Privacy Policy

This Privacy Policy ("Policy") describes how TELCOMET LTD ("Company", "we", "us", or "our") processes information, technical data and personal data in connection with the provision of telecommunications infrastructure, VoIP routing, SIP connectivity, call handling, messaging functionality, APIs, call recording, AI-assisted processing, cloud communications functionality and related technology services (collectively, the "Services").

The Company operates primarily as a carrier-grade infrastructure and technology provider in a business-to-business (B2B), wholesale and/or carrier-to-carrier capacity.

1. Regulatory Positioning and Service Model

1.1 Infrastructure and Technical Intermediary Status

The Company operates exclusively or primarily as:

• a technology provider;
• routing intermediary;
• infrastructure operator;
• communication enablement platform;
• carrier-grade technical intermediary.

Unless expressly agreed otherwise in writing, the Company does not act as:

• a retail telecommunications operator;
• public telecom utility;
• electronic communications provider to consumers;
• marketing agency;
• sender of communications;
• publisher;
• broadcaster;
• content provider;
• data broker;
• communication originator;
• controller of customer campaigns;
• emergency communications provider.

1.2 No Initiation or Control of Communications

The Company does not independently:

• initiate communications;
• generate content;
• select recipients;
• determine routing objectives;
• supervise campaigns;
• approve communications;
• verify message legality;
• verify consent collection;
• monitor customer databases;
• determine lawful basis for processing;
• verify customer identity representations;
• review marketing practices.

The Services operate as customer-configured infrastructure and technical enablement tools controlled by users and/or their downstream customers.

1.3 Exclusive Customer Responsibility

The Customer remains solely, independently and exclusively responsible for:

• all traffic transmitted through the Services;
• legality of communications;
• legality of content;
• legality of routing;
• telecommunications compliance;
• spam compliance;
• anti-phishing compliance;
• anti-fraud compliance;
• call recording legality;
• lawful interception obligations;
• biometric data compliance;
• AI-related compliance obligations;
• consent collection;
• opt-out management;
• sender identification;
• recipient targeting;
• downstream traffic sources;
• campaign management;
• end-user compliance;
• reseller compliance;
• affiliate compliance;
• subcontractor compliance;
• compliance of connected platforms and integrations.

This responsibility applies under:

• UK laws;
• EU laws;
• US federal laws;
• US state laws;
• destination-country laws;
• local telecom regulations;
• anti-spam frameworks;
• ePrivacy laws;
• GDPR-equivalent laws;
• consumer protection laws;
• sanctions regimes;
• carrier requirements;
• industry rules;
• provider requirements;
• self-regulatory standards.

1.4 No Legal or Regulatory Advice

The Company does not provide legal, regulatory or compliance advice regarding:

• telecom licensing;
• communications legality;
• consent requirements;
• call recording restrictions;
• interception laws;
• spam restrictions;
• A2P messaging laws;
• marketing regulations;
• biometric processing;
• AI governance;
• cross-border communications;
• sanctions exposure.

Customers must independently assess all legal and regulatory obligations applicable to their activities.

2. Data Protection Philosophy

2.1 Operational Principles

The Company applies commercially reasonable operational principles including:

• data minimization;
• least-privilege access;
• privacy-by-design;
• infrastructure segregation;
• limited retention;
• restricted visibility;
• operational compartmentalization.

2.2 Infrastructure Architecture

Infrastructure may be designed to:

• avoid unnecessary centralization;
• reduce persistent traceability;
• minimize unnecessary retention;
• segregate billing and routing systems;
• distribute processing geographically;
• reduce exposure of sensitive communications.

2.3 No Advertising Monetization

The Company does not intentionally engage in:

• behavioral advertising;
• advertising profiling;
• resale of personal data;
• cross-platform consumer profiling;
• data brokerage activities.

3. Categories of Data Processed

3.1 Account and Business Information

The Company may process:

• account identifiers;
• company names;
• contractual contacts;
• authentication credentials;
• support communications;
• administrative records.

The Company attempts to minimize collection of direct personal identity information where business identification is sufficient.

3.2 Billing and Financial Information

The Company may process:

• invoices;
• prepaid balances;
• transaction history;
• payment confirmations;
• tax records;
• anti-fraud information;
• financial compliance records.

3.3 Communication Metadata

Depending on Service configuration, the Company may process:

• timestamps;
• routing data;
• SIP headers;
• signaling data;
• source and destination identifiers;
• connection records;
• delivery reports;
• call duration;
• network metadata;
• API request logs.

3.4 Communication Content

Depending on customer-enabled functionality, the Company may process:

• voice communications;
• audio streams;
• call recordings;
• voicemail;
• messaging content;
• SMS content;
• transcripts;
• AI-generated summaries;
• AI-generated classifications;
• speech analytics outputs.

3.5 Technical and Infrastructure Data

The Company may process:

• IP addresses;
• device information;
• API interaction logs;
• infrastructure diagnostics;
• security events;
• system logs;
• authentication logs;
• traffic risk indicators;
• fraud detection signals.

4. Purposes of Processing

The Company processes information solely for legitimate operational purposes including:

• telecom routing;
• communication enablement;
• infrastructure functionality;
• API execution;
• billing operations;
• fraud prevention;
• abuse detection;
• security monitoring;
• troubleshooting;
• system diagnostics;
• infrastructure optimization;
• compliance obligations;
• enforcement of policies;
• dispute handling;
• service protection.

The Company does not intentionally process personal data for unrelated commercial exploitation purposes.

5. Fraud Prevention, Security and Traffic Control

5.1 Fraud and Abuse Detection

The Company may use automated, AI-assisted and manual mechanisms to detect:

• artificial traffic;
• spam campaigns;
• SMS pumping;
• wangiri fraud;
• spoofing;
• phishing activity;
• SIM box activity;
• bypass routing;
• signaling anomalies;
• fraud rings;
• unusual traffic spikes;
• abnormal routing behavior;
• suspicious messaging activity;
• unauthorized access;
• compromised accounts;
• prohibited content;
• sanctions-related risks.

5.2 Broad Enforcement Rights

The Company reserves the unrestricted right, at its sole discretion and without prior notice, to:

• suspend Services;
• block traffic;
• restrict functionality;
• terminate accounts;
• preserve data;
• disclose data;
• investigate activity;
• remove content;
• limit routing;
• freeze balances;
• reject traffic;
• apply rate limits;
• disable integrations.

Such actions may be taken where the Company reasonably believes this is necessary for:

• fraud prevention;
• telecom compliance;
• security;
• abuse mitigation;
• sanctions compliance;
• infrastructure protection;
• provider requirements;
• legal obligations;
• reputational protection;
• risk mitigation.

5.3 No Monitoring Obligation

The Company has no obligation to actively monitor communications, recordings, content, traffic, customer behavior or user activity.

The Company shall not be deemed to possess knowledge of unlawful activity solely because such activity passes through, is transmitted via, or is stored within the Services.

6. Legal Bases for Processing

Processing may be based on:

• contractual necessity;
• legitimate interests;
• legal obligations;
• consent where applicable.

Legitimate interests include:

• infrastructure security;
• fraud prevention;
• abuse mitigation;
• network reliability;
• system integrity;
• protection of business operations;
• enforcement of contractual rights.

7. Data Retention, Deletion and Availability

7.1 Retention Principles

Data may be retained only for periods reasonably necessary for:

• operational purposes;
• infrastructure functionality;
• legal compliance;
• telecom compliance;
• fraud prevention;
• dispute resolution;
• provider requirements;
• security purposes.

7.2 Flexible Retention Periods

Retention periods may vary depending on:

• legal obligations;
• provider rules;
• technical limitations;
• infrastructure requirements;
• telecom standards;
• fraud investigations;
• security risks;
• operational needs.

7.3 No Preservation Obligation

The Company does not guarantee:

• preservation of data;
• recoverability of recordings;
• integrity of communications;
• successful delivery;
• uninterrupted storage;
• permanent availability;
• backup continuity.

Users remain solely responsible for:

• independent backups;
• archival requirements;
• legal retention obligations;
• export of data.

7.4 Deletion Rights

The Company may, at its discretion and without liability:

• delete data;
• anonymize data;
• aggregate data;
• irreversibly transform data;
• remove inactive content;
• purge logs;
• restrict access to stored information.

8. International Data Transfers

Data may be processed, routed, cached, mirrored or temporarily stored across multiple jurisdictions and infrastructure regions.

Processing may involve:

• telecom carriers;
• cloud providers;
• CDN providers;
• routing vendors;
• AI providers;
• external infrastructure partners.

Transfers may rely on:

• Standard Contractual Clauses;
• contractual safeguards;
• adequacy mechanisms;
• provider compliance frameworks.

The Company does not guarantee that data will remain within any specific jurisdiction unless expressly agreed in writing.

9. Call Recording, AI Processing and Consent Disclaimer

9.1 Recording and Monitoring Functionality

The Services may include functionality enabling:

• call recording;
• monitoring;
• interception;
• transcription;
• speech analytics;
• AI-assisted processing;
• AI-generated summaries;
• automated classifications.

9.2 Customer Compliance Responsibility

The Company:

• does not obtain consent on behalf of users;
• does not verify legality of recordings;
• does not determine applicable consent standards;
• does not monitor customer compliance;
• does not provide legal assessment of recording laws.

Users remain solely responsible for compliance with all laws relating to:

• recording;
• monitoring;
• interception;
• storage;
• transcription;
• biometric identifiers;
• voiceprints;
• AI processing;
• communications monitoring.

9.3 AI Disclaimer

AI-generated outputs may contain:

• inaccuracies;
• omissions;
• hallucinations;
• incorrect interpretations;
• incomplete summaries;
• false classifications.

The Company does not guarantee the:

• accuracy;
• reliability;
• completeness;
• legal sufficiency;
• evidentiary value

of AI-generated outputs. Users assume all risks associated with reliance on AI-generated outputs.

10. Third-Party Infrastructure Disclaimer

The Services may depend on third-party:

• telecom carriers;
• cloud infrastructure;
• hosting providers;
• AI vendors;
• payment providers;
• SMS aggregators;
• routing partners;
• internet providers;
• CDN operators.

The Company shall not be responsible for:

• outages;
• interruptions;
• filtering;
• carrier blocking;
• spam classification;
• delays;
• routing failures;
• third-party security incidents;
• provider restrictions;
• telecom disruptions;
• external infrastructure failures.

11. Data Sharing and Disclosure

The Company may disclose information:

• to infrastructure providers;
• telecom carriers;
• payment providers;
• fraud prevention partners;
• regulators;
• competent authorities;
• law enforcement;
• external advisors;
• insurers;
• auditors.

Disclosure may occur where reasonably necessary for:

• legal compliance;
• fraud prevention;
• enforcement of policies;
• infrastructure protection;
• dispute resolution;
• telecom compliance;
• sanctions compliance;
• business protection.

12. Security Disclaimer

The Company implements commercially reasonable technical and organizational measures including:

• encryption;
• segmentation;
• access controls;
• monitoring systems;
• logging mechanisms;
• security reviews.

However:

• no infrastructure is fully secure;
• no transmission method is fully secure;
• no storage system is immune from compromise.

The Company does not guarantee that unauthorized access, cyberattacks, interception, corruption, outages, service interruptions or security incidents will never occur.

13. High-Risk Use Disclaimer

The Services are not intended for:

• emergency communications;
• life-critical systems;
• public safety infrastructure;
• healthcare emergency services;
• mission-critical operations;
• military operations;
• aviation safety systems;
• nuclear facilities.

Users assume all risks associated with such use.

14. Data Subject Rights

Where applicable under law, users may request:

• access;
• correction;
• deletion;
• restriction;
• objection.

The Company may:

• require verification;
• deny requests where legally permitted;
• delay responses where reasonably necessary;
• retain information where required for legal or security reasons.

Certain rights may be restricted due to:

• fraud prevention;
• telecom compliance;
• security concerns;
• provider obligations;
• legitimate interests;
• ongoing investigations.

15. Limitation of Liability

To the maximum extent permitted by law, the Company disclaims liability for:

• unlawful customer conduct;
• spam campaigns;
• phishing activity;
• telecom violations;
• marketing violations;
• downstream customer activity;
• consent failures;
• recording violations;
• interception claims;
• biometric claims;
• AI inaccuracies;
• loss of recordings;
• message filtering;
• carrier blocking;
• routing failures;
• delivery failures;
• service interruptions;
• data corruption;
• data loss;
• third-party outages;
• sanctions exposure;
• fraud losses;
• unauthorized traffic;
• indirect damages;
• consequential damages;
• punitive damages;
• reputational harm;
• business interruption;
• lost revenue;
• lost profits;
• anticipated savings.

To the fullest extent permitted by law, the Services are provided strictly on an "as is" and "as available" basis without warranties of any kind, whether express, implied or statutory.

The Company acts solely as a technical intermediary and infrastructure provider.

16. Incident Response

The Company maintains internal incident response procedures and reserves the right to take any action reasonably necessary to:

• investigate incidents;
• preserve infrastructure integrity;
• suspend activity;
• restrict traffic;
• cooperate with authorities;
• mitigate risks;
• preserve evidence.

The Company may prioritize infrastructure protection and security considerations over service continuity.

17. Changes to This Policy

The Company may modify this Policy at any time and without prior notice where reasonably necessary for:

• legal compliance;
• regulatory requirements;
• fraud prevention;
• infrastructure protection;
• operational needs;
• security reasons.

Updated versions may be published via the website, platform or Services.

Continued use of the Services constitutes acknowledgment and acceptance of the updated Policy.

18. Contact Information

Legal Entity: TELCOMET LTD
Registered Office: 86-90 Paul Street London EC2A 4NE
Contact Email: support@telcomet.net

19. Final Provisions

By using the Services, users acknowledge and agree that:

• the Company provides infrastructure and technical services only;
• communications laws vary across jurisdictions;
• telecom and privacy compliance obligations remain solely with the user;
• the Company does not guarantee uninterrupted or error-free Services;
• use of communication infrastructure inherently involves operational, legal, technical and regulatory risks;
• users assume responsibility for all activities conducted through the Services.