Effective date: January 1st, 2022

Data controller Celltrum Ltd (later Netradar, contact details: Tekniikantie 12, 02150 Espoo, Finland, contact person: Jukka Manner, jukka.manner@netradar.com) is committed to enhancing privacy and complies with data protection laws applicable in Finland and the EU General Data Protection Regulation (GDPR).

1. Why Do We Collect Data?

Netradar vision is to increase customer satisfaction by enhancing mobile network quality and connectivity.

We will achieve this by helping mobile operators to make optimal and fact-based network investments. We work with selected mobile application developers to enhance their services. We strive for increased transparency between users, application developers and mobile operators what comes to the quality of internet connectivity.

We empower you to track and benchmark the quality of internet connectivity based on your unique usage pattern and we collect this data for drawing the data coverage maps and preparing various statistics and analyses to you and our partners.

2. How Do We Collect Data?

We collect data through use of Netradar software (later Service) running in your device.

If you do not allow collection of your data, you will no longer have access to our Service as we will not have the data required to run the Service.

You can modify the positioning settings of your device from the device settings by changing or disabling positioning methods or location servers or modify the accuracy of your location data. If you disable positioning, this will have severe impact on our capability to deliver the Service to you and our capability to help various stake holders to enable high-speed mobile internet connectivity.

3. What Data Do We Collect?

We collect the following data:

• • • Date and time
    • Device data: Device vendor, model and operating system version
    • Operator data: Network and SIM-card operator
    • Location data: Location information from GPS or network-based positioning
    • Performance data: Bit rate of sending and receiving data, network maximum transfer unit and latency
    • Usage data: Battery usage, data usage and device orientation
    • Application data: List of applications with network activity, IPv4 address (only 24 significant bits), IPv6 address (only 96 significant bits), technical details on application connectivity
    • Network data: Wireless network technology (like UMTS, LTE etc.), radio type (wifi or cellular), base station identifier, SSID and BSSID, detailed network technical information (signal strength, signal power, receive power, channel quality, bit error rate, link speed, frequency used etc.) and IPv4 address (only 24 significant bits)

The only collected personal data where you may be identifiable is location data. We do not collect your name, mobile phone number, SIM-card details (IMSI) or the unique mobile device identifier (IMEI). 

Depending on your positioning settings and your use of location services of other service providers your device may connect to service providers’ servers, which are not controlled or operated by Netradar. We recommend that you check the privacy policies of such service providers to understand how they process your location data.

4. What is the Basis for the Collection?

The basis for the collection of data is the legitimate interest of Netradar based on the customer relationship with you. The collection may also be based on the performance of the contract or your consent.

5. How Do We Protect and Store the Data?

We take appropriate steps to address both physical and online security, risk of data loss or breach and other such risks, always taking into consideration the nature of the data being processed. We limit access to our database to authorized persons having a justified need to access such information.

Netradar data shall be stored with European Union.

6. How the Data Will be Used?

Netradar uses the data we collect to operate our business and provide you the Service, which includes using data to improve our products and personalize your experiences as well as to share data and analysis to enhance people’s everyday mobile internet connectivity. 

All the communication related to the Service – security updates and product information – shall be done through our web-site or posted within the Application. We do not use the data for direct marketing purposes.

7. Who It Will be Shared With?

Data will be shared with our Partners – Mobile operators, Telecom regulators, Mobile device vendors, Mobile network vendors or Application developers – for enhancing people’s everyday mobile internet connectivity as mentioned in the section “Why Do We Collect Data?”.

8. Data Retention

The periods for which we keep your information depend on the purpose for which your information was collected and the use to which it is put. We will not keep your personal information for longer than necessary for our business purposes or for legal requirements.

After period of five years (5) data will be kept only at aggregated level.

9. Your Rights

You have several rights in relation to collection and usage of your data. You have right to:

• • • Request to know what information has been collected and stored
    • Request correction on this data
    • Object processing on grounds relating to your particular situation
    • Request to limit the usage of the data if in your opinion i) the data is incorrect, ii) processing is unlawful and you oppose the removal of data, iii) we do not need data, but you need it to present or defend a claim or iv) you have objected the processing and it is not yet established whether our interests override your interests.
    • Request to be forgotten and removal of all the data
    • Request transfer of your information that you have provided to us to another provider
    • Withdraw your consent for processing at any time without affecting the lawfulness of processing based on consent before withdrawal

Please proceed with these requests as follows.

• • • Click “Privacy” – link in your Netradar application or follow the link “How Netradar uses data when you use our partners’ apps” which can be found from our Partner App privacy policy
    • This will lead you into a web page with a pseudonymous installation identification code
    • Send your request along with this code to privacy@netradar.com
    • Where permitted by local law, we may reject requests that are unfounded or excessive
    • We will respond to your requests in a reasonable timeframe. If you have requested to be forgotten and your data has been removed, you will no longer have access to our Service as we no longer hold the data required to run the Service.

10. Contact Details of Data Protection Officer

Netradar Data Protection Officer is Jukka Manner. The Data Protection Officer may be contacted from one of the following email addressed: privacy@netradar.com or jukka.manner@netradar.com.

If you have any queries or complaints about our compliance with this Privacy Policy, or if you would like to make any recommendations or comments to improve the quality of our Privacy Policy, please email us at privacy@netradar.com.

11. Changes to Our Privacy Policy

We may update this Privacy Statement from time to time. If we modify our Privacy Statement, we will post the revised version at www.netradar.com, with an updated revision date.