Honest Mobile T&Cs
1. These T&Cs
We’re Honest Enterprises Limited, a company registered in England and Wales with company number 11648112. Our registered office address is Trust House, 10 Guildhall Street, Grantham, United Kingdom, NG31 6NJ and our contact address is Honest Mobile c/o Workspace, Canterbury Court, Kennington Park, 1-3 Brixton Road, London, SW9 6DE. We trade using the name Honest Mobile. In these Ts&C references to “Honest Mobile”, “Honest” or “we” all mean Honest Enterprises Limited.
These T&Cs will apply to you when you place an order on the honest website (https://honestmobile.co.uk) (the Honest Website) or use an Honest SIM Card (SIM). Separate terms apply to the use of the website and our blog, which you can find here .
These T&Cs include important information on how we provide you with your mobile service and what to do if there’s a problem. If you do not agree to these Ts&C then don’t order an honest mobile plan (an Honest Plan) from us or stop using Honest’s service.
2. How to contact us
The fastest way to contact us is through the honest mobile or web application (the Honest App). You can also contact us by email (email@example.com) or by sending us a letter to Honest Mobile’s address . We’ll contact you through the Honest App or by email.
3. Your Honest Plan
Your Honest Mobile Plan starts from the day you activate your SIM in the Honest App. SIMs are normally delivered within 1-3 days of your order, but please let us know if your SIM doesn’t arrive.
When you set up an Honest Plan you’ll need to set up a payment method for your monthly payment on the Honest App. Once you have set up your payment method your SIM can be activated. You can change your payment method in the Honest App. The price for your Honest Plan will be shown in the Honest App. If your payments are late or overdue we may cancel your plan with immediate effect. We will try to warn you in advance of this happening.
Additional fees apply to any usage outside of your Honest Plan (for example if you make international calls). You can find these additional fees here . You can buy extra bolt-ons using the Honest App. Any additional fees or bolt-ons will be shown in the Honest App, and will be added to your monthly bill. Additional terms might apply to bolt-ons, these will be shown in the Honest App before you buy the bolt-on.
4. Other payments
We accept payment for phones and other services with the credit and debit cards listed on the Honest Website.
If you’ve ordered a phone, we’ll deliver your new phone to you as soon as reasonably possible, usually within 1-2 working days. We’ll usually contact you with the details to track your order once it has been dispatched. The phone you order from us will be your responsibility from the time we have delivered the order to the address you gave us. You’ll own the phone once we have received full payment for it.
6. Problems with our service
If our supply of your mobile service or the delivery of your phone is interrupted by an event outside our control then we’ll contact you as soon as possible and try to minimise the interruption. As long as we have tried to minimise the interruption we won’t be liable for short term interruptions to your mobile service or short delays in the delivery of your phone. If the interruption continues you might be able to cancel your Honest Plan under section 7.
If we need to suspend our services (e.g. to resolve technical problems or to implement important change in law or in our regulatory requirements), then we’ll contact you to let you know. We’ll be able to let you know in advance of any suspension unless it’s an emergency, in which case we’ll let you know as soon as reasonably possible. If we need to suspend our services for more than a few days we’ll refund you for the days you weren’t able to use your Honest Plan.
If our network is experiencing high demand or unusually high traffic we might need to slow down the speed of your mobile service. We might also need to suspend or terminate your mobile service if we think your use of the mobile service is affecting the network or other users.
If you’re making calls using your internet connection (for example by using Skype or WhatsApp to make calls), and you make a call to the emergency services, the emergency services may not be able to find your location. To ensure that the emergency services can find you, make sure you use your normal phone service to call the emergency services.
7. If there is a problem with your Honest Plan
If there is a problem with your Honest Plan or new phone, please contact us using the details above.
We’re responsible for providing our mobile service and any phone you order from us in a way which complies with this contract, and you have legal rights where our mobile service or the phone we have supplied is not as we have described or is faulty. A summary of your legal rights is available here .
8. Ending the contract
You can cancel your Honest Plan up to 14 days after you have activated your SIM (regardless of whether you have ordered a 30 day SIM or a 12 month SIM). If you cancel during this 14-day period we’ll refund you for your Honest Plan less the days you have used..
You can also return your new phone if you change your mind up to 14 days after you receive it. You will need to return the phone to us (we’ll send you a returns label) and the phone must be undamaged and in the same condition as you received it.
You can end your 30 day SIM by giving 30 days’ notice at any time or using a PAC code to leave us. You can end your 12 month sim at the end of the 12 month period, by cancelling your Honest Plan using the Honest App. If you’re a business you can cancel individual sims without cancelling your whole Honest Plan.
You can end your Honest Plan if we have breached these Ts&C, if we don’t provide the Honest Plan to you for a period of time or if we make a significant change to the way we provide you with your Honest Plan. If you end your Honest Plan for any of these reasons you’ll get a refund for any unused days on your Honest Plan that you have paid for but not received.
If you have a problem with your phone or if you don’t think your phone meets the description on our website please get in touch with us using the details above. You have the right to return your phone if it does not meet the description on our website or is faulty. If this is the case we will provide you with a refund once you have returned the phone to us (we’ll send you a returns label).
If we believe you (or any of your employees) are using or will use your Honest Plan fraudulently, illegally, to make nuisance, spam or automate calls/SMS, to threaten, harass, stalk, abuse, disrupt or otherwise violate or infringe the rights of others or in a way that harms our network or the experience of other users then we can cancel your Honest Plan straightaway.
If you or the phone number allocated to you appear on a consumer protection list, we have the right to end your Honest Plan and to withdraw your number. You can find details of what this is here .
9. Our responsibility to you
Nothing in these Ts&C will limit or exclude our liability for death or personal injury caused by our negligence (including the negligence of our employees, agents or subcontractors), or to the extent our liability cannot be excluded or limited under applicable law.
If you’re a consumer, nothing in these Ts&C will affect your legal rights as a consumer. You can find out more about these rights here .
If you’re a business, we exclude all implied terms that may apply to our site or any content on it and we will not be liable for loss of profits, business, or revenue, business interruption, loss of anticipated savings, or reputation, or any indirect or consequential damage.
10. Other important terms
If you have a complaint which we’ve not been able to resolve you can ask for it to be resolved using alternative dispute resolution. Alternative dispute resolution is a process where an independent body considers the facts of a dispute and seeks to resolve it, without you having to go to court. You can submit a complaint to the Centre for Effective Dispute Resolution here. CEDR will not charge you for making a complaint and if you are not satisfied with the outcome you can bring legal proceedings in court.
These Ts&C are governed by English law and you can bring legal proceedings in the English courts. If you live in Scotland you can bring legal proceedings in either the Scottish or the English courts. If you live in Northern Ireland you can bring legal proceedings in either the Northern Irish or the English courts.
Fair usage policy
The following Fair Usage Policy applies from the 01 April 2019.
Roaming in the EU and selected destinations
All our members have certain usage obligations which we ask that they consider as part of use of our Service in relation to our EU and selected destinations roaming. Generally speaking, these obligations require your use of our services to be for private, personal, and non-commercial purposes as we mention in our Terms and Conditions unless you have a business plan, but also extend to how you use roaming abroad.
These Fair Usage Guidelines explain your usage obligations when roaming in the EU and selected destinations, how to avoid breaching these obligations and what will happen if your usage breaches these obligations and falls outside this Fair Usage Guidelines.
You may only use our services in the EU and our other selected destinations (excluding the UK) for periodic travel, like holidays or short breaks. IIf you’re on our 100GB plan, there’s a 20GB fair usage policy outside the UK. Once you hit this, you’ll be charged at the out of bundle rate.
You must not engage in the organised, fraudulent resale of our services. If we reasonably suspect you to be doing so, we reserve the right to take appropriate action to stop such resale.
What to avoid:
Using our services for the first time outside of the UK, using a large volume of your allowance (be that text, calls or data) in the EU and our other selected destinations (excluding the UK), or using our services and travelling within the EU and our other selected destinations (excluding the UK) for prolonged periods which don’t follow reasonable consumer holiday and travel patterns and behaviour. If you use our services outside the UK in the EU and our other selected destinations for 63 or more days in any four-month period and you cannot demonstrate prevailing use or presence in the UK this is likely to be deemed to be an unfair use of our services. When this happens charges will apply (see below), but we will always contact you 14 days before this time to make you aware of this. These charges will cease to apply when your behaviour is in accordance with this policy.
Please remember that the examples above aren’t an exhaustive list of how you could be breaching our Fair Usage Policy. Other activities which we reasonably believe to be outside of legitimate consumer use may also be subject to the terms in this Fair Usage Policy.
What happens if your usage falls outside this Fair Usage policy?
Calls, texts and data:
If we reasonably suspect you’re not acting in accordance with this policy, we reserve the right to impose further charges or disconnect your SIM card or your subscription at any time, having attempted to contact you first.
A data controller is the organisation or person responsible for deciding how personal information is collected and stored and how it is used. We are the data controller of the personal information we collect, hold and use about you, as explained in this policy.
You can contact us by emailing us at firstname.lastname@example.org.
1. Details of personal information that we collect and hold about you
Personal information is any information from which a living individual can be identified. It does not include information where the identity of the individual has been fully and effectively removed (anonymous information).
We collect personal information about you, including:
|General Category||Types of Personal Information|
|Identity information||This is information relating to your identity such as your name (including any previous names and any titles that you use)|
|Contact information||This is information relating to your contact details such as email address, physical address, telephone numbers|
|Account information||This is information relating to your account with us (including username and password)|
|Payment information||This is information relating to the methods by which you provide payment to us such as bank account details, credit or debit card details and details of any payments you make (including amounts and dates)|
|Transaction information||This is information relating to transactions between us such as details of the goods, services and/or digital content provided to you and any returns|
|Survey information||This is information that we have collected from you or that you have provided to us in respect of surveys and feedback|
|Marketing information||This is information relating to your marketing and communications preferences|
|Communications information||Any other personal information you provide to us directly in the course of communicating with us.|
2. When is your personal information collected?
We collect and retain personal information about you that you have given us in different contexts, for example:
- Direct interactions: such as where you create an account with us, use our website, subscribe to our newsletter and/or correspond with us by post, phone, email or otherwise.
- Publicly available sources: we may collect your personal information from publicly available sources such as your organisation’s website or social media sites such as LinkedIn.
- Third parties’ services: we receive personal information from analytics providers such as Google Analytics.
3. Why we need your information and the legal bases we rely on
We will only use your personal information where this is consistent with our obligations under data protection law. Usually, we will use your personal information in the following circumstances:
- 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. For example, we have a legitimate interest in providing our services to you;
- Where it is necessary for the performance of a contract with you;
- Where it is necessary to comply with a legal obligation that applies to us (for example, reporting to HM Revenue and Customs or Companies House).
We use your personal information for the following purposes:
|Purpose||Type of data||Lawful basis for processing including legitimate interests|
|To provide you with our services||Account information, Contact information||Necessary to perform a contract with you|
|To receive payment for the services that we provide to you||Payment information, Usage information||Necessary to perform a contract with you|
|To keep records of the services we provide to you||Transaction information||Our legitimate interests in providing good customer service|
|To undertake research and receive feedback on the services we provide||Survey information||Our legitimate interests in improving and developing our business|
|To provide you with a response when you use our contact function on our website.||Identity information and Contact information||Our legitimate interests in promoting and developing our business|
|To administer and protect Honest Mobile, our services, our people, and our websites||Identity information and Contact information, Device information||For our legitimate interests (network security, to prevent fraud)|
To comply with laws
|To use data analytics to improve our website||Device information||Consent|
For our legitimate interests (defining categories of website users, keeping our website updated and informing our engagement strategy)
|To provide you with information relating to our services and other information that we think you might be interested in as well as ways to contribute – you can unsubscribe to emails using the link in the email||Identity information and Contact information, Marketing information.||For our legitimate interests and, where necessary, on the basis of your consent.|
|To communicate with you and handle concerns and queries||Identity information, Contact information and Communications information||Our legitimate interests in providing good customer service|
|Generally to protect our legal rights and comply with laws||All of the above||Our legitimate interests and to comply with laws.|
In some circumstances, we may ask for your consent to use your personal information for a specific purpose. In particular, we will seek your consent to send you any email marketing, newsletters or other communications about topics and events which we think might interest you.
You may unsubscribe from our email communications by following the instructions in any email that we send you, or you can withdraw your consent and request us to remove your personal information at any time by emailing us at email@example.com.
We do not carry out any automated decision-making using personal information which produces legal effects or otherwise significantly affects individuals.
4. Retaining your personal information
We will not keep personal information for longer than necessary, and the appropriate retention period will vary according to the intended purpose for which we collected the personal information.
The criteria we use to determine the retention period of personal information are: (i) the relevant statutory retention period; (ii) our contractual and/or business relationships with you; (iii) (potential) disputes; and (iv) any guidelines issued by relevant regulators. After expiration of the relevant period, the information is routinely deleted, as long as it is no longer necessary for the fulfilment of a contract, or to protect or defend our position or that of a third party. If you have any questions about our retention periods, please contact us at firstname.lastname@example.org.
5. How we share your personal information
We may share your personal information with third parties, including the following:
- with contractors, suppliers, or other third parties that provide services on our behalf (such as website host providers);
- as part of a sale, merger or acquisition, or other transfer of all or part of our assets including as part of a bankruptcy proceeding;
- pursuant to a court order, or other legal process or as otherwise required or requested by law, regulation, or government authorities, or to protect our rights or the rights or safety of third parties;
- with our professional advisors, lawyers, accountants and auditors; or
- with other third parties, on the basis of your consent.
6. Communications and marketing
Where you have provided consent, we will contact you by e-mail and text message, to keep you updated on products and features that you may be interested in.
You can opt-out from receiving our marketing communications, or update your contact preferences at any time by emailing email@example.com.
Social Media Advertising
You may receive targeted advertisements through our use of social media tools. For example, data collected from our website may be shared with Meta via our use of Meta Pixels. We may also provide your email address to Meta or another social media platform to check you have an account. Meta uses this information to display our ads on your social media page and to create ‘Lookalike’ audiences., so that we can advertise to potential new customers. We also use Facebook/ Meta ‘Custom’ and ‘Lookalike’ audience tools to enable us to display adverts to our existing customers.
We use data device collection tools such as pixels, cookies, application programming interfaces (APIs) and software development kits (SDKs) which are operated by third parties including TikTok and Google to collect information about how users use our website. This information is collected via the data device collection tools to provide measurement services or to target ads.
For more information about how you can opt in or out of Social Media Advertising see our cookies notice. You can also manage your social media ad preferences via the relevant social media platform –
- Facebook Custom Audiences guides
- Facebook Data Policy (also applies to Instagram)
- Twitter Privacy Notice
- Google Privacy Notice
- TikTok Privacy Notice
When we engage with Meta, TikTok or Google to identify you on their platforms and to provide you with our adverts, we are joint controllers of your personal information with those companies. Our agreements with Meta, TikTok and Google set out our responsibilities to you – for example, we are responsible for informing you about this activity. Both we and Meta, Google or TikTok are responsible for keeping your information secure. You can exercise your privacy rights against each of us individually.
If you do not want us to use your data for social media advertising you can opt-out by contacting us using the contact information in section 12. Please note that even if you opt-out you may still see adverts related to us. This is because the social media platform may receive information about you (such as the websites you have visited) that was not provided by us.
7. International data transfers
We do not currently transfer personal information we hold to a country outside the UK or the EU. If we do so, we will take steps to ensure that your personal information is protected in accordance with appropriate safeguards, especially where the recipient country is not considered to be adequate under UK or EU law. In particular, we will rely on the appropriate safeguards under data protection legislation, such as standard contractual clauses approved by the European Commission or a UK authority, as appropriate, to protect your personal information.
8. How we keep your personal information safe
To protect your privacy we will make sure your personal information is kept securely and disclosed only to relevant organisations or representatives who need to access it to perform their roles. We use appropriate organisational, technical and administrative measures to protect personal information within our organisation. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact us” section below.
9. Your rights
You have rights relating to your personal information under data protection law. These include the right:
- to request access to the personal information we hold about you;
- to request that we rectify or erase your personal information;
- to request that we restrict the processing of your personal information;
- to object to our processing of your personal information in certain circumstances;
- to ask us to port personal information about you that you have provided to us to you or to a third party; and
- to withdraw consent to processing your personal information, where we previously obtained your consent,
These rights may be limited, for example if answering your request would reveal personal information about another person or if you ask us to delete information which we are required by law to keep. To exercise any of these rights, or to make a complaint to us, you can get in touch using the details set out in the “Contact us” section below.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address is:
Information Commissioner’s Office
Helpline number: 0303 123 1113 ICO
A list of the EU data protection authorities and their contact details are here.
11. Updates to this Notice
12. Contact Us
Product privacy notice
We are Honest Enterprises Limited. We’re a company registered in England and Wales with company number 11648112, whose registered address is at Trust House, 10 Guildhall Street, Grantham, United Kingdom, NG31 6NJ. In this privacy notice, we will refer to ourselves as ‘we’, ‘us’ or ‘our’. We are the Data Controller of the personal information we collect, hold and use about you, as explained in this notice.
You can get hold of us by emailing us at firstname.lastname@example.org
We take the privacy, including the security, of personal information we hold about you seriously. This privacy notice is designed to inform you about how we collect personal information about you and how we use that personal information. You should read this privacy notice carefully so that you know and can understand why and how we use the personal information we collect and hold about you.
We do not have a data protection officer, but if you have any questions about this privacy notice or issues arising from it, you should contact Andy Aitken, who is responsible for matters relating to data protection at our organisation, including any matters in this privacy notice. You can contact them using the details set out above.
We may issue you with other privacy notices from time to time, including when we collect personal information from you. This privacy notice is intended to supplement these and does not override them.
We have a separate privacy notice in respect of our website, which you can access here (honestmobile.co.uk/legal).
We may update this privacy notice from time to time. This version was last updated on 11th September 2023.
1. Key definitions
1.1. The key terms that we use throughout this privacy notice are defined below, for ease:
1.2. Data Controller: under UK data protection law, this is the organisation or person responsible for deciding how personal information is collected and stored and how it is used.
1.3. Data Processor: a Data Controller may appoint another organisation or person to carry out certain tasks in relation to the personal information on behalf of, and on the written instructions of, the Data Controller. (This might be the hosting of a site containing personal data, for example, or providing an email marketing service that facilitates mass distribution of marketing material to a Data Controller’s customer base.)
1.4. Personal Information: in this privacy notice, we refer to your personal data as ‘personal information’. ‘Personal information’ means any information from which a living individual can be identified. It does not apply to information that has been anonymised.
2. Details of personal information that we collect and hold about you
2.1. Set out below are the general categories and details of retention periods in relation to those categories (see section 8 below for more details about retention)and in each case the types of personal information that we collect, use and hold about you:
|General Category||Types of Personal Data in that category|
|Identity information||This is information relating to your identity such as your name (including any previous names and any titles that you use), gender, marital status and date of birth||7 years from the end of the accounting period to which the information relates.|
|Contact information||This is information relating to your contact details such as email address, addresses, telephone numbers||7 years from the end of the accounting period to which the information relates.|
|Payment information||This is information relating to the methods by which you provide payment to us such as [bank account details, credit or debit card details] and details of any payments (including amounts and dates) that are made between us.||7 years from the end of the accounting period to which the information relates.|
|Transaction information||This is information relating to transactions between us such as details of the goods, services and/or digital content provided to you and any returns details||7 years from the end of the accounting period to which the information relates|
|Survey information||This is information that we have collected from you or that you have provided to us in respect of surveys and feedback.||7 years from the end of the accounting period to which the information relates.|
|Marketing information||This is information relating to your marketing and communications preferences.||7 years from the end of the accounting period to which the information relates.|
Website, Device and Technical Information
|This is information about your use of our website and technical data which we collect (including your IP address, the type of browser you are using and the version, the operating system you are using, details about the time zone and location settings on the device and other information we receive about your device)||Up to one year from your last interaction, after which your personal information will be removed.|
2.2. The types of personal data we collect about you may differ from person to person, depending on who you are and the relationship between us.
3. Details of special information that we collect and hold about you
3.1. We do not collect or hold any special information about you.
3.2. We do not collect information from you relating to criminal convictions or offences.
4. Details of how and why we use personal information
4.1. We are only able to use your personal information for certain legal reasons set out in data protection law. There are legal reasons under data protection law other than those listed below; but, in most cases, we will use your personal information for the following legal reasons:
Contract Reason: this is in order to perform our obligations to you under a contract we have entered into with you;
- Legitimate Interests Reason: this is where the use of your personal information is necessary for our (or a third party’s) legitimate interests, so long as that legitimate interest does not override your fundamental rights, freedoms or interests;
- Legal Obligation Reason: this is where we have to use your personal information in order to perform a legal obligation by which we are bound; and
- Consent Reason: this is where you have given us your consent to use your personal information for a specific reason or specific reasons.
4.2. So that we are able to provide you with services, we will need your personal information. If you do not provide us with the required personal information, we may be prevented from supplying the services to you.
4.3. It is important that you keep your personal information up to date. If any of your personal information changes, please contact us as soon as possible to let us know. If you do not do this, then we may be prevented from supplying the services to you.
4.4. Where we rely on consent for a specific purpose as the legal reason for processing your personal information, you have the right under data protection law to withdraw your consent at any time. If you do wish to withdraw your consent, please contact us using the details set out at the beginning of this notice. If we receive a request from you withdrawing your consent to a specific purpose, we will stop processing your personal information for that purpose, unless we have another legal reason for processing your personal information – in which case, we will confirm that reason to you.
4.5. We have explained below the different purposes for which we use your personal information and, in each case, the legal reason(s) allowing us to use your personal information. Please also note the following:
if we use the Legitimate Interests Reason as the legal reason for which we can use your personal information, we have also explained what that legitimate interest is; and
- for some of the purposes, we may have listed more than one legal reason on which we can use your personal information, because the legal reason may be different in different circumstances. If you need confirmation of the specific legal reason that we are relying on to use your personal data for that purpose, please contact us using the contact details set out at the start of this privacy notice.
|Legal Reason(s) for using the personal information|
|To enrol you as a customer|
Legitimate Interests Reason (in order to [offer you other goods, services and/or digital content which helps us to develop our business)
|To process your order, which includes taking payment from you, advising you of any updates in relation to your order or any enforcement action against you to recover payment|
Legitimate Interests Reason (in order to recover money that you owe us)
|To manage our contract with you and to notify you of any changes|
Legal Obligation Reason
|To comply with audit and accounting matters||Legal Obligation Reason|
|For record keeping, including in relation to any guarantees or warranties provided as part of the sale of goods, services and/or digital content|
Legal Obligation Reason
|To improve the goods, services, and/or digital content that we supply||Legitimate Interests Reason (in order to improve the goods, services, and/or digital content for future customers and to grow our business)|
|To recommend and send communications to you about goods, services, and/or digital content that you may be interested in. More details about marketing are set out in section 11 below|
Legitimate Interests Reason (in order to grow our business
4.6. Sometimes we may anonymise personal information so that you can no longer be identified from it and use this for our own purposes. In addition, sometimes we may use some of your personal information together with other people’s personal information to give us statistical information for our own purposes. Because this is grouped together with other personal information and you are not identifiable from that combined data we are able to use this.
4.7. Under data protection laws, we can only use your personal information for the purposes we have told you about, unless we consider that the new purpose is compatible with the purpose(s) we told you about. If we want to use your personal information for a different purpose that we do not think is compatible with the purpose(s) we told you about, then we will contact you to explain this and what legal reason is in place to allow us to do this.
5. Details of how we collect personal information and special information
5.1. We usually collect Identity Information, Contact Information, Payment Information, Transaction Information, Survey Information, Marketing Information, directly from you when you fill out a form, survey or questionnaire, purchase goods, services and/or digital content from us, contact us by email, telephone, in writing or otherwise. This includes the personal information that you provide to us when you subscribe to our mailing list enter a competition or survey.
5.2. We may receive some of your personal information from third parties or publicly available sources. This includes:
Contact Information and Payment Information from our selected third-party suppliers, such as LinkedIn or Crunchbase;
- Identity Information and Contact Information from publicly available sources such as Companies House
6. Details about who personal Information may be shared with
6.1. We may need to share your personal information with other organisations or people. These organisations include:
Third parties. These may include:
- Suppliers: such as IT support services, payment providers, administration providers, marketing agencies ;
- Government bodies and regulatory bodies: such as HMRC, fraud prevention agencies ;
- Our advisors: such as lawyers, accountants, auditors, insurance companies
- any organisations that propose to purchase our business and assets, in which case we may disclose your personal information to the potential purchaser.
6.2. Depending on the circumstances, the organisations or people who we share your personal information with will be acting as either Data Processors or Data Controllers. Where we share your personal information with a Data Processor, we will ensure that we have in place contracts that set out the responsibilities and obligations of us and them, including in respect of security of personal information.
6.3. We do not sell or trade any of the personal information that you have provided to us.
7. Details about transfers to countries outside of the EEA
7.1. If any transfer of personal information by us will mean that your personal information is transferred outside of the EEA, then we will ensure that safeguards are in place to ensure that a similar degree of protection is given to your personal information as is given to it within the EEA and that the transfer is made in compliance with data protection laws (including, where relevant, any exceptions to the general rules on transferring personal information outside of the EEA that are available to us – these are known as ‘derogations’ under the data protection legislation). We may need to transfer personal information outside of the EEA to the third parties listed above in section 6 who may be located outside of the EEA.
7.2. The safeguards set out in data protection laws for transferring personal information outside of the EEA include:
- where the transfer is to a country or territory that the EU Commission has approved as ensuring an adequate level of protection;
- where personal information is transferred to another organisation within our group, under an agreement covering this situation which is known as ‘binding corporate rules’;
- having in place a standard set of clauses that have been approved by the EU Commission;
- compliance with an approved code of conduct by a relevant data protection supervisory authority (in the UK, this is the Information Commissioner’s Office (ICO);
- certification with an approved certification mechanism;
- where the EU Commission has approved specific arrangements in respect of certain countries, such as the US Privacy Shield, in relation to organisations that have signed up to it in the USA.]
8. Details about how long we will hold your personal information
8.1. We will only hold your personal data for as long as is necessary. How long is necessary will depend upon the purposes for which we collected the personal information (see section 4 above) and whether we are under any legal obligation to keep the personal information (such as in relation to accounting or auditing records or for tax reasons). We may also need to keep personal information in case of any legal claims, including in relation to any guarantees or warranties that we have provided with the services or digital content.
8.2. We have set out above the details of our retention periods for different types of data. You can find them in section 2 .
9. Your rights under data protection law
9.1. Under data protection laws, you have certain rights in relation to your personal information, as follows:
- Right to request access: (this is often called ‘subject access’). This is the right to obtain from us a copy of the personal information that we hold about you. We must also provide you with certain other information in response to these requests to help you understand how your personal information is being used.
- Right to correction: this is the right to request that any incorrect personal data is corrected and that any incomplete personal data is completed.
- Right to erasure: (this is often called the ‘right to be forgotten’).This right only applies in certain circumstances. Where it does apply, you have the right to request us to erase all of your personal information.
- Right to restrict processing: this right only applies in certain circumstances. Where it does apply, you have the right to request us to restrict the processing of your personal information.
- Right to data portability: this right allows you to request us to transfer your personal information to someone else.
- Right to object: you have the right to object to us processing your personal information for direct marketing purposes. You also have the right to object to us processing personal information where our legal reason for doing so is the Legitimate Interests Reason (see section 4 above) and there is something about your particular situation that means that you want to object to us processing your personal information. In certain circumstances, you have the right to object to processing where such processing consists of profiling (including profiling for direct marketing).
9.2. In addition to the rights set out in section 9.1, where we rely on consent as the legal reason for using your personal information, you have the right to withdraw your consent. Further details about this are set out in section 4.5.
9.3. If you want to exercise any of the above rights in relation to your personal information, please contact us using the details set out at the beginning of this notice. If you do make a request, then please note:
- we may need certain information from you so that we can verify your identity;
- we do not charge a fee for exercising your rights unless your request is unfounded or excessive; and
- if your request is unfounded or excessive, then we may refuse to deal with your request.
10.1. You may receive marketing from us about similar goods and services, where either you have consented to this, or we have another legal reason by which we can contact you for marketing purposes.
10.2. However, we will give you the opportunity to manage how or if we market to you. In any email that we send to you, we provide a link to either unsubscribe or opt out, or to change your marketing preferences. If you have an account with us, you can login to your account and manage your preferences there too. To change your marketing preferences, and/or to request that we stop processing your personal information for marketing purposes , you can always contact us on the details set out at the beginning of this notice.
10.3. If you do request that we stop marketing to you, this will not prevent us from sending communications to you that are not to do with marketing (for example in relation to services and digital content that you have purchased from us).
10.4. We do not pass your personal information on to any third parties for marketing purposes.
11.1. If you are unhappy about the way that we have handled or used your personal information, you have the right to complain to the UK supervisory authority for data protection, which is the Information Commissioner’s Office (ICO). Please do contact us in the first instance if you wish to raise any queries or make a complaint in respect of our handling or use of your personal information, so that we have the opportunity to discuss this with you and to take steps to resolve the position. You can contact us using the details set out at the beginning of this privacy notice.
If you want to complain about our services, please use the form below. If we don’t resolve your complaint you can contact the Ombudsman Services as outlined in the website terms and conditions. They offer a free, independent service, but will only deal with your complaint if it’s still unresolved after 8 weeks or there is a deadlock situation.