Privacy and Cookies Policy

Introduction

At Planet Talk looking after the personal data you share with us is important to us. We want you to be confident that your data is safe and secure with us and understand how we use it to offer you a better and more personalised experience.

We are committed to doing the right thing when it comes to how we collect, use and protect your personal data. That's why we've developed this privacy and cookies policy ("Policy"), which:

Sets out the types of personal data that we collect
Explains how and why we collect and use your personal data
Details when and why we will share personal data within the Planet Talk and with third parties
Explains the rights and choices you have when it comes to your personal data

What this Policy covers

The Data Controller is Planettalk Limited (collectively referred to as "we" or "us" in this Policy).

We offer different products and services, so we want you to be clear about what the Policy covers. If you use any website ("our Website") or mobile applications ("our Mobile Apps") where this Policy is posted (collectively known as "our Services"), then this Policy applies to you.

This Policy also applies if you contact us or interact with us with regard to our Services.

Our Website or Mobile Apps may contain links to other websites operated by third parties that have their own privacy policies. Please make sure you read their terms and conditions and privacy policy carefully before you submit any personal data to a third-party website as we do not accept any responsibility or liability for these third party websites.

Personal Data We Collect

When you register for our Services	Your personal details, including your postal and billing addresses, email addresses, phone numbers and date of birth and title Your debit or credit card details, bank details and other payment information Your account login details, such as your username and the password you have chosen
When you top-up your account or browse our Website or use our Mobile Apps	Personal data you provide about yourself any time you contact us in relation to our Services including by phone, email or post or when you interact with us online or on social media (for example, your name, social media handle and contact details) Information about when and how much you top up and pay your bill or how often and why you access your account with us Information about your online browsing behaviour on our Website and Mobile Apps Information about any devices you have used to access our Service; including device make, model and operating system, IP address, browser type and mobile device identifiers So we know how best to process your calls and also protect you from fraud we sometimes use certain information such as IP address to check which country you are located in
When you contact or interact with us or take part in promotions	Details of the emails and other digital communications we send to you that you open, including any links in them that you click on Your feedback and contributions to customer surveys and questionnaires

When you register for our Services	Your personal details, including your postal and billing addresses, email addresses, phone numbers and date of birth and title Your debit or credit card details, bank details and other payment information Your account login details, such as your username and the password you have chosen
When you top-up your account or browse our Website or use our Mobile Apps	Personal data you provide about yourself any time you contact us in relation to our Services including by phone, email or post or when you interact with us online or on social media (for example, your name, social media handle and contact details) Information about when and how much you top up and pay your bill or how often and why you access your account with us Information about your online browsing behaviour on our Website and Mobile Apps Information about any devices you have used to access our Service; including device make, model and operating system, IP address, browser type and mobile device identifiers So we know how best to process your calls and also protect you from fraud we sometimes use certain information such as IP address to check which country you are located in
When you contact or interact with us or take part in promotions	Details of the emails and other digital communications we send to you that you open, including any links in them that you click on Your feedback and contributions to customer surveys and questionnaires

Additional Sources of Personal Data

We may supplement the data we collect with personal data from other sources, such as specialist companies that supply data, companies that operate online media channels and public registers. For example, this additional data helps us to:

Review and improve the accuracy of the data we hold
Improve and measure the effectiveness of our marketing communications, including online advertising

How and Why We Use Your Personal Data

We use personal data to:	This means that processing your personal data allows us to:	Do we have to process your personal data this way?
Make our Services available to you	Manage the accounts you hold with us, check whether you qualify for credit or our products are appropriate for you, and process your orders and refunds. Please see further information below about how we use and share your data with credit reference agencies.	Yes, it is necessary for us to process your personal data so that we can operate your customer accounts, provide you with the goods and services you want to purchase (including assessing and deciding on whether we can give you and members of your household credit or credit related services) and to help you with any orders and refunds that you may request.
	Manage your connection to our Network and to get in touch with you if we need to tell you about any problems with the Network.	Yes, it is necessary for us to process your personal data so that we can connect you to and improve the operation of the Network.
	Manage and improve our Websites and Mobile Apps. We use cookies and similar technologies on our websites and apps to improve your customer experience. Some cookies are necessary so should not be disabled if you want to make use of the full functionality of our Websites and Mobile Apps. Other cookies can be disabled, but this may affect your customer experience.	For more information about cookies and how you can disable some of them, see the Cookies and similar technologies section.
Manage and improve our day-to-day operations	Help to develop and improve our product range, services, information technology systems, know-how and the way we communicate with you.	Yes, it is in our legitimate interest to undertake market research and internal research and development, and to improve our information technology systems (including its security) and our product ranges and services.
	Detect and prevent fraud, money laundering or other crime. See further information below about how we use and share your data with fraud prevention agencies.	Yes, it is in our legitimate interest to monitor how our Services are used to detect and prevent fraud, other crimes and the misuse of services. This helps us to ensure that you can safely use our Services.
	Recover any money you might owe us. Assign your debt to permitted third parties.	Yes, it is in our legitimate interest to obtain payment for our Services.
Personalise your Planet Talk experience	Use your online browsing behaviour as well as your online to help us better understand you as a customer and provide you with personalised offers and services.	Yes, it is in our legitimate interest to look at your preferences that we derive from your browsing behaviour and purchases so that we can personalise our offers and services for you, to better meet your needs as a customer – provided this is in line with your marketing choices.
	Provide you with relevant marketing communications (including by text, email, post or online advertising), relating to our products and services. This includes measuring the effectiveness of our marketing communications campaigns, including online advertising.	It is in our legitimate interest to provide you with marketing communications that are relevant to your interests. However, you can change your marketing choices, at any time. Please see your choices when it comes to cookies below.
Contact and interact with you	Investigate any complaints or questions you may raise and contact you in relation to our Services, for example by phone, email, online or post or responding to social media posts that you have directed at us.	Yes, it is in our legitimate interest to provide any clarification or assistance in response to your communications to serve you better as a customer.
	Manage promotions and competitions you take part in.	Yes, it is necessary for us to process your personal data so that we can manage the promotions and competitions that you choose to enter into.
	Invite you to participate in and manage customer surveys, questionnaires and other market research activities carried out by the Planet Talk Group and by third parties on our behalf.	It is in our legitimate interest to carry out market research. However, while we may contact you about this, you are of course not obliged to take part in these activities. If you tell us that you do not want to be contacted for market research, we will respect this choice and you will not receive any further market research communications from us. This will not affect your ability to use our Services.

Fraud Prevention Agencies

When processing credit and debit card payments, we may access and use information held by fraud prevention agencies to prevent fraud and money laundering, for example, when: checking applications for, and managing credit and credit related or other facilities and recovering debt. We will also share personal information we have collected from you with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found below.

Full Fraud Prevention Notice

General

Before we provide you with certain of our account based or pre-pay products, where you pay by debit or credit card we may undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.

The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity.
Details of the personal information that will be processed, for example: name, address, date of birth, contact details, financial information, employment details, device identifiers including IP address.
We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services you have requested.
Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

Automated Decisions

As part of the processing of your personal data decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk or if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct; or is inconsistent with your previous submissions; or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision making: if you want to know more please contact us using the details provided.

Consequences of Processing

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services you have requested, or we may stop providing existing services to you.
A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details provided.

Data Transfers

Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to 'international frameworks' intended to enable secure data sharing.

Your Rights

Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data; request that your personal data is erased or corrected; request access to your personal data.
For more information or to exercise your data protection rights, please contact us using the contact details provided.
You also have a right to complain to the Information Commissioner's Office which regulates the processing of personal data.

How to Contact Us

If you have any questions about how we collect, store and use personal data please contact us.

Mail:

Planettalk Limited,
71-75 Shelton Street,
London WC2H 9JQ
United Kingdom

Email: privacy@planettalk.com