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OneCloud
CONTENTS
* Introduction
* Our privacy promise
* Who we are
* Your rights
* How the law protects you
* Types of personal data we collect
* Where we collect personal data from
* Who we share your personal information with
* Purposes for which we will use your personal data
* Credit Checks
* Automated Decision Making
* How long we hold your personal data for
* Marketing
* If things go wrong and you wish to make a complaint
* Website & Live Chat
* Cookies
* Data Protection Officer Contact Details
* Supervisory Authority Contact Details
Privacy Policy
1. INTRODUCTION
This Privacy Policy:
1.1 Explains how Onecom uses your personal data, what we do to ensure the
safety and security of it, and who we share it with. It also informs you of your
rights and how the law protects you.
1.2 Applies when you visit our website, or if you (or your business) are a
customer, supplier or partner of Onecom.
1.3 Applies to former employees/staff of companies/businesses which have been
acquired by Onecom.
2. OUR PRIVACY PROMISE
We promise:
2.1 to keep your personal data safe and secure;
2.2 to give you ways to manage your marketing choices; and
2.3 not to sell your data.
3. WHO WE ARE
3.1 Onecom is a UK-based independent business telecommunications provider
delivering fixed line, mobile, unified communications and connectivity
solutions.
3.2 Onecom is a data controller, and is responsible for deciding how it holds
and uses your personal data. Certain parts of our business are managed by other
companies within the Onecom group, who may also act as a data controller in some
circumstances. When we use the expressions “Onecom”, “we” “us” and “our” in this
Privacy Policy, this refers to the applicable data controller within the Onecom
group. Please see our list of Onecom group companies.
3.3 If you are applying for a role with the Onecom group, please see our
Privacy Notice – Applicant.
3.4 Additionally, in some circumstances, Onecom may process your personal data
as a data processor acting on behalf of a data controller. In those situations,
the applicable data controller is responsible for deciding how your personal
data is collected and used.
3.5 You can find out more about us by visiting the About Us
4. YOUR RIGHTS
4.1 At any point while we are in possession of or processing your personal
data, you, the data subject, have the following rights:
4.1.1 Right of access – you have the right to request a copy of the personal
data that we hold about you.
4.1.2 Right of rectification – you have a right to correct personal data that
we hold about you that is inaccurate or incomplete.
4.1.3 Right to be forgotten – in certain circumstances, you can ask for the
personal data we hold about you to be erased from our records. Bear in mind, if
you ask us to erase your personal data from our records, we may purchase data in
the future that contains your information. We can however mark it as “do not
contact” therefore stopping any contact we may make to you.
4.1.4 Right to restriction of processing – where certain conditions apply, you
have a right to restrict our processing of your personal data.
4.1.5 Right of portability – you have the right to have the personal data we
hold about you transferred to another organisation.
4.1.6 Right to object – you have the right to object to certain types of
processing of your personal data, such as direct marketing.
4.2 To help us respond more quickly should you wish to exercise any of these
rights, please use the contact form. We may on occasion need to verify your
identity before addressing your request, in which case we will contact you to
request the relevant information.
4.3Should there be a third party involved in the processing of your personal
data, we will inform them of your request. If we are not the data controller in
relation to your personal data but are a data processor, it will be the data
controller’s responsibility to respond to your request.
5. HOW THE LAW PROTECTS YOU
5.1 As well as our Privacy Promise, your personal data is protected by law.
This section explains how that works.
5.2 Data protection law states that we are allowed to use personal data only
if we have a proper reason to do so. This includes sharing it outside Onecom.
The law says we must have one or more of the following reasons:
5.2.1 to fulfil a contract we have with you;
5.2.2 you have given us your consent;
5.2.3 it is necessary for compliance with a legal obligation that we are
subject to; and/or
5.2.4 it is in our legitimate interest.
5.3 A legitimate interest is when we have a business or commercial reason to
use your personal data, We make sure we consider and balance any potential
impact on you and your rights (both positive and negative) before we process
your personal data for our 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 or permitted to by law).
6. TYPES OF PERSONAL DATA WE COLLECT
6.1 Personal data means any information about an individual from which that
person can be identified.
6.2 We may collect, use, store and transfer different kinds of personal data
about you which we have grouped together as follows:
6.2.1 Identity Data includes title, first name, last name, username or similar
identifier.
6.2.2 Contact Data includes billing address, delivery address, email address
and telephone numbers.
6.2.3 Financial Data includes bank account and payment card details.
6.2.4 Transaction Data includes details about payments to and from you and
other details of products and services you have purchased from us.
6.2.5 Technical Data includes internet protocol (IP) address, your login data,
time zone setting and location, device ID and other technical information we may
have access to as a result of your use of our website and the products and
services you have purchased from us.
6.2.6 Profile Data includes your username and password, purchases or orders
made by you.
6.2.7 Usage Data includes information about how you interact with and use our
website, products and services.
6.2.8 Marketing and Communications Data includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
6.3 We also collect, use and share aggregated data such as statistical or
demographic data which is not personal data as it does not directly (or
indirectly) reveal your identity. For example, we may aggregate individuals'
Usage Data to calculate the percentage of users accessing a specific website
feature in order to analyse general trends in how users are interacting with our
website to help improve the website and our service offering.
7. WHERE WE COLLECT PERSONAL DATA FROM
We may collect personal data about you from these sources:
7.1 personal data you give us:
7.1.1 when you talk to us on the phone, in person or via the web;
7.1.2 when you use our websites or interact with us through social media;
7.1.3 in emails and letters;
7.1.4 when you buy our products and services – this includes banking details
for billing; and
7.1.5 when we buy your products and services;
7.2 personal data from third parties:
7.2.1 companies and people that pass us your personal data;
7.2.2 credit reference agencies; and
7.2.3 reputable data suppliers;
7.3 personal data from companies/businesses which have been acquired by
Onecom; and
7.4 personal data from publicly available sources such as information held in
Companies House, and information about you that is openly available on the
internet.
8. WHO WE SHARE YOUR PERSONAL DATA WITH
8.1 Onecom will not pass on your personal data to third parties unless at
least one of the following applies:
8.1.1 it is a requirement of the service or product you have with us, where
this will be detailed within the contract;
8.1.2 it is a prerequisite of a prospective service or product you intend to
have with us, where you will be notified beforehand;
8.1.3 we wish to undertake marketing to you with your consent or under our
legitimate interests; and/or
8.1.4 it is a legal requirement to do so.
8.2 We may share your personal data with the following parties for the
purposes set out in section 9 below:
8.2.1 companies within the Onecom group;
8.2.2 network service providers, or other sub-contractors engaged by us, who
provide the service agreed in your contract
8.2.3 other service providers if purchased through us, e.g. insurance
companies;
8.2.4 if you use direct debits, we will share your data with the Direct Debit
scheme;
8.2.5 debt collection agencies or other debt recovery organisations;
8.2.6 law enforcement agencies, regulatory organisations, courts or other
public authorities if we have to, or are authorised to do so by law and;
8.2.7 in the event that we sell or buy any business or assets or any third
party invests in our business, in which case we may disclose your personal data
to the prospective or actual seller, buyer or investor of such business or
assets as part of the process of evaluation and to ensure continuity of service.
8.3 Some of the personal data that we collect from you may be transferred to,
and stored at, a destination outside the UK This includes to our staff in India
or to service providers that carry out certain functions on our behalf. We will
take all steps necessary to ensure that your personal data is treated securely
and in accordance with this Privacy Policy and data protection laws.
8.4 Where we process your personal data as a data processor, we may share your
details with sub-processors. Please see our current List of Sub-processors.
9. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan
to use the various categories of your personal data, and which of the legal
bases we rely on to do so. We have also identified what our legitimate interests
are where appropriate.
Purpose of processing
Categories of
individuals
Types of
personal data
Our reasons (purpose for collection)
Lawful
basis for
processing
Retention
period
Marketing and responding to enquiries
Prospective customers / enquirers
Name(s), email address,
telephone
number(s),
work address, call
recordings,
IP address,
email communications, social media communications
Commercial proposition to sell telecommunication products and associated
services/products
Legitimate interests
Up to 6 years
Business email address
After 90 days if it’s not edited or being used in any active campaigns
Billing data
Reviewing historical mobile phone data
Legitimate interests
30 days
Marketing
Business customers
Name(s),
email address,
telephone number(s),
work address,
call recordings,
IP address,
email communication
Commercial proposition to sell telecommunication products and associated
services/products
Legitimate interests
Up to 6 years
Business email address
After 90 days if it’s not edited or being used in any active campaigns
Customer orders
Customers
Name(s),
email address,
telephone number(s), call recordings,
IP address, telephone numbers, xDSL, 4G routers,
banking details, date of birth, passwords, tokens and 2nd
factors of authentication,
user login ID, MAC address, email communication,
CCTV
Credit checks, fulfilling orders
Performance of contract
7 years + length of contract
Name(s), email address, telephone number(s), call recordings, IP address,
telephone numbers, xDSL, email communication
Protect our commercial interest against bad debt
Legitimate interests
7 years + length of contract
10. CREDIT CHECKS
10.1 When you make a request for the supply of any products or services from
us or any of our business partners and during the course of any such supply we
may carry out credit checks on you at any time. We will only use licensed credit
references agencies but such agencies will keep a record of our search on your
credit record.
10.2 We may search the electoral roll to verify your address.
10.3 We may use credit searches and other information, which is provided to us
or the credit agencies, about you and those who are linked financially to you,
if credit decisions are made about you, or other members of your household.
10.4 We will use this data to:
10.4.1 assess whether you or your business is able to afford to make payments;
10.4.2 make sure what you’ve told us is true and correct;
10.4.3 manage accounts with us; and
10.4.4 trace and recover debts
10.5 If at any time during the provision of any goods and services to you, you
fail to meet our credit conditions, we will contact you.
10.6 You can request a copy of your credit record by writing directly to the
credit agencies.
11. AUTOMATED DECISION MAKING
Onecom does not use automated processes for decision making. We may use a credit
reference agency to perform credit checks when you apply for products or
services with us however this is not an automated process; we use the credit
reference agency’s recommendations and then we will manually review and make our
decision based on this and other factors.
12. HOW LONG WE HOLD YOUR PERSONAL DATA FOR
12.1 The length of time we retain your personal data is dependent on what we
are holding and why we are holding it. We will not keep your personal data for
longer than is necessary for our business or legal requirements. To determine
the appropriate retention period for personal data, we consider the amount,
nature and sensitivity of the personal data, the potential risk of harm from
unauthorised use or disclosure of your personal data, the purposes for which we
process your personal data and whether we can achieve those purposes through
other means, and the applicable legal, regulatory, tax, accounting or other
requirements.
12.2 We may store your personal data in paper or electronic formats, both of
which are stored securely and based on the guidelines as specified in ISO/IEC
standards 17799, 27001 and 27002.
12.3 We also have processes in place to securely dispose of personal data we
no longer require.
13. MARKETING
13.1 We may use your personal data to tell you about relevant products and
offers. This is what we mean when we talk about ‘marketing’.
13.2 The personal data we have for you is made up of what you tell us and data
we collect when you use our services or from third parties we work with.
13.3 We study this to form a view on what we think you may want or need, or
what may be of interest to you. This is how we decide which products, services
and offers may be relevant for you.
13.4 We can only use your personal data to send you marketing messages via
email or text either if we have your consent to do so, or (if you are a
business) it falls under our ‘legitimate interest’.
13.5 We may phone or email you to offer these services using our ‘legitimate
interest’. That is when we have a business or commercial reason to use your
data. It must not unfairly go against what is right and best for you.
13.6 You can of course tell us if you wish to opt out of these calls or emails
at any time, either verbally whilst on the phone or by using the contact form on
this page.
13.7 You can ask us to stop sending you marketing messages by contacting us.
Or, if it’s an email marketing message you can simply click on the unsubscribe
link at the bottom of the email.
13.8 Whatever you choose, you still may occasionally receive other important
customer service information relating to your existing products and services.
13.9 If you change your mind, you can update your choices at any time by
contacting us.
14. IF THINGS GO WRONG AND YOU WISH TO MAKE A COMPLAINT
You have the right to make a complaint at any time to the Information
Commissioner’s Office, the UK regulator 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 our Data Protection
Officer in the first instance using the below details, or via this contact form.
15. WEBSITE & LIVE CHAT
15.1 With regard to each of your visits to our website we will automatically
collect technical information, information about your visit, including the full
Uniform Resource Locators (URL), clickstream to, through and from our site
(including date and time), products you viewed or searched for, page response
times, download errors, length of visits to certain pages, page interaction
information (such as scrolling, clicks, and mouse-overs). However, we do not
collect the Internet protocol (IP) address used to connect your computer to the
Internet.
15.2 Live Chat currently collects and stores your IP address.
16. COOKIES
Our website uses cookies to distinguish you from other users of our website.
This helps us to provide you with a good experience when you browse our website
and also allows us to improve our site. For detailed information on the cookies
we use and the purposes for which we use them, see our Cookies Policy.
17. DATA PROTECTION OFFICER CONTACT DETAILS
Address: Onecom House, 4400 Parkway, Solent Business Park, Fareham, Hampshire,
PO15 7FJ
Website: https://onecom.co.uk/
Email: privacy@onecom.co.uk
Telephone: 03300 888999
18. SUPERVISORY AUTHORITY CONTACT DETAILS
Name: Information Commissioners Office
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Website: https://ico.org.uk/
Email: casework@ico.org.uk or the contact form
at: https://ico.org.uk/global/contact-us
Telephone: 0303 123 1113
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The data you submit via this form will be used as detailed in our privacy policy
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time using the automated links provided on the emails we send, or by contacting
us as detailed in our privacy policy.
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