This Privacy Notice applies to personal data ZONE BUSINESS SOLUTIONS TRADING AS JUST TELECOM collects through software products, and mobile applications. Below are highlights of our personal data handling practices.

Privacy Notice Highlights

1. Information We Collect

We collect your information from the following sources:

(i) information you give us when you fill out forms, such as during online purchases, customer service inquiries and surveys;

(ii) information from other sources, such as companies that help us to update our records; and

(iii) information that we collect automatically when you visit our website, such as information about your browser settings and other information collected through cookies.

2. How We Use and Disclose Your Information

(i) We use your information to provide products and services and to manage our business operations. For example, we use your information in order to fill your orders, answer your inquiries, authenticate you when you sign into online services, prevent loss and fraud, and analyse our business operations and website performance.

(ii) We combine all the information we collect other than information relating to your browsing history.

(iii) We use third parties to assist us in our operations. We may share your information with these third parties in order to provide services to you such as invoicing.

3. Your Rights

(i) ZONE BUSINESS SOLUTIONS TRADING AS JUST TELECOM allows you to change your communication preferences with respect to e-mail newsletters and notifications of special offers and products.

(ii) You may also choose to withdraw your consent from further use of your information by ZONE BUSINESS SOLUTIONS TRADING AS JUST TELECOM. We may, however, retain information about your previous transactions for audit purposes, to ensure the integrity of our data and to fulfill legal requirements.

4. How to Contact Us If you have a privacy question or concern, please call 0114 229 9132 send an email to: support@justtelecom.co.uk.

Detailed Privacy Notice

5. About Us

ZONE BUSINESS SOLUTIONS TRADING AS JUST TELECOM. Our head office is Hope Works, 25 Mowbray Street, Sheffield, S3 8EL

We have appointed a Data Protection Officer who is accountable for our personal data handling practices. Our Data Protection Officer is Mr Neil Roberts. If you have a 0114 229 9132 send an email to: support@justtelecom.co.uk.   In this Privacy Notice, the terms “we”, “our” and “us” mean ZONE BUSINESS SOLUTIONS TRADING AS JUST TELECOM .

6. Effective Date and Scope

This Privacy Notice is effective as of 18^th February 2020.

This Privacy Notice governs our practices with respect to personal data we collect through our software products, and mobile applications.

7. What Personal Information Do We Collect?

Personal information is information that identifies you or could be combined by us or our service providers with other information to identify you. This information may include your name and surname, e-mail address, your home address, your telephone number, location data, internet protocol (IP) address, a cookie ID, your image, and may include your age and other similar information when associated with you.

We collect personal information from you when you create an account, make a purchase, enter a contest or promotion, communicate with us using our web forms to make a request or ask a question, submit a product review, take a survey or otherwise submit personal information to us with your communication. For example, we will request your full name and other identifying information to process a support ticket when you submit a support request. We will also ask you for contact information in order to either issue out your product or issue to the recipient that you designate.

We receive personal information about you from other sources. For example, we will receive information from shipping companies regarding whether items we shipped were delivered or undeliverable. ZONE BUSINESS SOLUTIONS TRADING AS JUST TELECOM may receive information from credit reference agencies which will add to the information we already have about you on order to help us provide, improve, and personalize our service to you. We may also acquire information about you from other promotional or marketing companies with whom you shared your information and whom you have consented and allowed to provide information to us.

If you provide ZONE BUSINESS SOLUTIONS TRADING AS JUST TELECOM information on behalf of someone else, you confirm that the other person has appointed you to act on their behalf and has agreed that you can:

• give consent on their behalf to the processing of their personal data;
• receive on their behalf any data protection notices;
• give consent to the transfer of their personal data abroad; and
• give consent to the processing of their personal data

8. How Do We Use Your Personal Information?

We use your information to provide products and services and to manage our business operations. Some examples include:

(i) to register your account;

(ii) to authenticate you when you log into your account;

(iii) to process and fulfil your requests for products and services;

(iv) to communicate with you about your requests;

(v) to administer contests and promotions that you participate in;

(vi) to recommend or to offer you other products and services based on your inferred interests;

(vii) to post your product reviews;

(viii) customize our websites and its contents to your particular preferences;

(ix) improve our services;

(x) to communicate with you regarding customer service issues and any product recalls or warranty service; and

(xi) to protect the security or integrity of our websites and our business. We retain your information for as long as necessary to fulfil the purposes for which we collected the information or as required by law. We maintain a records retention and destruction program to destroy information when it is no longer needed or required.

9. Monitoring and Recording Communications

ZONE BUSINESS SOLUTIONS TRADING AS JUST TELECOM may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance.

10. Cookies

When you use ZONE BUSINESS SOLUTIONS TRADING AS JUST TELECOM’s website we may gather information about you through Internet access logs, cookies and other technical means. ‘Cookies’ are text files placed on your computer to collect Internet log information and user behaviour information. These are used to track website usage and monitor website activity and for other data processing reasons set out below.

For example, we may monitor how many times you visit the ZONE BUSINESS SOLUTIONS TRADING AS JUST TELECOM  website or any of ZONE BUSINESS SOLUTIONS TRADING AS JUST TELECOM ’s affiliated sites, which pages you go to, traffic data, location data and the originating domain name of a user’s internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

11. Personalized Offers and Web Analytics

We also automatically collect information when you visit our website in order to customize your experience. For example, we collect information about what site referred you to our website, your browser type, operating system type and version, language, and your Internet Protocol (“IP”) address. We also collect information about how you browse through our website, including logging the pages you visit and the amount of time you spend on certain pages. We use this information for a number of technical purposes to ensure that our pages load correctly in your browser, as well as to personalize our offers to you. We also use this information to improve our website. For example:

(i) we use IP addresses to correct pages for your geographical location;

(ii) we log the frequency of visits to certain pages on our website and how visitors navigate through our website in order to detect problems, improve our website and learn about what products and services are of interest to our customers;

(iii) we use information about products that you have clicked on to make suggestions about other products or services that you might be interested in viewing; and

12. Regarding Children and Minors

Our website and the services offered on our website are not directed to children under the age of 13 years. We will not knowingly collect personal information about a child under the age of 13.

We do not allow minors (persons who are under the age of majority in their place of residence) to create accounts, make purchases or enter contests or promotions.

13. Do We Disclose Your Personal Information to Others?

We may share your personal information with our service providers and our corporate affiliates that help us with our business operations. For example, we will share information about your shipping address with companies that provide shipping services to us. We share information with service providers and/or our affiliates who provide us with marketing and promotional services. We require our service providers to keep your personal information secure. In addition, our service providers may not use or disclose personal information for any purpose other than providing the services on our behalf unless we or they have obtained your consent.

We may also disclose your personal information if it is necessary for us to collect a debt from you or where we have reason to believe that it is relevant to the investigation or decision to investigate a breach of the law and we are legally permitted to do so to help prevent unlawful activity.

14. Law Enforcement Requests

We will disclose personal information without your knowledge or consent if we receive an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of your personal information. If we receive a request from a police officer or other law enforcement agency for access to your personal information in the course of an actual or potential investigation, our policy is to require the police officer or law enforcement agency to obtain an order, subpoena or warrant, unless the information is urgently required to prevent serious bodily injury or serious damage to personal property. If we receive a written request from a police officer or other law enforcement agency with authority to request access to your personal information in the course of an actual or potential investigation into a breach of a law, our policy is to provide the requested information.

15. Keeping Data Secure

ZONE BUSINESS SOLUTIONS TRADING AS JUST TELECOM will use technical and organizational measures to safeguard your personal data.

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us.

16. Storage Outside of the UK

Your personal information may be used or stored by us or our service providers outside of the UK. We require that our service providers safeguard your personal information. However, if your personal information is used or stored outside of the UK, it will also be subject to the laws of the country in which it is used or stored.

17. Storage Outside EEA

Your personal information may be used or stored by us or our service providers outside of the European Economic Area for the purposes as described in this Privacy Notice (see ‘How Do We Use Your Personal Information?’ above). We require that our service providers safeguard your personal information. Any transfer of your data will be subject to a European Commission approved contract that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.

18. Retention of Personal Data

ZONE BUSINESS SOLUTIONS TRADING AS JUST TELECOM retains personal data for as long as necessary to provide the products, services, and fulfil the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly.

19. What Rights Do You Have?
20. i) Right to Access Your Information You can request a copy of your information which we hold. If you would like a copy of some or all of your information in a structured, commonly used and machine-readable format, please: • email or write to us (see ‘How Do You Access and Modify Your Personal Information or Make a Complaint?’ below) • provide proof of your identity, and • identify the information you want a copy of, including any account or reference numbers, if you have them ZONE BUSINESS SOLUTIONS TRADING AS JUST TELECOM may charge a small fee for this service where you request the information in a format other than what was provided.
21. ii) Right to Modify Your information You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please: • email or write to us (see ‘How Do You Access and Modify Your Personal Information or Make a Complaint?’ below) • provide us enough information to identify you (e.g. account number, user name, registration details), and • let us know the information that is incorrect and what it should be replaced with.

iii) Right to be Forgotten You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please: • Email or write to us (see ‘How Do You Access and Modify Your Personal Information or Make a Complaint?’ below). • provide proof of your identity; • let us know the nature of your complaint and how ZONE BUSINESS SOLUTIONS TRADING AS JUST TELECOM  may be in contact with you, if at all (for example, you may be happy for us to contact you by email but not by telephone).

20. How Do You Access and Modify Your Personal Information or Make a Complaint?

If you have an account, log in to access and to modify the personal information stored with your account. If you have questions or concerns about other personal information collected by us and would like assistance accessing that information, or have any questions about this privacy notice, please call 0114 229 9132 send an email to our Data Protection Officer: support@justtelecom.co.uk or write to us at ZONE BUSINESS SOLUTIONS TRADING AS JUST TELECOM  Hope Works, 25 Mowbray Street, Sheffield, S3 8EL.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.

21. How Do We Protect Your Personal Information?

We take administrative, technical and physical measures to safeguard your personal information against unauthorised access, unauthorised disclosure, theft and misuse. This includes limiting access of employees to, and the use of, your personal information through the use of passwords and graduated levels of clearance to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We do not publish all of our security measures because this may reduce their effectiveness. We take physical precautions to ensure that the computer servers on which your personal information is stored and archived are secure and that access to such servers is protected. We educate our employees with respect to their obligations to protect your personal information and we require any third-party service providers to take comparable steps to ensure the protection of any of your personal information that is shared with them.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Although we take precautions against possible breaches of our security systems, no company can fully eliminate the risks of unauthorised access to your personal information and no system is completely secure. We cannot guarantee that unauthorised access, hacking, data loss or breaches of our security systems will never occur. Accordingly, you should not transmit personal information to us using our applications if you consider that information to be sensitive.

22. Changes to the Privacy Notice

We may change this privacy notice from time to time. You should check this notice occasionally to ensure you are aware of the most recent version that will apply each time you access this website.