This Privacy Policy explains how FRST Media Europe B.V. ("we", "our", "us") collects, uses, and protects personal data in connection with the Telechargeables service accessible at telechargeables.com. We are committed to handling your data lawfully, transparently, and in line with the General Data Protection Regulation (GDPR) and applicable national data protection law.
Please read this policy carefully before using the service. If you have questions, contact us at info@telechargeables.com.
1. Data Controller
The data controller responsible for your personal data is:
2. What We Collect
We collect the minimum personal data necessary to provide the service:
- Mobile phone number: Required to process your carrier-billed payment and activate your access.
- Mobile network operator data: Passed to us by your carrier as part of the billing process, including your operator identifier and country code.
- Payment transaction data: Reference numbers and confirmation status from the carrier billing process. We do not store payment card data — no card is used.
- Technical data: IP address, browser type and version, device type, and referring URL, collected automatically when you visit our site.
- Usage data: Pages visited, time on site, and interaction events collected via analytics tools (see Section 7).
We do not collect your name, postal address, or email address unless you contact us directly.
3. How We Use Your Data
We use your personal data for the following purposes:
- To process your monthly carrier-billed subscription charge and activate your content access.
- To verify your mobile carrier and route the billing request correctly.
- To respond to support enquiries and refund requests you send to us by email.
- To analyse site traffic and usage patterns in order to improve the service.
- To comply with legal obligations, including record-keeping and responding to lawful data requests.
We do not use your data for direct marketing, profiling, or automated decision-making that produces legal or similarly significant effects.
4. Legal Basis for Processing
We process your data on the following legal bases under GDPR Article 6:
- Performance of a contract (Art. 6(1)(b)): Processing your mobile number and carrier data is necessary to fulfil the service you purchased.
- Legitimate interests (Art. 6(1)(f)): We have a legitimate interest in analysing traffic and usage to improve the service, provided this does not override your privacy interests.
- Legal obligation (Art. 6(1)(c)): Retaining transaction records to meet our statutory accounting and tax obligations.
5. How Long We Keep Your Data
We retain personal data only for as long as necessary:
- Transaction records (mobile number, billing reference): retained for 7 years to meet Dutch statutory accounting requirements.
- Support correspondence: retained for 2 years after the final message in the thread.
- Technical/analytics logs: aggregated and anonymised after 14 months; raw logs deleted after 90 days.
6. Who We Share Data With
We share personal data with third parties only where necessary:
- Mobile carriers and billing partners: Your mobile number and transaction details are shared with your network operator and our carrier billing partner to process the payment.
- Analytics providers: Aggregated, anonymised usage data is processed by analytics software. Where data is shared with providers outside the EEA, we ensure adequate transfer safeguards apply.
- Legal and regulatory authorities: We may disclose data where required by law, court order, or competent regulatory authority.
We do not sell personal data to third parties. We do not share data with advertisers.
7. Cookies & Similar Technologies
We use a small number of cookies to make the site function correctly and to understand how visitors use it. We do not use advertising or tracking cookies. For detailed information, see our Cookie Policy.
You can manage cookies through your browser settings. Disabling cookies may affect some site functionality.
8. Your Rights
Under GDPR, you have the right to:
- Access: Request a copy of the personal data we hold about you.
- Rectification: Ask us to correct inaccurate data.
- Erasure: Request deletion of your data where it is no longer necessary for the purpose it was collected.
- Restriction: Ask us to pause processing your data in certain circumstances.
- Objection: Object to processing based on our legitimate interests.
- Portability: Receive your data in a structured, machine-readable format where technically feasible.
To exercise any of these rights, email info@telechargeables.com. We will respond within 30 days. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, autoriteitpersoonsgegevens.nl).
All privacy-related enquiries should be directed to:
We may update this Privacy Policy from time to time. Material changes will be communicated by updating this page with a revised "Last updated" date. Continued use of the service after changes are published constitutes acceptance of the revised policy.