1. Introduction

1. 1.1  We are committed to safeguarding the privacy of our website visitors and service users.

2. 1.2  This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

3. 1.3  We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

2. How we use your personal data

1. 2.1  In this Section 2 we have set out:

   1. (a)  the general categories of personal data that we may process;

   2. (b)  in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

   3. (c)  the purposes for which we may process personal data; and

   4. (d)  the legal bases of the processing.

2. 2.2  We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for providing our services, ensuring the security of our website and services and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3. 2.3  We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

4. 2.4  We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include name, address, contact details. The source of the service data is you or your employer. The service data may be processed for the purposes of providing our services and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

5. 2.5  We may process information relating to transactions, including purchases of goods and services that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

6. 2.6  We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is namely the proper management of our customer relationships.

7. 2.7  Please do not supply any other person's personal data to us, unless we prompt you to do so.

8. 3. Providing your personal data to others

9. 3.1  We may disclose contact details to our suppliers insofar as reasonably necessary for the provision/smooth running of telecom services.

10. 3.2  Financial transactions relating to our website products and services may be handled by our payment services providers, FastPay Ltd. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at www.fastpayltd.co.uk

11. 4. Retaining and deleting personal data

12. 4.1  This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

13. 4.2  Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

14. 4.3  We will retain your personal data as follows:

15. (a) Contact details will be retained for a minimum period of 1 month following the date of initial contact, and for a maximum period of 72 months following the date of initial contact.

16. 4.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

17. (a) the period of retention of contact details will be determined based on contractual obligations.

18. 5. Security of personal data

19. 5.1  We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

20. 5.2  We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

21. 5.3  You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

22. 6. Amendments

23. 6.1  We may update this policy from time to time by publishing a new version on our website.

24. 6.2  You should check this page occasionally to ensure you are happy with any changes to this policy.

25. 6.3  We may notify you of changes to this policy by email.

26. 7. Your rights

27. 7.1  In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

28. 7.2  Your principal rights under data protection law are:

29. (a)  the right to access;

30. (b)  the right to rectification;

31. (c)  the right to erasure;

32. (d)  the right to restrict processing;

33. (e)  the right to object to processing;

34. (f)  the right to data portability;

35. (g)  the right to complain to a supervisory authority; and

36. (h)  the right to withdraw consent.

37. 7.3  You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

38. 7.4  You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

39. 7.5  In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

40. 7.6  In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

41. 7.7  You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

42. 7.8  You have the right to object to our processing of your personal data for direct marketing purposes including profiling for direct marketing purposes. If you make such an objection, we will cease to process your personal data for this purpose.

43. 7.9  To the extent that the legal basis for our processing of your personal data is:

44. (a)  consent; or

45. (b)  that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

46. and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

47. 7.10  If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

48. 7.11  To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

49. 7.12  You may exercise any of your rights in relation to your personal data by written notice to us OR by email.

50. 8. Third party websites

51. 8.1  Our website may include hyperlinks to, and details of, third party websites.

52. 8.2  We have no control over, and are not responsible for, the privacy policies and practices of third parties.

53. 9. Personal data of children

54. 9.1  Our website and services are targeted at persons over the age of 18

55. 9.2  If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

56. 10. Updating information

57. 10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

58. 10. About cookies

59. 11.1  A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

60. 11.2  Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.