Hello Telecom GDPR
Welcome to Hello Telecom (UK) Ltd privacy notice (referred to as “Hello Telecom”, “we”, “us” or “our” in this privacy notice). Hello Telecom respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when: (a) you visit our website (regardless of where you visit it from); or (b) you enter into a contract with us for the purchase of products or services by signing our offline contract (whether signing it electronically or by wet signature); (c) your employer, or other business you are engaged by, enters into a contract with us for the purchase of products or services by signing our offline contract and provides us with your contact details; or (d) you become a shareholder of shares in our company; and tell you about your privacy rights and how the law protects you. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
Important information and who we are
Purpose of this privacy notice This privacy notice aims to give you information on how Hello Telecom collects and processes your personal data through: (a) your use of this website; or (b) you entering into an offline contract (whether signed electronically or by wet signature) with us for the purchase of products and services; (c) your employer, or other business you are engaged by, enters into a contract with us for the purchase of products or services by signing our offline contract and provides us with your contact details; or (d) you becoming a shareholder in our company. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. Controller Hello Telecom (UK) Ltd is the controller and responsible for your personal data. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights then please contact the data privacy manager. Contact details Our full details are: Full name of legal entity: Hello Telecom (UK) Ltd Name or title of current data privacy manager: Gary Arnold Email address of current data privacy manager: email@example.com Postal address: 19 Musters Road, West Bridgford, Nottingham, NG2 7PP. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Changes to the privacy notice and your duty to inform us of changes This version was last updated on 11/05/2018. The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until 25 May 2018 as we are still working towards getting our systems ready for some of these changes. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. Third-party links This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, feedback and survey responses.
- Usage Data includes information about how you use our website, products and telecommunication services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the total calls made and received so that we may optimise our network architecture and purchasing requirements to ensure the best possible service to you. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- complete and sign (electronically or by wet signature) our order form or contract;
- request marketing to be sent to you; or
- contact us through our website or give us some feedback.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers such as Google LLC based outside the EU;
- Identity, Contact, Financial and Transaction Data from providers of technical, payment and delivery services. For example, we use credit reference agencies to check and monitor your credit worthiness. At the moment, we use Experian Limited based inside the EU.
- Identity and Contact Data from your employer, or the business you are engaged by, to whom we are providing products or services.
- Identity and Contact Data from publicly available sources, such as Companies House, based inside the EU.
- Identity and Contact Data from our share registrar who hold information about our shareholders.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (for example, to send suggestions and recommendations to you about products or services that may be of interest to you, your employer or the business you are engaged by).
- Where we need to comply with a legal or regulatory obligation.
We generally do not rely on consent as a legal basis for processing your personal data, but where we do you have the right to withdraw consent to marketing at any time by contacting our data privacy manager using his contact details above. Purposes for which we will use your personal data We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest To register you as a new customer (a) Identity (b) Contact Performance of a contract with you To register your employer, or the business you are engaged by, as a new customer (a) Identity (b) Contact Necessary for our legitimate interests (to perform a contract with your employer or the business you are engaged by) To process and deliver your order including: (a) Manage payments, fees and charges (b) conduct a credit reference search to determine your creditworthiness; (b) Collect and recover money owed to us (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to limit your credit available to an amount for which you are creditworthy; and to recover debts due to us) To process and deliver an order placed by your employer, or the business you are engaged by, including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications Necessary for our legitimate interests (to: (a) perform a contract with your employer, or the business you are engaged by; and (b) recover debts due to us) To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice (b) Asking you to leave a review or take a survey (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) To manage our relationship with your employer, or the business you are engaged by, which will include: (a) Notifying them via you about changes to our terms or privacy notice (b) Asking them via you to leave a review or take a survey (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) To enable you to complete a survey (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical (b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) To make suggestions and recommendations to you about products or services that may be of interest to you, your employer or the business you are engaged by (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (a) Necessary for our legitimate interests (to develop our products/services and grow our business) (b) Consent To register you as an officer of our company or a new shareholder, and to maintain our register of officers and shareholders to our Annual General Meeting (a) Identity (b) Contact (a) Necessary for our legitimate interests (for running our business and understanding who our officers and shareholders are, and have been, and inviting our shareholders to attend our Annual General Meeting) (b) Necessary to comply with a legal obligation to maintain a register of officers and shareholders and to hold an Annual General Meeting.
Marketing We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms: Promotional offers from us We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us: (a) if you have requested information from us; or (b) you have purchased products or services from us (in which case such marketing communications will only be about similar products and services to those you have already purchased from us); or (c) you have consented; and, in each case, you have not opted out of receiving that marketing. Third-party marketing We will not share your personal data with any third party for marketing purposes. Opting out You can ask us to stop sending you marketing messages at any time by contacting us by telephone, email, or post using the contact details set out above. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions. Change of purpose We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
- We do not transfer your personal data outside the European Economic Area (EEA).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for? We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at firstname.lastname@example.org. In some circumstances you can ask us to delete your data: see Request erasure below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
- Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact us by telephone, post or email. No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
LAWFUL BASIS Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. Consent means processing your personal data where you have given your unambiguous consent to our processing of your personal data. THIRD PARTIES External Third Parties
- Service providers acting as processors based in the United Kingdom who provide IT and system administration services (such as our billing system provider).
- Service and equipment providers acting as processors or controllers based in the United Kingdom who provide us with equipment, facilities and services so we can perform our contract with you, or your employer or the business you are engaged by.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Companies House for the purpose of filing legally required information about our officers and shareholders.
YOUR LEGAL RIGHTS You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.