Privacy Policy
Last updated
Oct 9, 2024
Introduction
Voop Wireless Limited and Voop Inc. respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our websites or the Voop Inc. web based platform (the Platform) or when you receive services from us, and tells you about your privacy rights and how the law protects you.
This privacy policy relates to the activities of the Voop group (collectively referred to as Voop, we, us or our in this privacy policy).
Important information and who we are
Purpose of this privacy policy
This privacy policy describes how we collect and process your personal data in connection with our business where you:
(or your business) are a prospective, current or former customer (Customers); or
visit our website or Platform (regardless of where you visit it from) (Website Visitors).
It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you, so that you are fully aware of how and why we are collecting and processing your Personal Data.
Our websites and the Platform are not intended for children, and we do not knowingly collect data relating to children.
Controller
The Voop Group is made up of different legal entities located in the UK and the USA.
Voop Inc is the controller responsible for this website and the Platform. However, depending upon the group company that you are purchasing services from, another group company may be the controller for your data.
We will let you know which entity will be the controller for your data when we hold or process your personal data. If you have any queries, please see section 3 for details of how to contact us.
How to contact us
If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Email address: privacy@voop.com
Postal address: Unit 205 16-16a Baldwins Gardens, London, England, EC1N 7RJ
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (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.
Types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store, transfer the following types of personal data about you:
From employees of our customers:
Identity Data including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data including address, email address and telephone number.
Financial Data including bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
Profile Data including purchases or orders made by you, your interests, preferences, feedback and survey responses.
From Website Visitors:
Identity Data including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data including address, email address and telephone number.
Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data including information about how you use our website and services.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website or Platform feature in order to analyse general trends in how users are interacting with our website or Platform to help improve the website or Platform and our service offering.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) unless you provide this information to us in our communications with you. Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
How we collect your personal data
We use different methods to collect data from and about you including through:
Personal data you provide to us: You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, through social media platforms or otherwise. This includes personal data you provide when you:
apply for our services;
create an account on our website or Platform;
subscribe to our service or publications;
request marketing information to be sent to you;
enter a competition, promotion or survey; or
give us some feedback or raise any complaints relating to our products.
Personal data we collect from third parties or publicly available sources: This covers personal data that is provided to us, usually electronically, or in some cases via other means by a third party. This includes:
Contact, Financial and Transaction Data collected from providers of technical, payment and delivery services; and
Identity and Contact Data collected from publicly available sources such as Companies House.
Automated technologies or interactions: As you interact with our website and Platform, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
How we will use your personal data
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
Performance of a contract with you: where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: we may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Complying with a legal obligation: we may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
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.
Purposes for which we will use your personal data
We have set out below, a description of all the ways we plan to use the various categories of 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.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Direct marketing
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.
We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view of which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.
Third party marketing
We will get your express opt-in consent before we share your personal data with any third party for their own direct marketing purposes.
Opting out of marketing
You can ask us to stop sending marketing communications at any time by following the opt-out links within any marketing communications sent to you, or by contacting us.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations for a service, updates to our terms and conditions and checking that your contact details are correct.
Cookies
For more information about the cookies we use and how to change your cookie preferences, please see the link to the cookie policy set out on our website.
Data sharing
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer our relationship with you or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
Third parties include third-party service providers (including contractors and designated agents) and other entities within the Voop group. We also share personal information with third parties such as IT providers who are undertaking processing on our behalf and in accordance with our instructions.
How secure is my information with third-party service providers and other entities in the group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
When might you share my personal information with other entities in the group?
We will share your personal information with other entities in the Voop group as part of our provision of services to you, our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise and for system maintenance support and hosting of data.
What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.
We may also need to share your personal information with professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Transferring information outside the UK
Within the Voop group
We may share your personal data within the Voop group. This may involve transferring your data outside the UK to our USA entity.
Whenever we transfer your personal data to other entities within the Voop group, we transfer this data on the basis of a legally binding transfer mechanism (such as the International Data Transfer Addendum to the European Commission's standard contractual clauses for international data transfers) entered into by the relevant entities within the Voop group.
Service providers
We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as UK law.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long we keep your personal data
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 unauthorised 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, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your rights in connection with your personal data
You have a number of rights under data protection laws in relation to your personal data.
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
if you want us to establish the data's accuracy.
where our use of the data is unlawful, but you do not want us to erase it.
where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any other of your rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, in those circumstances we could refuse to comply with your request.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Changes to this privacy policy and informing us of changes
We keep our privacy policy under regular review. This version was last updated on 3 October 2024.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address