FibreWiFi GDPR Policy

GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS

Fibre WiFi Ltd ("We") are committed to protecting and respecting your privacy.
This policy, together with our terms of use as detailed on this website, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”). 

1 - Definitions

Data controller - A controller determines the purposes and means of processing personal data.
Data processor - A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data - The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.


2 - Who are we? 

Fibre WiFi Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: FibreWiFi, Media House, Boyton Hall, Roxwell Road, Chelmsford, Essex, CM1 4LN. For all data matters contact our Data Representative, Hal Ponton, on data@fibrewifi.com

3 - The purpose(s) of processing your personal data

We use your personal data for the following purposes:
To be able to survey/install/supply you with broadband services once you have signed up for our service.
If you have enquired either on our website / via email / or on over the phone. We will use your information to contact you about the results of your enquiry.


4 - The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we process the following categories of your data: 
Personal data
We have obtained your personal data from you when you decided to become a customer of Fibre WiFi Ltd, or if you have enquired with us.

5 - What is our legal basis for processing your personal data?

Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
A. Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract. The contract is between the subscriber and Fibre WiFi Ltd for the supply of services. This does not require a GDPR consent form from the subscriber.
B. Notification of new subscriber packages, this will require a signed GDPR consent form from the existing or potential subscriber.

6 - Sharing your personal data

Your personal data will be treated as strictly confidential, and will be shared only with the employees and directors of Fibre WiFi Ltd.

7 - How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary and we only retain your data for the following purposes and use the following criteria to determine how long to retain your personal data we look at the following criteria:
Are you currently a customer of ours? If so we’ll keep your data for as long as the contract period lasts + 2 months. This allows us to contact you whilst you’re a customer and for a short period afterwards in case we need to remove any of our hardware from your property after you cancel.
Do you have a financial record with us? If you’ve ever paid us any money we are required by law to keep the financial data for a period of between 7-10 years. This is for the purposes of fraud prevention.
Did you enquire with us? If you’ve ever sent us an enquiry then we’ll keep your data up until we’ve responded to you. If you’ve agreed for us to keep your details on file (for the purposes of contacting you about service upgrades or expansion) then we’ll keep your data for a period of 4 years, or until you ask us to remove it.

8 - Providing us with your personal data

We require your personal data as it is a contractual requirement in order to be a subscriber to the FibreWiFi service. If you fail to adhere the consequences will be that you will be unable to be a subscriber to the FibreWiFi service.

9 - Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: 
The right to request a copy of the personal data which we hold about you;
The right to request that we correct any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary to retain such data;
The right to withdraw your consent to the processing at any time, the consequence of which will be termination of service, with any outstanding monies due on demand; 
The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means); 
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics). 

10 - Transfer of Data Abroad

We do not transfer personal data outside the EEA.

11 - Automated Decision Making

We do not use any form of automated decision making in our business.

12 - Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

13 - Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

14 - How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact our Data Representative, Hal Ponton at: data@fibrewifi.com
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.