This policy explains how we Sport Mobile Ltd, collect, store, and processes information that we hold about you.
What we collect and hold about you
As part of processing business information, we store details about you as our client and as such we need to hold certain details in order to facilitate business with you. We keep the information we hold as limited as we can, but in some circumstances we cannot facilitate business with you without it. We request and hold such information as:-
- Name, date of birth, address, email address, and VAT or company number
- Bank account details for processing your Direct Debit payments
- Details that help us to service your account such as your mobile phone number, IMEI, Serial Number, or SIM number
- Your communications with us (be that by voice, text, in writing or via email)
As part of using our service we may also collect information relating to your digital communications such as:
- Date time and duration of calls, text messages, MMS messages and data usage
- The country of origin and the destination country of phone calls, text messages and MMS messages, data use (including roaming)
- Your activity on Sport Mobile’s website, or its services such as IP address, date and time of visit and browser information
- Your device details such as IMEI, SIM Number & Mobile Number
When visiting one of our sites we may collect CCTV footage of you whilst you are on our premises for the purpose of the health and safety of our visitors, the security of our premises and access to / from our offices. This footage is kept securely and only for a limited time period before being erased.
We regularly review the types and detail of information we require, and when information is no longer necessary then it is appropriately disposed of.
How we use that information
You might wonder how we intend to use the information we hold. In most cases this is used in order for us to make business decisions about your account or contract with us, this may include:
- Analysis of your use of services with us, so we can provide up to date information on the best prices available to you
- To verify your identity, and to provide you with goods and business services that may be of interest to you
- For administration, customer service, billing and marketing purposes
- We may make use of your address to check network coverage for the services we provide to you
- To provide information to the emergency services should it be requested
- To comply with the relevant legislation governing the use of your personal data, and to comply with law enforcement agencies, regulations and court orders
- We may also collect anonymous statistical information about our web services to better understand our users, performance or web presence
By using our website you are agreeing to allow us to use tracking cookies in order to provide you with the best experience and you allow us to gather anonymous statistical information about the performance of our website.
Contracts With Us
If you are supplied with a mobile phone contract with Sport Mobile we are using a contractual basis for processing your data. We require certain information about you and we may need to share that with select parties to ensure that we give you the best service.
We may make use of your details to supply you with products or services that may be of interest to you, we’ll only do this with your consent and if you want to you can opt-out at any time. Our marketing emails will contain a link at the bottom for automatic opt-out.
How we share that information
As part of providing a service to you, it is necessary that we share some limited information with the mobile phone networks. Sport Mobile takes measures to protect you (the end user) and your identity, but nevertheless some information sharing is required. When this happens, the information we hold is only ever shared in a secure and confidential way.
- When you are supplied with a mobile plan, in order to have that work we need to allow the network to see such information as your mobile number, or IMEI number & SIM number that will identify your device to the network
- With your permission, we might need to share with them diagnostic information about your mobile phone’s make and model to aid in faults with the network
- This information is only shared with select third parties as is necessary and is never used for the purposes of advertising
- There may also be a time when we need to share your information with government and law enforcement agencies. This is so that we comply with UK local and national law
- Due care will be taken to assess law enforcement requests on a case by case basis to ensure that any request for information is legal, is not spurious in nature and relates to a specific need
How long we keep that information
While you are a customer of ours we will need to keep the data we gather about you for a period of time as is necessary to provide you with the service you require (such as call records).
This also means that after you leave us we may keep certain information about you for a reasonable period of time or unless you have specifically instructed us to take alternate action via a written request.
Right of Rectification
The information we hold about you we will keep up to date and accurate, and we may need to confirm this with you when you make contact with us. Any new information you give us will then update our records. You can also contact us to verify if the details we hold about you are correct.
Right to Erasure (“Right to be forgotten”)
You have the right to request that the information we hold about you is removed and deleted. Although your details are automatically removed from our systems periodically when there is no longer a basis to hold them you can make a request verbally to us or in writing asking us to remove your details from our systems.
The right to be forgotten depends on a number of factors and is not absolute, however we will strongly consider any request before responding to you within 30 days of notifying us.
Right to Restrict Processing
You can ask us to place a restriction on your data being processed by our systems. Under this request we can still hold data about you but not use it. You can use this in conjunction with your right of rectification if the details we hold about you are incorrect. It can apply until those details are rectified before continuing to process your data.
Right to Data Portability
As a user of our services we have to store certain details about you and it can sometimes be cumbersome to move to another provider. Data portability allows you to request that we supply your data to yourself so that you can migrate to a new supplier without hindrance. At your specific request we can also transmit that data directly to another supplier.
Data supplied to you will be given in what’s called a machine readable format, a common form of this is through the use of a CSV file in which your new supplier should be able to interpret on your behalf.
We will respond to your request for data portability within one month of the request being made, though this may be extended up to two months if the request is particularly complicated. If we do extend it to two months you’ll be informed why the extension is necessary.
Right to Object
You have the right to object to data processing based upon the grounds of your particular situation. We will consider any right to objecting from data processing but may override it where we have compelling grounds to do so. Your request will be considered and if your request is overridden you will be informed as to the reasons why.
Opting out of Marking Materials
Where we make use of marking materials to promote products and services to you that may be of interest. You have the right to object from any of the contact methods we might use.
Subject Access Request
You as the data subject have the right to request information that we hold about you, this is called a Subject Access Request (SAR). You can ask a number of things about the information we hold about you and why. If you are unsure as to what a Subject Access Request is, or for examples on requesting that information please see the Information Commissioners Office (https://ico.org.uk/) for guidance on such requests.
Subject Access Requests should be made by email and addressed to the data controller who you can email at email@example.com, alternatively you can write to us at our registered address.
The data controller will aim to provide the relevant data within 1 month from the date all relevant information relating to the request has been received. This can be extended to 2 months if the request is complex or if we receive multiple requests. You will be notified of this action.
The data controller will always verify the identity of anyone making a subject access request before handing over any information.
Your information protection
We take your personal data very seriously and as such we have measures in place to ensure its security and protection. These measures are reviewed and updated on a regular basis to protect you and the business.
How to contact us
You can contact us via phone on 0843 216 0400, email us at firstname.lastname@example.org or write to us at:-
Data Protection Officer, Sport Mobile Ltd, 1 Brassey Road, Old Potts Way, Shrewsbury, Shropshire, SY3 7FA
Sport Mobile Ltd is registered with the ICO under the Data Protection Act 1998, our registration number is ZA279356.
Company Number: 04904208