Velocity 1 Limited (“Velocity 1”)
Please note that this Privacy Statement may be updated from time to time. We advise you to review this Privacy Statement regularly for any changes. If there is a significant change to this Privacy Statement, we will notify you by email.
It was last updated on 17 April 2020.
This Privacy Statement sets out what kinds of personal information we collect; how and when we collect personal information; why we collect personal information; what we do with personal information and with whom we share it; and how we safeguard personal information.
In this Privacy Statement we, our and us refers to Velocity1 Limited (Velocity1), and you and your refers to the person who is the account holder and a party to the agreement for Broadband Services with Velocity1.
Your privacy is very important to us, which is why we are committed to protecting and respecting your privacy, and adhering to the requirements of the UK’s data protection legislation.
We collect and process personal information about you when you use our residential broadband services or when we answer your questions about our services. This makes us a Controller of the personal information that you provide to us. This means that we make decisions about how and why we use your personal information and, because of this, we are responsible for making sure it is used in accordance with the UK’s data protection legislation.
If you have a specific question about this Privacy Statement or any concerns or questions about our use of your personal information, you can contact us using the details set out at the end of this Privacy Statement.
2. What kinds of personal information do we collect from you?
The personal information we collect will depend on whether we collect that personal information from you or someone else and how/when we collect that personal information.
We collect the following personal information from you in order to provide further details on our residential broadband services:
- your generic details (i.e. name, surname, date of birth, gender)
- your contact details (i.e. address, email, phone number)
- your financial details (i.e. bank account, payment method, debit/credit card number)
We collect and process the following additional personal information from you when you become our customer and use our residential broadband services / manage your account with us:
- details of the residential broadband services you use or order from us
- passwords and credentials (such as the security questions and answers we have on your account)
- usage data (i.e. frequency, time, location and duration of service usage, data traffic used per month)
- billing, payment and transaction data (i.e. your financial details and bills and its components)
- communications data (i.e. your emails, webchats, and phone calls to us which are recorded for quality and training purposes).
We will collect all personal information in an open and honest manner and we will obtain it fairly. We will make you aware of all purposes for which we intend to use your personal information at the time we collect your personal information and prior to the use of the personal information.
The personal information we collect will be adequate, relevant, and not excessive in relation to the purposes for which it was obtained. It will also be accurate and complete and where necessary kept up to date.
3. How and when do we collect personal information from you?
You directly provide us with most of the personal information we collect.
There are a number of ways that we collect your personal information. This could be when:
- you use or visit our website which will provide personally identifying information such as Internet Protocol (IP) addresses used to connect your computer to the Internet, your browser type and version, your time zone setting, your browser plug-in types and versions, operating system and platform
- you place an order for our residential broadband services or call our support team over the telephone
- you use our residential broadband services, including when you create and use your login information to access your account you correspond with us by telephone, email, electronic messaging (such as SMS, MMS, or live chat tools), or post in order to enquire about a service or a bill, pay a bill, place an order, report a technical fault and/or book a service appointment
- you voluntarily complete one of our forms, questionnaires or customer surveys or otherwise provide feedback on our residential broadband services on any of our message boards or via email
- you interact with us on social media (such as likes, shares and tweet)
We may also collect your personal information indirectly from the following sources:
- members of your household
- someone who refers you to our residential broadband services
- third party organisations such as content providers and/or delivery service providers that have obtained your permission to share your personal information with us
- reporting agencies such as credit reference agencies who give us information about your financial history so we can assess credit worthiness and product suitability, check your identity, manage your account, trace and recover debt, and prevent criminal activity. We will continue to exchange information about you with credit reference agencies on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. Credit reference agencies will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates.
Our account application forms, marketing surveys, and competition entries will have clear information to explain the intended purposes including secondary uses that may not be obvious to you (for example if a competition entry is intended to be used for marketing purposes we will clearly advise you of this and the appropriate opt out mechanism).
4. Why do we collect and process personal information from you?
There are three reasons why we collect and process your personal information:
- Necessity. We collect and process your personal information because it is necessary to enable us to perform our contract with you (i.e. you have enquired about our residential broadband services or you have ordered our residential broadband services, so we collect and process your personal information in order to provide those services to you (including responding to any questions or complaints you may have about the services) and bill you for it)
- Consent. We collect and process your personal information because you gave us your consent so that we may send you details of products, services, special offers that we think may be of interest to you; to occasionally carry out market research; and administer contests and competitions.
- Legitimate Interest. We collect and process your personal information because we have a good reason to do so, such as to enable us to operate as an efficient and effective business and protect it against threats (i.e. cyber-attacks, crime, and fraud). In such an instance, we will always assess whether our use would be fair and not override your right to privacy.
Withdrawing Consent. Where we collect and process your personal information on the basis of consent, you have the right to withdraw your consent at any time. You can do this by emailing email@example.com, by calling us on 020 3744 4905, or by writing to us at Residential Broadband Sales, Velocity1 Limited, 11 Rutherford Way, Wembley HA9 0BP.
Right to Object. Where we collect and process your personal information on the basis of legitimate interest, you have the right to object. You can do this by emailing firstname.lastname@example.org, by calling us on 020 3744 4905, or by writing to us at Residential Broadband Sales, Velocity1 Limited, 11 Rutherford Way, Wembley HA9 0BP.
Legal Obligation. We may collect and process personal information where we are required to do so by law. Reasons for which we may have a legal obligation to collect and process personal information include blocking unauthorised/illegitimate content; responding to courts or enforcement authorities; helping authorities with any security, crime or anti-terrorism activities; demonstrating compliance with anti-money laundering rules; and ensuring compliance with regulatory requirements about fair treatment of customers and proper processing of records.
5. What do we do with the personal information?
We collect and process personal information so that we can:
- process an enquiry received from you, or respond to an expression of interest in our residential broadband services and to provide you with the information and services that you request from us
- process your order and carry out our obligations arising from any contract for our residential broadband services entered into between you and us
- provide you with service information messages (i.e. to confirm your order, to tell you how to manage your account and about any changes that might affect your service such as planned infrastructure work, to inform you of technical faults in your area)
- provide you with updates on when we will deliver, connect or install equipment for your residential broadband service
- ensure that the residential broadband services that you receive are correctly administered
- send you invoices and process your payment information
- contact you to request feedback and comments on our residential broadband services or to provide information to you which may be of interest to you
- notify you about changes to our residential broadband services
- provide you with information about other services we offer that are similar to those that you have already purchased or about which you have enquired and we think may be of interest to you
- ensure that content from our website is presented in a manner that is safe, secure and most effective for you and for your computer
- administer our website for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
- create aggregated and anonymised information for further use, such as to measure and understand the effectiveness of advertising we provide to you and others, and deliver relevant advertising to you
- detect and prevent fraud
- secure and protect our broadband network
You agree that we may share your personal information with the following selected third parties as well as our partner companies so that they may offer you their products and services:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- analytics and search engine providers that assist us in the improvement and optimisation of our website
- Quintain Limited and its subsidiaries (we are a subsidiary of Quintain Limited)
When we process your order, we may send your personal information to, and also use the resulting information from, credit reference agencies to verify your credit status or to prevent fraudulent purchases.
6. With whom do we share your personal information?
Your personal information may be shared with:
- our employees, agents and contractors (including our engineers who may be required to visit your home) so they can administer and deal with any questions or complaints you may have about your account with us or about our residential broadband services provided to you by us now or in the future
- credit reference agencies, who will keep a record of the search when you apply for our residential broadband services, so that we can confirm your eligibility for our services
- content partners and advertisers (however, personal information is provided in aggregate form to these third parties, and the statistics provided to them do not include information that can be used to identify any individual)
- third party service providers, including our CRM platform provider, to support our provision of our residential broadband services. These third party service providers could process personal information on our behalf as well as provide customer service, marketing, infrastructure and information technology services; process payment transactions; carry out fraud and credit checks and collect debts; analyse and improve the information we hold (including your interactions with our service); and run surveys
Where we use third party service providers, we still control your personal information and we have strict controls in place to make sure your personal information is properly protected by requiring the third party service providers to process your personal information based on our instructions and requirements consistent with this Privacy Statement and the UK’s data protection laws.
We do not share your personal information with any other third parties except in accordance with this Privacy Statement and our Terms and Conditions or where we are required to disclose that information in order to comply with any legal or regulatory requirements.
7. How do we keep your personal information secure?
We ensure that your personal information is stored securely via the cloud-based platforms which we use, and we ensure that reasonable security precautions are taken to protect your personal information. Please note that our CRM system is a US-based platform so some of your personal information may be processed in the United States.
We will collect and process your personal information during the duration of any contract between us for our residential broadband services and will continue to retain the personal information needed in accordance with the retention periods set out below and as required by applicable law:
|Call detail records will remain visible on our system for up 2 years. Call details records that form part of your invoice will be visible on reprints of invoices and kept for a period of 6 years plus the current year. By law we must retain call detail records for a period of 2 years. Records are located in a secure area.|
|Recorded Calls||Recorded Calls are stored for a period of up to 30 days|
|Data Usage/ Connection Stats/ Website traffic||Data Service usage is kept for a period up to of 6 months plus current month. Service usage record will not include data content. Connection statistics are kept for a period of up to 1 year post contract end date. Web site traffic data is only kept on our network for 24 hours but does not include data content.|
|Invoice Details||Legally invoice details are required to be maintained for a period of 6 years and the current year.|
|Customer Support Information||Customer communications in relation to a contracted service is maintained for a period up to 2 years post contract end date.|
|Customer Contracts||Contracts are stored to support invoices raised which must be kept for a period of 6 years plus current year|
From time to time we may send you a marketing communication that could be of interest to you in relation to amending our current residential broadband services or in relation to a survey that we are conducting about our residential broadband services.
You can unsubscribe from our direct marketing communications at any time by clicking ‘unsubscribe’ on any of our marketing communications or by contacting us using our contact details set out at the end of this Privacy Statement. This will not unsubscribe you from receiving communications from us in relation to your account.
9.What data protection rights do I have?
At any point whilst we are in possession of or processing your personal information, you have the following rights:
- right of access – you have the right to request a copy of the information that we hold about you
- right of rectification – you have the right to correct information that we hold about you that is inaccurate or incomplete
- right to be forgotten – in certain circumstances you can ask for the information we hold about you to be erased from our records
- right to restriction of processing – where certain conditions apply you have a right to restrict the processing of your personal information
- right of portability – you have the right to have the personal information we hold about you transferred to another organisation
- right to object – you have the right to object to certain types of processing such as direct marketing
- right to object to automated processing, including profiling – you have the right not to be subject to the legal effects of automated processing or profiling
In the event that we refuse your request under right of access, we will provide you with a reason as to why, which you have the right to challenge legally.
At your request, we can confirm what personal information we hold about you and how this information is processed.
You can request the following information:
- identity and the contact details of the person or organisation (Velocity1) that has determined how and why to process your personal information
- contact details of our data protection officer or the person who is responsible for dealing with data protection issues at Velocity1
- the purpose of the processing as well as the legal basis for processing
- if the processing is based on the legitimate interests of Velocity1 or a third party such as one of our customers, information about those interests
- the categories of personal information collected, stored and processed
- recipient(s) or categories of recipients that the personal information is/will be disclosed to
- how long the personal information will be stored
- details of your rights to correct, erase, restrict or object to such processing
- information about your right to withdraw consent at any time
- how to lodge a complaint with the supervisory authority (the Information Commissioner’s Office)
- whether the provision of personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal information and the possible consequences of failing to provide such personal information
- the source of personal information if it was not collected directly from you
- any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing
To access what personal information is held by us, identification will be required. We will accept the following forms of identification:
- national identity card
- driving licence
- birth certificate
- utility bill not older than three months
A minimum of one piece of photographic identification listed above and a supporting document is required (we will require copies of the identification). If we are not satisfied with the quality of the identification, we may seek further details before we release personal information.
All requests should be made to email@example.com or writing to us using the contact details set out at the end of this Privacy Statement.
10. Governing Law
This Privacy Statement is governed by the laws of England and Wales and you submit to the exclusive jurisdiction of the courts of England and Wales.
11. Contact us and Complaints
If you have a specific question about this Privacy Statement or any concerns or questions about our use of your personal information, you can:
- Write to us at: Velocity1 Limited, 11 Rutherford Way, Wembley HA9 0BP
- Send an email to: firstname.lastname@example.org
- Call us on: 020 3744 4905
Please mark your communication as “Data Protection Enquiry”.
In the event you wish to make a complaint about how your personal information is being collected and/or processed by us or our partners, you have the right to complain to us.
If you do not receive a response within 30 days, you can complain to the Information Commissioner’s Office (ICO). You may also lodge a complaint with the ICO if you consider that we are in breach of our obligations under the UK’s data protection laws. You can contact the ICO as follows:
- Call the ICO on: 0303 123 1113
- Send the ICO an email via: https://ico.org.uk/global/contact-us/