Privacy Policy

Introduction

We strive to ensure your privacy and online safety is at the forefront of the services and products we provide. We try to only collect the data that is necessary to use, operate and support Connected Networks services.

This privacy policy tells you how we look after your personal data and tells you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

Important information and who we are
Third party links
What kind of data do we collect?
How do we use this information?
Purposes for which we will use your personal data
Change of purpose
Disclosures of your personal data
Is my personal information secure?
International transfers
Data retention
Can I access, correct or delete information about me?
Changes to this policy
Your legal rights
Questions or complaints

Important information and who we are

XCO Holdings Limited trading as Connected Networks is the controller and responsible for your personal data (referred to as “Connected Networks”, “Connected”, “we”, “us” or “our” in this privacy policy).

XCO Holdings Limited is a company incorporated and registered in England and Wales with company number 12323257 with its registered office at Chart House, 2 Effingham Road, Reigate, Surrey, England RH2 7JN.

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

XCO Holdings Limited t/a Connected Networks

Email Address: hello@connectednetworks.io

Postal Address: Chart House, 2 Effingham Road, Reigate, Surrey, England RH2 7JN.

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.

Third Party Links

This website 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. When you leave our website, we encourage you to read the privacy policy of every website you visit.

What kind of data do we collect?

Personal data, or personal information, means information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect personal information in a couple of different ways – directly and indirectly.

Personal information we collect directly from you

We directly collect personal information if you send an enquiry to us from our website, use our portal, or get in touch with us by email or phone. The personal data we may collect includes:

Identity Data, such as your first name, last name, username or similar identifier

Contact Details, such as your postal address, telephone number, email address;
Financial and transactional data, such as credit card number and banking details;
Marketing and communications data, including your preferences in receiving
marketing from us and our third parties and your communication preferences.

Personal information we collect indirectly from you

In order to record data about the use of our website and our portal, we use data that can be

retrieved from cookies and other technology whose purpose is gathering data about website

and portal use. This data may include:

Browser and hardware data, such as IP address, type of device, operating system,
browser type, screen resolution, language, device make and model, as well as the
versions of the above mentioned services.
Cookie and tracking technology data, which would include pages visited, time spent
on pages, language preferences, and other anonymous traffic data.
Transaction data, including details about your Connected Networks subscription, payment dates,
and renewal dates.

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). Nor do we collect any information about criminal convictions and offences.

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 but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific service or feature of a service. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Information for customers of providers using Connected Networks

If you are a customer or subscriber of a provider who uses Connected Networks then any information you

submit to them is collected under their privacy policy and this privacy policy does not apply to

you in respect of information held by such provider. You should contact your provider with any

requests or enquiries you may have.

How do we use this information?

We will only use your personal information when the law allows us to. Most commonly we will

use your personal information in the following circumstances:

where we need to perform the contract we are about to enter into or have entered into
with you;
where it is necessary for our legitimate interests (or those of a third party) and your
interest and fundamental rights do not override those interests);
where we need to comply with a legal or regulatory obligation.

We may, with consent, use email addresses to share news, tips, updates and special offers.

People who receive these promotional emails can unsubscribe at any time. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to your via email or text.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use 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.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interestTo register you as a new customer(a) Identity

(b) ContactPerformance of a contract with youTo activate and maintain you as a user of our services including:(a) Identity

(b) Contact

(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 manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey(a) Identity

(b) Contact

(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 study how customers use our products/services)To enable you to complete a survey(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (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 obligationTo deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) TechnicalNecessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)To use data analytics to improve our website, products/services, marketing, customer relationships and experiences(a) Technical

(b) UsageNecessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)To make suggestions and recommendations to you about goods or services that may be of interest to you(a) Identity

(b) Contact

(d) Usage

(e) ProfileNecessary for our legitimate interests (to develop our products/services and grow our business)

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide what products, services and offers may be relevant for you (we call this 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 that marketing.

Third Party Marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Except as described in this Privacy Policy, Connected Networks will not share, sell, or rent individual personal information with anyone without your permission or unless ordered by a court of law.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider we need to use it for another purpose and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, 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.

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.

Disclosures of your personal data

We may share your personal data with:

service providers to allow us to install any equipment or to carry out any works
necessary in order for you to receive the services
financial institutions and payment providers to process payments and to deal with outstanding or overdue payments
law enforcement agencies, regulatory authorities, courts or other public authorities where we have a legal obligation to do so
third parties to whom we may choose 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 this happens to our business, then the new owners may use your personal data in the

same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Is my personal information secure?

We take security seriously. We take appropriate measures to ensure that the information we collect and maintain is kept secure, accurate and up to date and only kept for so long as is necessary for the purposes for which it is used.

In the unlikely event that there is a breach and your personal information is at risk, you will be notified within 72 hours of discovering the breach. You will be informed of what information is at risk, steps that we have taken to ensure your safety, and what we have do to rectify the breach.

International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

Data Retention

How long will you use my personal data for?

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 data: see [your legal rights] below for further information.

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.

Can I access, correct or delete information about me?

You can request to see what personal information we hold about you at any time. If you are a customer of a provider that uses our services you should ask your provider as they are the data controller for your personal data.

If you think there’s a problem with the personal information we hold about you we will resolve it if necessary.

If you want us to delete your personal information, we’ll take all reasonable steps to do so unless we need to keep it for legal, auditing or internal business purposes.

Changes to this policy

We may review and amend this Privacy Policy from time to time. We will post updated versions of the Privacy Policy on our website.

Your legal rights

You have 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 products or 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 at datacontrol@connectednetworks.io.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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 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.

Questions or complaints

If you have any questions or complaints about our privacy policy or the way we handle your personal information, you can contact us at hello@connectednetworks.io or by mail to XCO Holdings Limited t/a Connected Networks, Chart House, 2 Effingham Road, Reigate, Surrey, England RH2 7JN.

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