Privacy Policy

Last updated: 1 August 2024

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Welcome

As a communications and technology service provider, using personal information is fundamental to what we do – from connecting calls and data services to developing and promoting our services. We believe that it is very important that our customers trust us with their personal information. Full details of our Data Collection Policy are enclosed.

This privacy notice explains what personal information we collect about you and how we use it during our relationship with you. You can also find details of what rights you have (including the right to object to some of the data handling we carry out), as well as how to exercise those rights in the “Your Rights" section below.

Technology is a fast-changing area and can be complicated. We’ve included a “Glossary” which explains the meaning of any technical terms we use in our general business terms. Link: Terms

Who Are We

Where we use the words “We” or “Our” we mean either Manx Telecom Group or Manx Telecom Limited or a sub-company within the group structure, such as Manx Telecom Trading Limited and companies trading as OV, Synapse360 and Smartroam and in addition Isleofmandatecentre.com – all part of the Manx Telecom Group.

Details at: https://www.manxtelecomgroup.com/

This privacy notice explains how we use the personal information collected from or about you when you are one of our customers or when you contact us or use our services and how do we collect your data.

The company that is responsible for your personal information will be the company that is named in any terms and conditions or messages sent to you or who you contracted with.

In some circumstances Manx Telecom Limited and or any sub company are jointly responsible for deciding what personal information is collected, used and stored. This happens where we work together to give you the best customer experience and to be more efficient across our businesses to:

• Provide assistance through our customer service teams;
• Understand how people interact with us;
• Understand how people use our products and services; and
• Carry out checks for account information access (security), fraud and credit risk.

We may also share your personal information with other companies in the Manx Telecom Group. You can find out more details about this in the "Sharing Your Information" section below.

What does this privacy notice cover?

This notice applies to the products and services we provide you (such as mobile, fixed lined, ADSL, Internet based services (broadband and fibre), eSIM, IT Managed Services, your use of our apps and our websites and where we pass your details on to any associated approved sub-contractor as part of your payment for our products or services.

It also applies even if you’re not one of our customers, but you interact with us as part of us running our business, for example by:

• using one of our products or services – paid for by someone else
• acting with authorisation on behalf of one of our customers
• taking part in a survey or trial
• entering a prize or promotion
• calling our helpdesk
• generally enquiring about our services, offers

If you need to give us personal information about someone else in relation to our products and services, this privacy notice will also apply to their information. If we need the permission of the other person to use that information, we’ll ask you to check they are OK with this.

We may have separate privacy notices in the Manx Telecom Group that apply if you buy products or services directly with other companies in the group or if you are a business customer (which applies if you are a sole trader, partnership, or company). You can find links to our other Manx Telecom Group privacy notices below:

• Manx Telecom – Click Here
• OV – Click Here
• Synapse360 – Click Here
• Smartroam – Click Here
• Manx Telecom Group – Click Here
• Isle of Man DataCentre – Click Here
• Business customers – Click Here

For details on any correspondence address for the above, please see our contact section below.

Share and Disclose of Information to 3rd Parties

This notice doesn’t cover other third-party companies or organisations collecting and using your personal information to provide you with products and services, including those who use cookies, tags and other technologies to offer relevant online advertisements to you. You can find more details about how those third parties use your data by visiting their privacy notices on their own websites. You should review their privacy notices before giving them your information.

Your Data Rights

You can ask us to provide you with a copy of your personal data at any time. If you have given us your personal information because you have a contract with us or because you have consented to us handling it, you are entitled to ask us for a copy of this information in a structured, commonly used and machine readable format so that you can reuse it or share it with other organisations.

In some circumstances (including where we rely on ‘legitimate interests’), you have the right to object to our processing of your data and can ask us to restrict our use of your data and to delete it. You also have the right to ask us to correct your information if it’s inaccurate and, as described below, to object to automated decision making.

We aim to provide our products and services in a way that protects information and respects your request. Because of this, when you delete or change (or ask us to delete or change) your information from our systems, we might not do so straight away from our back-up systems or copies on our active servers. And we may need to keep some information to fulfil your request (for example, keeping your email address to make sure it’s not on our marketing list). We may also keep relevant information to provide you service update messages also.

Where we can, we’ll confirm any changes. For example, we’ll check a change of address against the Postal Address File, or we might ask you to confirm it.

There are some exceptions to these rights, for example we might not be able to delete your data if we need it to fulfil your contract or we are required to keep it by law or any legislation. We also might not be able to provide you with information if it would infringe someone else’s rights. We’ll always try to help you with your request and if we believe we are unable to fulfil your request we will always explain why.

Where you have given consent for us to handle your personal information or permission to provide a service, you can change your mind and withdraw this consent at any time. It only applies to how we use your personal information in the future, not what we’ve done in the past (for example if we’ve run a credit check at the start of your contract).

How do I make a request?

You can exercise any of your rights by using the online forms “here”, by accessing your MYMT account, by calling 01624 624624, by visiting our retail premise or by e-mailing DataProtection@manxtelecom.com.

Once we’ve looked at your request, we’ll let you know when you can expect to hear from us. It will normally take us up to one month to complete your request, but it could take longer (up to a further two months) if it’s a complicated request or you send us a lot of requests at once.

Want your bill information?

If you want a copy of your billing information, the quickest way to access this information is by logging into your MYMT account “link”, for your billing information, by calling 01624 624624 from your mobile or landline and we’ll send it to you (you must be the account holder or authorised contact to ask for this information.) If you want to see what contact information we hold about you, you can also log in to your MYMT account. It’s quick and simple to access it this way. If you would like to request any other personal information you can do this by clicking the link above. If you receive your bills by post, this is the method in which your bill information will be sent to you. There will be a charge as outlined on your paper bill for this method of delivery.

Want to change your cookies, marketing or consent preferences?

We only enter into contracts with customers who are over the age of 18. Although the account holder will always be an adult, we recognise that some of our products and services, like mobile devices, may be purchased on behalf of children and so we cannot guarantee that every mobile number or service is held by an adult.

Where you have purchased a product or service on behalf of a child or another individual we may collect and use this person’s data as part of providing our services to the end user in line with this privacy notice. We have developed safety features for devices that belong to a child as well as educational material to help keep your child safe online. You can find more information on these features for “mobile” and “PAYG” for Pay as You go Mobiles.

For specific information on our Cookie policy and how to manage cookies please click “here”

Information we collect about you and how we use it and what data do we collect

The personal information we collect, store and use will depend on the products and services you have with us and how you use them. In most cases we have this information because we collect it directly from you, or because it has been derived from your use of our products and services. In some circumstances we will obtain this information from a third party.

Some of the personal information we may collect, store and use is considered more sensitive (for example data about health or biometric data where applicable). We will only collect, store and use this more sensitive information to support you and your use of our products and services, and only where we put additional measures in place to protect this personal information.

Below you can find details of how and why we use your information and our permitted reason in law (known as ‘legal basis’) to use it. For some products and services, we handle additional information. You can find specific details by looking at the section for the product or service you’ve bought and see an overview in the ways in which we collect and use your personal information during our relationship.

When you create and use your account

When you create an account, we will collect details about you so we can identify you and contact you about your account. As you buy different products and services or contact us these details will be linked to your account so we have a clear record of your relationship with us.

What can be captured here:

• Setting up your Account
• Service Messages
• Connection or Installation Messages
• To Carry Out any Verification, Identification Checks
• Filter Content for Parental Control – Where Applicable
• Customer Service and Complaints
• To Manage any Agreement with us and any potential Credit Services
• Charges and Payment Details, Methods
• Managing Overdue Payments, Debt Collection

Sending you marketing and identifying products and services that may interest you

We want to make sure that our customers know about the great products and services that we offer and that you receive the best offers available, which are tailored and personalised by using the information we know about you.

What can be captured here:

• Marketing Messages
• Prize Draw, Competition or Other Promotion
• Customer Profile Creation – To enable a Tailored Service
• Other Relevant Digital Advertising
• To Run Surveys and Market Research

Full details on what data is captured, on what basis and any further details are available on request, by contacting us at DataProtection@manxtelecom.com.

To give additional help or support where needed

We understand that some customers may need additional help and support from us. We want to ensure that we are here for you and so have in place processes to support those customers who may have additional needs.

Where you have told us that you have additional needs when you purchase a product or service from us, through your interactions with us during our relationship with you (for example if you tell an advisor of your change of circumstances), or if a family member, or carer provides this information on your behalf, we record this to tailor our services to those needs.

You can find more information about what we mean by additional needs and on how we support these customers “here”.

What can be Captured here:

• Managing Your Account
• Products and Servies that are Appropriate for your needs
• To enable a Third Party to Manage Your Account on your Behalf
• Sharing your Information with a debt-recovery agencies

To perform credit and fraud prevention checks

Before we provide you with a product or service (including upgrades or renewals), or sometimes when you use our products and services, we’ll use the personal information you have given us together with information we may collect from any reputable credit reference agencies), and fraud prevention agencies to carry out credit and fraud checks.

If we, a credit reference or fraud prevention agency, decide that you are a credit, fraud or money laundering risk, we may refuse to provide the services or financing you have asked for, or we may stop providing existing services to you.
Or furthermore we may require a security deposit to be paid for a minimum period of 12 months. The value of deposit will depend on the circumstance and or product set that you are taking services with us. This will be advised to you at the time or account registration, taking services out. Any such deposit will be held in account and returned to you after the deposit retention period is completed. No interest will be paid on any deposit being held by us on your behalf. Regular or continued late payment may see the period of your deposit on account being extended.

If you give us false or inaccurate information which we identify as fraudulent, we’ll pass that on to fraud prevention agencies. We might also share it with law enforcement agencies, as may the agencies we have shared the information with.

In the first instance we will utilise information we have on file to determine any initial credit check.

How credit reference and fraud prevention agencies use your information:

What can be captured here:

• Check Details on Application for Products and Services
• Check Affordability Assessments, whether to accept your application and setting credit limits where required
• To Create “Modelling Tools” to establish likelihood of default on payments or to take on new products or to help us improve products and services for customers

Linked Accounts:

If you tell us you’re associated with someone else financially (for example, by marriage or civil partnership), we may link your records together. You must make sure you have their agreement to share information about them. The agencies we share the information with also link your records together and these links will stay on your and their files – unless you or your partner asks the agency to break that link.

If you don’t become one of our customers, we’ll still keep the result of our credits checks about you if we have a legal obligation and it’s in our legitimate interests to help prevent or detect fraud.

We might also share the information with other organisations. We do this because it’s in our, and the organisations’, legitimate interests to prevent fraud and money laundering, and to check identities, to protect our business and to keep to laws that apply to us.

To protect our business, our customers and the public

We use your information to prevent and detect attacks on our network or against your equipment. This helps protect our business, our customers and the wider public.

What can be captured here:

• To prevent and detect criminal activity on our network against your equipment
• To monitor traffic over our network
• To trace nuisance or malicious calls or messages
• To track Malware and Cyber-Attacks
• To help detect and stop crims, prosecute offenders and provide national security
• To make and defend claims
• To route communications through parts of our network and systems
• To assist and review any relevant fraud checks

To develop our business and services and to create aggregated and anonymised information for further use

We use your information to maintain, develop and test our products and services although we’ll always try to use anonymised information for this purpose

What can be captured here:

• To train our people and suppliers to provide you with products and services and to continuously improve our customer service offerings (but we make the information anonymous before where possible)
• To ensure our network is working correctly and to continuously improve and develop our network, products and services for our customers and consumers
• To run management and KPR reporting, resource analytics to improve our business
• To provide other organisations with aggregated and anonymous reports

Platform Analytics – Web Traffic

The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

Google Analytics 4 (Google Ireland Limited)

Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.

Personal Data processed: number of Users; session statistics; Trackers; Usage Data.

Place of processing: Ireland – Privacy Policy – Opt Out.

Fathom Analytics (Conva Ventures Inc.)

Fathom Analytics is an anonymized analytics service provided by Conva Ventures Inc. that gives the Owner insight into the use of this Application by Users without needing to identify them. Data collected is anonymized by making use of hashing techniques. Further information may be found here and within the service's privacy policy.

Personal Data processed: Usage Data.

Place of processing: Canada – Privacy Policy.

Meta ads conversion tracking (Meta pixel) (Meta Platforms Ireland Limited)

Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms Ireland Limited that connects data from the Meta Audience Network with actions performed on this Application. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.

Personal Data processed: Trackers; Usage Data.

Place of processing: Ireland – Privacy Policy – Opt out.

LinkedIn conversion tracking (LinkedIn Insight Tag) (LinkedIn Corporation)

LinkedIn conversion tracking (LinkedIn Insight Tag) is an analytics and behavioural targeting service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this Application. The LinkedIn Insight Tag tracks conversions that can be attributed to LinkedIn ads and enables to target groups of Users on the base of their past use of this Application.

Users may opt out of behavioural targeting features through their device settings, their LinkedIn account settings or by visiting the AdChoices opt-out page.

Personal Data processed: device information; Trackers; Usage Data.

Place of processing: United States – Privacy Policy.

Tag Management

This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralised fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

Google Tag Manager (Google Ireland Limited)

Google Tag Manager is a tag management service provided by Google Ireland Limited.

Personal Data processed: Usage Data.

Place of processing: Ireland – Privacy Policy

CCTV

CCTV systems are used in many of our premises for the purposes of employee safety, public safety and crime prevention and detection. CCTV is also installed on the outside of some of our buildings for the purposes of monitoring building security, crime prevention and detection.

Images captured by CCTV will not be kept for longer than necessary (unless a crime is being investigated when there may be a need to keep images for longer).

Full details on what data is captured, on what basis and any further details are available on request, by contacting us at Dataprotection@manxtelecom.com.

Sharing Your Information:

Who do we share your personal information with, why and how?

We share your personal information with other companies within the Manx Telecom Group for administrative purposes. We have a group-wide arrangement, known as binding corporate rules, to make sure your personal information is protected, no matter which company in the Manx Telecom Group holds that information.

We share your personal information with other organisations for the following reasons:

• With our insurance providers, for example if there is a claim made against us
• With credit reference agencies and collection companies to carry out fraud and credit checks and collect debts, where applicable
• With third parties whose products and services we market to you (where you have given consent to receive such messages)
• With other communications companies (for example where you switch provider)
• With the IOM regulatory and or legal body where we are legally required to share any such data.
• With other organisations, such as spam detection, for the purposes of fraud prevention
• If you enter into a handset and airtime agreement or consumer credit agreement with us, we may need to share details of that agreement and its administration with our third-party finance provider for reporting purposes.

We may also share your information:

• With any public authority or law enforcement agency (if they ask for it)
• To comply with law or regulations, or for possible legal proceedings
• If there's an emergency and we think you or other people are at risk (including for example with the Environment Agency for flood warnings or if you call the emergency services we’re required to give them information about where you are)
• If there’s a change in who owns us or any of our assets, we might share personal information to the new (or prospective) owner and our advisors.

When we share your information with other organisations we’ll make sure it’s protected, as far as is reasonably possible.

Data use Policy. Protecting your information and how long we keep it.

How do we protect your personal information

We have strict security measures to protect your personal information. We check your identity when you get in touch with us, and we follow our security procedures and apply suitable technical measures, such as encryption, to protect your information.

How long do we keep your person information?

We’ll keep details about your account and the products and services you’ve bought and paid for while you’re a customer. In particular we’ll keep the following:

Data Type and how Long We Keep it

• General Account Details - 7 Years from the date of account closure
• Authentication Checks: Fraud, Credit (Identity document checks) - Up to 7 Years, all from date of checks
• Financial payment information - Up to 7 Years, from date of creation
• Summary copy of your bills - Up to 7 Years, from date of the bill
• Customer Service Records - Up to 7 Years, from date of interaction
• Marketing Preferences - 24 months – all scenario’s
• Details Relating to a Dispute - 7 Years from date of case closed
• Data relating to calls and SMSs - Up to 12 Months
• Itemised Billing Records - up to 2 years

In other cases, we’ll store personal information for the periods needed for the reason we collected it or need to use it. And sometimes we’ll keep it for longer if we need to, for example if we’re required to retain data to comply with our legal obligations, or if we need to retain it for the purpose of dealing with legal claims. Otherwise, we delete it. You can ask us for specific information on retention periods using the details below.

Do Not Track

We will adhere to the standard set within our Data Collection Policy and we do not monitor or respond to Do Not Track browser requests.

How to contact us and further details

Complaints regarding data protection

If you have a complaint relating to data protection, please contact our Data Protection Officer at the address above. You also have the right to lodge a complaint with the Isle of Man Information Commissioner’s Office – view contact details at www.inforights.im.

Changes to Your Privacy Policy and Notice Updates

We may keep this privacy policy under review and may make changes from time to time which we will publish on the website. This privacy policy was last updated on 1st August 2024.

How to Contact Us

Questions, comments and requests are welcomed and should be addressed to Manx Telecom Trading Limited, Isle of Man Business Park, Cooil Road, Braddan, Isle of Man, IM99 1HX or by email to Dataprotection@manxtelecom.com.

If you have any queries, please kindly reach out to our Privacy Policy Officers as enclosed above.

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