Apelby GmbH (hereinafter “Apelby”) respects your personal privacy and is committed to maintaining your trust and confidence. Please take time to read this policy, and contact us if you have any questions or concerns.

Personal data (Privacy) Ordinance (“the Ordinance”)

The policies and practices of Apelby in relation to the collection, use, security and access of personal data of our customer are as follows:

Types of Personal Data Held

There is no obligation for our customers to provide their personal data to us. However, if the personal data requested by us is not provided, we may not be able to provide the services and/or products (“Services”) required by our customers.

We hold details of our customers including the names, addresses, identity numbers, telephone numbers, data relating to calls and billing together with other data necessary for the provision of our Services.


We collect and hold the personal data of our customers to facilitate our business as a provider of telecommunications, directory and other related services and/or products.

The purposes for which personal data relating to our customers may be used are as follows:

  • the daily provision of our Services to our customers;
  • conduct credit reference checks;
  • conduct market research, customer, product and service surveys;
  • processing of any benefits arising out of or in connection with our Services;
  • subject to the requirements of the Ordinance, direct marketing of our Services;
  • handling of complaints and enquiries from our customers;
  • enabling us to comply with our obligations to interconnect or other industry practices;
  • observing any legal, governmental or regulatory requirements including any disclosure or notification requirements, to which we are subject;

We also utilise specific personal data to assist us in protecting our customers against unauthorized use of our Services.

Security of Personal Data

We restrict access to personal data to persons who have a need to use the data and who have been trained to handle such data properly and observe confidentiality.

Retention of Personal Data

We retain personal data of customers for as long as reasonably necessary to fulfill the purposes of collecting and using the data.