- The information we collect and when
- How we use your information
- Who we might share your information with
- How we are keeping you updated on our products and services
- Your rights on your information
- How long we keep your information for
- How to contact us
Comms Unite Ltd is committed to protecting the privacy and security of your personal information. We take care to protect the privacy of our customers and users of our products and services that communicate (online or offline) with us, events, over the phone, websites and social media platforms.
2. The information we collect and when
We only collect information that we know we will genuinely use and in accordance with the General Data Protection Regulation (GDPR). The type of information that we will collect on you, and you voluntarily provide to us either over the phone, via our websites or communication (online or offline).
The types of data we collect about you include:
- Your first name, middle name, surname, username, title, date of birth, and gender
- Contact Data may include your billing address, delivery address, email address and any contact telephone numbers.
- Financial Data may include your bank account name, sort code, account number and/or payment card details
- Transaction Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, location, operating system and platform, and other technology on the devices you use.
- Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
We do not collect any Sensitive Data about you. Sensitive data refers to data that 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.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We collect information through a variety of different methods including:
- Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
- order our products or services;
- create an account on our site;
- subscribe to our service or publications;
- request resources or marketing be sent to you;
- enter a competition, prize draw, promotion or survey; or
- give us feedback.
- Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below analytics providers such as Google based outside the EU;
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
- Data will be created as part of the services and products we supply to you under support contracts and Service Level Agreements.
3. How we use your information
We will only use your personal datae when legally permitted. The most common uses of your personal data are:
- To contact you, following your enquiry, reply to any questions, suggestions, issues or complaint you have contacted us about.
- Where we need to perform the contract between us.
- Process your orders.
- Make available our products and services to you.
- Take payment from you, or to provide you with a refund.
- To power our security measures and services so you can safely access our website and mobile apps.
- 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.
- Help us to understand more about you as a customer, the products and services you consume so we can serve you better.
- Where we need to comply with a legal or regulatory obligation.
Please be aware we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at email@example.com
4. Who might we share your information with
We may share your personal data with other organisations in the following circumstances;
- Service providers of telecoms and broadband.
- Service providers of IT and system administration services.
- If the law or a public authority says we must share the personal data; or
- If we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk).
Your personal data is extremely important and as a requirement we expect all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
5. How we keep you updated on our products and services
You will receive marketing communications from us if you have:
- requested information from us or purchased goods or services from us; or
- if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
- in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by emailing us at firstname.lastname@example.org
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us email@example.com
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
6. Your rights over your information
6.1 Right to Access your personal information
You have the right to access the personal information that we hold about you in many circumstances, by making a request. This is sometimes termed ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge and aim to do so within 30 days from when your identity has been confirmed.
We would ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information.
If you would like to exercise this right, please contact us as set out below
6.2 Right to correction of your personal information
If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it.
If you would like to exercise this right, please contact us as set out below.
6.3 Right to stop or limit our processing of your data
You have the right to object to us processing your personal information if we are not entitled to use it any more, to have your information deleted if we are keeping it too long or have its processing restricted in certain circumstances.
If you would like to exercise this right, please contact us as set out below.
6.4 For more information about your privacy rights
The information Commissioners Office (ICO) regulates data protection and privacy matters in the UK. They make a lot of information accessible to consumers on their website and they ensure that the registered details of all data controllers such as ourselves are available publicly. You can access them here at https://ico.org.uk/for-the-public.
You can make a complaint to the ICO at any time about the way we use your information. However, we hope that you would consider raising any issue or complaint you have with us first. Your satisfaction is extremely important to us, and we will always do our very best to solve any problems you may have.
7. How long we keep your information for
We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including
or the purposes of satisfying any legal, accounting, or reporting 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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Some of the security measures we have in place are:
- Limiting access to our building to those that we believe are entitled to be there (by use of passes, key card access and other related technologies).
- Implemented access controls to our information technology
- We use appropriate procedures and technical security measures (including strict encryption, anonymisation and archiving techniques) to safeguard your information across all our computer systems, networks, websites, mobile apps, and offices.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. How to contact us
If you would like to exercise one of your rights as set out above, or you have a question about this policy, the way your personal information is processed, please contact us by one of the following means:
By email: firstname.lastname@example.org
By post: Office W2-01, Columba House, Adastral Park, Martlesham, Suffolk, IP5 3RE