Privacy Policy – Timor Telecom

In Short

We want you to know exactly how we use and protect your data.

Who we are
Timor Telecom, S.A., the first national telecommunications operator.

What we collect
Name, contact details, service usage data, preferences, and technical data (e.g., IP address).

Why we collect it
To provide services, manage our relationship with you, enhance your experience, comply with legal obligations, and send updates (with consent).

How we protect it
Robust technical and organizational measures to ensure security and confidentiality.

Your rights
Access, correct, delete, restrict, object to processing, request data portability, withdraw consent, and file complaints.

How to contact us
Data Protection Officer (DPO) – info@timortelecom.tl | Tel.: +670 330 3000

1. Who is responsible for your data?

Entity
Timor Telecom, S.A. (“TT”)

Address
Rua Presidente Nicolau Lobato, Timor Plaza, 4th Floor – P.O. Box 135, Dili – Timor-Leste

Data Protection Officer (DPO)
info@timortelecom.tl

2. What data do we collect?

Identification: name, address, date of birth, identification document number and type.
Contact: phone number, email, and other details you provide.
Service usage: call records, SMS, traffic and session data, location (when applicable and lawful), data usage, apps and subscribed services.
Technical data: IP address, device identifiers, IMEI/IMSI, cookies, and similar technologies.
Preferences and consents: marketing preferences, communication channels, and subscriptions.

3. Why do we process your data?

Validade dos carregamentos
Purpose	Legal Basis	Retention Period
Service provision and contract management (activation, billing, customer support, roaming, portability)	Contract performance	Duration of contract + 2 years
Legal compliance (data retention, regulatory response, billing, accounting)	Legal obligation	As required by law
Marketing and commercial communications (news, campaigns, VAS)	Consent (opt-in)	Until consent withdrawal
Service improvement and customer experience (network quality, aggregated analytics, surveys)	Legitimate interest	Up to 2 years after collection
Network security and fraud prevention (anomaly detection, abuse prevention)	Legal obligation / Legitimate interest	As required by law
Complaint and dispute management	Legitimate interest / Legal obligation	Until legal limitation period expires

4. When and how do we collect data?

When you sign up for services (in-store, via partners, online, or by phone).
When using TT services (calls, SMS, internet, apps, VAS).
Through forms, campaigns, contests, events, or satisfaction surveys.

5. Who do we share data with?

Service providers and partners acting on TT’s behalf (e.g., billing, mailing, technical support, debt collection, contact centers, VAS platforms, fraud analysis).
Operators and industry entities (e.g., portability, roaming, interconnection) when necessary to provide the service.
Authorities and public bodies when required by law or legitimate order.
We never sell your data to third parties.

7. Cookies and similar technologies

We use cookies to:

Essential: enable website and account functionality.
Performance/Analytics: measure performance and improve features.
Personalization/Marketing: deliver relevant content and offers (with consent where applicable).

You can manage cookies in your browser settings or through our Cookie Preference Center (link on website/app).

8. Security

We apply appropriate technical and organizational measures, including encryption, access control, pseudonymization, backups, and periodic audits, to protect against unauthorized access, loss, misuse, or alteration.

9. Policy updates

Any changes will be published on our website/app, and where relevant, communicated via email or SMS. We will always indicate the update date.