Privacy Policy

BEELINE NETWORKS PRIVACY POLICY 

Suite A 8th Floor St James House, Pendleton Way, Salford, Manchester, M6 5FW 

INTRODUCTION 

WHO WE ARE 

Beeline Networks limited (“Beeline”, “we”, “us”, or “our”) is committed to protecting  personal data. This privacy policy describes why and how we collect and use personal  data and provides information about individuals’ rights. It applies to personal data  provided to us, both by Customers themselves, by our Business Partners or which is  collected by us when we conduct our business including through our products, services,  content, websites, online portals and user applications (the “Sites”). We may use  personal data provided to us for any of the purposes described in this privacy policy or  as otherwise stated at the point of collection. 

WHAT WE DO 

We deliver market-leading voice and data connectivity across a converged mobile, VoIP  and broadband platform together with software solutions to business customers in the  UK (“Customers”) together with instant access to tools and real-time data insights that allow businesses to manage their people and productivity and minimise their costs. In  this privacy policy: 

Personal data is any information relating to an identified or identifiable living person. 

CATEGORIES OF PERSONAL DATA 

The information we collect and how we collect it can vary depending on the products  and services that you use and subscribe to, how you have used the products and  services, and how you have interacted with Plan even if you are not a customer, or what  we have obtained from a third party with permission to share it with us. 

Beeline collects and processes personal data under four primary heads:

• Customers 

• Customer End Users 

• Business Partners 

When collecting and using personal data, our intention is to be transparent about why  and how we process personal data. To find out more about our specific processing  activities, please go to the relevant sections of this statement. 

CUSTOMERS 

WHAT WE COLLECT 

If you are a director, partner, owner or authorised signatory of one of our Customers or  a sole trader then, Beeline may collect and process the following data about you: 

• name, address, phone and/or mobile number 

• date of birth, email address 

• your contact with us, such as a note or recording of any call you make to us, an  email or letter sent, or other records of any contact with us 

• address location for billing, delivery, installation or as provided by individual,  phone location 

• how you conduct and manage your account(s) with us 

• whether you are considered vulnerable for the purpose of the Ofcom General  Conditions 

• if you are a sole trader, debit or credit card details, banking details and other  payment information 

HOW WE COLLECT 

We collect your personal information directly from you when you, for example: 

• register to become a Beeline customer 

• submit enquiries to us or contact us (via phone, email, letter, chat or any other  form of communication) 

• enter any promotions, competitions or prize draws via the Services;

• use Beeline products and Services 

• take part in market research 

• when you terminate your account with us 

We may also collect information about you from other sources, including but not limited  to: 

• credit reference agencies 

• fraud prevention agencies 

• our partners. 

HOW WE USE PERSONAL DATA 

We will use our personal information for the following purposes:

To enter into a contract and provide the services: 

Processing your order and providing you with your products and services 

• To verify your identity and confirm that we are dealing with an Authorised  User/Signatory 

• To process the products and services you’ve bought from us, and keep you  updated with the progress of your order. 

• To provide the relevant product or service to you. 

• To monitor and manage the quality of our customer service and to identify  training and development needs and for evidential purposes if required to  resolve a dispute or enquiry 

Billing and customer care 

• To bill you for using our products and services, or to take the appropriate  amount of credit from you. 

• Contact you if the billing information you provided us with is about to expire or  we’re not able to take payment. 

• To respond to any questions or concerns you may have about our network,  products or services. 

Service messages 

• We will contact you with customer service messages to keep you updated with  current information about products and services you’ve taken. For example,  changes to our terms and conditions or service interruptions. 

 To improve our service

Improving and innovating our products and services 

• We collect anonymous, anonymised or aggregate information in order to  improve the service we offer to everyone. 

Managing our networks and understanding network usage 

• To understand how you use our networks, products and services. That way we  can seek to review and improve these, and develop more interesting and  relevant products and services, as well as personalising our products and  services. 

Marketing and tailoring our service to you 

Marketing 

• We may contact you to keep you informed about new and existing products and  services, competitions, prize draws and other promotions. We may also send you  newsletters or white papers and occasionally invite you to participate in market  research. We may tailor these messages based on the products and services  you’ve bought from us in the past. 

• We may also contact you to let you know about products and services of other  companies which we think may interest you. 

• There are various ways that we may do this – including by email, post, phone,  message or notifications through our apps. 

• You can control your marketing permissions and the data we use to tailor these  communications at any time. We will include opt-out options in any marketing  email. 

Research and analytics 

We use a variety of data analytics methods. These data analytics are mathematically  driven analysis techniques on large and varied data sets to uncover hidden patterns and  hitherto unrevealed trends. 

We use our analytics to, for example: 

• Conduct market research and to carry out research and statistical analysis,  including to monitor how customers use our networks, products and services; • Frame our marketing campaigns and determine how we might personalise  those; 

• Provide reports to third parties (such reports don’t contain information which  may identify you as an individual).

 Credit checks, fraud prevention and security 

We will sometimes need to profile you, for credit, fraud and security purposes. Credit checks and ID 

• We will carry out a credit check when you apply for a contract for any products  or services with us. 

• We will also use your personal information for identity verification purposes, for  access to your account and for general account management. We sometimes  supplement the information we collect about you with information from other  sources (for example, the electoral roll and credit reference agencies) to assess  the accuracy of the information that we hold. 

• On occasion this process may involve automated decision-making and profiling  which utilises a series of key data points that (if passed) we consider sufficient to  justify entering into a contract. If any of those data points are not passed, we will  introduce a manual, human-managed check. As the automated decision process  only approves, not rejects, we do not consider that it can negatively affect you. 

CUSTOMER END USERS 

Customer End User Data 

Where our customer is a body corporate, partnership, charity or other entity that is not  an individual (a “Business Customer”), then we process the personal data collected in  accordance with the instructions of that Business Customer. 

Our Business Customers may use the Sites and Services to better understand how their  own users (for example their employees) (“Customer End Users”) engage with and use  our products and services (including our networks). The Personal Information that we  may process regarding Customer End Users is referred to as “Customer End User Data.” 

Our Business Customers choose the type of Customer End User Data processed through  their use of our Sites. The collection of Customer End User Data is governed by our  Business Customers’ own privacy policies and notices, and if you are provided with  access to our services by one of our Business Customers then you should review that  Business Customer’s privacy policy to learn more about that Business Customer’s data  handling practices. 

As an individual you have the right to access, delete and amend the data collected about  you. As we act as the data processor of your data on behalf of the relevant Business  Customer, you need to contact the Business Customer directly if you would like to  access, amend or delete your data.

What we collect 

If you are an employee, consultant, agent or director of one of our Business Customers  or a sole trader then Beeline may collect and process the following data about you: 

• name and mobile number 

• traffic data (data, voice and messaging); 

• data, voice and messaging traffic data, for e.g. the numbers you call or message,  the time and duration of the call or SMS using our network 

• voice and messaging content data, for e.g. the content of a call you make or SMS  you send using our network 

• the time and duration of network data usage for e.g. the duration of your internet  browsing and the volume of any file downloads or streaming whilst connected to  our network 

• network data usage, for e.g. your internet browsing history (including web sites  you visit, apps you use) and classification of content visited, in order to apply  blocks and filters 

• location data. This can be precise where it uses Global Positioning System (GPS)  data or by identifying nearby mobile phone masts and you enable location-based  services or features. Or less precise where, for example, a location is derived  from your data such as a post code or name of a town or city 

• your contact with us, such as a note or recording of any call you make to us, an  email or letter sent, or other records of any contact with us 

• if you are a sole trader, account information, such as dates of payment owed or  received, subscriptions you use, account numbers or other information related to  your account or your use of our Services. 

• your searching, browsing history (including web sites you visit and the time and  duration of such browsing) and location data, internet PC location 

How we collect 

We collect information indirectly from you when you use the Services, including but not  limited to when you: 

• visit or browse the Sites or other Beeline Networks websites or online portals • browse or otherwise access the Internet sites and/or the mobile internet via the  Services 

• download any software that allows us to view your broadband setup  functionality and to proxy on to your computer 

• use our networks (mobile/broadband/wifi or other) 

• call or contact (via email, letter, chat or any other form of communication) to us,  including recording conversations on the phone, as well as the capture of  additional information about these interactions e.g. telephone numbers that you  can call us from and information about the devices and software you use

How we use personal data 

We will use your personal information for the following purposes: 

To provide the services: Providing our Customer with products and services 

• To provide the relevant product or service to our Customer by identifying the  user of a connection (e.g. via a SIM) to our network 

• To provide the Customer with network usage data and content for our  Customer’s training, quality, productivity monitoring, compliance monitoring  (e.g. health and safety) or other purposes 

• To monitor and manage the quality of our customer service and to identify  training and development needs and for evidential purposes if required to  resolve a dispute or enquiry 

Service messages 

• We will contact you with customer service messages to keep you updated with  current information about products and services. For example, service  interruptions. 

To improve our service Improving and innovating our products and services 

• We collect anonymous, anonymised or aggregate information in order to  improve the service we offer to everyone. 

Managing out networks and understanding network usage 

• To understand how you use our networks, products and services. That way we  can seek to review and improve these, and develop more interesting and  relevant products and services, as well as personalising our products and  services. 

• To ensure that we’re meeting our commitments around fair use, to detect and  resolve fraudulent use of our networks (and our partners’ roaming networks)  and to solve technical issues 

Marketing and tailoring our service to you Marketing 

• We may contact you to keep you informed about new and existing products and  services, competitions, prize draws and other promotions. We may also send you  newsletters or white papers and occasionally invite you to participate in market  research. We may tailor these messages based on the products and services  you’ve bought from us in the past. 

• We may also contact you to let you know about products and services of other  companies which we think may interest you 

• There are various ways that we may do this – including by email, post, phone,  message or notifications through our apps.

• You can control your marketing permissions and the data we use to tailor these  communications at any time. We will include opt-out options in any marketing  email.

Research and analytics 

We use a variety of data analytics methods. These data analytics are mathematically  driven analysis techniques on large and varied data sets to uncover hidden patterns and  hitherto unrevealed trends. 

We use our analytics to, for example: 

• Conduct market research and to carry out research and statistical analysis,  including to monitor how customers use our networks, products and services; • Frame our marketing campaigns and determine how we might personalise  those; 

• Provide reports to third parties (such reports don’t contain information which  may identify you as an individual). 

What we collect 

If you are an employee, consultant, agent or director of one of our Business Customers  or a sole trader then Beeline may collect and process the following data about you: 

• name, address, phone and/or mobile number 

• date of birth, email address 

• your contact with us, such as a note or recording of a call you make to us, an  email or letter sent, or other records of any contact with us 

• address location for billing, delivery, installation or as provided by individual,  phone location; 

• how you conduct and manage your account(s) with us 

• if you are a sole trader, debit or credit card details, banking details and other  payment information 

How we collect 

We collect your personal information directly from you when you, for example: 

• register to become a Plan partner 

• submit enquiries to us or contact us (via phone, email, letter, chat or any other  form of communication) 

• enter any promotions, competitions or prize draws; 

• use or sell a customer any Plan products and Services 

• take part in market research 

• when you terminate your account with us

We collect information indirectly, including but not limited to when you: 

• visit or browse the Sites or other Beeline Networks websites or online portals • call or contact (via email, letter, chat or any other form of communication) our  Sales or Partner Support teams, including recording conversations on the phone,  as well as the capture of additional information about these interactions e.g.  telephone numbers that you call us from and information about the devices and  software you use 

We collect information about you from other sources, including but not limited to: 

• credit reference agencies 

• fraud prevention agencies 

• business directories and other commercially or publicly available sources .

To improve our service 

Improving and innovating our products and services 

• We collect anonymous, anonymised or aggregate information in order to  improve the service we offer to everyone. 

• Investigating any queries or complaints that you may raise in respect your  account of the account of a Business Customer. 

 Marketing and tailoring our service to you 

Marketing 

• we may contact you to keep you informed about new and existing products and  services, competitions, prize draws and other promotions. We may also send you  newsletters or white papers and occasionally invite you to participate in market  research. 

• We may also contact you to let you know about products and services of Beeline Group companies and those of other companies which we think may interest you • There are various ways that we may do this – including by email, post, phone,  message or notifications through our apps. 

• You can control your marketing permissions and the data we use to tailor these  communications at any time. See ‘Access to personal data’ within the ‘Your  rights’ section of this privacy policy. 

Research and analytics 

We use a variety of data analytics methods. These data analytics are mathematically  driven analysis techniques on large and varied data sets to uncover hidden patterns and  hitherto unrevealed trends. 

We use our analytics to, for example:

• Conduct market research and to carry out research and statistical analysis,  including to monitor how customers use our networks, products and services; • Frame our marketing campaigns and determine how we might personalise  those; 

• Provide reports to third parties (such reports don’t contain information which  may identify an individual). 

Credit checks, fraud prevention and security 

We will sometimes need to profile you or your directors, shareholders or other officers,  for credit, fraud and security purposes. 

Credit checks and ID 

• We will carry out a credit check when you apply for a contract for any products  or services with us. 

• We may also use personal information of your directors, shareholders or other  officers for identity verification purposes, for access to your account and for  general account management. We sometimes supplement the information we  collect about you with information from other sources (for example, the electoral  roll and credit reference agencies) to assess the accuracy of the information that  we hold. 

Fraud prevention and security 

• We will process your personal and traffic data in order to protect against and  detect fraud, to protect and detect misuse or damage to our networks, to recover  debts or trace those who owe us money resulting from the use of our services. 

OUR LAWFUL BASIS FOR PROCESSING

We have set out below, in a table format, a description of the primary ways we may use  your personal data, and which of the legal bases we rely on to do so. We have also  identified what our legitimate interests are where appropriate. 

Legal basis 

Legitimate interests 

Our legitimate interests are: 

• to run, grow and develop our business;

Legal basis 

• marketing, market research and business development; 

• to provide goods and services to our customers, make and receive payment, provide  customer services and to know the customer that we are providing goods and services  to. 

Performance of a contract 

• The personal information you provide may be processed when it is necessary in order for us  to: enter into or perform a contract with you; supply you with any products or services, or where you are in discussions with us about any new product or service. 

Compliance with legal obligations 

• Where we are under a duty to disclose or share your personal information in order to comply  with a request from government or law enforcement officials.

Consent 

• Where we rely on your consent as the legal basis for processing your personal information,  you may withdraw your consent at any time by contacting us using the details at the end of  this Privacy Statement. If you withdraw your consent, our use of your personal information  before you withdraw is still lawful.

SECURITY 

DATA HOSTING 

We take the security of all the data we hold very seriously. We have policies, procedures  and training in place covering data protection, systems access, confidentiality and  security and regularly review the appropriateness of the measures we have in place to  keep the data we hold secure. 

Beeline’s IT infrastructure is located in secure data centres in the United Kingdom, and  personal data will be stored in those data centres.  

SECURITY OF COMMUNICATIONS 

Please be aware that communications over the Internet, such as e-mails and web-chats,  are not secure unless they have been encrypted. Your communications may route  through a number of countries before being delivered – this is the nature of the Internet.  Beeline cannot accept responsibility for any unauthorised access or loss of personal  information that is beyond our control. 

Media Messaging If you are registered with Beeline, any Media Messages you send to an  email address, including Media Messages from your phone and messages from Beeline,  may include personal details such as your registered first name and last name, your  phone number or email address which will be displayed in the ‘from’ field of the  message. 

TRANSFERS OF PERSONAL DATA 

HOW WE SHARE PERSONAL DATA 

Where applicable, we share personal data with: 

• Companies in the Beeline Group 

• Business Partners, suppliers or agents involved in delivering our products and  services to Business Customers including sharing Customer End User data where  a Business Customer has explicitly consented to a specific Business Partner being  provided with third party access to the Beeline account of that Business  Customer 

• Companies who are engaged to perform services for, or on behalf of, Beeline Group for example third party software developers or third party software  providers. 

• Credit reference, fraud-prevention or business-scoring agencies, or other credit  scoring agencies 

• Debt collection agencies or other debt-recovery organisations 

• Law enforcement agencies, government bodies, regulatory organisations, courts  or other public authorities if we have to, or are authorised to by law

• A third party or body where such disclosure is required to satisfy any applicable  law, or other legal or regulatory requirement 

• Emergency services (if you make an emergency call), including your approximate  location 

• Other third parties when you are signing up to their service and it is used by  them for authentication and fraud-prevention purposes 

• Third parties that we use to serve you marketing. Beeline will use reasonable  endeavours to ensure that any supplier that is provided with or has access to  personal data provides assurances that they will protect that personal data with  at least the same level of privacy protection as is required by this Policy. Where  Beeline has knowledge that a supplier is using or sharing personal information in  a way that is contrary to this policy, Plan will take reasonable steps to prevent or  stop such processing. 

Fraud management and law enforcement 

We will release information if it’s reasonable for the purpose of protecting us against  fraud, defending our rights or property, or to protect the interests of our customers. 

We also may need to release your information to comply with our legal obligation to  respond to the authorities’ lawful demands. Your personal data shall only be provided  when we in good faith believe we are obliged to do so in accordance with the law and  pursuant to an evaluation of all legal requirements. 

Mergers and acquisitions 

If we’re reorganised or sold to another organisation, we will provide your information  to that organisation. 

Third parties that we work with 

Where you’ve purchased Plan products and services using a third party or partner  organisation, we often need to exchange information with them as part of managing that  relationship and your account – for example, to be able to identify your order and be  able to pay them. 

If we have a contract with a service provider or contractor to provide us with services  or provide a service on our behalf, and they may have access to your personal  information, we don’t authorise them to use or disclose your personal information  except in connection with providing their services. 

We collect and combine information in order to monitor your use of products and  services, and that of our other customers, as well as to help us to improve the quality of  our products and services. 

Third-party products that you buy through your Plan account 

Where you buy a third-party product or service through your Plan account (such as  Office365 from Microsoft), the contract for it is with the party selling that product or 

service. Beeline is only charging the amount directly to your bill as part of its  arrangements with the seller (or with a third party authorised by the seller). As part of  this, you’re agreeing that Plan may pass certain personal information to such parties to  complete your purchase. 

The seller’s terms and conditions and privacy and cookies policies will apply to how it  uses your personal information – please read them carefully. 

RETENTION OF DATA 

We retain information only for as long as we need it. In relation to the following  information we are required to retain it for not less than six months and not more than  two years after you have been a customer of Plan in order to ensure that this  information is available for the purpose of the investigation, detection and prosecution  of serious crime: 

• User ID and telephone number allocated to any communication entering the  public telephone network 

• name and address of subscriber to whom an Internet Protocol (IP) address, user  ID or telephone number was allocated at the time of a communication • user ID or telephone number of the recipient of an Internet telephony call • name and address of subscriber and user ID of the intended recipient of a  communication 

• date and time of log-in and log-off of our Internet access service, IP address and  user ID of the subscriber 

• internet service used 

• calling telephone number for dial-up Internet access of the originator of a  communication and 

• digital Subscriber Line (DSL) or other end point of the originator of a  communication 

CHILDREN’S INFORMATION 

We do not provide services to children or proactively collect their personal information.  If we obtain information about children while addressing a service request or query the  information in the relevant part of this notice applies to children as well as adults. 

CALL RECORDING 

We record calls made to and by us across our business. These recordings are made for a  number of purposes including staff training and quality control. Each recording is  encrypted and stored on a secure server. Access to the call recordings is tightly  controlled in accordance with our internal policies and can only be obtained on the  authority of our Data Protection Officer.

YOUR RIGHTS 

Access to personal data 

You have a right of access to personal data held by us. You have the right to: 

• information about how your personal data is processed 

• a copy of your personal data 

• an immediate correction to your personal data 

• raise an objection about how your personal data is processed 

• request that your personal data is erased if there is no longer a justification for it • ask that the processing of your personal data is restricted in certain  circumstances 

How to exercise your rights 

If you are a registered with beeline Networks and are an Authorised User for the  account of a Business Customer, you may verify, update or amend the personal  information you have provided to Beeline Networks at any time by the contact form details”. 

This right may also be exercised by emailing us at [email protected].  

We will aim to respond to any requests for information promptly, and in any event  within the legally required time limits (currently 1 month). 

Correction of personal data 

To update inaccurate personal data submitted to or held by us, you may email us at [email protected] or, where appropriate, contact us via the relevant website  registration page or by amending the personal details held on relevant portals or  applications with which you registered. 

When practically possible, once we are informed that any personal data processed by us  is no longer accurate, we will make corrections (where appropriate) based on your  updated information. 

Withdrawal of consent 

Where we process personal data based on consent, individuals have a right to withdraw  consent at any time. We do not generally process personal data based on consent (as we  usually rely on another legal basis). Nevertheless, to withdraw consent or instruct us to  stop processing of your personal data please email us at [email protected] or,  

to stop receiving emails from a Beeline marketing list, please click on the unsubscribe  link in the relevant email received from us.

Right to data portability 

You have the right to be able to take with you the personal data you provided to us in  certain circumstances.  

Other data subject rights 

This privacy statement is intended to provide information about what personal data we  collect about you and how it is used. As well as rights of access and amendment referred  to above, individuals may have other rights in relation to the personal data we hold,  such as a right to erasure/deletion, to restrict or object to our processing of personal  data and the right to data portability. 

If you wish to exercise any of these rights, please send an email  to [email protected] 

Marketing 

Generally, we do not rely on consent as a legal basis for processing your personal data  although we will get your consent before sending direct marketing communications to  you via email or text message. You have the right to withdraw consent to marketing at  any time by contacting us. 

You can ask us to stop sending you marketing messages at any time by following the  opt-out links on any marketing message sent to you OR by contacting us via email at any  time. Where you opt out of receiving these marketing messages, this will not apply to  service messages. 

We will not sell or rent your data to third parties or share your data with third parties  for marketing purposes. We may use third party software to send you information for  marketing or service purposes. 

If you receive an email which claims to come from us but does not use our domain, or if  you are suspicious that an email may not be approved by us, then please send a copy of  the email to [email protected] so we can investigate.

CHANGES TO THIS PRIVACY STATEMENT 

We recognise that transparency is an ongoing responsibility so we will keep this privacy  statement under regular review. 

This privacy notice was last updated on 13th July 2020 when we changed the layout and  sought to set out examples of the information that was contained in the previous  version of the notice. 

We hope that you won’t ever need to, but if you do want to complain about our use of  personal data, please send an email with the details of your complaint  to [email protected] We will investigate and respond to any complaints we  receive.