Your privacy is our priority
Your data is important. It’s important to us, and we understand that it’s important to you. We are committed to safeguarding your information in line with the latest data protection and privacy laws. We also want to be transparent about what information we collect about you, how we use it, and how you can control what we do with this information.
About this notice
In this notice, “We”, “Us” and “Our” means Outernet Global LimitedThis privacy notice was last updated on October 2018.
What information do we collect?
The information we collect about you depends on which of our Services you’re using, but we’ll only collect your personal information where necessary. Information we may collect includes:
[your name, address, postcode, email address, date of birth, telephone number, payment details and details of the Service(s) you are using]
information about your use of our Services, including details of your internet protocol (IP) address, device type and identifier, operating system, browser version, cookie data, the content you viewed and details of your navigation around the Services
location data from your IP address or by accessing global positioning functionality on your device (e.g. GPS)
other data from time to time, to help us provide you with improved products and services - for example when we ask you to fill in a survey or questionnaire;
other data to review compliance with the our terms and conditions and/or otherwise as required by law]
When and how do we collect information?
We (or our authorised third parties) may collect information about you:
[when you first register for our Services or otherwise update your detailswhen you buy, or subscribe to, content from us
when you contact us with an enquiry, request or other feedback
when you participate in interactivity (for example, when you submit an entry to a competition or prize draw, or you vote in one of our polls)
when you request to be sent communications such as updates or newsletters
in monitoring your use of the Services
when you send communications via the Services
when we are checking compliance with our terms and conditions and/or otherwise as required by law
when you disclose your personal information to us or otherwise through the Services
from third party suppliers who have confirmed they are authorised to pass your information to us in accordance with your legal rights]
We may also combine information you provide on one Service with information collected from other Services and/or with information that is either publicly available or received from other reputable sources. All information will be stored and used in accordance with this privacy notice.
It’s your responsibility to ensure that any registration data you provide to us is accurate and kept up to date.
Some of our Services may only be available to you if you provide us with the data requested.
How long do we keep your information?
We keep your personal information for only as long as necessary, which is longer in some cases than in others. The length of this retention period depends on the purpose for which the data was obtained and its nature. For example:
we may need to keep some personal information about you so we can deal with any complaints you might make about the Services we provide to you
if you ask us to stop processing your personal information for direct marketing, we need to retain enough information about you to enable us to ensure we stop including you in those direct marketing activities
we may need to keep personal information so we can defend possible future legal claims. Unless there’s some other reason for keeping it, personal information will be deleted when such a claim could no longer arise or it is no longer required in order to defend legal claims that have arisen
we may have a legal or regulatory duty to retain particular personal information for a certain minimum period (for example under the ASA rules, or under HMRC tax rules)
How will you use my information?
We and our authorised third parties may use your information in a variety of ways, to:
monitor, develop and improve the Services and/or your experience of them (this may include personalising the advertising or content you see)
assist in and administer the provision of Services to you
provide you with product and Service recommendations
process payments from you to us (where applicable)
deal with any complaints or enquiries made by or about you
contact you with Service messages
administer your prize and publish details if you win a competition
provide you with access to one or more social networking sites from the Services or your Outernet account (note that if you choose to connect to a social networking site from your Outernet account or the Services, your personal information may be shared between us and your social networking account and any personal information shared with a third party social network provider will be processed in accordance with their own privacy notice)
geo-block or regionalise our Services to ensure that we comply with our legal obligations
We’ll only process your personal information where we have legal grounds to do so. Generally, we’ll only process it on the following grounds:
you have given consent for the processing. When we rely on consent to process your personal information, you always have the right to withdraw this consent (please see the privacy notice for the applicable Service for details of how to withdraw your consent) or the processing is necessary for the performance of a contract to which you are a party (including the terms & conditions of the relevant Service)
the processing is necessary in order to take steps at your request prior to entering into a contract
the processing is necessary for compliance with a legal obligation placed on us
the processing is necessary for the purposes of the legitimate interests pursued by the Outernet or by a third party.
An example of where we process your personal information on the basis of legitimate interest is geo-blocking. Some of our content is only available in certain parts of the world. This is due to a range of legal and regulatory issues, and we have a legitimate interest in complying with these restrictions. To ensure we only show you content when you’re in the appropriate territories we detect the IP address of your device to work out your location.
Will we send you marketing messages?
We’ll only send you marketing messages if you indicate that you consent (for example by opting in) to receiving such messages. Where we have your consent we may:
send you information by email, telephone (including SMS and MMS), mail or other methods of communication about existing and new Services and special offers from us
send you information by email, telephone (including SMS and MMS), mail or other methods of communication about related products or services of selected third parties that may be of interest to you
pass your details to selected third parties so they may send you information by email, telephone (including SMS and MMS), mail or other methods of communication about products or services that may be of interest to you. You always have the right to object to us processing your personal information for the purposes of direct marketing. For details of how to exercise this right, see the privacy notice for the relevant Service. Generally:
to stop receiving marketing communications from us, you can use the 'unsubscribe', 'stop' or similar facility contained in any such communication. Alternatively, you can email us at the email address set out in ‘Contact Us’ below stating that you do not wish to receive further communications from us.
to opt-out of receiving any such communications from a third party, you’ll need to contact the applicable third party. Please note that we are not responsible for the communications you receive from any such third party. We don’t pass or sell your personal information to third parties for any other purpose than as set out in this privacy notice or in any applicable service-specific privacy notice. Unless you’ve given us your consent to pass your details to a third party for marketing, we don't give any third party access to your details for marketing. The marketing referred to in this section is conducted by us on our own behalf, or on behalf of third parties.
We may pass information about you to other parties as follows:
to third parties authorised by us and acting on our behalf, such as our employees, contractors, suppliers and/or agents, to administer the Services provided to you. These third parties are only allowed access to your information as needed to perform functions of the Services or to provide services to us. They’re not allowed to use it for any other purpose.
for marketing communications, where we have your consent to do so (see section above on “Will we send you marketing messages?").
as part of general statistical information about the Services’ user base, sales patterns, traffic volumes and related matters. This information won’t include details from which you could personally be identified.
for the purpose of industry measurement (for example by the Broadcasters Audience Research Board).
where relevant, the user name and some profile information you voluntarily provide may be published on areas of the Services such as forums, leaderboards, chat rooms or pages where user submissions are displayed, and this will be the identity by which you are known on those areas.
if there are changes to our business (see section below on ‘Changes to our business’).
We may also share your personal information with other parts of the the Outernet group of companies. We do this to:
provide a more personalised experience across the different Services
provide and/or manage cross or intergroup Services
provide other services and products you request or which might be of interest to you
What are your rights?
Any personal information you supply will be treated in accordance with applicable data protection laws including the General Data Protection Regulation (the “GDPR”) and any other applicable or superseding legislation. We are committed to delivering the rights that individuals are entitled to under data protection laws in the UK. These are:
the right to request a copy of the personal information we hold about you. To do this, please contact us via the Contact Us page making clear that you are requesting a copy of your personal information and including full details of what you require. You may also be required to submit a proof of your identity.
the right to object to your personal information being used for direct marketing. Where required we will ensure we obtain your consent before undertaking marketing and you will have the ability to opt out.
the right to object to your personal information being processed where the legal basis for the processing is our own legitimate interests as a business (see ‘How will we use your information?’ section above). We will comply with such a request unless there is a lawful reason for not doing so, such as when we need to continue to process your information to defend a legal claim or if this information is necessary for the ongoing provision of our Services.
the right to rectification. You may request that we correct any inaccurate and/or complete any incomplete personal information.
the right to withdraw consent. Where we are processing your personal information on the basis that you have given us your consent to do so, you may withdraw your consent at any time.
the right of erasure. You may request that we erase your personal information and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for retaining your personal information, such as keeping your payment information for several years to comply with HMRC rules.
the right to data portability. In certain circumstances, you may request that we provide your personal information to you in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services to us. Where this right is applicable, we will comply with such transfer as far as it is technically feasible.
the right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your personal information. However, you do have the right to contact the relevant supervisory authority directly. To contact the Information Commissioner’s Office in the United Kingdom, please visit the ICO website for instructions.
What this privacy notice does not cover
This privacy notice doesn’t cover companies, services or applications that we don’t own or control, or people that we don’t employ or manage. This includes (without limitation) third party websites or applications/widgets (e.g. from social media platforms such as Youtube, Facebook or Twitter) that we link to or offer via our Services. Nor does it cover advertisers so if you click on an advert and it takes you to an advertiser site, please check their privacy notice.
Also, it doesn’t cover certain pages and services provided via our Services that are hosted, managed and operated by other parties. These third parties, applications and services are wholly independent of us and are solely responsible for all aspects of their relationship with you and any use you may make of them. They may have their own privacy notices and/or terms and conditions of use, which we recommend you read before using.
Service providers based outside Europe
We use certain third party companies to perform some functions of the Services on our behalf or to provide services to us. These third parties are only allowed access to your information as needed to perform such functions or to provide such services. They’re not allowed to use it for any other purpose.
Some of these third party companies are located, or have servers that are located, outside the European Economic Area. Where we share your information with such companies, we take all steps reasonably necessary to ensure your information is treated securely and in accordance with this privacy notice.
However, please note that the data protection and other laws of such countries may not be as comprehensive as those in the European Economic Area. We’ll only transfer your personal information to a territory outside of the European Economic Area under the following circumstances:
the European Commission has determined that an adequate level of protection for personal information is in place in the country to which we transfer your data.
standard data protection clauses as adopted by the European Commission are in place governing the transfer (you can view the standard clauses on the European Union’s legal website at eur-lex.europa.eu).
for transfers to the USA, the recipient organisation is a participant in the EU-US Privacy Shield programme; or
other appropriate safeguards have been put in place, as described in the privacy notice for the applicable Service.
Changes to our business
If we decide to change or restructure our business we may need to pass your personal information to one of our group companies so we can continue to effectively deliver the Services to you.
Also, if we become involved in a merger, acquisition, restructuring, reorganisation or other transaction involving the sale of some or all of our group companies’ assets, then your information may be included in the assets that are transferred to the new owner and may be provided to the entities and advisors involved. Such a transaction may involve us:
retaining the right to continue to use transferred personal information in addition to the right of the new owner to use such information; and
engaging in additional transfers of personal information (including new personal information) with the new owner from time to time following such a transaction.
If there are changes to our business (such as a re-organisation or restructuring), your personal information will remain subject to this privacy notice (as amended from time to time). However, where your personal information is transferred to a new owner following a merger or acquisition it may be subject to a different privacy notice. We, or the new owner, will provide notice to you before any of your personal information becomes subject to a different privacy notice.
Outernet Global Limited is a company registered in England and Wales (registered number 09637757 with registered office at 3rd Floor 114a Cromwell Road, London, United Kingdom, SW7 4AG
The Information Commissioner’s Office (ICO) regulates our processing of your personal information. You have the right to lodge a complaint with the ICO. Details of how to contact the ICO can be found on their website at ico.org.uk.
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