LIT FIBRE GROUP LTD – PRIVACY NOTICE
1 IMPORTANT NOTICE
This is the Privacy Notice of Lit Fibre Group Ltd (company number 12560467) whose registered office is at 9 Greyfriars Road, Reading, England, RG1 1NU (“we”, “us” or “our”) and sets out how we collect and process your personal data. ‘Personal data’ means any information relating to an identified or identifiable natural person (a ‘data subject’): an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. This Privacy Notice also provides certain information that is legally required and lists your rights in relation to your personal data. Please read this Privacy Notice to understand how we may use your personal data. This Privacy Notice relates to personal information that identifies “you” meaning, by way of example, customers or potential customers or individuals who browse our website. If you are an employee, contractor or otherwise engaged in work for us or applying to work for us, a separate privacy notice applies to you instead. This Privacy Notice is not intended for children and we do not knowingly collect personal data relating to children. Additionally, this Privacy Notice is not intended to apply to personal data collected during the recruitment of employees, for which there is a separate privacy notice. This Privacy Notice may vary from time to time so please check it regularly.
2 HOW TO CONTACT US
This Privacy Notice applies where we are a controller in respect of your personal data – this is where we decide how and why your personal data is processed.
If you wish to correct your personal data held by us or to opt out at any time from receiving marketing correspondence from us or to alter your marketing preferences please contact firstname.lastname@example.org
If you need to contact us in connection with our use of, or the processing of your personal data, or to gain access to it our contact details are DPO@litfibre.com
3 CATEGORIES OF PERSONAL DATA WE COLLECT
The categories of personal data about you that we may collect, use, store, share and transfer are:
Individual Data. This includes personal data which relates to your identity, such as your first name, middle name, last name, username or similar identifier, marital status, title, date of birth and gender and your contact details such as your billing address, delivery address, email address and telephone numbers;
Advertising Data. This includes personal data which relates to your advertising preferences, such as information about your preferences in receiving marketing materials from us and our third parties and your communication preferences;
Information Technology Data. This includes personal data which relates to your use of our website, such as your internet protocol (IP) address, login data, traffic data, weblogs and other communication 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 our website
Account and Profile Data. This includes personal data which relates to your account or profile on our website, such as your username and password, purchases or orders made by you, your preferences, feedback and survey responses;
Economic and Financial Data. This includes personal data which relates to your finances, such as your bank account and payment card details and information which we collect from you for the purposes of the prevention of fraud;
Sales Data. This includes personal data which relates to the transactions you have conducted with us, such as details about payments to and from you, details of subscriptions to our services and other details of products and services you have purchased from us;
Audio and Visual Data. This includes personal data which is gathered using our CCTV or other recording systems in the form of images, video footage and sound recordings that is taken at any of our locations [or otherwise by us for promotional purposes]; and
Market Research Data. This includes personal data which is gathered for the purposes of market research, such as price comparison information.
We may also create Personal Data about you, for example, if you contact us by telephone to make a complaint, for example about our services or goods, then we may make a written record of key details of the conversation so that we can take steps to address the complaint.
We also obtain and use certain aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data may be derived from your personal data but does not directly or indirectly reveal your identity. For example, we may aggregate your Information Technology Data to calculate the percentage of users accessing a specific feature on our website. However, if we re-combine or re-connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
In addition, we may obtain certain special categories of your data / sensitive personal data, and this Privacy Notice specifically sets out how we may process these types of personal data. The special categories of data are: (i) personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; and (ii) the processing of genetic data, biometric data for the purposes of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
We do not collect any information about criminal convictions and offences.
4 THE SOURCES FROM WHICH WE OBTAIN YOUR PERSONAL DATA
We obtain your personal data from the following sources:
(a) Directly from you, either in person (at our locations or otherwise), via our website or by telephone or via hand held PDAs. This could include personal data which you provide when you
place an order for our products or services;
create an account on our website;
subscribe to our publications;
request information on our products or services or for other marketing to be sent to you;
enter into a competition or promotion; and
complete a survey from us or give us feedback.
(c) From someone else, such as:
analytics providers (such as Google Analytics)
our provider of customer feedback;#
our provider of online bookings;
search information providers;
data brokers or aggregators;
providers of social media platforms (such as Facebook, Twitter and Instagram) for example where you share our content through social media, for example by liking us on Facebook, following or tweeting about us on Twitter; and
(d) From publicly available sources, such as the electoral roll:
5 HOW WE USE YOUR PERSONAL DATA We collect personal data about you in order to: a) perform our contractual obligations to you. This would include:
processing and performing any orders placed by you;
making or receiving payments, fees and charges; and
collecting and recovering money owed.
b) manage our relationship with you including
to send you important notices such as communications about changes to our terms and conditions and policies (including this Privacy Notice);
to provide you with important real-time information about products or services you have ordered from us (e.g. a change of time or location due to unforeseen circumstances);
to send you information you have requested;
to deal with your enquiries; and
to ask you to leave a review or feedback on us;
c) administer our business and carry out business activities;
d) make suggestions and recommendations to you about goods or services that may be of interest to you, deliver relevant website content and advertisements to you and to measure or understand the effectiveness of our advertising;
e) communicate with you about, and administer your participation in, special events, programs, promotions, any prize draws or competitions;
f) for internal purposes to use data analytics, to identify usage trends, determine and measure the effectiveness of promotional campaigns and advertising and to improve our website, products/services, marketing, customer relationships and experiences;
g) protect our business including to deal with any misuse of our website and to comply with our security policies at our locations;
h) use your personal data to comply with our own legal and industry obligations e.g. to comply with health and safety requirements, or to assist in a police investigation;
6 OUR LAWFUL BASIS FOR PROCESSING YOUR PERSONAL DATA Where we may rely on consent
For certain purposes it may be appropriate for us to obtain your prior consent. The legal basis of consent is only used by us in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way. In the event that we rely on your consent, you may at any time withdraw the specific consent you give to our processing your personal data. Please contact us using the contact details set out in Section 1 to do so. Please note even if you withdraw consent for us to use your personal data for a particular purpose we may continue to rely on other lawful bases to process your personal data for other purposes.
Other legal bases we may rely on
Where we are relying on a basis other than your consent, the lawful basis for processing personal data will be one of the following:
a) the processing is necessary in order for us to comply with our legal obligations (such as compliance with anti-money laundering legislation);
b) the processing is necessary for the performance of a contract you are party to or in order to take steps at your request prior to you entering into a contract; c) the processing is necessary for the establishment, exercise or defence of legal claims; or
d) the processing is necessary for the pursuit of our legitimate business interests. In particular, our legitimate interests include:
the provision of goods and services;
the recovery of debt;
the provision of administration and / or IT services;
the security of our IT network;
the prevention of fraud;
marketing of goods and services and promotion of our business;
the reorganisation or sale or refinancing of the business;
the study in how to develop and the update of our products and services;
the development of our business strategy; and
protecting our business and property;
(e) the processing is necessary in order to protect the vital interests of an individual e.g. where there is a medical emergency at one of our premises.
7 WHO RECEIVES YOUR PERSONAL DATA
We may disclose your personal data to:
our group companies and affiliates or third party data processers who may process data on our behalf to enable us to carry out our usual business practices. Any such disclosure will only be so that we can process your personal data for the purposes set out in this Privacy Notice;
our PR agency;
HMRC, legal and other regulators or authorities, including Ofcom where relevant, and those who request your personal data or to report any potential or actual breach of applicable law or regulation;
external professional advisers such as accountants, bankers, insurers, auditors and lawyers;
law enforcement agencies, courts or other relevant party, to the extent necessary for the establishment, exercise or defence of legal rights;
third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
third parties which are considering or have decided to acquire some or all of our assets or shares, merge with us or to whom we may transfer our business (including in the event of a reorganisation, dissolution or liquidation); and
third parties operating plugins or content (such as Facebook, Twitter, Instagram) on our website which you choose to interact with
8 PERSONAL DATA ABOUT OTHER PEOPLE WHICH YOU PROVIDE TO US
If you provide personal data to us about someone else (such as someone you want to be added to your account, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Notice. You must ensure the individual concerned is aware of the various matters detailed in this Privacy Notice, as those matters relate to that individual, including our identity, how to contact us, the way in which we collect and use personal data and our personal data disclosure practices, that individual's right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided.
9 ACCURACY OF YOUR PERSONAL INFORMATION
It is important that the personal data we hold about you is accurate and current and we take all reasonable precautions to ensure that this is the case but we do not undertake to check or verify the accuracy of personal data provided by you. Please keep us informed if your personal data changes during your relationship with us either by logging onto your account on the website or by contacting us. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us. 10 INTERNATIONAL TRANSFERS OF PERSONAL DATA In connection with such transfers we will ensure that:
a) there are appropriate safeguards in place such as binding corporate rules or the approved EU model contractual clauses between us and the recipient (as per Article 46 GDPR (or English law equivalent)). A copy of the appropriate safeguard can be obtained by contacting us using the contact details set out in Section 2; or
b) one of the derogations for specific situations in the first sub-paragraph of Article 49(1) GDPR (or English law equivalent) applies to the transfer including explicit consent or necessary for the performance of a contract or exercise or defence of legal claims.
11 HOW LONG WE WILL STORE YOUR PERSONAL DATA FOR
We will only retain your personal data for as long as necessary to satisfy the purposes we collected it for, including for the purposes of fulfilling any legal, accounting, or reporting requirements. We keep the length of time that we hold your personal data for under review. These reviews take place annually.
12 CONTRACTUAL REQUIREMENTS ON YOU TO PROVIDE PERSONAL DATA
In certain circumstances the provision of personal data by you is a requirement to comply with the law or a contract, or necessary to enter into a contract. It is your choice as to whether you provide us with your personal data necessary to enter into a contract or as part of a contractual requirement. If you do not provide your personal data then the consequences of failing to provide your personal data are that we may not be able to perform to the level you expect under our contract with you. An example of this would be where we are unable to provide you with certain products or services as we do not have your full details, or where we cannot perform our contract with you at all because we rely on the personal data you provide in order to do so.
13 YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
Subject to applicable law including relevant data protection laws, in addition to your ability to withdraw any consent you have given to our processing your personal data (see Section 6), you may have a number of rights in connection with the processing of your personal data, including:
the right to request access to your personal data that we process or control;
the right to request rectification of any inaccuracies in your personal data or, taking into account the purposes of our processing, to request that incomplete data is completed;
the right to request, on legitimate grounds as specified in law:
(a) erasure of your personal data that we process or control; or (b) restriction of processing of your personal data that we process or control;
the right to object, on legitimate grounds as specified in law, to the processing of your personal data;
the right to receive your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller, to the extent applicable in law; and
the right to lodge complaints regarding the processing of your personal data with the Information Commissioner’s Office or other relevant supervisory body. Please see https://ico.org.uk/concerns/ for how to do this.
If you would like to exercise any of the rights set out above, please contact us using the contact details set out in Section 2.
14 LINKS TO OTHER WEBSITES