Terms of Service

Our Terms of Service | Data Retention & Privacy Policy

Terms of Service

This website is operated by Mint+. Throughout the site, the terms “we”, “us” and “our” refer to Mint+. Mint+ offers this website, including all information, tools and services available from this site to you, the user, conditioned upon your acceptance of all terms, conditions, policies and notices stated here.

By visiting our site and/ or purchasing something from us, you engage in our “Service” and agree to be bound by the following terms and conditions (“Terms of Service”, “Terms”), including those additional terms and conditions and policies referenced herein and/or available by hyperlink. These Terms of Service apply to all users of the site, including without limitation users who are browsers, vendors, customers, merchants, and/ or contributors of content.

Please read these Terms of Service carefully before accessing or using our website. By accessing or using any part of the site, you agree to be bound by these Terms of Service. If you do not agree to all the terms and conditions of this agreement, then you may not access the website or use any services. If these Terms of Service are considered an offer, acceptance is expressly limited to these Terms of Service.

Any new features or tools which are added to the current store shall also be subject to the Terms of Service. You can review the most current version of the Terms of Service at any time on this page. We reserve the right to update, change or replace any part of these Terms of Service by posting updates and/or changes to our website. It is your responsibility to check this page periodically for changes. Your continued use of or access to the website following the posting of any changes constitutes acceptance of those changes.

Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you.

Section 1 - Online Store Terms
By agreeing to these Terms of Service, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.

You may not use our products for any illegal or unauthorized purpose nor may you, in the use of the Service, violate any laws in your jurisdiction (including but not limited to copyright laws).

You must not transmit any worms or viruses or any code of a destructive nature.

A breach or violation of any of the Terms will result in an immediate termination of your Services.

Section 2 - General Conditions
We reserve the right to refuse service to anyone for any reason at any time.

You understand that your content (not including credit card information), may be transferred unencrypted and involve (a) transmissions over various networks; and (b) changes to conform and adapt to technical requirements of connecting networks or devices. Credit card information is always encrypted during transfer over networks.

You agree not to reproduce, duplicate, copy, sell, resell or exploit any portion of the Service, use of the Service, or access to the Service or any contact on the website through which the service is provided, without express written permission by us.

The headings used in this agreement are included for convenience only and will not limit or otherwise affect these Terms.

Section 3 - Accuracy, Completeness And Timeliness Of Information
We are not responsible if information made available on this site is not accurate, complete or current. The material on this site is provided for general information only and should not be relied upon or used as the sole basis for making decisions without consulting primary, more accurate, more complete or more timely sources of information. Any reliance on the material on this site is at your own risk.

This site may contain certain historical information. Historical information, necessarily, is not current and is provided for your reference only. We reserve the right to modify the contents of this site at any time, but we have no obligation to update any information on our site. You agree that it is your responsibility to monitor changes to our site.

Section 4 - Modifications To The Service And Prices
Prices for our products are subject to change without notice.

We reserve the right at any time to modify or discontinue the Service (or any part or content thereof) without notice at any time.

We shall not be liable to you or to any third-party for any modification, price change, suspension or discontinuance of the Service.

Section 5 - Products Or Services (If Applicable)
Certain products or services may be available exclusively online through the website. These products or services may have limited quantities and are subject to return or exchange only according to our Return Policy.

We have made every effort to display as accurately as possible the colors and images of our products that appear at the store. We cannot guarantee that your computer monitor's display of any color will be accurate.

We reserve the right, but are not obligated, to limit the sales of our products or Services to any person, geographic region or jurisdiction. We may exercise this right on a case-by-case basis. We reserve the right to limit the quantities of any products or services that we offer. All descriptions of products or product pricing are subject to change at anytime without notice, at the sole discretion of us. We reserve the right to discontinue any product at any time. Any offer for any product or service made on this site is void where prohibited.

We do not warrant that the quality of any products, services, information, or other material purchased or obtained by you will meet your expectations, or that any errors in the Service will be corrected.

Section 6 - Accuracy Of Billing And Account Information
We reserve the right to refuse any order you place with us. We may, in our sole discretion, limit or cancel quantities purchased per person, per household or per order. These restrictions may include orders placed by or under the same customer account, the same credit card, and/or orders that use the same billing and/or shipping address. In the event that we make a change to or cancel an order, we may attempt to notify you by contacting the e‑mail and/or billing address/phone number provided at the time the order was made. We reserve the right to limit or prohibit orders that, in our sole judgment, appear to be placed by dealers, resellers or distributors.

You agree to provide current, complete and accurate purchase and account information for all purchases made at our store. You agree to promptly update your account and other information, including your email address and credit card numbers and expiration dates, so that we can complete your transactions and contact you as needed.

For more detail, please review our Returns Policy.

Section 7 - Optional Tools
We may provide you with access to third-party tools over which we neither monitor nor have any control nor input.

You acknowledge and agree that we provide access to such tools ”as is” and “as available” without any warranties, representations or conditions of any kind and without any endorsement. We shall have no liability whatsoever arising from or relating to your use of optional third-party tools.

Any use by you of optional tools offered through the site is entirely at your own risk and discretion and you should ensure that you are familiar with and approve of the terms on which tools are provided by the relevant third-party provider(s).

We may also, in the future, offer new services and/or features through the website (including, the release of new tools and resources). Such new features and/or services shall also be subject to these Terms of Service.

Section 8 - Third-Party Links
Certain content, products and services available via our Service may include materials from third-parties.

Third-party links on this site may direct you to third-party websites that are not affiliated with us. We are not responsible for examining or evaluating the content or accuracy and we do not warrant and will not have any liability or responsibility for any third-party materials or websites, or for any other materials, products, or services of third-parties.


We are not liable for any harm or damages related to the purchase or use of goods, services, resources, content, or any other transactions made in connection with any third-party websites. Please review carefully the third-party's policies and practices and make sure you understand them before you engage in any transaction. Complaints, claims, concerns, or questions regarding third-party products should be directed to the third-party.

Section 9 - User Comments, Feedback And Other Submissions
If, at our request, you send certain specific submissions (for example contest entries) or without a request from us you send creative ideas, suggestions, proposals, plans, or other materials, whether online, by email, by postal mail, or otherwise (collectively, 'comments'), you agree that we may, at any time, without restriction, edit, copy, publish, distribute, translate and otherwise use in any medium any comments that you forward to us. We are and shall be under no obligation (1) to maintain any comments in confidence; (2) to pay compensation for any comments; or (3) to respond to any comments.

We may, but have no obligation to, monitor, edit or remove content that we determine in our sole discretion are unlawful, offensive, threatening, libelous, defamatory, pornographic, obscene or otherwise objectionable or violates any party’s intellectual property or these Terms of Service.

You agree that your comments will not violate any right of any third-party, including copyright, trademark, privacy, personality or other personal or proprietary right. You further agree that your comments will not contain libelous or otherwise unlawful, abusive or obscene material, or contain any computer virus or other malware that could in any way affect the operation of the Service or any related website. You may not use a false e‑mail address, pretend to be someone other than yourself, or otherwise mislead us or third-parties as to the origin of any comments. You are solely responsible for any comments you make and their accuracy. We take no responsibility and assume no liability for any comments posted by you or any third-party.

Section 10 - Personal Information
Your submission of personal information through the store is governed by our Privacy Policy. To view our Privacy Policy.

Section 11 - Errors, Inaccuracies And Omissions
Occasionally there may be information on our site or in the Service that contains typographical errors, inaccuracies or omissions that may relate to product descriptions, pricing, promotions, offers, product shipping charges, transit times and availability. We reserve the right to correct any errors, inaccuracies or omissions, and to change or update information or cancel orders if any information in the Service or on any related website is inaccurate at any time without prior notice (including after you have submitted your order).

We undertake no obligation to update, amend or clarify information in the Service or on any related website, including without limitation, pricing information, except as required by law. No specified update or refresh date applied in the Service or on any related website, should be taken to indicate that all information in the Service or on any related website has been modified or updated.

Section 12 - Prohibited Uses
In addition to other prohibitions as set forth in the Terms of Service, you are prohibited from using the site or its content: (a) for any unlawful purpose; (b) to solicit others to perform or participate in any unlawful acts; (c) to violate any international, federal, provincial or state regulations, rules, laws, or local ordinances; (d) to infringe upon or violate our intellectual property rights or the intellectual property rights of others; (e) to harass, abuse, insult, harm, defame, slander, disparage, intimidate, or discriminate based on gender, sexual orientation, religion, ethnicity, race, age, national origin, or disability; (f) to submit false or misleading information; (g) to upload or transmit viruses or any other type of malicious code that will or may be used in any way that will affect the functionality or operation of the Service or of any related website, other websites, or the Internet; (h) to collect or track the personal information of others; (i) to spam, phish, pharm, pretext, spider, crawl, or scrape; (j) for any obscene or immoral purpose; or (k) to interfere with or circumvent the security features of the Service or any related website, other websites, or the Internet. We reserve the right to terminate your use of the Service or any related website for violating any of the prohibited uses.

Section 13 - Disclaimer Of Warranties; Limitation Of Liability
We do not guarantee, represent or warrant that your use of our service will be uninterrupted, timely, secure or error-free.

We do not warrant that the results that may be obtained from the use of the service will be accurate or reliable.

You agree that from time to time we may remove the service for indefinite periods of time or cancel the service at any time, without notice to you.

You expressly agree that your use of, or inability to use, the service is at your sole risk. The service and all products and services delivered to you through the service are (except as expressly stated by us) provided 'as is' and 'as available' for your use, without any representation, warranties or conditions of any kind, either express or implied, including all implied warranties or conditions of merchantability, merchantable quality, fitness for a particular purpose, durability, title, and non-infringement.

In no case shall Mint+, our directors, officers, employees, affiliates, agents, contractors, interns, suppliers, service providers or licensors be liable for any injury, loss, claim, or any direct, indirect, incidental, punitive, special, or consequential damages of any kind, including, without limitation lost profits, lost revenue, lost savings, loss of data, replacement costs, or any similar damages, whether based in contract, tort (including negligence), strict liability or otherwise, arising from your use of any of the service or any products procured using the service, or for any other claim related in any way to your use of the service or any product, including, but not limited to, any errors or omissions in any content, or any loss or damage of any kind incurred as a result of the use of the service or any content (or product) posted, transmitted, or otherwise made available via the service, even if advised of their possibility. Because some states or jurisdictions do not allow the exclusion or the limitation of liability for consequential or incidental damages, in such states or jurisdictions, our liability shall be limited to the maximum extent permitted by law.

Section 14 - Indemnification
You agree to indemnify, defend and hold harmless Mint+ and our parent, subsidiaries, affiliates, partners, officers, directors, agents, contractors, licensors, service providers, subcontractors, suppliers, interns and employees, harmless from any claim or demand, including reasonable attorneys’ fees, made by any third-party due to or arising out of your breach of these Terms of Service or the documents they incorporate by reference, or your violation of any law or the rights of a third-party.

Section 15 - Severability
In the event that any provision of these Terms of Service is determined to be unlawful, void or unenforceable, such provision shall nonetheless be enforceable to the fullest extent permitted by applicable law, and the unenforceable portion shall be deemed to be severed from these Terms of Service, such determination shall not affect the validity and enforceability of any other remaining provisions.

Section 16 - Termination
The obligations and liabilities of the parties incurred prior to the termination date shall survive the termination of this agreement for all purposes.

These Terms of Service are effective unless and until terminated by either you or us. You may terminate these Terms of Service at any time by notifying us that you no longer wish to use our Services, or when you cease using our site.

If in our sole judgment you fail, or we suspect that you have failed, to comply with any term or provision of these Terms of Service, we also may terminate this agreement at any time without notice and you will remain liable for all amounts due up to and including the date of termination; and/or accordingly may deny you access to our Services (or any part thereof).

Section 17 - Entire Agreement
The failure of us to exercise or enforce any right or provision of these Terms of Service shall not constitute a waiver of such right or provision.

These Terms of Service and any policies or operating rules posted by us on this site or in respect to The Service constitutes the entire agreement and understanding between you and us and govern your use of the Service, superseding any prior or contemporaneous agreements, communications and proposals, whether oral or written, between you and us (including, but not limited to, any prior versions of the Terms of Service).

Any ambiguities in the interpretation of these Terms of Service shall not be construed against the drafting party.

Section 18 - Governing Law
These Terms of Service and any separate agreements whereby we provide you Services shall be governed by and construed in accordance with the laws of Ireland, Dublin, Dublin, Ireland.

Section 19 - Changes To Terms Of Service
You can review the most current version of the Terms of Service at any time at this page.

We reserve the right, at our sole discretion, to update, change or replace any part of these Terms of Service by posting updates and changes to our website. It is your responsibility to check our website periodically for changes. Your continued use of or access to our website or the Service following the posting of any changes to these Terms of Service constitutes acceptance of those changes.

Section 20 - Contact Information
Questions about the Terms of Service should be sent to us at support@mintplus.ie

Privacy Policy

Who Are We?
We are Fónua Ltd. (Fónua) a company limited by guarantee at Cairn House, South County Business Park, Leopardstown, Dublin 18 registered under company number 267717.

We are a solutions provider to the Mobile Telecommunications and Consumer Electronics Industries. We also provide full turnkey solutions to a wide range of MVNOs, Independent and Online Retailers.

This notice sets out the basis on which any personal data we collect from you, or from others, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

For the purpose of the General Data Protection Regulation (the GDPR):

- The Data Controller is Fónua when acting as an employer, as a supplier of services and where dealing with suppliers & manufacturers and when selling directly to consumers;
- The Data Processor is Fónua when it processes personal data of consumers (also known as end users) when acting on behalf of its corporate customers.
Our data protection contact may be contacted via email

DataProtection@fonua.com

What Personal Information Do We Collect from You?
You may give us personal data by:

- Corresponding with us by phone, e-mail, or otherwise. We ask you to disclose only as much information as is necessary to provide you with our products and/or services or to submit a question/suggestion/comment in relation to our website or our services or products.
- Filling in forms on www.fonua.com (our Website) such as the contact us form or to apply for employment through our current vacancies form or returns form or our Q & A form.
- Using the Fónua portal: Corporate customers may supply us with information collected to include: customers Name, customers Address, Consumer’s home number, Second persons contact details, Email address.
- When Customers buy our products online. Customers supply us with name and address.
- When Customers pay for our products through Fónua Customer Care. Customers supply us with credit card details.
- Applying to work with us. The type of information you may provide includes your CV, a cover letter, your name, address, e-mail address and phone number. CVs should include information relevant to your employment history and education (degrees obtained, places worked, positions held, relevant awards, and so forth). We ask that you do not disclose sensitive personal information (e.g. gender, height, weight, medical information, religion, philosophical or political beliefs, financial data) in your application.
- Hiring Fónua or becoming a trading or business partner. Corporate customers supply us with information which may include employee’s contact details; a contact name; email; business address; telephone number and billing payment details.
- Visiting our premises. The type of information you may provide includes your name and your image which may be captured on our CCTV.


What Information About You Do We Obtain from Others?
When you use our services, we may obtain the following categories of personal data from others:

Name, Address, Email, Phone Number.

This is provided by our partners such as Vodafone, CPW, EIR, Tesco, PostMobile to allow us to fulfil orders.

Why Do We Collect This Information?
We collect the information in order to provide you with our services and products, to market our services, to improve our website and to recruit staff. Your information may also be recorded when contacting us by phone or in person on CCTV.

We will use this information:
Corporate Customer:

- To set you or your company up as a Customer on our systems when you apply to become a trading partner or a business partner with us;
- To send you marketing information when you subscribe to receive same;
- To deliver a service or product that you have requested
- To liaise with you about projects that we are undertaking with you;
- To deliver information about our products and services, where you have subscribed to receive same;
- To fulfil our statutory function which includes an obligation to Revenue i.e. to report on VAT;
- To ensure payment of our invoices;
- To update you on the status of the service or product that you have requested.

Consumers:
- To set you up to use our online store;
- To deliver a service or product that you have requested;
- To deliver information about our products and services, where you have subscribed to receive same;
- To fulfil our statutory function which includes an obligation to Revenue i.e. to report on VAT;
- To take payment for our products;
- To update you on the status of the service or product that you have requested.

Candidates:
- To create a candidate profile for you if you are a prospective employee;
- To process employment applications, including by assessing qualifications, verifying information, conducting reference or other employment-related checks, and notifying you of future opportunities that might be of interest to you.

Website users:
- To answer queries submitted through our websites;
- To administer and improve our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
As part of our efforts to keep our website safe and secure;
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- To make suggestions and recommendations to you and other users of our website about services that may interest you or them.
The legal bases for the processing of your data are:

That you have provided consent for the processing for updates on the status of your service or product for marketing for example when you subscribe to our email updates;
Processing necessary for the performance of a contract which you have entered into with us or to take steps at your request prior to entering into a contract;
Processing necessary for compliance with a legal obligation to which we are subject;
Processing necessary for the purposes of the legitimate business interests which we pursue in providing you with quotes and proposals about our products and services prior to contract where such interests are not overridden by your interests or fundamental rights or freedoms which require the protection of your information.

Who Do We Share This Information With?
We may share your personal data with our selected business associates/ suppliers and contractors to provide you with our services and products. For example, these business partners may include our IT service providers INFOR. Our Courier partners Nightline, An Post and Relay. Where an assessment of your credit score is a condition of us entering into a contract with you, we will share information with our selected credit reference agencies.

In addition, we may disclose your personal information to third parties:

- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If we or substantially all of our assets are acquired by a third party, in which case information held by us about our customers will be one of the transferred assets;
- If we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Disclosure of Your Information
We may share your Personal Data with any employee/company in the Fónua Group.

We may also share your information with selected third parties including:

- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
We attach at Schedule 1 a list of all entities with whom your personal data is shared.

How Long Do We Keep Hold of Your Information?
The time periods for which we retain your information depends on the type of information and the purposes for which we use it. We will keep your information for no longer than is required or permitted.

For further information on the periods for which your personal data is kept, please see our data retention policy which can be accessed here.

Do We Transfer Your Information Outside the European Union Or European Economic Area?
Yes, we transfer data outside the EEA through the following entities:

- Infor
- Mailchimp
- Survey monkey


The data that we collect from you may be transferred to, and stored in, Switzerland, US outside the European Economic Area (“EEA”) for which there is an adequacy decision relating to the safeguards for personal data from the European Commission.

What Are Your Rights with Respect To Your Personal Data?
You have the following rights:

- The right to access the personal data we hold about you.
- The right to require us to rectify any inaccurate personal data about you without undue delay.
- The right to have us erase any personal data we hold about you in circumstances such as where it is no longer necessary for us to hold the personal data or, in some circumstances, if you have withdrawn your consent to the processing.
- The right to object to us processing personal data about you such as processing for profiling or direct marketing.
- The right to ask us to provide your personal data to you in a portable format or, where technically feasible, for us to port that personal data to another provider provided it does not result in a disclosure of personal data relating to other people.
- The right to request a restriction of the processing of your personal data.


Where our processing of your personal data is based on your consent to that processing, you have the right to withdraw that consent at any time but any processing that we have carried out before you withdrew your consent remains lawful.

You may exercise any of the above rights by contacting Dataprotection@fonua.com completing a Subject Access Request

You may lodge a complaint with your local supervisory authority with respect to our processing of your personal data. The local Supervisory Authority in Ireland is the Data Protection Commission. The website is www.dataprotection.ie.

What Will Happen If We Change Our Privacy Notice?
This notice may change from time to time, and any changes will be posted on our website and will be effective when posted. Please review this notice each time you use our website or our services. This notice was last updated on 24th May 2018.


How Can You Contact Us?
Our Data Protection Contact can be contacted by Bríd O’Connor

On our website contact form: fonua.com

Or by email: Dataprotection@fonua.com

Data Retention Policy

1) The purpose of this policy
Fónua is firmly committed to complying with our data protection obligations. In this context, and to achieve consistency and excellence of service, we believe that it is important to have a policy setting out how we manage document retention.

The General Data Protection Regulation (the GDPR) impose obligations on us, as a Data Controller, to process personal data in a fair manner which notifies data subjects of the purposes of data processing and to retain the data for no longer than is necessary to achieve those purposes.

Under these rules, individuals have a right to be informed about how their personal data is processed. The GDPR sets out the information that we should supply to individuals and when individuals should be informed of this information. We are obliged to provide individuals with information on our retention periods or criteria used to determine the retention periods.

2) Grounds for processing
Under the GDPR, Fónua are required to provide data subjects with the legal grounds or lawful basis that they are relying on for processing personal data.

The legal grounds for processing personal data are as follows:

- Consent;
- Performance of a contract;
- Legal obligation;
- Vital interest;
- Public interest; or
- Legitimate interests.


Explicit consent is required where special categories, also known as sensitive personal data are being processed.

Fónua may be able to rely a number of legal bases for collecting personal data. For example, as employers, Fónua can justify processing an employee’s personal data as necessary for the performance of a contract and as part of a statutory requirement.

If there is no justification for retaining personal information, then that information should be routinely deleted. Information should never be kept "just in case" a use can be found for it in the future. If we want to retain information about our customers or end users to help us to provide a better service to them in the future, we must obtain their consent in advance.

Further processing
Further retention of the personal data should be lawful only when it is compatible with the purposes for which it was originally collected. In this case no separate legal basis is required- it should be relied on where it is necessary, for exercising the right of freedom of expression and information, for compliance with a legal obligation, for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller, on the grounds of public interest in the area of public health, for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, or for the establishment, exercise or defence of legal claims.

Right of erasure
Individuals have the right to have their personal data erased and no longer processed in the following circumstances:

where the personal data are no longer necessary in relation to the purposes for which they are collected or otherwise processed,

where a data subject has withdrawn his or her consent or objects to the processing of personal data concerning him or her, or

where the processing of his or her personal data does not otherwise comply with the GDPR.

This right is relevant in particular where the data subject has given his or her consent as a child and is not fully aware of the risks involved by the processing, and later wants to remove such personal data, especially on the internet.

The data subject should be able to exercise that right notwithstanding the fact that he or she is no longer a child.

3) Document Retention Procedure
We are required to retain certain records, usually for a specific amount of time. The accidental or intentional destruction of these records during their specified retention periods could result in the following consequences:

- Fines and penalties.
- Loss of rights.
- Obstruction of justice charges.
- Contempt of court charges.
- Serious disadvantages in litigation.
We must retain certain records because they contain information that:

- Have enduring business value (for example, they provide a record of a business transaction, evidence Fónua’s rights or obligations, protect our legal interests or ensure operational continuity.
- Must be kept in order to satisfy legal, accounting or other regulatory requirements.
We must balance these requirements with our statutory obligation to only keep records for the period required and to comply with data minimisation principles. The retention schedule below sets out the relevant periods for the retention of Fónua’s documents.

4) Types of Documents
This policy explains the differences among records, disposable information, personal data and confidential information belonging to others.

Records
A record is any type of information created, received or transmitted in the transaction of Fónua’s business, regardless of physical format. Examples of where the various types of information are located are:

- Appointment books and calendars.
- Audio and video recordings.
- Photographs
- Computer programs.
- Contracts.
- Electronic files.
- E-mails.
- Handwritten notes.
- Invoices.
- Letters and other correspondence.
- Magnetic tape.
- Memory in mobile phones and - PDAs.
- Online postings, such as on Facebook, Twitter and other social media networks.
- Performance reviews.
- Voicemails.


Therefore, any paper records and electronic files, that are part of any of the categories listed in the Records Retention Schedule contained in the Appendix to this policy, must be retained for the amount of time indicated in the Records Retention Schedule.

A record must not be retained beyond the period indicated in the Record Retention Schedule, unless a valid business reason (or a litigation hold or other special situation) calls for its continued retention. If you are unsure whether to retain a certain record, contact the Data Protection Officer.

You can contact our Data Protection Representative at:

Dataprotection@fonua.com

Disposable Information
Disposable information consists of data that may be discarded or deleted at the discretion of the user once it has served its temporary useful purpose and/or data that may be safely destroyed because it is not a record as defined by this policy. Examples may include:

- Duplicates of originals that have not been annotated.
- Preliminary drafts of letters, memoranda, reports, worksheets and informal notes that do not represent significant steps or decisions in the preparation of an official record.
- Books, periodicals, manuals, training binders and other printed materials obtained from sources outside of Fónua and retained primarily for reference purposes.
- Spam and junk mail.


Personal Data
Personal Data is defined as any data which can identify an individual either on its own or when combined with other data which we possess. Some examples of personal data include Insert Names and addresses, email addresses, CVs, details of previous employment, medical records and references. We have specific obligations relating to personal data as set out in the GDPR.

5) The role of the Data Protection Representative in Records Management
OurData Protection Representative, in conjunction with senior management, is responsible for identifying the documents that Fónua must or should retain, and determining, in collaboration with the Legal Department, the proper period of retention. The responsibilities of the Data Protection Officer include:

- Arranging for the proper storage and retrieval of records, coordinating with outside vendors where appropriate.
- Handling the destruction of records whose retention period has expired.
- Planning, developing and prescribing document disposal policies, systems, standards and procedures.
- Monitoring departmental compliance so that employees know how to follow the document management procedures and the Legal Department has confidence that Fónuas’ records are controlled.
- Ensuring that senior management is aware of their departments' document management responsibilities.
- Developing and implementing measures to ensure that the Legal Department knows what information Fónua has and where it is stored, that only authorised users have access to the information, and that Fónua keeps only the information it needs, thereby efficiently using space.
- Establishing standards for filing and storage equipment and recordkeeping supplies.
- In cooperation with department heads, identifying essential records and establishing a disaster plan for each office and department to ensure maximum availability of Fónua’s records in order to re-establish operations quickly and with minimal interruption and expense.
- Determining the practicality of and, if appropriate, establishing a uniform filing system and a forms design and control system.
- In conjunction with the Legal Department, periodically reviewing the records retention schedules and legislation to determine if Fónua ’s document management program and its Records Retention Schedule is in compliance with legislation.
- In conjunction with the Legal Department, informing the various department heads of any laws and administrative rules relating to corporate records.
- In conjunction with the HR Department explaining to employees their duties relating to the document management program.
- Ensuring that the maintenance, preservation, computer disk storage, destruction or other disposition of Fónua ’s records is carried out in accordance with this policy, the procedures of the document management program and our legal requirements.
- Planning the timetable for the annual records destruction exercise and the annual records audit, including setting deadlines for responses from departmental staff.
- Evaluating the overall effectiveness of the document management program.
- Reporting annually to the Legal Department on the implementation of the document management program in each of Fónua ’s departments.


6) How to Store and Destroy Records
Storage
Fónua’s records must be stored in a safe, secure and accessible manner. Any documents and financial files that are essential to our business operations during an emergency must be duplicated and/or backed up at least once per week and maintained off-site.

Destruction
Fónua’s IT team and Department Managers are responsible for the continuing process of identifying the records that have met their required retention period and supervising their destruction. The destruction of personal data, confidential, financial and personnel-related records must be conducted by shredding. The destruction of electronic records must be coordinated with the IT Department.

The destruction of records must stop immediately upon notification from the Legal Department that a litigation hold is to begin because Fónua may be involved in a litigation or an official investigation. Destruction may begin again once the Legal Department lifts the relevant litigation hold.

7) Questions About the Policy
Any questions about this policy should be referred to the Fónua’s Data Protection Representative via email who is in charge of administering, enforcing and updating this policy.

Appendix

Record Retention Schedule
In this policy Fónua establishes retention or destruction schedules or procedures for specific categories of records. This is done to ensure legal compliance and accomplish other objectives, such as protecting intellectual property and controlling costs. Employees should give special consideration to the categories of documents listed in the record retention schedule below. Avoid retaining a record if there is no business reason for doing so, and consult with the Data Protection Committee if unsure.

Disclaimer

To the fullest extent permissible by law, we hereby exclude and disclaim all and any warranties, conditions, representations and terms, implied by statute or otherwise, including in a course of dealing. Your consumer rights are not affected.
There may be certain differences between the user manual description of the handset and the handset’s operation, as a result of software upgrades issued in respect of your handset by the OEM and/or specific operator services. We shall not be held legally responsible for such differences if any, nor for their potential consequences, which responsibility shall be borne by the entity responsible for the relevant software upgrade.

This handset may contain applications which have been created or developed by third parties and which may be downloaded to this handset (for example, applications designed for iOS and Android handsets and their corresponding stores) (“Third Party Apps”). All Third Party Apps downloaded to this handset are provided “as is”, without warranty from us of any kind, whether express or implied, including the implied warranties of merchantability, fitness for a particular purpose, functionality, performance, use and/or third party application and/or interoperability with other third party materials. We recommend that you contact your network operator to check service availability for any Third Party App on your particular network. Mint+™ reserves the right at any time to add or remove Third Party Apps from its handsets without prior notice; in no event shall Mint+™ be held responsible by the purchaser for any consequences that such removal may have on the purchaser regarding the use or attempt to use such Third Party Apps. Third Party Apps may be subject to paid updates and upgrades in the future and you may be required to pay for and/or implement such updates and upgrades. We shall not be responsible for additional costs which may be payable for such updates or upgrades, which shall be borne exclusively by you, save always that your handset shall otherwise be fit for the purpose for which it is required as set out in the user manual.

The availability of mobile phone applications may vary depending on the countries and the operators where the handset is used; in no event shall the list of possible applications and software provided with the handsets be considered as an undertaking from Mint+™ that such applications shall be available in all countries and across all operators; it shall remain merely as information for the purchaser. Therefore, Mint+™ shall not be held responsible for the lack of availability of one or more applications in a particular territory.

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