- Last Updated December 2022 Silux Mobile are committed to protecting your personal data and privacy. This policy tells you how we process your data – what data we collect, how we process and protect it and what rights you have
- In this policy: We are Silux Control LTD, Trading As Silux Mobile, of 13 Prospect House, Colliery Close, Staveley, Chesterfield, S43 3QE, hereinafter referred to as Silux Mobile. Where we refer to ‘we’, ‘us’ or ‘our’, this means Silux Mobile and our group companies. You are an individual about whom we hold personal information for one of the following reasons:
- You are a customer, or prospective customer of Silux Mobile or one of our group companies who enters a contract with us for our products or services;
- You have a contract, or are discussing arrangements with us, for access to your property to install our network;
- You visit www.siluxmobile.co.uk (our “site”);
- You have communicated with us at an event, or by phone, email, social media, surveys or other means.
- Silux Mobile is regulated by the Information Commissioner’s Office as a data controller and by Ofcom as a provider of Electronic Communications Services.
- OUR DATA PROTECTION PRINCIPLES Silux Mobile have several key principles in relation to the processing of personal data;
- We will be fair, lawful and transparent about how we use your personal data
- We will only use your personal data for the purpose we collected it
- We will only collect and process the minimum amount of personal data we need for that purpose
- We will always ensure your personal data is accurate
- We will only keep your personal data for as long as we need it
- We will always ensure that we keep your personal data secure
- INFORMATION WE MAY COLLECT FROM YOU We collect and process your data in several ways. Generally this is to provide you with the product or service you need or have asked for. We may collect and process the following data about you:
- Information you give us. You may give us information in several ways. These might include;
- filling in forms on our site or in person
- corresponding with us by phone, email or otherwise
- via our social media pages
- when you register interest in or purchase a product or service from us
- when you use our products and services
- via surveys, reviews and referrals
- at events we host
- Type of information we collect. The information we collect may include;
- contact details (your name, address, email, social media handle and phone numbers)
- bank account details
- health information and information about special requirements for vulnerable customers
- details of products and services you have with us
- call recordings with Customer Services
- CCTV images if you visit our offices
- Information we may collect about you on our website. When you visit our site, we may automatically collect the following information:
- limited personal, mostly anonymous technical information, including the Internet protocol (IP) address used to connect your device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- anonymous information about your visit, including the full Uniform Resource Locators (URL) you access, 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), methods used to browse away from the page and any phone number used to call our customer service numbers.
- Information we may collect about you from emails. When you receive an email from us, we may automatically collect the following information:
- Whether they are delivered to you
- Whether you open them (and time and date of opening)
- What links you click on
- Details of the type of device you have viewed on
- This information is used for analytical purposes to allow us to improve our service and communications to you.
- Information we may collect about you from social media. When you interact with one of our social media pages (including Facebook, Twitter and LinkedIn) we may automatically collect the following information:
- Posts you make
- Comments you make
- Name/profile handle
- Information we receive from other sources. We may obtain information about you from the following sources:
- public sources such as the Land Registry (to help us identify landowners for our network build)
- government – Department of Digital, Culture, Media and Sport (to administer Silux Mobile Vouchers)
- if you use any of the other websites we operate or the other services we provide – in this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site.
- third parties we work with including, for example
- business partners and sub-contractors
- suppliers
- payment and delivery services
- advertising networks
- social media networks and public posts
- analytics providers
- search information providers
- tracing and fraud prevention providers
- credit reference agencies
- Network Communications & Home Phone data. We may collect and retain certain types of communications data for any of the following purposes:
- traffic management and usage data
- billing
- customer and prospect enquiries
- anti-fraud measures
- when required to do so for legal or regulatory purposes
- Information collected by third parties Please note that third party service providers such as telephone, mobile phone, wi-fi or other communications service providers which provide a service to you using Silux Mobile’s Broadband, may also separately collect, access and retain data about you and your use of services across the Internet. They are controllers of the data they collect about you and you should ask them about their privacy policy. Our site may, from time to time, contain links to and from the websites of our partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal or confidential data to these websites.
- OUR USE OF YOUR INFORMATION This section explains how we will use your information and the legal basis we rely on to allow us to do that. We use information held about you in the following ways: Information you give to us. We will use this information:
- to carry out our obligations and to enforce our rights arising from any contracts entered between you and us and to provide you with the information, products and services that you request from us as part of those contracts (e.g., to install services or deliver products, billing)
- to notify you about changes to our service (e.g., terms and conditions, this privacy policy)
- to notify you about network maintenance, planned and unplanned outages;
- to manage Network Access Agreements. This may include sharing your information with other utility providers if we are using their infrastructure to deploy our network (e.g., shared ducts, poles). This information will not be used for any other purpose and is securely processed.
- to provide you with information about other services we offer, upgrades, special offers, events and other promotions
- to respond to any queries, complaints and requests
- to send you surveys from time to time
- to apply for Silux Mobile Vouchers on your behalf with your consent. This data will be shared with the Department for Culture, Media and Sport (DCMS) to administer the voucher scheme.
- to monitor the performance of our network build contractors
- to ensure that content from our site is presented in the most effective manner for you and for your computer or device
- to comply with any legal obligations we have because we run a business and because we are an Internet Service Provider and an Electronic Communications Provider
- monitoring what you do on the internet, i.e. what web sites you visit or the content of your emails, messages or calls. The only exception to this is where we are required to provide certain information to enable us to comply with any requirements imposed on us by law or court order.
- THE LEGAL BASIS OF OUR USE OF YOUR INFORMATION When using your information, we do so primarily to fulfil our contractual and legal obligations. Where we require your consent, we will use your information in accordance with that consent. We also use your information to enable us to run our business and to ensure the quality of our work. It is in our legitimate business interests to do this where this does not materially impact on your freedoms or rights. This would include using your information to assist the good governance of our business, provide you with the information you need, have asked for or would reasonably expect, management, accounting and auditing of our business and, for example, to monitor the service provided to us by third parties or when analysing traffic flows on our network to ensure all our customers have optimal service. If you communicate with us about our network build we will use your contact information to communicate with you and where necessary to ensure that our contractors communicate with you to investigate a complaint or rectify an issue. We will use your information to inform our quality control and management of our business and as part of our duties to promote health and safety at work.
- SHARING YOUR INFORMATION We may share your information with any member of our group, which means our subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We will not share your information for marketing purposes with companies outside our group unless we have specifically asked for your consent to do this We may share your information with selected third parties including
- business partners, suppliers and sub-contractors for the performance of any contract we enter with you. This includes our installation partners who will connect you to our mobile broadband service and operatives who may enter your property to install or repair our network. Third party suppliers will only be given access to your information for the purpose and the duration necessary and will be required to comply with our requirements regarding confidentiality and security of your information
- our professional advisers, to enable them to provide legal, accountancy and insurance services to our business
- regulators, Government and Local Councils where required to monitor and report on network build status and related matters
- analytics and search engine providers that assist us in the improvement and optimisation of our site
- credit reference agencies for assessing your credit score where this is a condition of us entering a contract with you
- tracing and Fraud prevention partners
- if we sell or buy any business or assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets.
- if Silux Mobile or substantially all its assets are acquired by a third party, in which case the information we hold about our customers will be one of the transferred assets.
- if we are under a duty to disclose or share information to comply with any legal obligation, or to enforce or apply our standard terms and other agreements; or to protect the rights, property, or safety of Silux Mobile, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- to comply with any legal obligations we have as an Internet Service Provider and an Electronic Communications Provider.
- PROCESSING YOUR INFORMATION All information we process about you is held securely. Any payment transactions will be made using authorised 3rd party payment gateways using appropriate encryption. The privacy policy of the appropriate provider will be displayed at the time of transaction. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. The data that we collect from you is primarily stored and managed in the UK, but some of our systems and other suppliers may transfer and store your information outside UK We will take all steps reasonably necessary to ensure that your data is treated securely and to the same standards as if it were being processed inside the UK in a way that is compliant with all applicable legislation governing data protection and security. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
- RETENTION OF YOUR INFORMATION We will only keep your data for as long as is necessary depending on the purpose for which we collected it. At the end of that period, we will either delete the information completely or anonymise it for statistical analysis and business planning. If you have a Network Access Agreement with us, we need to keep details of our agreement for as long as the equipment remains installed in your property. We also keep contact details for you in case we need to access your property for repairs or maintenance. We ask that you help us to keep that information accurate and up to date and if you sell your property, we request that you inform the new owner of our agreement (as it will apply to them) and ask them to get in touch with us.
- YOUR RIGHTS You have the following rights in relation to your information that we collect and process: Your Right Description Be Informed We hope that this Privacy Policy tells you what you need to know about how we use your information. If you would like any further information, please contact dataprotection@siluxmobile.co.uk Access You have the right ask us what information we hold and how we process it. Rectification You have the right to ask us to correct inaccurate information Erasure You have the right to ask us to erase the information we hold about you. However, there are some circumstances where this right does not apply, or where we are not required to comply with your request – for example if we need to retain your data for regulatory or other legal reasons. Restrict As an alternative to erasure, you may ask us to restrict certain processing Object You can object to certain aspects of our processing of your information Automated Decision Making & Profiling The right to request human intervention where we have relied on automated decision making or profiling. Portability Enables you to have a copy of your data given to you or transferred securely to another data controller For your security we may request verification prior to actioning your request. For more information or to exercise any of these rights please contact us at dataprotection@siluxmobile.co.uk.
- CHANGES TO THIS POLICY We will regularly review and update this policy. Any changes we make will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy. Previous changes to this policy are listed below
- • December 2022 Privacy Policy Created
- CONTACT Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to dataprotection@siluxmobile.co.uk. or in writing to; c/o The Data Protection Officer Silux Mobile 13 Prospect House Colliery Close, Staveley Chesterfield S43 3QE Our telephone number is 01246 912899
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