Contact us Home Privacy Policy Privacy policy Our promise We take data protection very seriously and are committed to ensuring your privacy is protected. This privacy notice explains how we use the information we collect about you and how we comply with all our privacy obligations. Changes to this notice We may update our privacy notice from time to time. Any changes we make to our privacy notice in the future will be posted on our website . For more information on your rights or if you would like to exercise any of your rights, you are welcome to contact us using contact details set out below under “Contacting us”. Last updated April 2021 About us This privacy notice applies to Neos Network Limited which is operated by the following data controller: Neos Networks Limited, No. SC213457 Our registered office is at Inveralmond House, 200 Dunkeld Road, Perth PH1 3AQ Neos Networks Limited is referred to as “we” or “us” throughout this privacy notice. We will be the “data controller” of the information you provide to us unless otherwise specified within a contract or product terms and conditions. Contacting us If you would like to contact us in relation to your rights or if you are unhappy with how we have handled your information, you may do so using the following details: Email: dataprotection@neosnetworks.com Address: Data Protection Office, Legal Services, Neos Networks, 7th Floor, No. 1 Forbury Place, 43 Forbury Road, Reading, RG1 3JH ICO Complaints If you’re not satisfied with our response to any complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) using the following details: Telephone Number: 0303 123 1113 Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF What information do we collect and how do we do it? We, or third parties on our behalf, collect your personal data when you use our website, communicate with us by phone, letter, email, social media or in person or when you receive our products and/or services. We may collect the following personal data and we refer to this as “personal data” throughout this notice: your name; gender; billing address; supply address; telephone number(s); e-mail address; your date of birth; details of secondary contact (e.g. name and phone number); call recordings; customer ID numbers- when you register an account with us, we create and record a customer ID number for you and record the date you were registered; financial information; your preferences (e.g. if you would prefer paperless billing); permissions; survey responses; and/or if you visit our website, we store your IP address, the browser software you use and your behaviour on our website (for example, the pages that you click on). This information is collected through cookies. More information on how we use cookies can be found in our cookie policies on the relevant website. Children We do not knowingly collect information from . If you are under 16 years old, you may not submit any personal data to us. What do we do with your personal data? We, or third-parties on our behalf, collect, use and store the personal data collected about you to: Respond to any enquiries or issues you have, including directing you to the correct support team; Identify you; Contact you, or authorised third parties, about our services- such as sending you information when you sign up, service announcements and administrative messages; Communicate with you by telephone, mail, email or other electronic means; Enter into legal contracts with you; Perform our obligations under any contract for the supply of services we have with you; Train our staff and improve our products and services, which may mean that we monitor and record communications that we have with you including phone conversations, emails, SMSs and web chats; Allow our engineers to visit you on site (where required); Use data analytics to understand and improve the way we do things as a business; Conduct, and contact you in relation to, market research e.g. through customer satisfaction surveys and questionnaires; Identify offers and advice tailored to your needs or lifestyle; Ensure the health and safety of you, our staff and contractors; Respond to and/or resolve any enquiries or requests that you may make via social media; Enable internal corporate reporting, business administration, adequate insurance coverage, the security of company facilities, research and development, and to identify and implement business efficiencies; Comply with any procedures, laws and regulations which apply to us – including where we reasonably consider it is in our (or others) legitimate interests to comply; Establish, exercise or defend our legal rights – including where we reasonably consider it is in our (or others) legitimate interests to do so; Facilitate the credit management process; Process wayleaves payments; Allow us to process charges in the event of damage to our equipment; Provide compensation to customers in certain circumstances; To detect and prevent crime, fraud or loss, including carrying out checks on customers, suppliers and other third parties, which relate to activities such as anti-money laundering, countering terrorist financing and other unlawful acts (for example, illegal trafficking and environmental crime) and anti-bribery and corruption requirements. Agree rights in land and manage existing land rights; Carry out other land liaison duties such as notification of project work, operations and maintenance; and Facilitate access to install, monitor, maintain and remove apparatus lawfully situated on your land. How do we use sensitive/special category personal data? We may collect information that would be particularly sensitive, for instance your need for billing to be provided in braille. If this occurs, we will ensure that all the appropriate consents are in place and your understanding of the processing is confirmed. Wayleaves What do we do with your personal information? We use your information to: Agree rights in land; Manage existing land rights; Carry out administrative duties relating to rights agreed inclusive of payments; Carry out other land liaison duties such as notification of project work, operations and maintenance; Process wayleaves payments; and Pacilitate access to install, monitor, maintain and remove apparatus lawfully situated on your land. We may also share your information with any legal representative you have appointed to liaise with us on your behalf, and with contractors undertaking development projects and maintenance. Marketing Communications Unless you’ve asked us not to, we may contact you in writing, by phone and via email or SMS with information on products, services and rewards that we, and occasionally our carefully selected partners, offer. We may also use third parties to send marketing communications. Unless you have asked us not to, we may also use your personal data to show you digital advertisements via your social media newsfeed, on search engine results pages, or on other websites. Unless you have asked us not to, we may profile your data to provide you with marketing and offers that are relevant to you. If you opt out of profiling, we will still run analysis that includes your data, but any decisions or marketing output that result from that analysis will not be used to market to you. You will be sent generic marketing that may not be relevant to you. If you have opted out, we may, after an appropriate time, ask whether you would like to receive marketing from us again. This will come in the form of a question and will never be sent with any marketing content. We believe this would be helpful and ensure that you are always receiving the best services. To opt out of receiving marketing messages, or to object to our use of profiling for direct marketing purposes, contact us at any time using the details at the top of this document or by clicking the unsubscribe option in emails that we send to you. Legal bases for processing, including legitimate interests In order to process and use your personal data lawfully, we rely on the following legal bases: For the performance of a contract with you for provision of our products and/or services or to take steps at your request prior to entering into such a contract; Legal Obligation – to comply with our legal obligations; Legitimate Interest – this may, for instance, be fraud prevention, ensuring network and information security, or indicating possible criminal acts or threats to public security; Consent – where we market to you via email or SMS, or where we process special categories of data e.g. vulnerability information. If we rely on your consent in these cases, but you later change your mind, you may withdraw your consent by contacting us or by clicking the unsubscribe link in emails, and we will stop doing so. Who do we share your personal data with? We may share your personal information with the following categories of third parties: Our third-party suppliers, partners and sub-contractors that provide, review and/or receive services in relation to our website, services and/or products. Our third-party suppliers include: payment processors; suppliers of technical support and installation services; cloud services providers, research agencies and contractors undertaking development projects and maintenance; Any legal representative you have appointed to liaise with us on your behalf; Government or law enforcement officials– If we’re under a duty to disclose your information in order to comply with any legal obligation then we may disclose your personal data to meet national security or law enforcement requirements or to prevent illegal activity; Debt collection and tracing agents if we provide you with a service and you fail to make payments; Authorised third parties or named account holders on any account you hold with us; If we sell, merge, or perform any internal re-organisations in relation to any of our (or any third party’s) business or assets, the personal information will be one of the transferred assets to the relevant buyer and/or new data controller of such business or assets. How long do we hold it for? We will keep your information only for as long as is necessary depending on the purpose for which it was provided. When determining the relevant retention periods, we will consider factors including: Our contractual obligations and rights in relation to the information involved; Legal obligation(s) under applicable law to retain data for a certain period of time; (Potential) disputes; and Guidelines issued by relevant data protection authorities. Otherwise, we securely erase your information once it is no longer needed. Where will your information be held? Where possible, your data will be processed either within the UK, EEA and to any countries which, as at 31 December 2020, were covered by a European Commission ‘adequacy decision’. If it is necessary to process personal data outside of these jurisdictions, then we may implement additional security and assurance controls, for instance, Standard Contractual Clauses (SCCs) approved by the European Commission [in accordance with Article 46(2)(c) of the General Data Protection Regulation]. Your rights You have the following rights regarding your information: Right to be informed You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. Therefore, we are providing you with the information in this privacy notice. Right of access You have the right to obtain access to your personal data (if we are processing it) and certain other information (similar to that provided in this privacy notice). This is so you are aware and can check that we are using your personal data in accordance with data protection law(s). Right to rectification You are entitled to have your personal data corrected if it is inaccurate or incomplete. Right to erasure This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there is no compelling reason for us to keep it. This is not an absolute right to erasure; there are exceptions. Right to restrict processing You have the right to ‘block’ or suppress further use of your personal data in certain circumstances. When processing is restricted, we can still store your personal data, but may not use it further. Right to data portability You have the right to obtain and reuse your personal data in a structured, commonly used and machine-readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party. Right to object to processing You have the right to object to your personal data being processed in certain circumstances. This includes where we are relying on legitimate interest and for direct marketing purposes (including profiling). Right to withdraw consent If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for direct marketing. Security It is important that personal data is kept, transferred and processed securely and we take this obligation seriously. We will hold your information in line with physical, technical and administrative security measures. To ensure safe data transfers, that we are responsible for, are executed appropriately we use industry standard measures which are continually assessed. This ensures that the most robust methods are always used. Personal data is stored inline with internal policies and safeguards. This ensures that only the appropriate individuals have access to the data and the necessary training is completed. When using third parties to assist us with data processing, security assessments are completed, including penetration testing, to ensure that the high level and standard of security is maintained. 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