Policy key definitions:
“I”, “our”, “us”, or “we” refer to the business, [Business name & other trading names].
“you”, “the user” refer to the person(s) using this website.
GDPR means General Data Protection Act.
PECR means Privacy & Electronic Communications Regulation.
ICO means Information Commissioner’s Office.
Cookies mean small files stored on a users computer or device.
Processing of your personal data
Under the GDPR (General Data Protection Regulation) we process any personal information about you electronically using the following lawful bases.
We are registered with the ICO under the Data Protection Register
We are a both a Controller and Processor of data; we process data provided by third parties i.e. you, The Customer, Networks, Suppliers and other third party companies. We also decide how we manage your data, in agreement with you, The Customer, to effectively manage your account.
Lawful basis: Contract
The reason we use this basis: To effectively manage your account whilst under contract with use outlined in the terms and conditions given to you before your contract commenced.
We process your information in the following ways: Processing your order using telephone numbers, email addresses; managing your account using names, telephone numbers, email addresses, to provide a full and complete service, including checking your contract bill, completing tariff reviews based on your requirements, building quotes based on your requirements, providing other products where necessary and effectively managing your contract/s.
Data retention period: We shall continue to process your information until the last contract between us ends or is terminated under any contract terms. We will keep your information on file for a maximum of double your contract length + 1 year if you terminate your contract with Frontier (e.g. 5 years for a 2 year contract) but no longer than 6 years. This is to ensure that all information is available after you terminate your contract in case of any future queries or disputes. We may retain invoices and technology fund statements for up to 7 years.
Sharing your information: We do share your personal information with third parties for account management purposes only and they include; Vodafone, EE, O2, Microsoft, and all other relevant suppliers. We will only share your information with the suppliers that you are purchasing from and will never share any information third parties irrelevant to your contract or account with us.
Examples of data we hold on you, provided by you, The Customer:
Business Direct Debit Details
MDM information including location and device usage (if MDM is purchased)
It is your responsibility as an employer to ensure you have an agreement in place with your employees that allows us The Frontier Group to effectively manage your account, including their names or username aliases, mobile numbers and end usage.
Email marketing messages & subscription
Under the GDPR we use the legitimate interest lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the “Processing of your personal data” above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any previous marketing messages for instructions on how to unsubscribe or manage your preferences, you can also email firstname.lastname@example.org or reply to the email address you received marketing from.
Our EMS provider is; iContact via Salesforce. We hold the following information about you within our EMS system;
Subscription time & date
Name and business
Lawful basis: Legitimate interests
The reason we use this basis: We may have purchased your data (Business name, business telephone, contact name, business email address) from a third party company that you have ‘double opted-in’ to, meaning you have given them permission to receive information from third parties such as Frontier. This will mean you are on a marketing database and can opt-out at any time using the clear ‘unsubscribe’ function. You can also be removed from all databases by emailing email@example.com
We process your information in the following ways: Marketing emails
Data retention period: We will only hold your data for a maximum of 12 months for marketing purposes unless you have specifically shown a reasonable interest in our products or company, or become a customer.
Sharing your information: We do not share your information with third parties. We will not transfer or share your data with any other countries except the United Kingdom.
You have the right to request information on where and how we received your data at any time, and will be provided with a full and transparent response. Please use the contact details provided in the ‘Subject Access Request’ section of the policy.
If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.
You also have the right to complain to the ICO [www.ico.org.uk] if you feel there is a problem with the way we are handling your data.
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