This privacy statement sets out how Guardian Mobile use and protect any personal data that you give us when you use this website or that we hold in connection with any of our products, services or offerings.

This privacy statement applies to users of our websites, customer contacts, supplier contacts and residential householders whose personal data is collected or used when you are accessing or using our websites or interacting with us.

Guardian Mobile’s respective responsibilities for data protection compliance are set out in this privacy statement.

We are committed to ensuring that your privacy is protected. We also want to ensure you are properly informed about how your information is used and that you receive certain information that we are required to give you by law, which is why we provide this privacy statement.

We may change this statement from time to time by updating this page. You should check this page from time to time to ensure that you are aware of and understand any changes.

The Information We Collect

We may collect, store and use personal data including:

• Information about your device and about your visits to and use of the website including IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, website navigation;
• Information provided when you register with us, subscribe to our website services and email notifications, or that you may send us via our website, email address or our business premises, for example when you make an enquiry;
• For business contacts at our existing and prospective customers, partners and suppliers / third party service providers, basic contact details such as name, address, telephone number, email address, Skype / messenger service details, LinkedIn profile details, job title and other information, such as details contained in commercial documentation;
• For customers, basic contact details such as name, address, telephone number, email address and personal healthcare information;
• Information that you may provide to our sales representatives, customer service team, trusted partners (as defined below) and third party service providers, for example, when they attend premises to carry out installations, when you contact us for pre or post-sales support, or at corporate events.

We may also obtain some information relating to you from trusted third parties such as our channel partners, our installation partners, our service provider partners and also providers of lead generation services.  We carry out due diligence and have contracts in place with such third parties to ensure they have obtained your information lawfully and can pass it on to us to use.

Using Your Information

We collect and securely store information about individuals for legitimate business purposes and in accordance with applicable data protection laws (including the General Data Protection Regulation (GDPR)) or the relevant national legislation.

Your personal data will be used for the purposes stated in this statement or such other purposes as we may notify you of from time to time, for example, on other parts of the website or in other relevant documentation.

Your personal data may be required by us from time to time in order to provide you with the best possible service and experience when using our website or our products or services, or to assess which products or services may best suit your needs or those of your business.

Specifically, information held about you may be used by us for the following reasons:

• To ensure that content from our website is presented in the most effective manner for you and for your device and to gain insights into how website users are using our website and to improve user experience;*
• To provide you with information (including information about network updates), products or services or take actions that you request;
• To provide you with promotional material which we feel may interest you (subject to the appropriate marketing permissions) – see ‘Marketing to business contacts’ below;*
• To provide third parties with statistical information about our web users (for example Google Analytics);*
• To allow you to participate in interactive features of our products and services (such as the availability checker), when you choose to do so;
• To notify you about changes to our products and services;
• For sales and lead generation, including for organising and attending corporate events and for marketing planning;*
• To undertake segmentation and demographical analysis to predict areas of demand;*
• To perform our obligations arising from or related to any contracts entered into between your business and us, and for effective customer account management, partner management and supply chain management, including performance monitoring and management;*
• To perform our obligations arising from any contracts between us and your service provider to deliver the connectivity requirements you have signed up to;
• To maintain risk and compliance records, and carry out compliance monitoring, incident management and investigations of relevant suppliers and third-party service providers;
• For internal administration, governance and recordkeeping and for business analytics, financial and accounts management and reporting purposes;*
• To help us prevent, detect and investigate fraud;*
• To meet our legal obligations or to bring or defend legal claims;
• To maintain the security of our websites, services, systems and assets, as well as to detect and investigate activities that may be illegal or prohibited.*

In more legal terms, we process your personal data where you have consented to this or where this is necessary to provide services or take actions that you have requested, to perform our legal and regulatory obligations or for the purposes of our legitimate interests. We have legitimate interests in those uses of personal data indicated with a “*” above.

We consider the risk to your rights of data protection is not excessive or overly intrusive and is overridden by our legitimate interests.  We have also implemented protections for your rights by ensuring proper retention periods and security controls, and your other rights under this privacy notice (if applicable).

*You can object to processing on this basis at any time by contacting us using the contact details below. See also “Your rights” regarding your right to object below.

Marketing

We may periodically send promotional information to you by email, phone or mail about new products, special offers, service updates, local events or other information from us, our affiliate companies, or our approved third party partners which we think you may find interesting and relevant, using the contact details which you have provided.

In practice, you will usually either expressly agree in advance to our use of your personal data for marketing purposes, or we will provide you with an opportunity to opt-out of the use of your personal data for marketing purposes.

Please follow the “unsubscribe” or opt-out process in any of our communications or email  enquiries@guardianmobile.co.uk  at any time with “Unsubscribe” in the subject line if you do not wish to receive such information.

Third Party Services and Websites

We may, from time to time, engage the services of other parties for the provision of services related to payment handling, delivery of purchased items or services, search engine facilities, hosting and IT services, advertising and marketing and network activities (such as installation, testing, repair, upgrade or removal). The providers of such services may be granted access to certain personal data to the extent strictly necessary for them to perform the services that we request. Any personal data that is processed by third parties must be processed in accordance with data protection laws and subject to contractual obligations, including regarding security and confidentiality.

Where our website contains links to other websites, we are not responsible for the privacy policies or practices of such third-party websites.

Disclosures

We may disclose information about you to any of our employees, officers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes as set out in this privacy statement. We may also disclose your personal data:

• To other companies in our corporate group for the purposes of internal administration, governance and recordkeeping, business analytics, financial and account management and reporting purposes;
• To other companies that provide essential support to our service network, such as (where relevant) our network integrators and resellers, data centres and mobile operators and our wholesale channel partner (“trusted partners”);
• To authorised third parties providing a service on our behalf or in connection with our business, including our insurers and professional advisors;
• To the extent that we are required to do so by law, including by regulators, courts or law enforcement agencies;
• In connection with any legal proceedings or prospective legal proceedings;
• In order to establish, exercise or defend our legal rights;
• For the purposes of fraud prevention and reducing credit risk;
• To the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
• To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information,

or as otherwise set out in this privacy statement.

International Data Transfers

Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information as set out in this privacy statement, in particular to provide you with our products or services. Currently this is only within the UK.

Some of our trusted partners who have access to your personal data may be located or transfer or host data outside the European Economic Area (EEA).  Additionally, some of the third-party service providers we use who have access to your personal data may be located or transfer or host data outside the EEA.

In these circumstances, we will ensure your personal data is processed under strict organisational and contractual controls, specifically EU model clauses or the EU-US Privacy Shield framework for transfers to the U.S.  For more information about these controls and how to access a copy, please visit the ‘International transfers’ section of the ICO website:  https://ico.org.uk or contact us using the contact details below.

Security Of Your Personal Information

We are committed to ensuring that your information is secure. We have put in place appropriate technical and organisational measures to safeguard and secure your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access.

You are responsible for keeping your password and user details for any restricted areas of our websites confidential and for implementing your own security measures to protect your information, network and devices. We will not ask you for your password (except when you log in to the website).

How we use cookies

We use cookies in a number of ways on our website, which include improving user experience of our website or online services and remembering information about your preferences.  You have choices about how you want cookies to be used.  For further information about how we use cookies and how to update your preferences, see our Cookies Policy.

Retaining Your Personal Data

We will retain your personal data for as long as we are obliged, under relevant legislation and regulation, or otherwise for no longer than it is necessary for our lawful purposes.  We securely erase it once no longer needed.

The retention period of your personal data may need to be extended where we require this to bring or defend legal claims.  We may also retain data for longer periods for statistical purposes, and if so we will anonymise or pseudonymise this.

Your Rights

You have the following rights regarding your information (each of which is subject to various exceptions and limitations):

To make a request to exercise any of your rights in relation to your information, please contact:

Attention: Company Secretary

Guardian Mobile

At our registered address below.

To find out more about these rights, visit the UK Information Commissioner’s Office (ICO) website: ico.org.uk

If you are not satisfied with our response to your request or believe our processing of your information does not comply with data protection law, you can make a complaint to the ICO: https://ico.org.uk/concerns/.

Contact

If you have any questions about this privacy statement or our treatment of your personal data, please contact us:

Attention: Company Secretary

Guardian Mobile

support@guardianmobile.co.uk

This Privacy Statement will be reviewed annually and amended as required.