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Deutsche Telekom AG_Connected Vehicle_Features_Service Description.pdf

Service Description for Connected Vehicle Features (Deutsche Telekom AG)

1

Content Preface .............................................................................................................................................................. 2

Connecting the vehicles to the internet ............................................................................................................... 2

Information about the SIM card network profiles .................................................................................................. 2

Data transfer between the vehicle and the Internet............................................................................................... 3

Shared Use of the data connection by the vehicle occupants................................................................................ 3

Types of Connected Vehicle Features .................................................................................................................. 4

Infotainment systems with basic telematics functionalities (case 1)................................................................... 4

Infotainment systems with additional entertainment functionalities (case 2) ...................................................... 4

Infotainment systems with messaging functionalities (case 3) .......................................................................... 4

Infotainment systems with browser applications (case 4) ................................................................................. 5

WiFi-based Internet Access in the vehicles (case 5) ......................................................................................... 5

Regulatory assessment of Connected Vehicle Features ........................................................................................ 5

Introduction of Local ISP .................................................................................................................................... 5

Prerequisites for using the Connected Vehicle Features ....................................................................................... 6

Technical Equipment of the vehicle ................................................................................................................. 6

Activation of Connected Vehicle Features ........................................................................................................ 6

Payment for Connected Vehicle Features ......................................................................................................... 7

Technical solution .............................................................................................................................................. 7

Data communication ...................................................................................................................................... 8

Data Storage .................................................................................................................................................. 8

Annex ............................................................................................................................................................... 9

Illustration of contractual relationships ............................................................................................................ 9

Involved parties and roles ............................................................................................................................. 11

Service Description for Connected Vehicle Features (Deutsche Telekom AG)

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Preface

For several years now, the topic "Connected Vehicle Features" has been very relevant for the auto- motive industry. Vehicle manufacturers connect vehicles to the internet, for example to collect data on vehicle use or to provide their customers with an enhanced user / driving experience.

In the past, these Connected Vehicle Features were mainly designed to support the driving experi- ence (e.g., navigation services) . Today, these Connected Vehicle Features are also increasingly focusing on entertainment purposes (e.g., audio streaming) , which can be accessed through the vehicles ’ own infotainment systems. Industry -wide trends such as the development of autonomous driving wil l further increase the relevance of Connected Vehicle Features . When people no longer need to focus on driving, they can use driving time to watch videos, make phone calls or read the news.

Consequently, the amount of use cases related to Connected Vehicle Features are increasing. From the point of view of data volume (traffic in the mobile network s), however, traditional telematics applications remain dominant ( e.g., transmission of vehicle data to the manufacturers' IT systems).

The introduction of Connected Vehicle Features is linked to numerous legal questions. We are par- ticularly interested in those questions that are closely related to telecommunications regulation and telecommunications law.

In the following, we describe how we support vehicle manufacturers in connecting vehicles to the internet and how this connection affects the customer (e.g., driver of the vehicle or passengers inside the vehicle). Furthermore, we will introduce various parties, who play an active role in ena- bling Connected Vehicle Features. These parties are vehicle manufacturer, Telekom Deutschland GmbH, Local ISP and End Customers. Annexed to this Service Description you can find a table, where the parties and their roles are summarized.

Connecting the vehicles to the internet

To enable a data connection in the car, a mobile network transmission is used. For this purpose, the vehicle manufacturers purchase SIM cards from a supplier and install s these SIM cards in the vehicles. The term “SIM card” only describes the piece of hardware and at this point the SIM card cannot yet connect to the mobile network.

For the SIM cards to be able to connect to the mobile network, a network profi le is installed on the SIM cards. This network profile is provided to the vehicle manufacturers by Telekom Deutsch- land GmbH. “Provision” means that the features of the SIM cards (e.g., phone number, IMSI, MSISDN) are registered with the vehicle manufacturer. If a law enforcement agency wanted to know to whom a SIM card is registered ( “Who is the subscriber of the SIM card profile?”), the cor- responding information systems would refer to the vehicle manufacturer.

The process of registering the SIM card profile to its subscriber (vehicle manufacturer) is de- signed according to the legal requirements in Germany, as Telekom Deutschland GmbH has its registered office in Germany. The company headquarters of the vehicle manufacturer is irrelevant for the design of the aforementioned process.

After registering the SIM card to the subscriber, the SIM card’s status is changed to active . The SIM card can now establish a data connection with the respective mobile networks.

Information about the SIM card network profiles

Telekom Deutschland GmbH uses two different SIM card network profiles. On the one hand, a TDG Global SIM profile and a SIM profile of T-Mobile Austria GmbH.

Service Description for Connected Vehicle Features (Deutsche Telekom AG)

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The TDG Global SIM profile is in permanent roaming status in all mobile networks, even inside Germany. The T-Mobile Austria GmbH profile is in permanent roaming status in all mobile net- works outside Austria. The SIM profiles can establish data connections to the mobile networks of other providers in the respective market.

All Connected Vehicle Features are realized via one/the same SIM card installed in the vehicle. This SIM card cannot be accessed by an average user and shall not be removed by an average user. If the SIM card is removed without permission, technical security measures will prevent the usage in other devices (e.g., smartphone, tablet).

Data transfer between the vehicle and the Internet

Assume that the vehicle is located in Country A (not Germany and not Austria). For the Connected Vehicle Features to work, the SIM card connects to the local mobile network. The local mobile net- work recognizes that the incoming mobile network signal (request) is connected to a foreign net- work profile. In addition, the mobile network signal contains information that the request is to be routed to Germany. The request is always routed from the mobile network to Germany and inde- pendent from the fact, which network profile is instal led on the respective SIM card .

The request from the vehicle located in Country A is processed and handled in Germany by several IT systems. All IT systems are operated by Telekom Deutschland GmbH and its (technical) service providers. After processing the request through the IT systems in Germany the “answer” is sent from the IT system to the mobile network in Country A. The mobile network in Country A sends the data back to respective vehicle.

Neither Telekom Deutschland GmbH nor the vehicle manufacturers nor the service providers used by Telekom Deutschland GmbH operate any infrastructure in country A. The existing infrastructure of established mobile network providers is used, and this is also contractually regulated via roam- ing agreements in line with industry standards .

Shared Use of the data connection by the vehicle occupants

The vehicle manufacturer has equipped its vehicles with SIM cards and these SIM cards can con- nect to the internet. Furthermore, the vehicle manufacturer installs an infotainment system in the vehicle and might offer third parties the opportunity to place their applications (apps) on its plat-

I S I S

ehic e in our urisdiction Mobi e networ in our urisdiction

I S ste s in er an

ra c re uest e uest routing

ra c answer nswer routing

Service Description for Connected Vehicle Features (Deutsche Telekom AG)

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form (infotainment system). We point out that the infotainment systems are a subordinate compo- nent of the vehicle. In other words, the main purpose of the vehicle (mobil ity) functions and oper- ates even if a customer does not use the infotainment system.

As a result , customers can benefit from the built - in Connected Vehicle Features. Connected Vehi- cle Features are primarily third-party apps which are installed on the operating system of the info- tainment systems. After completing this installation, customers can use these apps through th e vehic e’s in otain ent s ste . his can –to some extent be compared to the situation an average user knows from his or her smartphone or tablet.

The data traffic that is generated during the use of these apps is usually realized via the SIM card installed in the vehicle, which is registered to the vehicle manufacturer. The manufacturer allows its customers to co-use the respective data traffic and to benefit from the data connection in the vehicle (hereina ter “Shared Use”). Shared Use means, that a customer does not have to pay acti- vation fees or usage fees to use Connected Vehicle Features.

We emphasize that the manufacturer does not provide its customers with the data connection as such. The manufacturer rather enables its customers to co-use the existing data connection , which is provided by Telekom Deutschland GmbH to the manufacturer. This data connection enables the usage of Connected Vehicle Features, such as apps, - which can be accessed by a customer throughout the vehicles infotainment system. A customer - as usual on e.g., smartphones - must use his or her own credentials to use the apps based on the respective agreements directly con- cluded between the customer and the relevant app lication providers.

The data connection cannot be used by just anyone. The person must have at least access to the vehicle. This can –to some extent be compared to a situation in which a restaurant offers its guests free internet access on its premises, provided that the guests also use its main service (gastronomy). The restaurant is the connection owner (subscriber) and allows other (certain) per- sons to co-use this connection in special situations.

Types of Connected Vehicle Features

In the following, the client provides a clustered overview of the types of Connected Vehicle Fea- tures that can be used via the infotainment systems.

Infotainment systems with basic telematics functionalities (case 1)

Customers can only access / use applications that support the driving experience. Such applica- tions are, for example, navigation apps. If the customer uses these applications via the infotain- ment system, the required data connection is realized via the SIM card installed in the vehicle.

Infotainment systems with additional entertainment functionalities (case 2)

Additional applications to case 1 may be installed on the infotainment system. These applications are designed to entertain the customer. Such applications are, for example, audio streaming apps such as Spotify. If the customer uses these applications via the infotainment system, the required data connection is realized via the SIM card installed in the vehicle. Whereby a customer - as usual on e.g., smartphones - must use his or her own credentials to use the apps based on the re- spective agreements directly concluded between the customer and the relevant application pro- vider. Please note that these features are primarily characterized by the fact that no interpersonal communication is possible.

Infotainment systems with messaging functionalities (case 3)

Additional applications to case 1 and 2 may be instal led on the infotainment system. These appli- cations are designed to enable interpersonal communication between the customer and o thers. Such applications are, for example, messaging apps such as WhatsApp or applications to partici- pate in telephone conferences. If the customer uses these applications via the infotainment sys- tem, the required data connection is realized via the SIM card installed in the vehicle. Whereby a customer - as usual on e.g., smartphones - must use his or her own credentials to use the apps

Service Description for Connected Vehicle Features (Deutsche Telekom AG)

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based on the respective agreements directly concluded between the customer and the relevant ap- plication provider.

Infotainment systems with browser applications (case 4)

Additional applications to case 1, 2 and 3 may be installed on the infotainment system. These ap- plications are designed to enable web browsing for customers. Such applications are, for exam- ple, a web browser like Safari or Google Chrome. If the customer uses these applications via the infotainment system, the required data connection is realized via the SIM card installed in the ve- hicle. Whereby a customer - as usual on e.g., smartphones - must use his own credentials to use the apps based on the respective agreements directly concluded between the customer and the relevant application provider.

WiFi-based Internet Access in the vehicles (case 5)

Irrespective of the Connected Vehicle features that can be used via the infotainment system, there is the case that a Wi -Fi router may be installed in the vehicles. If desired, customers can then acti- vate a Wi-Fi network in the vehicle and connect their de vices to this Wi-Fi network. If the customer uses this WiFi network the data connection is realized via the SIM card installed in the vehicle.

Please note, that WiFi -based Internet Access might only be possible, if the customer buys a spe- cific data plan (WiFi pass). WiFi -based Internet Access might not be subject to the shared use concept.

Regulatory assessment of Connected Vehicle Features

To our understanding the vehicle manufacturer provides its customers solely access to the Con- nected Vehicle Features and is not responsible for any mobile network transmission . The transmis- sion is realized through the SIM card which is instal led within the vehicle. The corresponding SIM card network profile is provided to the vehicle manufacturer by Telekom Deutschland GmbH and therefore the vehicle manufacturer shall be consid ered as the subscriber of the SIM card network profile. Telekom Deutschland GmbH is responsible for all measures related to handling and man- aging the transmissions.

The vehicle manufacturer grants its customers the right to co -use the data connection (Shared Use) without directly charging the customer any fees for this right.

Introduction of Local ISP

If one concludes that the provision of Connected Vehicle Features is subject to telecommunica- tions regulation and telecommunications law, these services shall be provided to the End Custom- ers by a company entioned herein as “Local ISP”. The term “End Customer” describes the per- son, who will enter into a contract with Local ISP about the provision of the connection services.

Local ISP, as a company, shall take over any obligations stemming from telecommunication law and regulation (if there are any), such as notifying telecommunication authorit ies about the ser- vice offer. Furthermore, the Local ISP shall enter into a direct contractual relationship with the End Customer and inform them about all features of its services in a clear and transparent way. P ease note, that the ter “ oca ” sha not indicate, that the co pan has necessari an estab l ishment and / or premises in your jurisdiction, although this might be the case.

The role of Local ISP will be assumed by T -Mobile HotSpot GmbH (Friedrich Ebert Allee 140, 53223 Bonn, Germany, HRB 16010). T -Mobile HotSpot GmbH wil l provide the access to the Con- nected Vehicle Features in your jurisdiction. Local ISP will notify the regulatory authority about the service offer .

Service Description for Connected Vehicle Features (Deutsche Telekom AG)

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Prerequisites for using the Connected Vehicle Features

If you conclude that the provision of Connected Vehicle Features is subject to telecommunications regulation and telecommunications law, the following prerequisites for using Connected Vehicle Features shall apply.

Technical Equipment of the vehicle

A vehicle must have the appropriate technical equipment. First, a SIM card must be in stalled within the vehicle and be equipped with the corresponding network profile . For enabling cases 1 to 4 an infotainment system must be installed in the vehicle (cases 1 to 4). Case 5 would require a Wi-Fi router to be installed.

Activation of Connected Vehicle Features

a) Customer documents

Before an End Customer can access the Connected Vehicle Features for the first time, they have to agree to the terms of use and to take note of the privacy policy. Both documents are provided by Local ISP prior to the service activation. Without the respective consents by the End Customer, Local ISP will not provide access to the Connected Vehicle Fea tures. Both documents (terms of use and privac po ic ) can be accessed on oca ISP’s website.

Terms of use are written in the official languages of your jurisdiction and provide the End Cus- tomer with a comprehensive overview of the service. When using the expression “co prehensive overview” the c ient intends to indicate, that the docu ent contains in or ation about the o ow ing aspects at least:

• Name and contact details of the service provider (Local ISP) • Description of offered services and intended quality level • Contractual terms (i.e., perquisites for access to the services) • Prices & payment methods • Right of withdrawal • Customer service and dispute resolution • Termination of the contract • Liability

The privacy policy is a document intended to make the data gathering and processing transparent for End Customers. It is written in in the official languages of your jurisdiction and explains the type and scope of data collection, whether and which data is st ored, and to what extent third par- ties are involved in these processes. The document is designed in accordance with the obliga- tions stemming from data protection law, such as GPDP article 13.

Furthermore, Local ISP provides End Customers with a contract su mmary, prior to the service acti- vation. This document is designed in accordance with the Commission Implementing Regulation (EU) 2019/2243 of 17 December 2019 and sums up the most relevant points of the terms of use in one page.

b) Customer data

If required, Local ISP will gather personal data from its End Customers prior to the service activa- tion. Such data is for example, name and address of the End Customer. This shall only take place if there is a business or legal purpose for the data process ing and End Customers explicitly agreed to such data processing.

All customer data shall be stored at least for the duration of the customer relationship. If there is a legal obligation to store this data for a longer period, Local ISP will act accordingly . The authen- ticity of the information is verif ied by sending End Customers a link by e -mail following their regis- tration. This link must be confirmed and then the corresponding customer account is created in the IT systems. Without confirmation of this l in k, the End Customers cannot access the Connected

Service Description for Connected Vehicle Features (Deutsche Telekom AG)

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Vehicle Features. End Customers can always revoke their consent for the data processing. They can also receive information about data processing from the customer service.

All customer data related issues are subject to data protection law (e.g., GPDR), and Local ISP es- tablished several mechanisms to ensure a very high level of data protection and data security.

c) Verification of customer data

Furthermore, it might be required that Local ISP checks the informa tion of the End Customer for correctness. If such a check is necessary, then this check is done electronically. Local ISP estab- lished two different mechanisms for doing so.

Mechanism 1: Verification via SMS code

During the registration, End Customers provide a mobile phone number. Local ISP will send a code to this mobile phone number via SMS. End Customers need to enter this code on Local ISPs website. If the End Customer enters the code correctly, Local ISP wil l consider the provided cus- tomer data as verif ied and activate the access to the Connected Vehicle Features. This step has to be carried out in addition to the confirmation of the e -mail l ink (see above).

Mechanism 2: Verification via service agent (video i dent)

After the registration, End Customer wil l be forwarded to a video chat. During the video chat, the End Customer has to show his or her personal ID to a trained service agent. The service agent checks if the information provided by the End Customer ma tches with the information on the ID. If required, service agent will take a picture of the ID provided by the End Customer. This copy will at east be stored or the duration o the custo er re ationship. ter the nd Custo er’s identit has been confirmed successfully, the Local ISP will grant access to the Connected Vehicle Fea- tures.

Payment for Connected Vehicle Features

It might be the (rare) case, that End Customers cannot benefit from the Shared Use concept. In this case the End Customers have to purchase the services from Local ISP directly ( e.g., Wi-Fi pass). In this case, a successful payment process is a prerequisite for the activation of the Con- nected Vehicle Features. Local ISP will issue a receipt of purchase for the End Customer. Al l infor- mation about prices and the quality of services to be expected as well as potential rights of End Custo ers (e.g., right o withdrawa , dispute reso ution) are pub ished on oca ISP’s website. Lo- cal ISP does not process or store any data related to payment process. Such data is handled by the companies handling the payment functionalities of the services (payment service providers).

Technical solution

Telekom Deutschland GmbH developed an IT infrastructure which ensures that the Connected Ve- hicle Features can be provided towards customers (hereinafter Internet Platform ). The Internet Platform consists of several frontend and backend systems and provides various frontend and backend business processes.

The Internet Platform is developed, maintained and operated by Telekom Deutschland GmbH and its technical enablers. A “ technical enabler” is a company that provides IT services, which are needed to operate the Internet Platform. All IT systems associated to the Internet Platform are lo- cated within the territory of Germany (e.g., servers). Consequently, all data storage will take place on servers located within the territory of Germany. Local ISP informs its End Customers about this fact in the privacy policy.

Local ISP has the right to use the Internet Platform in connection with the provision of the Inter- net Access Services. This right is manifested within the contract between Telekom Deutschland GmbH and Local ISP.

Service Description for Connected Vehicle Features (Deutsche Telekom AG)

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Data communication

The communication between the vehicle and the Internet Platform is realized via mobile radio net- works. Therefore, the vehicle manufacturer installs a SIM card into the vehicle. The installation is performed during the vehicle production.

To manage the internet traffic between the vehicle and the Internet Platform appropriately Tele- kom Deutschland GmbH relies on dedicated Access Point Names (hereinafter APN). The internet traffic is routed to Germany. All communication is secured by appropriate technical measures.

All internet traffic is geo -localized and therefore, every internet session will be routed with local IP-addresses of the underlying country. As a resu lt, End Customers will always have a home spe- cific user experience, regardless of whether they are connected to a mobile network in their home country or are roaming from abroad.

If legally required, Local ISP has the possibility to restrict / f ilter the i nternet traffic. The filtering of internet traffic refers to the fact that some IP addresses might be blocked. Such measures are especially applied if Local ISP is legally obliged to prevent access to dedicated IP addresses / websites (e.g., pornography, online gambling).

In the case, that Connected Vehicle Features include WiFi -based Internet access (case 5), the In- ternet Platform communicates with the End Customers device via a WiFi router that is instal led within the vehicle. The transfer of content to t he End customers device in the vehicle is done with secure HTTPs protocol for all user specific data to ensure privacy and secure of crit ical infor- mation.

Data Storage

If required, Local ISP processes and stores various types of data. Reasons for this processing are either the technical enabling of the services or further legal obligations. Data is only used for these purposes and is not reused commercial ly. Local ISP do es not process nor gather any mobile network location data, Cell IDs and/or GPS data. The Service merely roams with local mobile net- works and uses third parties for transportation of data. However, records are kept on a session level in order to determine how much data volume has been consumed at which point of time by a customer account.

In the following we point out, what kind of data will be stored:

Customer data

• Title • Last Name • First name • Street + No. • Post code • City • Country • Email address

Service Description for Connected Vehicle Features (Deutsche Telekom AG)

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Traffic data

• IMSI • MSISDN • MCC • MNC • IP Address • NAT IP Address • NAT Port Range Start • NAT Port Range End • Start Time • End Time • Session Time • Consumed data volume

Annex

Illustration of contractual relationships

If you conclude that the provision of Connected Vehicle Features is subject to telecommunications regulation and telecommunications law, the following contractual chain can be installed (current setup).

I S I S S

oca ISP

nd Custo er

e e o eutsch and b and vehic e anu acturer conc ude a contact about enab ing connectivit or vehic es

nd Custo er purchases eases ro anu acturer, which inc udes

right to co use data vo u e

oca ISP provides access to Connected ehic e eatures towards nd Custo ers Service provision is based on oca ISP s ter s o use and privac po ic

and oca ISP conc ude an separate contract (ISP gree ent)

ehic e anu acturer

Service Description for Connected Vehicle Features (Deutsche Telekom AG)

10

I S I P C S

oca ISP

nd Custo er

e e o eutsch and b and vehic e anu acturer conc ude a contact about enab ing connectivit or vehic es

nd Custo er purchases eases ro anu acturer

oca ISP provides access to Connected ehic e eatures towards nd Custo ers Service provision is based on oca ISP s ter s o use and privac po ic

nd Custo er pa s the service ee to oca ISP

and oca ISP conc ude an separate contract (ISP gree ent)

ehic e anu acturer

Service Description for Connected Vehicle Features (Deutsche Telekom AG)

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Involved parties and roles

Vehicle manufacturer Telekom Deutschland

GmbH

Local ISP End Customer

Vehicle manufacturer

produces a vehicle and

sel ls or leases it to a

person.

As part of the produc-

tion process, the com-

pany prepares vehicles

for Connected Vehicle

features. This means

that SIM cards are in-

stalled in the vehicles

and the necessary tech-

nical equipment is in-

stalled (e.g., the info-

tainment system or the

WiFi router).

During the period of ve-

hicle operation, the ve-

hicle manufacturer as-

sumes the costs in-

curred for data con-

sumption in the shared

use scenario.

Telekom Deutschland

GmbH is the contractual

partner of the vehicle

manufacturer to enable

a data connection be-

tween the vehicles and

the mobile networks.

Telekom Deutschland

GmbH provides the SIM

card network profi les to

the manufacturer.

Telekom Deutschland

GmbH handles al l data

traffic related to the

Connected Vehicle Fea-

tures.

Telekom Deutschland

GmbH operates the In-

ternet Platform to ena-

ble the Connected Vehi -

cle Features.

Telekom does not pro-

vide the mobile commu-

nications infrastructure.

Telekom does not have

any contractual relation-

ship with the End Cus-

tomer

If you conclude that the

provision of Connected

Vehicle Features is af -

fected by obligations

stemming from telecom-

munication regulation,

Local ISP assumes the

role of the provider of

the services to the End

Customer.

Local ISP will take over

all responsibil it ies

stemming of telecommu-

nication regulation as-

sociated with providing

access to Connected

Vehicle Features.

Local ISP will conclude

a contract with Telekom

Deutschland GmbH to

use the Internet Plat-

form for technical ena-

bling the access to Con-

nected Vehicle Fea-

tures.

Local ISP will conclude

a contract with End

Customer to regulate

the provision of the ser-

vices (access to Con-

nected Vehicle Fea-

tures).

End Customer is a per-

son, who uses the Con-

nected Vehicle Features

in the car.

In the Shared Use con-

cept, there is a contrac-

tual relationship be-

tween End Customer

and manufacturer,

which grants the End

Customer to right to co -

use the data connection

in the car.

I f there is no shared

use scenario, End Cus-

tomers will purchase

the access to the Con-

nected Vehicle Features

from Local ISP through

oca ISP’s website.

E-kiri.eml

Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga.
Tundmatu saatja korral palume linke ja faile mitte avada.

[Disclaimer: The following message is originally written in English. The English version is the authoritative source. A machine-generated translation in Estonian is provided below for your convenience.]

To whom it may concern,

we, the x-ion GmbH, are an “Infrastructure as a Service (IaaS)“ provider based in Germany.

We take part as a technical enabler in the so-called project “HotSpot Drive”.
Please see attachment for the full-service description.

The commercial partner/internet service provider in Estonia will be T-Mobile HotSpot GmbH (TMHS).

TMHS will be a commercial partner and face to the customer in Estonia.
TMHS also acts as a data controller.
x-ion is responsible for data transmission without any customer relations.

We would like to get in touch with you to clarify the obligations for x-ion, as well as for TMHS.

We investigated different sources but have not been able to fully answer these questions or need to double check to be sure.

Please review and respond/forward the questions below and send us the contact information of the people/departments/authorities responsible.

Our major goal is to reach full compliance with the local laws and authorities.

We thank you in advance for your support.

Short introduction

As pointed out in the Service Description, TMHS does not run any network equipment in Estonia.

Only roaming facilities of the local mobile network operators (MNOs) will be used for this service.
The installed SIM card is provided by T-Mobile Austria GmbH. This SIM card roams with all MNOs in Estonia.

We would like to hear your opinion about how to implement “Lawful Interception” into our environment.
We are already live with this service in more than 10 countries in Europe.
In the other countries we always found a very simple way to support the local Law Enforcement Agencies (LEAs).

Questions concerning Interception Requests

In case of a request, we provide the IMSI number of the installed SIM card.

With this information the local LEAs contact the local MNOs (which already have implemented interception mechanisms)
and proceed with the interception.

Could this be a suitable solution for you/in Estonia, too?

Furthermore, we would like to ask for information about different procedures and technical solutions.
We, x-ion, act as a representative for TMHS in case of requests (DR: Data Records or LI: Lawful Interception).
The attached document “LI-Gate – x-ion GmbH” shows the contact data of our lawful interception officers.

Would you accept the attached „LI-Gate“ document from us, as a third party and would you work with it?
Is the provided information in the attached „LI-Gate“ document enough?

Further questions

4. How would a data disclosure requests reach us? (e.g. e-mail)

5. Is any specific encryption needed?

6. Are there any logging obligations for requests and if yes - are there any requirements for these logs?

7. What kind of data will be requested by the authorities ?

8. Is there a specified reaction time & availability time for request?

9. What is the skill or legal requirements for the personnel handling the requests (special qualifications, language skills etc.)

10. Which authorities must be supplied with data/information?

Best regards,
Florian Wagner
Project Lead Regulatory Affairs

x-ion GmbH
Marschnerstr. 52
22081 Hamburg
https://www.x-ion.de/

Kellele see võib puudutada,

meie, x-ion GmbH, oleme Saksamaal asuv „Infrastructure as a Service (IaaS)“ teenuse pakkuja.

Osaleme tehnilise võimaldajana nn projektis „HotSpot Drive“.

Täielik teenuse kirjeldus on esitatud lisas.

Äripartneriks/interneti teenusepakkujaks Eestis on T-Mobile HotSpot GmbH (TMHS).

a) TMHS on äripartner ja klienditeenindaja Eestis.

TMHS tegutseb ka andmete vastutava töötlejana.

b) x-ion vastutab andmete edastamise eest, ilma et tal oleks kliendisuhteid.

Soovime Teiega ühendust võtta, et selgitada x-ioni ja TMHS-i kohustusi.

Oleme uurinud erinevaid allikaid, kuid ei ole suutnud neile küsimustele täielikult vastata või peame need veel kord üle kontrollima, et olla kindlad.

Palun vaadake läbi ja vastake/edastage allpool esitatud küsimused ning saatke meile vastutavate isikute/osakondade/asutuste kontaktandmed.

Meie peamine eesmärk on saavutada täielik vastavus kohalikele seadustele ja asutustele.

Täname teid eelnevalt toetuse eest.

Lühike sissejuhatus

Nagu teenuse kirjelduses märgitud, ei kasuta TMHS Eestis ühtegi võrguseadet.

Selle teenuse osutamiseks kasutatakse ainult kohalike mobiilsideoperaatorite (MNO) rändlusteenuseid.

Paigaldatud SIM-kaardi on tarninud T-Mobile Austria GmbH. See SIM-kaart võimaldab rändlust kõigi Eestis tegutsevate mobiilsideoperaatorite võrkudes.

Soovime kuulda teie arvamust selle kohta, kuidas rakendada „seaduslikku pealtkuulamist” meie keskkonnas.

Me pakume seda teenust juba enam kui 10 Euroopa riigis.

Teistes riikides oleme alati leidnud väga lihtsa viisi kohalike õiguskaitseasutuste (LEA) toetamiseks.

Pealtkuulamisnõuetega seotud küsimused

Nõude korral anname paigaldatud SIM-kaardi IMSI numbri.

Selle teabe abil võtavad kohalikud õiguskaitseasutused ühendust kohalike mobiilsideoperaatoritega (kes on juba rakendanud pealtkuulamise mehhanismid)

ja jätkavad pealtkuulamist.

Kas see võiks olla sobiv lahendus ka teile/Eestis?

Lisaks soovime küsida teavet erinevate protseduuride ja tehniliste lahenduste kohta.

Meie, x-ion, tegutseme TMHS-i esindajana taotluste korral (DR: andmed või LI: seaduslik pealtkuulamine).

Lisatud dokumendis „LI-Gate – x-ion GmbH” on esitatud meie seadusliku pealtkuulamise ametnike kontaktandmed.

Kas Te aktsepteerite meilt, kolmandalt osapoolelt, lisatud „LI-Gate” dokumendi ja kas Te töötate sellega?
Kas lisatud „LI-Gate” dokumendis esitatud teave on piisav?

Täiendavad küsimused

Kuidas jõuavad andmete avaldamise taotlused meieni? (nt e-postiga)
Kas on vaja mingit spetsiaalset krüpteerimist?
Kas taotluste registreerimiseks on kehtestatud kohustused ja kui jah, siis kas nendele registritele on kehtestatud nõuded?
Milliseid andmeid ametiasutused taotlevad?
Kas taotluste puhul on kehtestatud kindel reageerimisaeg ja kättesaadavusaeg?

Millised on taotlusi käsitlevate töötajate oskused või õiguslikud nõuded (erialane kvalifikatsioon, keeleoskus jne)?
Millistele ametiasutustele tuleb andmeid/teavet edastada?

Parimate tervitustega,

Florian Wagner
Projektijuht regulatiivküsimuste alal

x-ion GmbH
Marschnerstr. 52
22081 Hamburg

https://www.x-ion.de/