Privacy Policy (after May 25th'18)

Introduction

Our privacy policy explains how we collect, use, share and protect your personal information. If we update this policy, we'll post any changes on our website so that you'll always know how your personal information is being used or shared.

We are Talkmobile Limited, registered with the Information Commissioner’s Office (ICO), registration number Z1030363

Your opinion matters to us – if you have any questions about our privacy policy, you can email us or direct your question to the Data Protection Officer at: customerdataquery@vodafone.com or you can contact us. If you would like to mail us by post directly, send it marked the “Privacy Team” to Vodafone House, The Connection, Newbury, Berkshire, RG14 2FN.

1. How we're collecting your personal information

a. We collect your personal information when you:

  • Buy a product or service from us (including buying products online, over the phone and in a retail store or other retail outlet);
  • Register for a specific product or service (such as registering your name and address details for a pay as you go phone or setting up an email account with us);
  • Subscribe to newsletters, alerts or other services from us;
  • Ask us for more information about a product or service or contact us with a question or complaint;
  • Respond to a competition, prize draw or survey;
  • Use our network and other Talkmobile products or services; or
  • Visit or browse our website.

b. We may also collect information about you from other organisations if this is appropriate, including fraud prevention agencies, business directories and credit reference agencies. We may also collect information about you from other companies, our business, or joint venture partners.

c. We may also use cookies (small text files stored in your browser) and other techniques, such as web beacons (small, clear picture files used to follow your movements on our website). These collect information that tells us how you use our websites, and web related products and services. This allows us to customise our website for you so that it is relevant to your interests and needs. We may use a persistent cookie (a cookie that stays linked to your browser) to record your details so that we can recognise you if you visit our website again.

You can choose to refuse cookies or you can set your browser to let you know each time that a website tries to set a cookie.

For more information about cookies (including information on how to turn them off) please visit www.allaboutcookies.org 

2. What personal information we're collecting

a. The information we collect about you will depend on the Talkmobile products and services you use and subscribe to. The information we collect includes, but is not limited to, the following,

  • Your name, address, phone number, date of birth and email address.
  • Credit or debit card information, information about your bank account number and sort code or other banking information.
  • Your preferences for particular products, services or lifestyle activities when you tell us what they are or when we assume what they are based on how you use our products and services.
  • Your contact with us, such as: a note or recording of a call you make to one of our contact centres; an email or letter you send to us; and other records of any contact you have with us.
  • Your account information, such as: dates of payment owed and received; top-up information; the subscription services you use; and any other information to do with your account.

b. We will also collect information about how you use our products and services, such as:

  • The phone numbers that you call or send messages to (or the phone numbers that you receive these calls and messages from);
  • The date, time and length of the calls and messages you send or receive through our network and your approximate location at the time these communications take place;
  • The level of service you receive, for example network faults and other network events which may affect our network services;
  • Your website browsing information (which includes information about the websites you visit and information about your browsing and how you use our website whether through your mobile or a PC); and
  • The date, time and length of your internet browsing and your approximate location at the time of browsing.

Talkmobile will process your personal data based on:

1.The performance of your contract or to enter into the contract and to take action on your requests. For example, so you can make calls and texts, and browse the internet on your phone, we process things like the numbers you dial, how much data you’re using and when you’re doing it so we can provide connectivity. This also enables us to generate your bill, based on your usage. We also need to conduct credit checks when you apply for a product or service.

2. Talkmobile’s legitimate business interests, for example, fraud prevention, maintaining the security of our network and services, direct marketing, and improvement of our services. Whenever we rely on this lawful basis to process your data, we assess our business interests to make sure they do not override your rights. Additionally, in some cases you have the right to object to this processing. For more information, visit the Your Rights section of this policy.

3. Compliance with a mandatory legal obligation, including for example accounting and tax requirements, which are subject to strict internal policies (such as retention periods), procedures, and your right to restrict usage of your data, which control the scope of legal assistance to be provided; or

4. Consent you provide where Talkmobile does not rely on another legal basis. Consent may be withdrawn at any time. When you give your consent, you will be given details on how to change your mind or visit the Your Rights section of this policy for more information.

3. Using your personal information

a. We may use and analyse your information to:

  • Carry out a credit check if you are applying for a contract for airtime services and to assess your application;
  • Process the goods and services that you have bought from us and keep you updated with the progress of your order;
  • Keep you informed generally about new products and services unless you do not want to receive our marketing messages;
  • Provide the relevant service or product to you, which includes other services not included in your agreement with us and services that use information about where you are when using your mobile equipment (location information), and to contact you with service related messages about changes to the service or product;
  • Contact you with offers or promotions based on how you use our products and services, including your calling and messaging activities, location information and browsing information. Where required, we will never do this without your permission;
  • Bill you for using our products or services or to take the appropriate amount of credit from you;
  • Respond to any questions or concerns that you may have about using our network, products or services;
  • Let you know about other companies products and services we think may interest you (including offers and discounts that we have specially negotiated for our customers);
  • Protect our network and to manage the volume of calls, texts and other use of our network (for example, we identify peak periods of use so that we can try and make sure that the network can handle the volume at those times;
  • Understand how our different customers use our network, products and services so we can develop more interesting and relevant products and services for our customers, as well as personalise the products and services we offer you;
  • Carry out research and statistical analysis and monitor customer use of our network, products and services;
  • Prevent and detect fraud or other crimes and recover debts or trace those who owe us money;

b. The location information that we use will be your approximate location based on the nearest mobile cell site. As a result, it will change as you move around with your mobile phone.

c. We will store your information for as long as we have to by law. If there is no legal requirement, we will only store your information for as long as we need it.

  • We’re required by law to keep certain personal information about how you use our services for 12 months. Some account information will be held for 6 years from the end of your contract with us.
  • We’ll keep some personal information for a reasonable period after your contract with us has finished in case you decide to use our services again. We, or one of our partners, may contact you about Vodafone services during this time if you haven’t opted out of receiving marketing communications from us.

4. Sharing your personal information

a. We may share information about you with:

  • Companies in the Talkmobile group of companies (Vodafone Group Plc and any company or organisation in which Vodafone Group Plc owns more than 15% of the share capital;
  • Partners or agents who are involved in delivering the products and services you have ordered or used;
  • Companies who are engaged to perform services for, on behalf of Talkmobile Limited or the Vodafone Group;
  • Credit-reference agencies, fraud prevention agencies, business scoring agencies or other credit scoring agencies;
  • Debt collection agencies or other debt recovery organisations;
  • Law enforcement agencies, regulatory organisations, courts or other public authorities if we have to or are authorised to by law; or
  • Emergency services (if you make an emergency call), including your approximate location.

b. We will release information if it is reasonable for the purpose of protecting us against fraud, defending our rights or property or to protect the interests of our customers.

c. If we are reorganised or are sold to another organisation, we may transfer any personal information we hold about you to that organisation.

d. We may need to transfer your information to other group companies or service providers in countries outside of the EEA (European Economic Area). The EEA consists of countries in the European Union, Switzerland, Iceland, Liechtenstein and Norway: they are considered to have equivalent laws when it comes to data protection and privacy. This may happen if our servers or suppliers and service providers are based outside of the EEA or if you use our services and products while visiting countries outside the EEA.

If Talkmobile sends your information to a country that is not in the EEA, we will make sure that your information is properly protected. We will always ensure that there is a proper legal agreement that covers the data transfer. In addition, if the country is not considered to have laws that are equivalent to EU data protection standards then we will ask the third party to enter into a legal agreement that reflects those standards.

e. We may share your information with partner organisations we have chosen carefully so that they might contact you about their products and services.

5. Security

a. We have specialised security teams who are constantly reviewing and improving our measures to protect your personal information from unauthorised access, accidental loss or destruction.

b. If we have a contract with another organisation to provide a service on our behalf, we will make sure they have appropriate security measures and only process your information as we have authorised.

Those organisations will not be entitled to use your personal information for their own purposes. If necessary, our security teams check these organisations to make sure that they are meeting the security requirements we have set.

c. Communications over the internet, such as emails, are not secure unless they have been encrypted.

Your communications may go through a number of countries before being delivered this is the nature of the internet. We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

6. Your privacy rights

Below we set out details on how you can exercise your rights. If you have a question or cannot find the answer, please contact our Customer Services team or email us at customerdataquery@vodafone.com

Right to correct personal data

You have the right to have information held about you corrected if it is not accurate. If what we hold on you needs updating, or you think it may be inaccurate, you can log in to My Account to update it (Login > My account) or contact our Customer Services team

Right to access personal data

You have the right to make a request for a copy of the personal data that Talkmobile holds about you. To make this request as an individual or an authorised 3rd party, see the section titled "Subject Access Request" below for details on how to do this.  

Right to data portability

You have the right to be able to take with your data you provided to us in certain circumstances. Talkmobile ensures that you can take your data with you by allowing you to download your monthly bills, at the click of a button. In order to do this, log in to My Account and go to your billing area.

Right to object to use of personal data

You have the right, in certain circumstances, to object to Talkmobile processing your personal information. Please contact our Customer Services team or email us at customerdataquery@vodafone.com

To opt out of Marketing messages

If you no longer want to receive marketing messages from Talkmobile, you can elect to opt out of all marketing communications or only selected methods (e.g. email, SMS MMS, phone or post).

There are various ways to opt out:

  • Log in to your Privacy Settings to manage your permissions;
  • Contact our customer services team;
  • Click the link at the end of a marketing email, SMS or MMS to unsubscribe;
  • Tell the adviser if you receive a marketing call;
  • Disable push notifications messages, including marketing messages, at any time in our apps by changing the notification setting on your device or by uninstalling the app;
  • Email customerdataquery@vodafone.com for guidance.

Opting out does not mean that you won't any longer receive service-related messages. You will still continue to receive those (unless we have indicated otherwise).

To opt out of receiving marketing communications from other Vodafone Group companies, just contact them directly.

To manage Cookies and understand more about what they are

Want to disable a cookie, or understand more about what these are? Check the Cookies policy for full details on how to do this..

How to lodge a complaint

If you want to contact us about any of your rights or complain about how we use your information, contact our Customer Services team or email us at customerdataquery@vodafone.com  We’ll do our best to help but if you’re still unhappy, you can contact the Information Commissioner’s Office. Their website www.ico.org.uk has details on how to contact them.

Right to restrict use of your data

If you feel data we hold on you is inaccurate or believe we shouldn’t be processing your data, please contact our Customer Services team to discuss your rights. In certain circumstances you will have the right to ask us to restrict processing.

Right to erasure

Talkmobile strives to only process and retain your data for as long as we need to. In certain circumstances you have the right to request that we erase personal data of yours that we hold. If you feel that we are retaining your data longer than we need, it is worth first checking that your contract with Talkmobile has been terminated which you can do with Customer Services. If your contract with Talkmobile has been terminated, we may still have lawful grounds to process your personal data. For more information on retention periods see paragraph c above under Section 3 “Using your personal information”.

Subject Access Request

The General Data Protection Regulation gives you the right to see personal information we hold about you. This is also known as a ‘Subject Access Request’ (SAR).

If you want copies of this information, please send us a written request with the following:

  • Your full name and address
  • Your Talkmobile account number
  • Details of any specific information you require
  • One proof of identity: we can accept a photocopy of either your birth certificate, your passport or your driver's licence;
  • One proof of identity of address: we can accept a photocopy of a recent credit or debit card statement, a utility bill showing the same name and address as on your Talkmobile account.

Please send your written request and proof of identity and address as follows:

By email to: customerdataquery@vodafone.com and in your request ask them to send you the link to upload your proof of identity and address documents;

By post to: Customer Relations, Talkmobile Limited, Shelton Boulevard, Stoke-on-Trent, ST1 5GP

We recommend you send your request by Recorded Delivery but this is not compulsory.

We have up to one calendar month (from 25th May 2018, and 40 days prior to that) from the date we receive your SAR to provide a response to you.  In some cases, this period may be extended and if that is the case, we will let you know.  In the meantime, we’ll let you know we’ve received your request.

Remember, to be able to act on your request, we will need to be able to verify your identity, and if you are authorised party acting on behalf of that individual, that you have the requisite authority to do so.

In some rare cases, we may need to charge you a reasonable fee or refuse to act on your request.  Where that is the case, we will let you know.

Talkmobile Limited is a Limited Liability Company registered in England and Wales under the number 04154716 with registered office located at Avon House, Horizon west, Canal View Road, Newbury, Berkshire, RG14 5XF. Copyright © 2015 Talkmobile Limited

Updated May 2018