PRIVACY POLICY
Policy version: February 2024
1
Introduction
This Privacy Policy is
provided by Dialledin Media Limited (trading as Fibre News) a company
registered in England and Wales under company number: 14304968 with registered
office Office 4 Wrentham Business Centre, Prospect Park, Exeter, United
Kingdom, EX4 6NA (‘we’, ‘our’ or ‘us’) for use of our
products and services including our website www.fibrenews.co.uk (Services).
We take your privacy
very seriously. Please read this privacy policy carefully as it contains
important information on how and why we collect, store, use and share any
information relating to you (your personal data).
It also explains your
rights in relation to your personal data and how to contact us or the relevant
regulator in the event you have a complaint. Our collection, storage, use and
sharing of your personal data is regulated by law, including under the UK General
Data Protection Regulation (UK GDPR).
We are the controller
of personal data obtained via the Services, meaning we are the organisation
legally responsible for deciding how and for what purposes it is used.
We have registered with
the Information Commissioner’s Office in the UK (ICO) with registration
number: ZB579110.
2
What this policy applies to
This privacy policy relates to your use of the Services only.
The Services may link
to or rely on other apps, websites, APIs or services owned and operated by us
or by certain trusted third parties to enable us to provide you with Services.
These other apps, websites, APIs or services may also gather information about
you in accordance with their own separate privacy policies. For privacy
information relating to these other apps, websites or services, please consult
their privacy policies as appropriate. For more information see the section ‘Who
we share your personal data with’ below.
3
Personal data we collect about
you
The personal data we
collect about you depends on the particular activities carried out through the Services.
We will collect and use the following personal data about you:
|
Category of data |
In more detail |
|
Identity and account data you
input into the Services. Registration is mandatory to
access some parts of the Services. |
·
Your name, phone number,
email address and home address |
|
Data collected when you use
specific functions in the Services |
Data you store online with us
using the Services including your usage history or preferences (while such
data may not always be personal data as defined at law in all cases we will
assume it is and treat it in accordance with this policy as if it were) |
|
Other data the Services
collects automatically when you use it |
·
Your activities on, and use
of, the Services which reveal your preferences, interests or manner of use of
the Services and the times of use ·
D |
|
Data collected when you make
an enquiry with us |
Your name, email address,
phone number, address |
If you do not provide
personal data we ask for where it is required, including the geo-localisation
services, it may prevent us from providing services and/or the Services to you.
We collect and use this
personal data for the purposes described in the section ‘How and why we use
your personal data’ below.
4
Sensitive Data
Sensitive personal data
(also known as special category data) means information related to personal
data revealing racial or ethnic origin; political opinions; religious or
philosophical beliefs; trade union membership; genetic data; biometric data
(where used for identification purposes); data concerning health; data
concerning a person’s sex life; and data concerning a person’s sexual
orientation.
Please note that we do
not knowingly or intentionally collect sensitive personal data or information
about criminal convictions from individuals and that you should not submit
sensitive data to us.
If, however you do
submit sensitive data to us, such as if you make this sensitive data available
to other users of the Services (such as by publishing it through any forum
feature we may make available from time to time) we will assume that you have
purposefully made any such sensitive data manifestly public.
5
Location services/data
The Services will
request your consent to use location services to precisely identify your
location each session (i.e. each time the Services is opened or has been placed
in the background for more than 30 seconds). We require access to that data in
order to provide you with accurate and/or relevant suggestions and
recommendations as part of the Services.
If you do not provide
your consent, you may use the Services but that will mean the “maps” feature on
the Services will not be available. To withdraw your consent at any time you
can turn off the localisation permissions for our app on your device.
The location services
in the Services will not operate unless location services/data are generally
enabled on your device. You may disable such functionality at any time by
turning your device’s location on “off” using the device’s settings app. When
you allow your device to use location services/data, data will also be
collected by Google in accordance with their Privacy Policy, as this is the map
service we integrate to our app.
We exert no control
over Google’s Privacy Policy and we therefore recommend that you consult their
privacy policy for further information on how Google protect personal data
please visit their site – https://policies.google.com/privacy?hl=en-US.
For more information see the section ‘Who we share your personal data with’
below.
6
How your personal data is
collected
We collect personal
data from you directly when you sign up to the Services, contact us directly or
reach out to us via social media, make submissions via the Services when a
forum element is available, or indirectly, such as your activity while using the
Services.
At this point in time,
we do not collect any personal information about you using cookies or similar
technologies. In the event that this were to change and if we were to decide to
collect personal data about you using cookies, you would be notified of this
change by means of in-app notification, with detailed information regarding our
use of cookies and similar technologies to be made available in the relevant
cookies policy.
7
How and why we use your
personal data
Under data protection
law, we can only use your personal data if we have a proper reason, e.g.:
(i)
where you have given consent
(ii)
to comply with our legal and
regulatory obligations
(iii)
for the performance of a
contract with you or to take steps at your request before entering into a
contract, or
(iv)
for our legitimate interests or
those of a third party
A legitimate interest
is when we have a business or commercial reason to use your information, so
long as this is not overridden by your own rights and interests. We will carry
out an assessment when relying on legitimate interests, to balance our interests
against your own. You can obtain details of this assessment by contacting us
(see ‘How to contact us’ below).
The table below
explains what we use your personal data for and why.
|
What we use your personal data for |
Our reasons
|
|
Create and manage your
account with us |
To perform our contract with
you or to take steps at your request before entering into a contract |
|
Providing services and/or the
functionalities of the Services to you |
Depending on the
circumstances: ·
to perform our contract with
you or to take steps at your request before entering into a contract (in this
case, the contract means the Terms and Conditions of Use which apply to the
Services) |
|
To connect you with third
party services you request via our Services |
If you sign up for a third party service via our Service (such as
signing up for an ISP connection), we will need to collect and process your
personal data (including sharing it with the third party company who will
provide the third party service (ISP Company)) in order to: –
provide you with our
Services; and –
connect you with the ISP
Company for their services.
|
|
To enforce legal rights or
defend or undertake legal proceedings |
Depending on the
circumstances: ·
to comply with our legal and
regulatory obligations ·
in other cases, for our
legitimate interests or those of a third party, i.e. to protect our business,
interests and rights or those of others |
|
Communications with you not
related to marketing, including about changes to our terms or policies or
changes to the Services or service or other important notices |
Depending on the
circumstances: ·
to comply with our legal and
regulatory obligations ·
in other cases, for our
legitimate interests or those of a third party, i.e., to provide the best
service to you |
|
Protect the security of
systems and data |
To comply with our legal and
regulatory obligations we may also use your personal data to ensure the
security of systems and data to a standard that goes beyond our legal
obligations, and in those cases our reasons are for our legitimate interests
or those of a third party, i.e., to protect systems and data and to prevent
and detect criminal activity that could be damaging for you and/or us |
|
Operational reasons, such as
improving efficiency, training, and quality control or to provide support to
you |
For our legitimate interests
or those of a third party, i.e., to be as efficient as we can so we can
deliver the best service to you |
|
Statistical analysis to help
us manage our business, e.g., in relation to our performance, customer base,
app and functionalities and offerings or other efficiency measures |
For our legitimate interests
or those of a third party, i.e. to be as efficient as we can so we can
deliver the best service to you and improve and develop our app |
|
Updating and enhancing user
records
|
Depending on the
circumstances: ·
to perform our contract with
you or to take steps at your request before entering into a contract (in this
case, the contract means the Terms and Conditions of Use which apply to the
Services) ·
to comply with our legal and
regulatory obligations ·
where neither of the above
apply, for our legitimate interests or those owf a third party, eg making
sure that we can keep in touch with our customers about their accounts and
new products or functionalities related to the Services and our services |
|
To comply with our legal and
regulatory obligations
|
Depending on the
circumstances: ·
to perform our contract with
you or to take steps at your request before entering into a contract (in this
case, the contract means the Terms and Conditions of Use which apply to the
Services) ·
to comply with our legal and
regulatory obligations where neither of the above
apply, for our legitimate interests or those of a third party, e.g. making
sure that we can keep in touch with our customers about their accounts and
new products or functionalities related to the Services and our services |
|
To share your personal data
with members of our group and third parties in connection with a significant
corporate transaction or restructuring, including a merger, acquisition,
asset sale, initial public offering or in the event of our insolvency. In such cases information
will be anonymised where possible and only shared where necessary |
Depending on the
circumstances: ·
to comply with our legal and
regulatory obligations ·
in other cases, for our
legitimate interests or those of a third party, i.e., to protect, realise or
grow the value in our business and assets |
See ‘Who we share
your personal data with’ for further information on the steps we will take
to protect your personal data where we need to share it with others.
8
Marketing
We intend to send you
email marketing to inform you of our services such as promotions.
We will always ask you
for your consent before doing sending you marketing communications, except
where you have explicitly opted-in to receiving email marketing from us in the
past or except where you were given the option to opt-out of email marketing
when you initially signed up for your account with us and you did not do so.
You will have the right
to opt out of receiving marketing communications at any time by:
o
contacting us at unsubscribe@fibrenews.co.uk
o
using the ‘unsubscribe’ link
included in all marketing emails you may received from us
We will always treat
your personal data with the utmost respect and never sell or share it with
other organisations for marketing purposes.
For more information on
your right to object at any time to your personal data being used for marketing
purposes, see ‘Your rights’ below.
9
Who we share your personal data
with
We routinely share
personal data with service providers we use to help us run our business or
provide the services or functionalities in the Services, including developers
and cloud storage providers, and Google, Inc. for Google Maps location
functionality. We exert no control over Google’s Privacy Policy and we
therefore recommend that you consult their privacy policy for further
information on how Google protect personal data – https://policies.google.com/privacy?hl=en-US
Our Services allow you
to sign up to receive services from third party providers, being the service
providers featured on our Service (ISP Companies), and we share your
data with the relevant ISP Company so you can receive their services. Their
privacy policies are available here:
1.
Gigabit Networks Ltd: https://gigabitnetworks.co.uk/gigabit-privacy-policy/
2.
Earth Broadband Limited: https://earthbroadband.com/legal/privacy
3.
Aerial Direct Limited: https://www.aerial-direct.co.uk/legal/privacy-cookies/
4.
Home Telecom: https://www.hometelecom.co.uk/contact-us?wpdmdl=1131
5.
Fusion Fibre Group Ltd: https://fusionfibregroup.co.uk/privacy-policy/
6.
BeSmart Utility Club: https://besmartuk.com/privacy-policy/
7.
BeFibre (Be Fibre Ltd): https://fusionfibregroup.co.uk/privacy-policy/
8.
Fiberly Limited: https://www.fibrely.co.uk/legal/privacy-policy
We only allow service
providers to handle your personal data if we are satisfied they take
appropriate measures to protect your personal data. We also impose contractual
obligations on service providers to ensure they can only use your personal data
to provide services to us and to you.
We or the third parties
mentioned above may occasionally also need to share your personal data with:
§
external auditors, e.g. in
relation to the audit of our accounts and our company —the recipient of the
information will be bound by confidentiality obligations
§
professional advisors (such as
lawyers and other advisors)—the recipient of the information will be bound by
confidentiality obligations
§
law enforcement agencies,
courts or tribunals and regulatory bodies to comply with legal and regulatory
obligations
§
other parties in connection
with a significant corporate transaction or restructuring, including a merger,
acquisition, asset sale, initial public offering or in the event of our
insolvency—usually, information will be anonymised but this may not always be
possible, however, the recipient of the information will be bound by
confidentiality obligations
If you would like more
information about who we share our data with and why, please contact us (see ‘How
to contact us’ below).
We will not share your
personal data with any other third party.
10
How long your personal data
will be kept
We will keep your
personal data for as long as you have an active account with us and for a
period of up to 6 years thereafter to comply with any accounting or legal
obligations including in the event of the pursuit or defence of legal claims.
Once you have closed your account with us, we will move your personal data to a
separate database so that only key stakeholders in our business on a ‘need to
know basis’ have access to such data.
Following the end of
the of the aforementioned retention period, we will delete or anonymise your
personal data.
11
Transferring your personal data
out of the UK
At this point in time,
we do not transfer your personal data outside of the UK. If this changes, we
would comply with applicable UK laws designed to ensure the continued
protection and privacy of your personal data. Any updated destinations to which
we send your personal data, would be indicated in the present section and
notified to you in accordance with the section on ‘Change to this privacy
policy’ below.
Furthermore, under UK
data protection laws, we can only transfer your personal data to a country
outside the UK where: the UK government has decided the particular country
ensures an adequate level of protection of personal data (known as an ‘adequacy
regulation’) further to Article 45 of the UK GDPR; there are appropriate
safeguards in place, together with enforceable rights and effective legal
remedies for you; or a specific exception applies under relevant data
protection law. Accordingly, if we were to start transferring your personal
data from the UK to:
§
The EEA: we would rely on the
adequacy finding granted by the UK to the EU under the Withdrawal Agreement to
do; for any transfers from the EU to the UK, we would rely on the adequacy
regulation granted to the UK under the Adequacy Decision.
§
Any country located outside the
UK/EEA: we would rely an appropriate safeguards under the UK GDPR, such as by
including the relevant Standard Contractual Clauses in our data processing
agreements
In the event we could
not or choose not to continue to rely on either of those mechanisms at any time
we would not transfer your personal data outside the UK unless we could do so
on the basis of an alternative mechanism or exception provided by UK data protection
law.
12
Your rights
You
generally have the following rights, which you can usually exercise free of
charge. For more information regarding these rights, please visit the ICO
website here.
|
Access to a copy of your
personal data |
The right to be provided with
a copy of your personal data. |
|
Correction (also known as
rectification) |
The right to require us to
correct any mistakes in your personal data. |
|
Erasure (also known as the
right to be forgotten) |
The right to require us to
delete your personal data—in certain situations. |
|
Restriction of use |
The right to require us to
restrict use of your personal data in certain circumstances, e.g. if you
contest the accuracy of the data. |
|
Data portability |
The right to receive the
personal data you provided to us, in a structured, commonly used and
machine-readable format and/or transmit that data to a third party—in certain
situations. |
|
To object to use |
The right to object: ·
at any time to your personal
data being used for direct marketing (including profiling) ·
in certain other situations
to our continued use of your personal data, e.g. where we use you personal
data for our legitimate interests.
|
|
Not to be subject to
decisions without human involvement |
The right not to be subject
to a decision based solely on automated processing (including profiling) that
produces legal effects concerning you or similarly significantly affects you We do not make any such
decisions based on data collected by the Services. |
For further information
on each of those rights, including the circumstances in which they do and do
not apply, please contact us (see ‘How to contact us’ below). You may also find
it helpful to refer to the guidance from the UK’s Information Commissioner on
your rights under the UK GDPR.
If you would like to
exercise any of those rights, please complete a request form—available on our
website at [insert link] or email , call or write to us—see below: ‘How to
contact us’. When contacting us please:
o
provide enough information to identify yourself (e.g., your
full name and username) and any additional identity information we may
reasonably request from you, and
o
let us know which right(s) you want to exercise and the
information to which your request relates
13
Keeping your personal data
secure
We have appropriate
security measures to prevent personal data from being accidentally lost, or
used or accessed unlawfully. We limit access to your personal data to those who
have a genuine business need to access it.
We also have procedures
in place to deal with any suspected data security breach. We will notify you
and any applicable regulator of a suspected data security breach where we are
legally required to do so.
If you want detailed
information from Get Safe Online on how to protect your information and your
computers and devices against fraud, identity theft, viruses and many other
online problems, please visit www.getsafeonline.org.
Get Safe Online is supported by HM Government and leading businesses.
14
How to complain
Please contact us if
you have any queries or concerns about our use of your information (see below ‘How
to contact us’). We hope we will be able to resolve any issues you may
have.
You also have the right
to lodge a complaint with the Information Commissioner.
The Information
Commissioner can be contacted at https://ico.org.uk/make-a-complaint
or telephone: 0303 123 1113.
15
Changes to this privacy policy
We may change this
privacy policy from time to time. When we make significant changes we will take
steps to inform you, for example via the Services or by other means, such as
email.
16
How to contact us
You can contact us by
post, email or telephone if you have any questions about this privacy policy or
the information we hold about you, to exercise a right under data protection
law or to make a complaint.
Our contact details are shown below:
§ Privacy Team
§ privacy@fibrenews.co.uk
§
02045998588