We understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
2) What is personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. The personal data that we use is set out in Part 4, below.
3) What are my rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it, with your consent for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way. Part 6 explains more about how we use your personal data, including automated decision-making and profiling.
For more information about our use of your personal data exercising your rights as outlined above, please contact us using the details provided in Part 11. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
4) What personal data do you collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us:
· Your Name
· Your Date of birth
· Your Gender
· Your Address
· Your Email Address
· Your Telephone Number
· Your Business Name
· Your Job Title
· Your Profession
· Your Payment Information
· Your Business IP Address(s)
5) How do you use my personal data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for or may be used for one of the following purposes:
· Providing and managing your account.
· Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you.
· Personalising and tailoring our products and services for you.
· Communicating with you. This may include responding to emails or calls from you.
· Supplying you with information by email and post that you have opted-in to (you may unsubscribe or opt-out at any time by emailing us at firstname.lastname@example.org).
· To login to your business PC or Telephone System to carry out system maintenance
With your permission and, where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone and post with information, news, and offers on our products and services.
You will not be sent any unlawful marketing spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We use the following automated system for carrying out certain kinds of decision making and profiling. If at any point you wish to query any action that we take on the basis of this wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 10.
The following automated decision-making method(s) may be used:
· credit approval for leasing one or more of our products.
6) How long will you keep my personal data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
We keep your data while you have an account or contract with us, and sometimes for a longer period, depending on whether there are legal or regulatory reasons for doing so. Contact details, account details and payment history must be retained for seven years.
We have a legal obligation to keep your communications data for a minimum of 12 months. This includes the number calling, the number called and the time, date and duration of the call, text or fax. Law enforcement agencies have the right to access this data to support the investigation and prosecution of serious crime.
We do not keep the content of phone calls unless you have our Call Recording Service enabled, but you are free to delete your recordings at any time or we can do this for you on request. Voicemail messages stored on Hosted Telephone Systems are automatically deleted, normally after 12 months.
7) How and where do you store my personal data?
We will only store transfer your personal data in the UK. This means that it will be fully protected under the GDPR.
8) Do you share my personal data?
We may share your personal data with other companies in our group in order for us to supply our products and services to you. This includes or subsidiaries and our holding company and its subsidiaries.
We may sometimes contract with third parties to supply our products and services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
Your data may be shared with the following categories of third parties:
· Telecoms and broadband partners we work with – so that we can provide you with our products and services.
· Hardware suppliers and delivery companies – if you order VoIP telephones, networking equipment, Business Headsets or accessories from us.
· Payment processors – to enable you to make online payments for our products and services.
· Professional voice artists – when you order professional sound recordings from us.
· Telephone directories – when you ask us to list your numbers in a directory.
· Emergency services – Contact details must be provided to the Emergency Services for each of your UK phone numbers.
· Website analytics – We use Google Analytics to supply statistics on the usage of our website.
· Finance Applications – If a customer requests to lease one of our products company your details will be shared with them in order to receive a decision.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 7.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 7. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings complying with legal obligations, a court order, the instructions of a government authority.
9) How can I access my personal data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within 30 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
10) How can I contact you?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of James Beck):
Email address: email@example.com
Telephone number: 0800 8491555
Postal Address: 2a High Street, Lane End, Buckinghamshire, HP14 3GA
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, if we change our business in a way that affects personal data protection.
Any changes will be made available on our website.