What is this policy for?
Your privacy is important to us. This policy explains what personal information we collect from you when you purchase products and services from us, when you use our website and when you contact us, how we store and use it, and how you can access and manage this information.
Why do we collect your personal information?
We collect information to help manage your account:
- To deliver your products and services.
- And to manage our network.
The law also requires us to keep some information. Occasionally this information is anonymised, so you can’t be identified.
Here is a list of things we will always do:
- Ensure all personal data is collected in a fair and lawful manner and used only for specified purposes.
- Ensure personal data sought is adequate, relevant and not excessive for the purpose.
- Ensure personal data we keep is accurate and up-to date. To achieve this, we rely on our customers notifying us of changes to their personal data.
- Keep personal data secure.
- Keep personal data no longer than is necessary and to dispose of it appropriately when it is no longer required.
- Take appropriate technical and organisational measures against unauthorised and unlawful processing accidental loss, destruction or damage to personal data.
- Only pass your personal data onto another organisation if we need to for the purposes of providing our products and services or are required to by law or regulation. Before transferring any such data, we will check that the organisation has appropriate data protection policies.
The type of information we have
- Who you are: Your name, address, your payment information.
- How you use your services: your call records, how much data you have used, when you paid your bills.
- Records of communications we have with you: including phone conversations, emails, community posts and web chat conversations for the purposes of training our staff, continually improving our services and where necessary, providing evidence or verification of transactions or events.
Where do we get your information?
We collect information when you sign up with us, contact us and when you use our products and services.
For example, when you:
- Register as a Trooli customer.
- Get in touch with us to ask something.
- Buy from us – whether it’s online, over the phone or somewhere else.
- Enter any promotions through one of our services.
- Make changes to or close your Trooli account.
- Go to our website.
- Use our networks.
- Apply for a job with us online.
How we use your information
We use and analyse your information to keep in touch with you and to supply and improve our products and services. Sometimes we’ll combine and anonymise this information, so you won’t be identified. In particular, this means using your information to:
- Manage your account and help you to manage your account.
- Sort out a payment, put your order through our system or send you an order.
- Get in touch with you (e.g. if we need to tell you about any problems with a service or tell you about important updates to our Terms & Conditions).
- Keep things secure and prevent crime and fraud.
- Manage our network and your use of our network.
- Look into any complaints or questions you may raise.
- Trace and recover debts, manage credit, detect and prevent fraud and money laundering.
- Recover any money you might owe us.
- Assign your debt to permitted third parties and look after any credit you might have.
- Tell you if we’ve changed the way a service works or tell you about a new service that we think may interest you.
- Improve our products and services and develop new ones.
- Send you information about our products and services by phone, post, email, text, online banner advertising, or other ways. For some of this marketing activity we need your consent, and, in those circumstances, we will only send you messages if you have asked to receive them. You can check and update your current preferences at any time by contacting Trooli.
We are allowed to use your information in these ways and share the information as described below because:
- We need to so that we can provide you with products and services and to manage your account with us.
- We need to use some of your information to comply with legal and regulatory obligations (such as legal obligations to keep details of calls made by customers for a certain period of time).
- You have given your consent to us using your data in relation to some forms of use. For example, in relation to using your information to send you marketing messages. You can opt out of this at any time.
How we share your information
In connection with the purposes described above, we may share your information with others. This might mean sharing your information with our sub-contractors or prospective partners who help us run our services, for example our billing or installation services.
We might 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 you give us personal information that’s wrong or we find out or suspect you’re responsible for fraud. In these circumstances we might share your information with third parties such as law enforcement agencies, credit reference agencies and other affected third parties.
- If one of our partners who are processing information for us are compelled to do so by law.
- If there’s an emergency and we think you or other people are at risk.
Why we keep hold of your information.
There are certain reasons we have to keep hold of your information.
We keep information while you’re our customer or after you’ve left us, but only as long as we need it for the purposes described above. How long we keep it depends very much on the type of information and purpose. For example, we might need to sort out disagreements, stop fraud and abuse, prove that you had an account with us or follow our legal obligations. Or the police may need it as evidence. In each case, the length of time that we need to keep the information may be different, but we will only keep the information for as long as we need it.
You have a number of legal rights in relation to the information that we hold about you, including
- The right to request details of the information we have about you; this is called a Subject Access Request (SAR). Only information considered to be your personal data will be released under a SAR. To make a valid SAR, you must put your request in writing to Trooli, and send it to: Data Controller, Subject Access, Trooli Fibre, Suite 2, Branbridges Industrial Estate, East Peckham, Kent, TN12 5HF.
- The right to withdraw your consent to the use of your information where we are relying on that consent (for example, you can opt out of receiving marketing messages from us). Please note that we may still be entitled to process your information if we have another legitimate reason (other than consent) for doing so.
- The right to ask that we update your information if it is inaccurate or incomplete.
- The right to ask that we erase your information in certain circumstances. Please note that there may be circumstances where you ask us to erase your information, but we are legally entitled to retain it.
- The right to request that we restrict the processing of your information in certain circumstances. There may be circumstances where you ask us to restrict the processing of your information, but we are legally entitled to refuse that request.
- The right to make a complaint with the Information Commissioner www.ico.org.uk if you think that any of your rights have been infringed by us.
If you don’t want us to send you relevant offers or marketing information let us know by contacting us using the details set out in the “Contact us” section of our website.
Communicating over the internet
Please remember, any emails or other communications you send over the internet aren’t safe unless they have been encrypted. The communications might go through a few countries before they get to the recipient, even if the recipient lives in the same street as you! Unfortunately, that is how the internet works. If someone gets into your emails without your permission, or your personal information is shared publicly as a result of unencrypted communications, we can’t accept responsibility because it is out of our control.