1. How your personal information is used
In compliance with the new General Data Protection Policy Regulation (GDPR) we have updated our policies with regards to how we use your data below. This will be implemented from 25th May 2018. You don’t have to do anything but if you have any questions, feel free to contact us on 0800 144 88 44/0330 100 2500.
Your information will be held by Go Get Headsets Ltd, a company registered in England with number, and whose registered office is at The Victoria Foundry, 17 Marshall Street, Leeds, LS11 9EH. We are part of the iFace Group of companies and may from time to time share your information within the group.
2. How we use your personal information
This privacy notice is to let you know how companies within the Group promise to look after your personal information. This includes what you tell us about you, what we learn by having you as a customer, and the choices you give us about what marketing you want us to send you. This notice explains how we do this and tells you about your privacy rights and how the law protects you.
Our Privacy Promise
- To keep your data safe and private.
- Not to sell your data.
- To give you ways to manage and review your marketing choices at anytime.
This notice sets out most of your rights under the new laws.
3. Who we are
The iFace Group is made up of a group of separate legal entities. These include Go Get Headsets Ltd, iFace Solutions Limited (Co no. 10671819), iFace Group Ltd (Co no. 1161821), Go Get Tech Ltd (Co no. 11219099) and Artriom Ltd (Co no. 08521555). We will let you know which one you have a relationship with, when you take out a product or service with us.
You can find out more about us at www.gogetheadsets.co.uk
If you have any questions, or want more details about how we use your personal information, you can ask us by calling us on 0330 1002500 or emailing us at firstname.lastname@example.org
4. How the law protects you
As well as our Privacy Promise, your privacy is protected by law. This section explains how that works.
Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside iFace Group. The law says we must have one or more of these reasons:
- To fulfil a contract we have with you, or
- When it is our legal duty, or
- When it is in our legitimate interest, or
- When you consent to it.
A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.
Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.
|What we use your personal information for:||Our reasons||Our legitimate interests|
Groups of Personal Information
We use many different types of personal information, and group them together like this.
|Types of personal information||Description|
|Financial||Your payment information including account details.|
|Contact||Your business address and how to contact you.|
|Transactional||Details about payments to and from the accounts you have with us.|
|Contractual||Details about the products or services that we provide to you.|
|Locational|| Data we get about where you are, such as may come from your service installation address or
company registered address.
|Behavioural||Details about how you use our products and services.|
|Technical||Details on the devices and technology you use with us.|
|Communications||What we learn about you from letters, emails, and conversations between us.|
|Usage Data||Other data about how you use our products and services.|
|Documentary Data|| Details about you that are stored in documents in different formats, or copies of them. This could
include things like your contracts with us and copies of email communication between us.
|Consents|| Any permissions, consents, or preferences that you give us. This includes things like how
you want us to contact you or whether you get paper invoices.
5. Where we collect personal information from
We may collect personal information about you or your business from other companies within the iFace Group and from these sources:
Data you give to us:
- When you purchase products and services with us
- When you talk to us on the phone or in person
- When you use our websites, mobile device apps, web chat services
- In emails and letters
- In customer surveys
Data we collect when you use our services. This includes the amount, frequency, type, location, origin and recipients:
- Profile and usage data. This includes the profile you create to identify yourself when you connect to our internet, mobile and telephone
services. It also includes other data about how you use those services. We gather this data from devices you use to connect to those services,
such as computers and mobile phones, using cookies and other internet tracking software
Data from third parties we work with:
- Companies that introduce you to us
- Fraud prevention agencies
- Public information sources such as Companies House
- Agents working on our behalf, such as channel partners
- Government and law enforcement agencies
6. Who we share your personal information with
- Agents and advisers who we use to help run your accounts and services, collect what you owe, and explore new ways of doing business
- Fraud prevention agencies
- Companies we have a joint venture or agreement to co-operate with organisations that introduce you to us
- Companies that we introduce you to
- Companies you ask us to share your data with
We may need to share your personal information with other organisations to provide you with the product or service you have chosen:
- If you apply a for maintenance package us, we may pass your personal or business details to the maintenance company.
We may also share your personal information if the make-up of the iFace Group changes in the future:
- We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may seek to acquire other businesses or merge with them.
- During any such process, we may share your data with other parties. We will only do this if they agree to keep your data safe and private.
- If the change to our Group happens, then other parties may use your data in the same way as set out in this notice.
7. How we use your information to make automated decisions
We sometimes use systems to make automated decisions based on personal information we have – or allowed to collect from others – about you or your business. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. These automated decisions can affect the products, services or features we may offer you now or in the future, or the price that we charge you for them. Here are the types of automated decision we make:
We may decide what to charge for some products and services based on what we know.
Tailoring products and services
We may place you in groups with similar customers. These are called customer segments. We use these to study and learn about our customers’ needs, and to make decisions based on what we learn. This helps us to design products and services for different customer segments, and to manage our relationships with them.
We use your personal information to help decide if your personal or business accounts may be being used for fraud or money-laundering. We may detect that an account is being used in ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual for you or your business. If we think there is a risk of fraud, we may stop activity on the accounts or refuse access to them.
8. Credit Reference Agencies (CRAs)
We carry out credit checks when you apply for a product or services for you or your business. We may use Credit Reference Agencies to help us with this.
If you use our services, from time to time we may also search information that the CRAs have, to help us manage those accounts.
We will share your personal information with CRAs and they will give us information about you. The data we exchange can include:
- Name, Business name and or address
- Account payment and history; and
- Public information, from sources such as the electoral register and Companies House.
We’ll use this data to:
- Assess whether you or your business is able to afford to make repayments;
- Make sure what you’ve told us is true and correct;
- Help detect and prevent fraud
- Trace and recover debts
We will go on sharing your personal information with CRAs for as long as you are a customer. This will include details about your account payments and any debts not fully repaid on time.
When we ask CRAs about you or your business, they will note it on your credit file. This is called a credit search. Other lenders may see this and we may see credit searches from other lenders.
If you apply for a product with someone else, we will link your records with theirs. We will do the same if you tell us that you are in business with other partners or directors.
You should tell them about this before you apply for a product or service. It is important that they know your records will be linked together, and that credit searches may be made on them.
CRAs will also link your records together. These links will stay on your files unless one of you asks the CRAs to break the link. You will normally need to give proof that you no longer have a financial link with each other.
You can find out more about the CRAs on their websites, in the Credit Reference Agency Information Notice. This includes details about:
- Who they are;
- Their role as fraud prevention agencies;
- The data they hold and how they use it;
- How they share personal information;
- How long they can keep data; and
- Your data protection rights.
9. Fraud Prevention Agencies (FPAs)
We may need to confirm your identity before we provide products or services to you or your business. Once you have become a customer of ours, we will also share your personal information as needed to help detect fraud and money-laundering risks. We use Fraud Prevention Agencies to help us with this.
Both we and fraud prevention agencies can only use your personal information if we have a proper reason to do so. It must be needed either for us to obey the law, or for a ‘legitimate interest’.
A legitimate interest is when we have a business or commercial reason to use your information. This must not unfairly go against what is right and best for you.
We will use the information to:
- Confirm identities
- Help prevent fraud and money-laundering
- Fulfil any contracts you or your business has with us.
We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent and prosecute crime.
FPAs can keep personal information for different lengths of time. They can keep your data for up to six years if they find a risk of fraud or moneylaundering.
The information we use
These are some of the kinds of personal information that we use:
- Name/ Business name
- Registered business address
- Contact details, such as email addresses and phone numbers
- Financial data
- Data relating to your or your businesses products or services
- Data that identifies computers or other devices you use to connect to the internet. This includes your Internet Protocol (IP) address.
Automated decisions for fraud prevention
The information we have for you or your business is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.
We and FPAs may process your personal information in systems that look for fraud by studying patterns in the data. We may find that an account is being used in ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual for you or your business. Either of these could indicate a possible risk of fraud or money-laundering.
How this can affect you
If we or an FPA decide there is a risk of fraud, we may stop activity on the accounts or block access to them. FPAs will also keep a record of the risk that you or your business may pose.
This may result in other organisations refusing to provide you with products or services, or to employ you.
Data transfers out of the EEA
FPAs may send personal information to countries outside the European Economic Area (‘EEA’). When they do, there will be a contract in place to make sure the recipient protects the data to the same standard as the EEA. This may include following international frameworks for making data sharing secure
10. Sending data outside of the EEA
We will only send your data outside of the European Economic Area (‘EEA’) to:
- Follow your instructions.
- Comply with a legal duty.
- Work with our agents and advisers who we use to help run your accounts and services.
If we do transfer information to our agents or advisers outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. We’ll use one of these safeguards:
- Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website
- Put in place a contract with the recipient that means they must protect it to the same standards as the EEA. Read more about this here on the European Commission Justice website
- Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA. You can find out more about data protection on the European Commission Justice website.
11. If you choose not to give personal information
We may need to collect personal information by law, or under the terms of a contract we have with you.
If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your products, services or policies. It could mean that we cancel a product or service you have with us. Any data collection that is optional would be made clear at the point of collection.
We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’. The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.
We study this 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 products, services and offers may be relevant for you.
We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you. You can ask us to stop sending you marketing messages by contacting us at any time.
We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.
If you change your mind you can update your choices at any time by contacting us.
13. How long we keep your personal information
We will keep your personal information for as long as you are a customer of the iFace Group.
After you stop being a customer, we may keep your data for up to 10 years for one of these reasons:
- To respond to any questions or complaints.
- To show that we treated you fairly.
- To maintain records according to rules that apply to us.
We may keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.
14. How to get a copy of your personal information
You can access your personal information we hold by writing to us at this address:
iFace Group Ltd
Manor Business Park
15. Letting us know if your personal information is incorrect
You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this. If you do, we will take reasonable steps to check its accuracy and correct it.
16. What if you want us to stop using your personal information?
You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.
There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it. We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted. You can ask us to restrict the use of your personal information if:
- It is not accurate
- It has been used unlawfully but you don’t want us to delete it
- It not relevant any more, but you want us to keep it for use in legal claims
- You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it
If you want to object to how we use your data, or ask us to delete it or restrict how we use it or, please contact us.
17. How to withdraw your consent
You can withdraw your consent at any time. Please contact us if you want to do so.
18. How to complain
If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.
Please let us know if you are unhappy with how we have used your personal information.
You also have the right to complain to the Information Commissioner’s Office.
19. Future formats for sharing data
The Data Privacy laws will change on 25 May 2018. From that date you will have the right to get your personal information from us in a format that can be easily re-used. You can also ask us to pass on your personal information in this format to other organisations. We are working with our industry to improve the way your data is shared.
This helps us to provide you with a good experience when you use our site or engage in e-mail communication with us and allows us to improve our site and e-mail communication.
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