Fleur Telecom Privacy Policy

1.1 This is the privacy Policy of Fleur Telecom. We are part of the TalkTalk group of

companies. Fleur Telecom is the data controller for this specific privacy policy only. Our

registered address is Telecom Acquisitions, 8 Piries Place, Horsham, RH12 1EH. Trading as

Fleur Telecom, we provide telephony, broadband, fibre, and TV services. We are

responsible for your personal data as data controller. Together we refer to the company as

“Fleur Telecom”, “we”, “us” or “our”.

1.2 We have a data protection officer who is responsible for all our issues relating to the

protection of personal data. The data protection officer can be contacted at the address below:

The Data Protection Officer

Fleur Telecom

Telecom Acquisitions

8 Piries Place

Horsham

RH12 1EH

1.3 This privacy policy replaces all previous versions and applies from 1

st June 2024.

2.1 This privacy policy applies to customers, prospective customers, individuals that use

our website, former customers, nominated users or individuals acting under a power of

attorney.

2.2 Our services are not intended for children, unless we expressly state otherwise, and

we do not knowingly collect or process personal data relating to children or anyone aged

under 18 years.

2.3 It is important that the personal data we hold about you is accurate and current. It’s

your responsibility to keep us up to date if you make any changes to your personal data

through updating your details via contact with our customer service team.

3.1 Personal data is any information that can identify a natural person. We may collect,

use, store and transfer different categories of personal data to enable us to deliver our

services, as follows:

a) Data about your Identity including first name, last name, title, date of birth and gender.

b) Data about your contact details including service address, correspondence/billing

address, email address, landline telephone number and mobile phone number.

c) Financial data including your bank account details for a direct debit and payment card

details and your credit rating.

d) Data relating to a transaction including details about payments to and from you and

about the products and services that you have purchased from us.

e) Technical data including IP address, your login data, browser type and version, time

zone setting and location, browser plug-in types and versions, operating system and

platform, online chat logs and other information on the devices you use to access our

services.

f) Data about your Origin portal profile including your username and password, your

marketing preferences, feedback and survey responses.

g) Data about your usage or potential usage of our products and services including the

suitability of your property for certain products, the devices, set up or configurations

you have, or might require, to use the services, the amount of time you spend online,

the channels and programmes you watch and record, websites you visit, or when you

make a call, the number, destination and length of your call.

h) Data relating to your marketing and communications choices including what method

you would like to receive marketing and how frequently which can be done in the

customer portal; and special categories of personal data including information about

your health that we may need to know to provide you with the best service for you.

3.2 We may also collect and use non-personal data such as statistical or demographic

data. This data may be derived from your personal data but is not considered personal data

as this data cannot identify you.

4.1 Information you give us:

a) When you place an order with us for any of our services (for example over the phone,

online or through a third-party affiliate), we will need certain information to process

your order.

b) When you contact us to discuss your services, we may ask for certain information to

be able to confirm your identity, check our records and answer your questions quickly

and accurately.

c) If you take part in any trials, complete any survey or enter any competitions we may

ask for information about you, which we will make clear to you at the time and for the

purpose we will be using this information.

4.2 Information we automatically collect:

a) We will automatically collect information:

I. When you use our services

II. When you visit our websites or use our mobile applications, we may collect and

process information about your usage of these by using “cookies” and other similar

technologies to help us make improvements to the websites and to the services

we make available.

III. When you download or use mobile applications created by us and, where

applicable, have requested or consented to location services, we may receive

information about your location and your mobile device, including a unique

identifier for your device. We may use this information to provide you with locationbased services, such as search results, and other personalised content. Most

mobile devices allow you to turn off location services. We do not collect precise

information about the location of your mobile device.

4.3 Information we receive from other sources;

a) we may receive personal data about you from third parties and other entities, publicly

available sources and other companies within the TalkTalk group in the following categories:

I. Companies contracted by us to help us provide services to you.

II. Other telecommunications operators when transferring services.

III. Marketing or market research organisations.

IV. Credit reference agencies or fraud prevention agencies.

5.1 The information we collect and receive helps us to better understand what you need

from us and to improve the provision of our services to you.

5.2 We use the information collected for example to:

a) Verify your identity when you use our services or contact us.

b) Process your enquiries, orders or applications, for example when assessing an

application, we may use automated decision-making systems.

c) 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 to meet our legal

and regulatory obligations.

d) Where you have agreed, provide you with information about other Fleur Telecom

services, offers or products which you may be interested.

e) To tell you about changes to our website, services or terms and conditions.

f) Carry out any personal data and/or marketing analysis, profiling or create statistical or

testing information to help us personalise the services we offer you and to understand

our users/customers better, understand what our users/customers want and how they

use our products and services.

g) Recover any monies you may owe to us for using our services.

h) Analyse our services with the aim of improving them.

i) Prevent or detect a crime, fraud or misuse of, or damage to our network, and to

investigate where we believe any of these have occurred.

j) Monitor network traffic from time to time for the purposes of backup and problem

solving.

5.3 Your data may also be used for other purposes for which you give your specific

permission or, in very limited circumstances, when required by law.

5.4 We may supplement the information directly collected by us with data from third

parties (for example, socio-demographic data, credit reference agencies and fraud prevention

agencies etc.) to further improve our data quality as well as the services or products we offer

customers.

6.1 We may need to share your information with organisations outside Fleur Telecom

e.g. to help us provide our services to you.

The categories of parties that we would share your details with are:

a) Third party suppliers who help Fleur Telecom to perform our services.

b) Professional advisors.

c) Law enforcement agencies.

d) Other companies as part of the process of selling one or more of our businesses or

part of those businesses.

e) Other TalkTalk group companies.

f) Regulators (such as Ofcom or the ICO).

Where we share your information with third parties, they are required to follow our express

instructions in respect of the use of your personal information and they must comply with all

applicable UK data protection laws to protect your information and keep it secure.

7.1 We take protecting your data seriously and will do our utmost to employ appropriate

organisational and technical security measures to protect you against unauthorised disclosure

or processing.kl6

7.2 Unfortunately, we cannot guarantee the security of transmitting information via the

internet. We have tried to create a secure and reliable website and mobile application for our

users in line with industry standards. However, we have no responsibility or liability for the

security of personal information transmitted via the internet.

8.1 We process each type of personal data for one the following reasons:

a) We need to process the data under our contract with you for our services.

b) We have a legitimate interest as a business processing your data.

c) We have a legal obligation to process the data.

d) We have your consent (which you can withdraw at any time).

8.2 If you don’t provide us with the data we need then we may not be able to perform our

contract with you and may need to terminate the contract. If this happens we will notify you

as set out in our Terms of Service.

9.1 From time to time the third parties we share our data with may be outside of the

United Kingdom in countries that do not always have the same standard of data protection

laws as the UK. However, we will have a contract in place to ensure that your information is

adequately protected, and we will remain bound by our obligations under applicable UK data

protection laws even when your personal information is processed outside of the UK. The

sorts of measures we use to protect your data in this instance are security reviews of the

organizations, contractual model clauses approved for use by the European Commission or

other approved transfer mechanisms.

10.1 Unless there is a specific regulatory or legal requirement for us to keep your

information longer, we will keep your information for as long as it is necessary for the purpose

for which it was collected.

10.2 To determine the appropriate retention period for personal data, we consider the

amount, nature, and sensitivity of the personal data, the potential risk of harm from

unauthorized use or disclosure of your personal data, the purposes for which we process your

personal data and whether we can achieve those purposes through other means, and the

applicable legal requirements.

11.1 As a data subject you have personal rights under data protection laws in relation to

your personal data. These are:

a) Subject access requests – You have a right to access personal data that we hold as a

data controller.

b) Right to be forgotten – In certain circumstances you have a right to request that your

personal data be erased from the systems within our control.

c) Rectification – You have a right to correct your personal data that we hold as a data

controller.

d) Withdraw consent – Where we have offered you the right to consent to giving us your

data, for instance with your marketing preferences, you have the right to withdraw

your consent at any time.

e) Objection and restriction of processing – In certain circumstances, you have a right to

object to or request we restrict our processing of your personal data.

f) Right to port – You have a right to receive certain information about you in a machine-readable format.

11.2 If you would like more information about these rights or how to apply them, please

contact our customer service team, you can find details on the “contact us” page of our

website.

12.1 If you would like to make a complaint about our use of the personal data you should

contact our Data Protection Officer at the details above. If we have not resolved your

complaint, you can contact the UK data protection regulator, the Information Commissioner’s

Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your

concerns before you approach the ICO so please contact us in the first instance.

We may update this privacy policy from time to time. The revised policy will be posted to the Fleur Telecom website.