Privacy Policy

Full Fibre Limited

Introduction

Welcome to the Privacy Policy of Full Fibre Limited (Full Fibre, the Company, we, us or our).

Full Fibre respects your privacy and is committed to protecting your Personal Data. This Privacy Policy sets out the types of Personal Data we obtain and process, how we use and look after your Personal Data (regardless of how we receive it), your privacy rights and how the law protects you.

This Privacy Policy covers the following specific areas:-

  1. Important Information and Contact Details
  2. The Data we Collect about You
  3. How Your Personal Data is Collected
  4. How We Use Your Personal Data
  5. Disclosure of Your Personal Data
  6. International Data Transfers
  7. Data Security
  8. Data Retention
  9. Your Legal Rights
  10. Glossary

1. Important Information and Contact Details

1.1 Purpose of this Privacy Policy

This Privacy Policy explains how Full Fibre collects and processes your Personal Data, whether it is received through your use of the Full Fibre website (https://www.fullfibre.co), the Fibre Heroes website (https://www.fibreheroes.co.uk) or by other means. It is important that you read this Privacy Policy so that you are fully aware of how and why we may collect or process Personal Data about you.

We may have other privacy policies which apply when we collect or process Personal Data about you on specific occasions – for example, when applying for a job or taking up employment with us. If so, this Privacy Policy should be read in conjunction with those other policies.

This Privacy Policy is not intended for children as we do not knowingly collect data relating to children.

The Glossary in paragraph 10 below sets out the meaning of some of the terms used in this Privacy Policy.

1.2 Contact Details

Name of the Company 

Full Fibre Limited
(registered in England & Wales under company number 11090610)

Registered Office and Postal Address

Suite 2, Pynes Hill Court, Pynes Hill, Exeter, Devon, EX2 5AZ

E-mail Address 

Telephone Number

Websites

Full Fibre website (https://www.fullfibre.co)
Fibre Heroes website (https://www.fibreheroes.co.uk)

1.3 Data Controller

Full Fibre is part of a group of companies which are the (direct or indirect) subsidiaries of Full Fibre Master Holdco Limited (registered in England & Wales under company number 13055343 whose registered office is at 2, Pynes Hill Court, Pynes Hill, Exeter, Devon, EX2 5AZ). Full Fibre is the company within that group which is primarily responsible for processing your Personal Data. It determines the processes to be adopted when using your Personal Data and so is a Data Controller.

1.4 Queries

Full Fibre is not required to appoint a data protection officer under Data Protection Legislation. However, we have appointed Dan Jones as our data protection champion (or data privacy manager) with responsibility for overseeing the operation of this Privacy Policy and for dealing with any questions arising from it. If you have any such questions or wish to exercise any of your rights under this Privacy Policy (see, in particular, paragraph 9 below), please contact Dan Jones (whose contact details are set out in paragraph 1.2 above).

1.5 Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the United Kingdom’s regulator of data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO, and so please contact us in the first instance.

1.6 Changes to the Privacy Policy and in Your Data

We keep our Privacy Policy under regular review. This version was last updated on 19 January 2022.

It is important that the Personal Data we hold about you is accurate and up-to-date. Please notify us if your Personal Data changes during the course of your relationship with us.

2. The Data We Collect About You

Personal Data is defined in the Glossary. Essentially, Personal Data means any information about an individual from which that person can be identified. It does not include anonymous data where the identity has been removed.

We may collect, use, store and transfer different kinds of Personal Data about you. This can be classified in broad terms as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, e-mail address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes 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 our websites.
  • Profile Data includes your username and password, your purchases or orders, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our websites, products and services.
  • Marketing and Communications Data includes your communication preferences, and preferences in receiving marketing from us and third parties.

 

We also collect, use and share Aggregated Data (such as statistical or demographic data) for any purpose. Aggregated Data could be derived from your Personal Data. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. Generally, Aggregated Data is not treated as Personal Data in law as it will not directly or indirectly reveal your identity. However, if we combine Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we will treat the combined data as Personal Data, the use of which is regulated in accordance with this Privacy Policy.

Special Categories of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health and genetic and biometric data. We do not collect any Special Categories of Personal Data about you, nor any information about criminal convictions and offences.

Failure to Provide Personal Data: Where we need to collect Personal Data from you under Data Protection Legislation or the terms of a contract we have with you or are trying to enter into with you, and you fail to provide that data when requested, we may not be able to discharge our obligations under the Data Protection Legislation or to perform that contract. In that case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How Your Personal Data is Collected

We use different methods to collect Personal Data from and about you. These may include the following:

3.1 Direct Contact: You may give us your Identity, Contact, Financial and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, e-mail or otherwise, or in face-to-face meetings with us. This includes Personal Data you provide when you:

(a) apply for our products or services;
(b) create an account on one of our websites;
(c) subscribe to our services or publications;
(d) request marketing to be sent to you;
(e) enter a competition, promotion or survey;
(f) give us feedback or contact us; or
(g) meet us or attend one of our personal visits.

3.2 Automated Technologies or Interactions: Our websites use cookies to distinguish you from other users of the websites, to assist us to optimise your experience when you browse our websites, and to enable us to improve the websites. A cookie is a small file of letters and numbers which, if you agree, we store on your browser or the hard drive of your computer. Cookies allow us to recognise and count the number of visitors to the websites and to monitor how they move around the sites, in order to help us to ensure they can find what they are looking for easily. As you use our websites, we will automatically collect Technical Data about your equipment, browsing actions and patterns by means of cookies. We may also use server logs and other similar technologies, and may receive Technical Data about you if you visit other websites employing our cookies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you wish to withdraw your prior agreement to our use of cookies, please contact the Customer Services Team at Full Fibre (support@fullfibre.co). However, if you disable or refuse all cookies, you may not be able to access fully all or parts of our websites. Please see our Cookie Policy (https://fullfibre.co/wp-content/uploads/2022/01/FullFibre_Cookies-Policy.pdf) for further details about the individual cookies we use and how to recognise them.

3.3 Third Party or Publicly Available Sources: We will obtain Personal Data about you from the following third parties and public sources:-

(a) Technical Data from:

(I) analytics providers (eg, Google based outside the United Kingdom);
(II) advertising networks; and
(III)search information providers.

(b) Contact, Financial and Transaction Data from providers of technical, payment and delivery services (eg, Amazon Web Services who host our portal and other services and are based outside the United Kingdom).

(c) Identity and Contact Data from data brokers or from existing business contacts who make referrals or recommendations.

(d) Identity and Contact Data from publicly available sources (such as Companies House and the Electoral Register based inside the United Kingdom).

(e) Identity and Contact Data from customer relationship managers (eg, HubSpot based outside the United Kingdom).

3.4 Third-Party Links

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy policy of every website you visit.

4. How We Use Your Personal Data

We will only use your Personal Data when permitted by the Data Protection Legislation. We will use your Personal Data in the following circumstances:

  • Where we need to perform a contract entered into, or about to be entered into, with you, and the processing of your data is necessary for that performance.
  • Where it is necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those Legitimate Interests (see “Legitimate Interest” in the Glossary – paragraph 10 below).
  • Where we need to comply with a legal obligation and the processing of your data is necessary for that purpose.

Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will obtain your consent before sending third party direct marketing communications to you via e-mail or text message, or sharing your Personal Data with internet service providers and other third parties for marketing and sales purposes (see paragraph 4.3(b) below). You have the right to withdraw your consent at any time by contacting us.

4.1 Purposes for which We will Use Your Personal Data

We have set out in the table below a description of the ways in which we plan to use your Personal Data, and the lawful basis (and, where appropriate, our Legitimate Interests) on which we would rely in doing so. In addition, we may use your Personal Data for marketing and related purposes as referred to in paragraph 4 above and paragraph 4.3(b) below.

We may process your Personal Data for more than one lawful basis depending on the specific purpose for which your Personal Data is being used. Please contact us if you need details about the specific lawful basis we are relying on to process your Personal Data where more than one basis has been specified below.

Purpose/Activity

Type of Personal Data

Lawful Basis for Processing (including Legitimate Interest)

To contact prospective customers and suppliers

(a) Identity
(b) Contact

Necessary for our Legitimate Interests (to develop our business)

To register you as a new customer

(a) Identity
(b) Contact

Performance of a contract with you

To process and deliver your order which will include:
(a) managing payments, fees and charges
(b) collecting and recovering money owed to us
(c) managing/addressing claims

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our Legitimate Interests (to recover debts due to us, to address claims or to maintain accurate accounting records)

To manage our relationship with you which will include:
(a) notifying you about changes to our terms of business or Privacy Policy
(b) asking you to undertake a review or survey

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our Legitimate Interests (to keep our records updated and to assess how customers use our products/services)

To enable you to participate in a prize draw, competition or complete a survey

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our Legitimate Interests (to assess how customers use our products/ services, to develop them and develop our business)

To administer and protect our business and websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity
(b) Contact
(c) Technical

(a) Necessary for our Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements for you, and measure or understand the effectiveness of the advertising we provide to you

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical

Necessary for our Legitimate Interests (to study how customers use our websites/products/services, to develop them, to develop our business and to inform our marketing strategy)
To use data analytics to improve our websites, products/services, marketing, customer relationships and experiences

(a) Technical
(b) Usage

Necessary for our Legitimate Interests (to define types of customers for our products/services, to keep our websites updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations about goods or services that may be of interest to you

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications

Necessary for our Legitimate Interests (to develop our products/services and develop our business)

4.2 Change of Purpose

We will only use your Personal Data for the purposes for which we first collected it unless we reasonably conclude that we need to use it for another purpose which is compatible with the original purpose. If you wish to receive an explanation as to how the new and original purposes are compatible, please contact us.

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.

Where so required or permitted by law, we may process your Personal Data without your knowledge or consent (provided that it is in compliance with the above principles).

4.3 Marketing

(a) Promotional Offers: We may use your Identity, Contact, Technical, Usage and Profile Data to help us to decide what you may want or need, what may be of interest to you, and which products, services and offers may be relevant for you. 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 that marketing.

(b) Third-party marketing: We will obtain your express opt-in consent before we share your Personal Data with any third party for marketing purposes or with an internet service provider or other third party to enable them to contact you as a prospective customer or to register you as a new customer.

(c) Opting out: You can ask us or third parties to stop sending you marketing material at any time by following the opt-out links on any digital marketing message sent to you or by contacting us at any time. Your opt-out of receiving marketing messages will not apply to Personal Data provided to us as a result of a product/service purchase, product/service experience or other transaction.

5. Disclosure of Your Personal Data

We may share your Personal Data with:-

(a) our employees and other personnel as necessary for them to perform their functions and discharge their duties;
(b) other companies (acting as joint Data Controllers or processors) within the Full Fibre Group for reporting purposes;
(c) (subject to your consent) third parties (including internet service providers) for marketing and sales purposes as mentioned in paragraph 4 above; and
(d) the following parties for the purposes set out in the table in paragraph 4.1 above:

(I) service providers (acting as data processors) who provide IT and system administration services. These include:

(A) Microsoft Office 365, our e-mail, office storage and software provider based inside the United Kingdom;

(B) HubSpot, our customer relationship managers based outside the United Kingdom;

(C)Google based outside the United Kingdom; and

(D) Amazon Web Services, who host our portal and other services and are based outside the United Kingdom;

(II) professional advisers (acting as data processors or joint Data Controllers) based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services;

(III) HM Revenue & Customs, regulators and other authorities (acting as data processors or joint Data Controllers) based in the United Kingdom who require the reporting of processing activities in certain circumstances;

(IV) HM Courts and Tribunals Service or any other relevant court or tribunal based in the United Kingdom for the purposes of instituting or defending legal and other proceedings to which we are or may be party;

(V) any third parties to whom we may decide to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your Personal Data in the manner set out in this Privacy Policy;

(VI) any third parties in compliance with a legal obligation binding on us; and

(VII) any other third parties relevant to our business, such as market researchers and price comparison sites.

We require all third parties to respect the security of your Personal Data and to treat and safeguard it in accordance with the Data Protection Legislation. We only permit third-party service providers to process your Personal Data for specified purposes and in accordance with our instructions.

6. International Data Transfers

We share your Personal Data with HubSpot, our customer relationship managers, Amazon Web Services, who host our portal and other services, and Google. This will involve transferring your data outside the United Kingdom to certain EU member states. Otherwise, we do not transfer your Personal Data outside the United Kingdom.

Whenever we transfer your Personal Data outside the United Kingdom, we will ensure that that Personal Data receives a similar degree of protection by implementing at least one of the following safeguards:-

(a) We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data.

(b) Where we use certain service providers, we may use specific contracts approved for use in the United Kingdom which give Personal Data the same level of protection as in the United Kingdom.

Please contact us if you want further information on the specific mechanism to be used where we transfer your Personal Data outside the United Kingdom.

7. Data Security

We have put in place appropriate security measures to prevent your Personal Data from being (a) accidentally lost; (b) used or accessed in an unauthorised way; (c) altered; or (d) disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who need to know it for the purposes of our business or discharging our obligations to you, or for the other purposes set out in this Privacy Policy. They will only process your Personal Data on our instructions and in accordance with a duty of confidentiality to which they are subject.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you, the ICO and any other relevant regulator should a breach occur in accordance with our legal obligations.

8. Data Retention

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes for which it was obtained or collected (including for the purpose 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 that there is a prospect of litigation in respect of your Personal Data.

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 any 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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances, you can ask us to delete your Personal Data (see paragraph 9.1(c) below for further information). We may also anonymise your Personal Data for research or statistical purposes so that it can no longer identify you; in that case, we may use this information indefinitely without further notice to you.

9. Your Legal Rights

9.1 Legal Rights

Under Data Protection Legislation and in relation to your Personal Data, you have the right to:-

(a) request access to your Personal Data. You are entitled to make a “subject access request”, which enables you to obtain a copy of the Personal Data we hold about you and to check that we are processing it lawfully;

(b) request correction of your Personal Data. This enables you to have any incomplete or inaccurate data we hold about you corrected although we may need to verify the accuracy of the new data provided to us;

(c) request deletion/erasure of your Personal Data. You are entitled to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to its processing (see paragraph 9.1(d) below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with Data Protection Legislation. However, we may not always be able to comply with your erasure request for specific legal reasons – if applicable, these will be notified to you at the time of your request;

(d) object to processing your Personal Data. You have the right to object to your Personal Data being processed where we are relying on a Legitimate Interest (or the Legitimate Interests of a third party) but you think the processing affects your fundamental rights and freedoms, or where we are processing your Personal data for direct marketing purposes. We will respect your objections unless we can demonstrate in any particular case that we have compelling legitimate grounds to process your Personal Data which override your rights and freedoms;

(e) request restrictions on the processing of your Personal Data: You may request that we suspend the processing of your Personal Data in the following cases, namely where:-

(i) you want us to establish the data’s accuracy;
(ii) our use of the data is unlawful but you do not want us to erase it;
(iii) you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend your own legal claims; or
(iv) you have objected to our use of your data but we need to verify whether we have overriding lawful grounds to use it;

(f) request the transfer of your Personal Data to you or to a third party. We will provide to you (or a third party of your choice) your Personal Data in a structured, commonly-used, machine-readable format. This right only applies to automated information where you initially consented to our use of it or which we used to perform a contract with you; and

(g) withdraw consent at any time. Where we are relying on consent to process your Personal Data (but subject as provided in paragraph 4 above), you may withdraw that consent. However, this will not affect the lawfulness of any processing carried out before your consent was withdrawn. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you notify us of the withdrawal of your consent.

If you wish to exercise any of the rights set out above, please contact Dan Jones, our data protection champion (or data privacy manager) – see paragraphs 1.2 and 1.4 above.

9.2 No Fee Usually Payable

You will not usually be required to pay a fee to access your Personal Data or to exercise any of your other rights under paragraph 9.1. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in such circumstances.

9.3 What We May Need From You

We may need to request specific information from you in order to confirm your identity or your right to access your Personal Data (or to exercise any of your other rights under paragraph 9.1). This security measure is to ensure that Personal Data is not disclosed to any person who has no right to receive it.

10. Glossary

Data Controller

means the person or organisation who determines when, why and how to process Personal Data, and is responsible for establishing practices and policies in accordance with the Data Protection Legislation. Full Fibre is the Data Controller of all Personal Data used in our business for our own commercial purposes or relating to its employees and other personnel;

Data Protection Legislation

means the Data Protection Act 2018 and all other laws and regulations applicable and in force from time to time relating to the use, processing and storage of Personal Data and the privacy of electronic communications (including, without limitation, the General Data Protection Regulation ((EU) 2016/679) and any other European Union legislation or regulation (for so long as, and to the extent that, they have legal effect in the United Kingdom), and any guidance and codes of practice issued by the ICO or other relevant data protection or supervisory authority, applicable and having force of law);

Legitimate Interest

means our interest in conducting and managing our business in order to enable us to give you the best service/product and the best and most secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights 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 we are otherwise so required or permitted by law). You can contact us to obtain further information about how we assess our Legitimate Interests against any potential impact on you in respect of specific activities;

Personal Data
means any information identifying a living, identified or identifiable individual, or information relating to that individual that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Special Categories of Personal Data (see below) but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal Data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behaviour; and
Special Categories of Personal Data
means any information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sex life or sexual orientation, or biometric or genetic data.

Fibre Heroes are swooping in to save underserved market towns across the country, by providing ultrafast fibre broadband to 500,000 homes and businesses by 2025.

Fibre Heroes is part of Full Fibre Limited. Prices shown are indicative of ISP pricing and subject to change.

Terms and Conditions

*Conditions

This information does not constitute an offer by Full Fibre Limited (“Full Fibre”) which is available to you to accept (or transfer or sell). Instead, Full Fibre is putting in place a network which would enable those ISPs which sign up to using that network to offer their own customers prices in the ranges illustrated. These prices (which would include free standard installation and VAT) are indicative only and whether they will be available to you depends on the following factors:-

  • Has your ISP signed up to using Full Fibre’s network?
  • Is your ISP offering these prices? Which prices are offered to end-users ultimately depend on the ISP concerned and Full Fibre does not control this decision or impose prices.
  • Has the Full Fibre network gone live in your area?
  • Are there any technical or other issues affecting your access to the Full Fibre network?
  • Would you be a new fibre connection with the ISP? The indicative prices are not aimed at an ISP’s existing customers.

Full Fibre also reserves the right to amend these price illustrations (and its website generally) at any time.”