1. Introduction
Welcome to the seethelight Privacy Policy.
Please note that, in this privacy policy, reference to "we", "us", "our" and seethelight denotes
Independent Fibre Retail Limited, trading as "seethelight", Registered number 07443511, whose
registered address is: Sky - Grant Way, Isleworth, Middlesex, TW7 5QD.
For the purpose of the Data Protection Act or any replacement legislation including the EU General
Data Protection Regulation (together, the "Data Protection Legislation"), the data controller is
Independent Fibre Retail Limited.
seethelight respects your right as our customer to
privacy and takes its responsibilities regarding the security and privacy of all visitors to our
website, www.seethelight.co.uk (the/our "Website") very seriously. We have developed this policy
because we want you to feel confident about the privacy and security of your personal information,
so please read it carefully before using our Website.
seethelight has notified the Information
Commissioner's Office of its activities in accordance with the Data Protection Act (Registration No.
Z1334015). This notification can be viewed at
www.ico.org.uk.
seethelight takes all reasonable care to prevent any
unauthorised access to your personal information.
By visiting and/or ordering services on the Website, you acknowledge and where required you consent
to the collection, use and transfer of your information as set out in this privacy policy.
2. About seethelight
seethelight is a leading-edge broadband and telephony
communications provider in the UK. It is currently deploying a next generation services in various
areas across the country to bring its customers advanced voice and high-speed Internet services.
seethelight's mission is to bring these advanced
services to business and residential customers alike. Please contact our sales office (please see
Contacting seethelight on our website) to find out if
you are able to receive our services in your area, or alternatively check on our website at
www.seethelight.co.uk.
3. Definition of Personal Data
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3.1 This privacy policy has been created to explain to you the way in which
seethelight uses your "personal data". When we
refer to "personal data" in this privacy policy, we mean personal information which identifies
you as an individual, or is capable of doing so. This may include information which tells us
something about you as an individual, for example your name, address or telephone number. We are
committed to providing you with a professional and personalised service whilst at the same time
safeguarding your privacy and protecting your personal data from unauthorised uses or
disclosures.
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3.2 "Sensitive personal data" is a particular category of information and is any "personal data"
which concerns racial or ethnic origin, political opinion, religious beliefs or other beliefs of
a similar nature, membership of a trade union, physical or mental health or conditions, sexual
life, commission or alleged commission of any offence or any proceedings for any offence
committed or alleged to have been committed by you, the disposal of such proceedings or the
sentence of any court in such proceedings. Any sensitive personal data that you provide to us
will be processed in accordance with this policy and the Data Protection Legislation. We will
not collect and/or use any sensitive personal data without your explicit consent.
4. Collection and Use of Personal Data
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4.1 When you visit our Website or order any of our services via our Website, we may collect and
use data about you. The types of personal data we will collect may include details of your name,
address, telephone number, email address, fax number and date of birth. We may also collect
information about your usage of our Website, our services or anything else from the emails and
letters you send to us, and the calls you make to us.
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4.2 Some of the information described above is collected and processed so that the contract with
you can be performed, some for the purpose of legal compliance and some for the purposes of our
legitimate business interests (subject to your rights), namely to analyse the use of our Website
and services in order to continually improve our business and services.
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4.3 In some instances, we may need your credit/debit card details to charge for the services.
All financial transactions are secured by SSL encryption to offer secure communications of
sensitive data to and from our website. However, no data transmission over the Internet can be
guaranteed to be totally secure, and any information which you send to us is sent at your own
risk.
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4.4 When you (or someone using your telephone line) make a telephone call or send a fax that
uses our telephone network or connect to the Internet, we keep a record of that call (including
the number called) to enable seethelight to
charge for it. We also receive information from other operators about calls made over our
network, where we need that information for connecting and billing purposes.
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4.5 If a customer abuses the seethelight telephone network, for example by making offensive or nuisance calls, we may keep any
information relating to that abuse for our internal investigations, or to assist with external
investigations, where necessary.
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4.6 If a customer abuses the seethelight Internet
Service or any value-add services connected with it, for example by breaching any of part of our
Internet Acceptable Use Policy (available on our website www.seethelight.co.uk), we may keep any
information relating to that abuse for our internal investigations, or to assist with external
investigations, where necessary.
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4.7 We will hold information about your use of our services (such as the amount of time you
spend on-line), which we will use to manage our network and for billing. We may also use this
information for marketing products and services. If you do not want to receive such information,
please let us know (see sections 5 and 8.4 below).
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4.8 seethelight may, from time to time, hold
competitions or promotions. If you enter into any of our competitions or promotions, we may ask
for information about you. This will be made clear at the time you enter the competitions or
promotions. We will also inform you of the purposes for which the information you provide may be
used.
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4.9 Where you have consented at the time we collected your data or where we otherwise have the
right to do so, we may ask you questions regarding the use you make of the services we provide,
the other services you would like us to provide in the future and regarding any other
information, such as lifestyle data by post, telephone, mobile message (e.g. SMS, MMS etc.)
The information obtained in your responses to our questions will only be used internally to
enable us to improve the quality of our service and to provide additional services to you.
This information will not be published on our Website. We may also use your data to perform
statistical analysis to help understand how people are using our services so that we can improve
them.
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4.10 If, at any stage, you object to seethelight's
use of your personal data for direct marketing in the way described in section 4.9 above, or to
the media in which such material is being sent, you may choose to unsubscribe to its receipt.
You may do this by following the methods contained in the relevant communication, or using any
one of the methods set out in paragraphs 5.2. – 5.4 below.
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4.11 When you order services from seethelight, we
may make enquiries about you for credit reference purposes. These enquires include searching
your records held by Experian/Equifax or any other credit reference agency and checking any
details held on you by the Interactive Media in Retail Group (IMRG) Security Alert or any other
fraud prevention scheme. At all times, where your information is disclosed to us, we will
protect it in accordance with this policy and the Data Protection Legislation and keep it
secure.
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4.12 We work closely with third parties (including, for example, our business partners) who may
collect personal information from you and pass it on to us. Where this is the case the third
party is responsible for obtaining the relevant consents from you to ensure you are happy with
the ways in which your personal data will be used.
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4.13 seethelight will use your personal data in
accordance with the Data Protection Legislation and in accordance with this policy.
seethelight will not disclose your personal
information to third parties other than when required to provide services to you, or where
outlined in this privacy policy.
5.Direct Marketing
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5.1 If you have consented at the point of data collection to
seethelight providing you with direct marketing
material, and you will be requested to elect the type of media via which this material shall be
provided (e.g. by post, email, telephone, fax, [or mobile message]).
seethelight will only provide you with such
material via your chosen media.
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5.2 If, at any stage, you object to seethelight's
use of your personal data for direct marketing or to the media in which such material is being
sent, you may choose to unsubscribe to its receipt. You may do this by following the methods
contained in the relevant communication, or using any one of the methods set out in paragraphs
5.2. – 5.4 below.
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5.3 If you would like to stop unsolicited telemarketing calls from companies (including
seethelight), please contact the Telephone
Preference Service on 0845 070 0707, or do this online at
www.tpsonline.org.uk and register your
telephone number(s). Direct marketing calls should stop after 28 days.
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5.4 If you would like to stop unsolicited direct marketing mailings companies (including
seethelight), please contact the Mail Preference
Service on 0845 7034599, or do this online at
www.mpsonline.org.uk. Direct marketing
mailers should stop after 3 months.
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5.5 If you would like to stop unsolicited fax calls from companies, please contact the Facsimile
Preference Service (FPS) on 0845 070 0702, or do this online at
www.fpsonline.org.uk and register your
telephone number(s). Direct marketing calls should stop after 28 days. Remember to re-register
if you change your address.
6. Sharing of your Personal Data
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6.1 The information you provide to us will be transferred and stored on our servers in the UK.
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6.2 As a normal part of our business, we share with other communications companies information
for connecting and charging for calls over each others' networks. We sometimes use other
companies to provide services to you or to provide services to us. To enable them to do this,
we may need to share your personal information with them. When we do so, these companies are
required to act in accordance with the instructions we give them and they must meet the
requirements of the Data Protection Legislation to keep the information secure. Disclosures to
third parties, other than as described in this privacy policy, will occur only with your express
consent or as is required by law.
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6.3 We make our customers' telephone numbers available to directory enquiry services, unless the
customers have chosen to be registered ex-directory.
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6.4 seethelight may share
information with credit reference or fraud prevention agencies.
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6.5 If you have consented at the point of data collection, we may allow carefully selected third
parties, including marketing and advertising companies, or our business partners to provide you
with direct marketing material, and you will be requested to elect the type of media via which
this material shall be provided (e.g. by post, email, telephone, fax, [or mobile message]).
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6.6 If at any stage, you object to the use of your personal data for direct marketing in the way
described at section 6.5 above, or to the media in which such material is being sent, you may
unsubscribe to its receipt of it. You may do this by following the methods contained in the
relevant communication, or contacting us via the details set out in section 8.4 below.
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6.7 We may also provide our advertisers with aggregate information about our users (for example,
we may inform them of how many people in a certain area have clicked on their advertisement on
any given day). You will not be personally identifiable from this aggregate information.
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6.8 If our business enters into a joint venture with, purchases or is sold to or merges with
another business entity, your information may be disclosed or transferred to the target company,
our new business partners or owners or their advisors.
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6.9 We may use the information that you provide to us if we are under a duty to disclose or
share your information in order to comply with (and/or where we believe we are under a duty to
comply with) any legal obligation; or in order to enforce our
Terms & Conditions and any other agreement; or to protect the
rights, property, or safety of seethelight, its customers, its employees or others. This
includes exchanging information with other companies and other organisations for the purposes of
fraud protection and prevention.
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6.10 We work closely with third parties (including, for example, our business partners) who may
collect personal information from you and pass it on to us. Where this is the case the third
party is responsible for obtaining the relevant consents from you to ensure you are happy with
the ways in which your personal data will be used.
7. Privacy policy call recording
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7.1 Please note that, subject to receiving your consent, we may record all inbound and outbound
telephone calls made to and by our customer support centre for training and quality purposes. In
addition, where we receive your consent to do so, in some instances we may be required to send
call recordings to third parties for whom we sell products or services over the phone. This is
so that they can monitor the quality of our calls when selling their products or services.
8. Retention of your Personal Data
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8.1 The time period for which we keep information varies according to the purpose for which the
information is used. In some cases, there are legal requirements to keep data for a minimum
period. Unless there is a specific legal requirement for us to keep the information, we will
retain the information for no longer than is necessary for the purposes for which the data was
collected or for which it is to be further processed.
9. Your Rights and Making Changes to Your Retained Personal Data
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9.1 You have the right to see the information we hold about you and to ask us to: (a) make any
changes to ensure that any information we hold about you is accurate and up to date; (b) erase
or stop processing any information we hold about you where there is no longer a legal ground for
us to hold it; or (c) transfer any information we hold about you to a specified third party. If
you wish to do this, please contact us using the contact details set out below.
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9.2 We will usually inform you (before collecting your information) if we intend to use your
information for marketing or research purposes or if we intend to disclose your information to
any third party for such purposes. You can exercise your right to prevent such processing by
checking certain boxes on the forms we use to collect your data. You can also exercise the
right at any time by contacting us at the details set out at section 8.4 below.
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9.3 Should you have any queries or complaints in relation to how we use your information, please
contact us via the details set out at section 8.4 below. Should you wish to take any complaints
or queries further, you have the right to contact the Information Commissioner's Office
regarding such issues.
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9.4 If you have any comments or concerns regarding our privacy policy, please contact our data
protection officer: Email: company.secretary@bu-uk.co.uk; Telephone: 02920 028 711 Address: Data
Protection Officer, seethelight, Driscoll 2, Ellen Street, Cardiff CF10 4BP.
10. Security of your Personal Data
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10.1 We take very seriously the guarding and security of your personal information and the
details of any transactions made. We take appropriate organisational and technical security
measures to protect your data against unauthorised disclosure or processing.
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10.2 Where you have chosen a password which allows you to access certain parts of the Website,
you are responsible for keeping this password confidential. We advise you not to share your
password with anyone.
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10.3 We use secure servers to store the information you give us when you register or place an
order (including your credit card details and your password). Any personal data you send us
online is securely encrypted. These measures ensure an appropriate level of security in relation
to the risks inherent in the processing and the nature of the personal data to be protected.
Your securely held personal data will only be accessible by select authorised members of
seethelight.
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10.4 Please note that your billing account number is a sensitive piece of information, which can
be used, with your telephone number to find out information about your use of the
seethelight's services. Please ensure that you
keep this information in a safe place and do not share it with others. For access to
information, such as itemised billing and some business account and ordering services, extra
proof of identity and authorisation may be required.
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10.5 The information that we collect from you may also be transferred to, and stored at, a
destination outside the European Economic Area ("EEA"). It may also be processed by staff
operating outside the EEA who work for us or for one of our suppliers. This includes staff
engaged in, among other things, the processing of your payment details and the provision of
support services. By submitting your personal data, you are acknowledging this transfer,
storing or processing. We will take all steps reasonably necessary to ensure that your
information is treated securely and in accordance with this privacy policy and the Data
Protection Legislation. This means that we will only transfer your information to third
parties that (a) are in countries that have been confirmed by the European Commission to
provide adequate protection to personal information; or (b) have agreed to provide all
protections to your personal information as set out in the Data Protection Legislation.
11. Your Privacy and Third Party Websites
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11.1 In the event that you access links to third party websites from the Website (for
information, products or services), please be aware that your use of these websites is not
covered by our privacy policy. We therefore urge you to be careful when you enter any personal
information on these third party websites. seethelight does not accept responsibility or
liability for these third party websites. You are strongly advised to read any privacy policy
which is displayed on a third party's website.
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11.2 In the event that we allow other companies to advertise or offer their products or services
on our Website, please be aware that they may also allocate cookies to your computer. The use of
the information generated by such cookies will be governed by their own privacy policies and not
ours. However, you may refuse such cookies by following the procedure described in section 9
above.
12. Changes to This Privacy Policy
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12.1 We may change our privacy policy from time to time without notice. Any changes to the
policy will be published on our Website and, where appropriate, notified to you by email. By
continuing to use the Website, you agree to the updated privacy policy. If you do not agree to
any changes that we make, you should not use or access (or continue to use or access) the
Website and/or our services.