SMS2 is a trading style of COM-TEL Telecom Ltd, a company registered in England and Wales under company registration 09136759. COM-TEL Telecom Ltd is the data controller and (“We”) take its responsibilities towards the security of your information very seriously. We are also committed to safeguarding your privacy whilst providing you with a professional and personalised service.
This statement explains how we collect any personal information from you or that you provide to us and how it will be processed by us. Please read this policy carefully so as to understand the practices regarding your personal data that are used by COM-TEL Telecom Ltd and how the obligations set out under Data Protection legislation affect you when using our services.
We collect from data from you!
Specific data that we may collect from you
- In the process of setting up an account for you or your company we may collect the following information: Name, postal address, telephone or mobile numbers, email addresses, job title, company name, company registration number, VAT number, IP address, financial information and social media information
- When you contact us to discuss your services, we will ask for certain information to be able to confirm your identity, check our records and answer your questions quickly and accurately.
- Where wholesale call origination services are provided, call record data, including the CLI (Caller Line Identification) passed, the call date and time, the IP the call originated from, the number dialled and the duration of the call.
- Where wholesale call termination services are provided, call record data including the CLI passed, the call date and time, the destination number or IP of the VoIP enabled device the call is delivered to, and the duration of the call.
- Where numbers both national and international the End User’s name, address and postcode.
- Where 999 services are provided the name and installation address (including postcode) of the End User.
- Where directory enquiry services are provided, the End User’s name, address and postcode.
- Where number portability services are provided, the End User’s name, address, postcode and any associated telephone numbers.
- Where broadband, internet and ethernet services are provided, the End User’s name, installation address, postcode and any contact details supplied to aid service delivery.
- Where SMS and text messaging services are provided, the End User’s name, telephone number, email address, postcode and any contact details supplied to aid service delivery.
- Where SMS and text messaging services are provided, the details of that message may be stored in order to assist in dispute resolution or query that may arise from the use of this service or to aid service delivery.
- Where equipment fulfilment and logistics delivery services are provided, the End User’s name, installation address, postcode and any contact details supplied to aid service delivery.
- Where service issues are reported, personal data may be requested in order to investigate these issues such as call date and time, number dialled, CLI passed, call traces and call recordings.
A cookie is a piece of text that a website transfers onto your computer or other browsing equipment, so that that website can remember who you are. It will typically contain the name of the website from which the cookie has come, the lifetime of the cookie and a value. It does not give us access to the rest of your computer or portable media device and only the site that created the cookie can read it. Our cookies cannot be used by themselves to make you personally identifiable but they make the interaction between you and our websites faster and easier.
How we use your information…
COM-TEL Telecom Ltd will only use your information because it is relevant to our dealings with you. This information is used but not limited to the following processes.
- Verify your identity when you use our services or contact us.
- Process any enquiries you have about the service.
- Monitor, record, store and use any telephone, e-mail or other electronic communications with you for training purposes, so that we can check any instructions given to us and to improve the quality of our customer service, and in order to meet our legal and regulatory obligations.
- Provide CDRs for billing verification.
- Provide access to the emergency services including passing the End User name and location data to the emergency operator.
- Provide Portability under Ofcom’s General Conditions.
- Provide the facility to make entries to BT Directory Enquiries.
- Tell you about changes to our websites, services or terms and conditions.
- Advise you about current billing and financial position.
- Recover any monies you may owe to us for using our services.
- Analyse our services with the aim of improving them.
- Prevent or detect a crime, fraud or misuse of, or damage to our network, and investigate where we believe any of these have occurred.
- Monitor network traffic from time to time for the purposes of network optimisation, backup and problem solving.
- If you have agreed, we will provide you with information about our other services, offers or products that you may be interested in.
- Your personal data will be kept secure, accurate and up to date with appropriate technical and organisational methods used to ensure the integrity of the data we hold and to prevent it being accidently lost, accessed or used in an unauthorised way, altered or disclosed. All personal data you provide to us is stored on secure servers located in the United Kingdom, EEA or a destination outside the EEA (European Economic Area).
- Any data that is stored or transferred outside the EEA is only transferred in full accordance with UK data protection laws and/or applicable EU data protection law.
How we retain your information…
We will keep the information for a time period that will vary depending on the way the data is used. Unless there is a specific legal requirement we will keep the data in a form that allows for identification of data subjects for as long as is necessary. Once the requirement to hold the data has passed and there is no legal obligation we will delete the data in line with the regulatory advice within the GDPR.
UK Law requires that we keep certain information about the usage of services that are provided by COM-TEL Telecom Ltd for a period of 12 months. This information includes, but is not limited to, records of the dates and times of the calls or text messages made via your account, the numbers dialled and recipient information. This information may be used by certain law enforcement agencies to prevent and detect crime and to protect national security. We will only disclose this information to them if and when we are legally required to.
In addition to this, we may keep information that is used within the contract of service for a period of six years. This will typically be contract and service related communication.
How we protect your information…
COM-TEL Telecom Ltd take its responsibilities towards the safety and security of all the information and personal data it collects and stores very seriously. We have strong and resilient security and data protection compliance measures in place to make sure your personal information is protected against unauthorised or unlawful disclosures or accidental or unlawful loss. However, we cannot guarantee the security of transmitting information via the internet.
Where any data breach is identified that affects the information that we hold about or have processed from you, we will notify you in writing immediately and provide full information about the personal data affected by this breach.
We will take all appropriate steps to restore any personal data which is lost or corrupted as a result of a data breach where we are at fault.
If you identify any data breach on your network that affects data we have passed to you, you must notify us in writing immediately and provide full information about the data affected by this breach. You have an obligation to take all appropriate steps, to restore all personal data which is lost or corrupted due to a data breach on your network.
Data subject access requests…
Under the General Data Protection Regulation (GDPR) a data subject has the right to request a record of the data held about them as well as asking for any data removal, restriction or transfer.
All requests must be made in writing and sent to the Data Protection Officer for processing. A verbal request is not a subject access request. These should be sent to the following;
The Data Controller
COM-TEL Telecom Ltd
16 Portland Street
Lincoln. LN5 7JX.
To assist the processing of these requests you should provide any identifying account or contract information including name, address, telephone numbers, usernames and email addresses.