right, you may do so by contacting us at: firstname.lastname@example.org
- Right to be informed:
- The right to information is served by this privacy notice which contains all relevant information that you need to know about Telenor’s data processing activities.
- Right of access to your personal data
- You can ask for more detail regarding the data we collect about you and how we process it. You may also obtain a copy of the personal data we hold about you for the purposes of Start IoT.
- Right of rectification
- You have the right to have your personal data corrected if it is incorrect. You may do so by contacting the email address above.
- Right of restriction
- You have the right to ask us to restrict the processing of your personal data if you feel the data we hold on you is inaccurate or believe we shouldn’t be processing it.
- Right of objection
- You have the right to object to the processing of your personal data where we are processing for our legitimate interests.
- Right of deletion
- You can request that we erase the personal information we hold about you. Please note, however, that we cannot delete information that is required for us to fulfill our contract with you.
You also have the right to lodge a complaint with a supervisory authority.
c/o Telenor ASA
1360 Fornebu, Norway
You can also contact our Data Protection Officer using the above address