Customer: an individual or business or other commercial organisation we engage with in relation to our business or broadband services;
User: any person accessing our Website.
Important information and who we are
What data do we collect?
If you fail to provide personal data
How do we collect your data?
How will we use your data?
Purposes for which we will use your personal data
How do we store your data?
What are cookies?
What types of cookies do we use and how do we use them?
How to manage your cookies
Important information about cookies
Change of purpose
Disclosures of your personal data
International transfers and Data Security
What are your data protection rights?
How to contact us
How to contact the appropriate authority
Email address: firstname.lastname@example.org
Postal address: 16 Young Street, Edinburgh, EH2 4JB
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Contact Data includes address, email address and telephone numbers.
Identity Data includes first name, last name, job title, employer/company details.
Financial Data includes bank account, direct debit and payment card details.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Technical Data includes internet protocol (IP) address, 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 this Website.
Profile Data includes your username and password, purchases or orders made by you, your preferences[, feedback and survey responses].
Usage Data includes information about how you use our Website and services.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the tables below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To enter into a contract with you, including processing your order and connecting your property.||(a) Identity|
|(a) Performance of a contract with you (b) To comply with our legal obligations|
|To liaise with you regarding our services.||(a) Identity|
|(a) Performance of a contract with you (b) Necessary for our legitimate interests.|
(d) Marketing and Communications
|(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how you use our services)|
|To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).||(a) Identity|
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.||(a) Identity|
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how Customers and Users use our services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our Website, Services, marketing, business relationships and experiences.||(a) Technical|
|Necessary for our legitimate interests (to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you.||(a) Identity|
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our services and grow our business)|
Highland Broadband securely stores your personal data.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We will normally keep your data for as long as you remain a Customer of us. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Profile, Technical, Usage and Marketing and Communications to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Cookies are text files placed on your computer. Some cookies we use are essential for parts of the Website to operate, some collect standard internet log information and visitor behaviour information. When you visit our Website, we may collect information from you automatically through cookies or similar technology.
For further information, visit allaboutcookies.org.
There are a number of different types of cookies, however, our Website uses:
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
|cookielawinfo-checkbox-performance||Necessary||This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Performance”.|
|cookielawinfo-checkbox-necessary||Necessary||This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category “Necessary”.|
|cookielawinfo-checkbox-others||Necessary||This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Other”.|
|cookielawinfo-checbox-functional||Necessary||The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category “Functional”.|
|cookielawinfo-checbox-analytics||Necessary||This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Analytics”.|
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table above:
|Service providers:||including those who provide: Web hosting, IT and system administration services such as Google, Inc. Third party service providers such as Plume Design, Inc. Metrics and analyticsMarketing services such as CX Services|
|Professional advisers:||including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.|
|Authorities:||including HMRC and other and authorities who require reporting of processing activities in certain circumstances.|
|Corporate partners:||includes third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.|
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Some of our external third parties may, from time to time, be based outside the United Kingdom (UK) so their processing of your personal data will involve a transfer of data outside the UK.
If we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
The table below sets out details of the services providers we use outside of the UK and the relevant safeguards in place.
|Service Provider||Description of service||Location||Safeguards|
|Plume Design, Inc||Provider of Smart Wi-Fi services||USA||Standard Contract Clauses (SCCs)|
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instruction and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Highland Broadband would like to make sure you are fully aware of all your data protection rights. Under data protection laws, every user is entitled to the following:
If you would like further information on how you can exercise these rights, please email us at email@example.com, or at any of the contact details listed below. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Should you wish to report a complaint or if you feel that Highland Broadband has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office.