Simple Telecommunications LTD General Data Protection Regulation (GDPR)
Simple Telecommunications Ltd understands 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 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 new GDPR (General Data Protection Regulation).
1. Information About Us
Simple Telecommunications Ltd
Registered in England under company number 8283225
Registered address: BBS, Princes Court, Princes Road, Ferndown, Dorset. BH22 9JG
Main trading address: BBS, Princes Court, Princes Road, Ferndown, Dorset. BH22 9JG
VAT number: GB163249312
ICO Registration: ZA346087
Data Protection Officer: Mr A C Franklin May
Email address: firstname.lastname@example.org.
Telephone number: 0330 122 0000
Postal address: BBS, Princes Road, Ferndown, Dorset. BH22 9JG
Regulated by Ofcom, and the ICO
ADR registered with CISAS
VAT section 55a compliant
VAT registered with MOSS for EU TAX
PCI DSS data compliant – Level 4
2. What Does This Notice Cover?
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 (GDPR) relating to your personal data.
3. 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 5, below.
4. 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 or 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 or 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 you can ask us for a copy of your personal data held by us 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.
i) 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.
j) 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.
k) 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.
l) 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.
m) 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.
For more information about our use of your personal data or 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.
5. 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:
- Date of birth;
- Email address;
- Telephone number;
- Mobile number
- Business name;
- Job title;
- Payment information;
6. 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 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 sending us an email to email@example.com with the subject line opt-out.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message and post with information, news, and offers on our products and. You will not be sent any unlawful marketing or 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.
7. 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):
- All forms of data will be retained for a minimum period of 7 years, and for an indefinite period.
- Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
8. How and Where Do You Store or Transfer My Personal Data?
We will only store your personal data within the European Economic Area (the "EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
The security of your personal data is essential to us, and to protect your data, we take several important measures, including the following:
- Our billing system/s are GDPR compliant
- Our Sage invoicing systems are GDPR compliant
- Our Direct Debit Partner Go Card Less is GDPR complaint
- All Cloud storage is End To end encrypted and GDPR compliant
- Encryption standard AES-256 and RSA-4096 encryption, using 256-bit keys
- Google G Suite - 2-step verification with Security key enforcement policy in place
9. Do You Share My Personal Data?
We may share your personal data with other companies in our group for billing and provision of services. This includes subsidiaries of our holding company and its subsidiaries.
We may sometimes contract with the following third parties to supply products services to you on our behalf. These may include payment processing, delivery, telephone and broadband services and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
We may disclose personal or service data to our suppliers or subcontractors identified at point of order insofar as reasonably necessary in order to supply the products or services purchased.
We may disclose your enquiry data to one or more of those selected third party suppliers of goods and
services identified on our website for the purpose of quoting you an indicative price of a product or service.
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.
Financial transactions relating to our website and services maybe handled by our payment services providers, SagePay, Sage One and Mangopay and we will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments.
10. 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 or 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 or 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 28 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.
11. How Do 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 Mr A C Franklin May:
Email address: firstname.lastname@example.org.
Telephone number: 0330 122 0000.
Postal Address: BBS, Princes Road, Ferndown, Dorset. BH22 9JG.
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be made available at www.simpletelecoms.co.uk and www.simpletelecoms.com
13. GDPR Forms
2. GDPR - Data Portability Form
3. GDPR - Limitation of Data Processing Form
Last updated - 14/06/2018