71-75 Shelton St, London WC2H 9JQ, UK
1. Introduction
Welcome to Fiberocity Limited’s Privacy Notice. Fiberocity respects your privacy and is committed to protecting your personal information. This document will tell you how we look after any personal information we collect from you or that you provide to us. It will also tell you about your privacy rights and how the law protects you. Please read it carefully to understand our views and practices regarding your personal information.
2. Important information and who we are
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Fiberocity collects and processes your personal data through your use of this website and our services, which includes any data you may provide through this website, over the phone or by email when you sign up to our newsletter, purchase a product or service or take part in a competition.It is important that you read this privacy notice together with any other privacy 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.
CONTROLLER
Fiberocity Limited is the controller and is responsible for your personal data (referred to as “Fiberocity”, “we”, “us” or “our” in this privacy notice). We have appointed a data protection officer (DPO) 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, please contact info@fiberocity.co.uk using the details set out below.
CONTACT DETAILS
Legal entity: Fiberocity Limited
Contact: Data Protection Officer
Email address: info@fiberocity.co.uk
Postal address: 71-75 Shelton St, London WC2H 9JQ, UK
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
Any changes to this privacy notice will be published on our website.
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.
3. 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 as follows:
IDENTITY DATA: First name, maiden name, last name, username or similar identifier, title and date of birth.
CONTACT DATA: Billing address, delivery address, email address and telephone numbers.
FINANCIAL DATA: Bank account and payment card details.
TRANSACTION DATA: Details about payments or communications to and from you and other details of products and services you have purchased from us.
TECHNICAL DATA: Internet protocol (IP) address, your login data, 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: Your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
USAGE DATA: Information about how you use our website, products and services.
MARKETING AND COMMUNICATIONS DATA: Your preferences in receiving marketing from us and your communication preferences.
IMAGE DATA: CCTV and Automatic Number Plate Recognition image data for staff, tenants and visitors to Fiberocity’s headquarters.
We also collect, use and share Aggregated Data such as statistical or demographic 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 reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can identify you in any way, we treat the combined data as personal data and it 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). We do not 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 that contract (for example, to provide you with services). In this case, we may have to cancel a service or order you have with us and we will notify you of this at the time.
4. How is your personal data collected?
We use different methods to collect data from and about you including through:
DIRECT INTERACTION
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us—or those acting on our behalf—by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
AUTOMATED TECHNOLOGIES OR INTERACTIONS
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
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 based inside and outside the EU;
• Contact, Financial and Transaction Data from providers of technical, payment and installation services such as Equifax or BT based inside and outside the EU;
• Identity and Contact Data from data brokers or aggregators based inside the EU;
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
5. 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 (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email, SMS, post or telephone. We will always ask for your express opt-in consent before we do so and you have the right to withdraw consent to marketing at any time by following the opt-out links on any marketing message we send to you or by contacting us at any time.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We set out below examples of how we use your personal data and the lawful bases relied upon:
• Register you as a new customer — Identity, Contact (performance of a contract).
• Process and deliver your order, manage payments/fees/charges, collect and recover money owed — Identity, Contact, Financial, Transaction, Marketing and Communications (performance of a contract; legitimate interests to recover debts).
• Manage our relationship (changes to terms/privacy notice; reviews/surveys; regulatory information) — Identity, Contact, Profile, Marketing and Communications (contract; legal obligation; legitimate interests to keep records updated and study usage).
• Enable participation in prize draws/competitions/surveys — Identity, Contact, Profile, Usage, Marketing and Communications (contract; legitimate interests to develop services and grow our business).
• Ask you to complete surveys via third-party providers — Identity, Contact (legitimate interests to understand and improve service levels and monitor third-party performance).
• Administer and protect our business and website (troubleshooting, data analysis, testing, system maintenance, support, reporting, hosting) — Identity, Contact, Technical (legitimate interests for running our business and network security; legal obligation).
• Deliver relevant website content/ads and measure effectiveness — Identity, Contact, Profile, Usage, Marketing and Communications, Technical (legitimate interests to develop services and inform marketing strategy).
• Use analytics to improve website, products/services, marketing, relationships and experiences — Technical, Usage (legitimate interests to define customer types, keep the website relevant, develop business and inform strategy).
• Make suggestions and recommendations about goods or services that may interest you — Identity, Contact, Technical, Usage, Profile (legitimate interests to develop products/services and grow our business).
• Monitor activity on and around Fiberocity’s Rochdale headquarters using CCTV — Identity (legitimate interests: prevention of crime; safety and security of staff, visitors and tenants).
• Assist with car park access at our headquarters using ANPR — Identity (legitimate interests to assist with access and management).
MARKETING
• Promotional offers and marketing communications: We may use Identity, Contact, Technical, Usage and Profile Data to determine products, services and offers that may be relevant for you. You may receive marketing communications if you have purchased services or requested information (e.g., quotes, basket activity, telephone enquiries) or provided details for competitions or promotions.
• Third-party marketing: We will obtain your express opt-in consent before sharing your personal data with any company for marketing purposes.
• Opting out: You can stop marketing messages at any time by using the opt-out links in our messages or by contacting us. Opting out does not affect service communications.
• Cookies: You can set your browser to refuse all or some cookies or to alert you when websites set or access cookies. Some parts of the website may not function properly without cookies. See our cookie policy for details.
• Change of purpose: We will only use your personal data for the purposes for which it was collected unless we reasonably consider that we need to use it for another compatible purpose. If we need to use it for an unrelated purpose, we will notify you and explain the legal basis.
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.
6. Disclosures of your personal data
We may share your personal data with:
• Service providers (inside and outside the EU) providing IT and system administration services;
• Professional advisers (UK) including lawyers, bankers, auditors and insurers;
• HM Revenue & Customs, regulators and other authorities (UK);
• Third parties in connection with business sales, transfers or mergers (new owners may use your personal data as set out in this notice);
• Market research companies;
• Fraud prevention and credit reference agencies;
• Specific third parties such as BT and other service providers we use to provide services to you, including One Touch Switching migration;
• Law enforcement agencies for the prevention of crime.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. They may only process your personal data for specified purposes and in accordance with our instructions.
INTERNATIONAL TRANSFERS
Some external third parties may be based or operate outside the EEA, so their processing of your personal data may involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure an equivalent level of protection through appropriate contractual safeguards. Please contact us for more information.
7. Data security
We have appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Access is limited to employees, agents, contractors and other third parties who have a business need to know and who are subject to confidentiality obligations. We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator where legally required.
8. Data retention
We retain personal information about our customers (including Contact, Identity, Financial and Transaction Data) for legal and tax purposes as well as accounting and reporting requirements.
Retention periods are determined by the amount and nature of the data, potential risk of harm from unauthorised use or disclosure, the purposes for processing and whether those purposes can be achieved by other means, and applicable legal requirements.
In some circumstances we may anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice.
9. Your legal rights
Subject to conditions in data protection laws, you have the right to:
• Request access to your personal data (data subject access request).
• Request correction of inaccurate or incomplete personal data.
• Request erasure of your personal data where there is no good reason for us continuing to process it, or where you have objected, or processing is unlawful, or we are required to erase it to comply with law.
• Object to processing where we rely on legitimate interests and your rights override those interests, and to object to direct marketing.
• Request restriction of processing in certain scenarios (accuracy contested; unlawful use; data needed for legal claims; pending verification of overriding interests).
• Request the transfer (portability) of your personal data to you or to a third party in a structured, commonly used, machine-readable format (applies to automated information processed by consent or for a contract).
• Withdraw consent at any time where consent is the legal basis (primarily marketing). Withdrawing consent does not affect the lawfulness of processing before withdrawal.
To exercise your rights, contact: info@fiberocity.co.uk.
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). We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or we may refuse to comply.
WHAT WE MAY NEED FROM YOU
We may need to request specific information to confirm your identity and ensure your right to access your personal data (or exercise other rights). We may also contact you to ask you to confirm your request in writing or to provide further information to speed up our response.
TIME LIMIT TO RESPOND
We aim to respond to all legitimate requests within one month. Occasionally it may take longer if your request is particularly complex or you have made multiple requests. In such cases, we will notify you and keep you updated.
10. Glossary of terms
Legitimate Interest: 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 balance any potential impact on you and your rights before processing for 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/permitted by law).
Performance of Contract: Processing your data where 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: Processing your personal data where necessary to comply with a legal or regulatory obligation to which we are subject.