WAVELY Connect
Privacy Supplement

Version 1.0

25 August 2021

WAVELY Connect is Greenwave Systems’ IoT connectivity and data roaming service including SIM card management solution for businesses. The solution allows businesses to connect employees’ devices to IoT devices and view and manage all IoT SIM connections in the fleet with the central management console. The management console provides businesses with an access to the data associated with user roles in the management system and SIM user’s profile, device details and data usage what they process as data controllers.

WAVELY processes technical details and identifiers of SIM cards and other data for the purposes of providing WAVELY services. We do not use the collected data to identify users personally, but this data may be associated with data subjects when SIM cards are being used with personal mobile devices. In addition, the data allows us to comply with legal obligations based on mandatory laws in case of payment processing, providing customer service, and developing our services and products.

WAVELY processes the following information as a data controller to provide the service that can identify the user of the management console:

• First and last name • Email address • Phone number

the user of a SIM card:

• SIM card identifiers (GUID, IMSI, ICC) • Cell Tower ID • Used mobile networks (local MNO) • IP address • Data usage country • Device IMEI

The roaming services are provided by our service providers that are data processors of WAVELY.