Version 1 (9.8.2019)
Who are we
Audacious Mobile Limited provides mobile telecoms services and is part of the Manx Telecom group of companies, which includes Goshawk Communications Limited, Vannin Ventures Limited and Partitionware Limited (“Group”). Your information will be held by us for and on behalf of us and our Group companies.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website is not intended for children and we do not knowingly collect data relating to children.
The data we collect data about you and how we collect it
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (“anonymised data”).
We may collect data directly from you, even if you are not an Audacious customer, via your calls to or correspondence with us or other submissions, for example, via our website including submitting forms or registering with us, or via the retailer selling you the SIM, particularly:
Usage Data includes information about how you use our website and products and services including Call Records (for example, when you make or receive calls or messages, we collect the telephone numbers of the calling and called persons, the relevant date, time, duration and cost of your communication, information identifying your device. We don’t collect the content of your calls or messages. When you use our data services, we collect time, date, usage and location information Technical Data includes internet protocol (IP) address, performance and security data, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, system logs, other technology on the devices you use to access this website, data identified as malicious (e.g. malware infections, cyberattacks, unsuccessful security incidents, or other threats);
We may also receive information about you from third parties, for example, from credit reference or fraud prevention agencies and from third party suppliers who help us provide our Services to you.
Special Category Personal Data
Under data protection law, “Special Categories of Personal Data” (“SCPD”) are 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 for the purpose of uniquely identifying a natural person).
The only SCPD that we collect, use, store and transfer is your Sound Data. See the section headed, “How we use the data we collect about you and our legal basis to use your data”, below, for more information about how we use this SCPD.
Criminal Offence Data
We do not collect any information about criminal convictions and offences.
We also collect, use and share anonymised data to improve our services and better understand our business by using analytics. We use aggregated and anonymised data for research and development purposes and may extend that to selected third parties.
How we use the data we collect about you and our legal basis to use your data
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
We need a legal basis to use your data. We rely generally on several such bases:
Examples of when we may use your data relying on our legitimate interests include when we:
Note that we may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one legal basis has been set out in the table below.
Who we share your data with
We may share your data with:
We may share Sound Data with:
In order to process your application we may pass your data to credit reference agencies and they will give us information about you. They may pass on your information to other organisations. Your data may be linked to the data of others such as your spouse. We use this information to assess your eligibility and creditworthiness, verify the accuracy of your application, and prevent fraud, money laundering or other criminal activity.
When we share your data with a third party we control their use of your data through strict controls contained in a contract. For example, 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 and the law.
We do this typically by using specific contracts approved by the European Commission which give personal data the same protection it has in the EEA, or by utilising one of the other permitted methods of transferring data overseas, for example, we may transfer data to US companies if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
This may happen if the servers where your data is stored or our suppliers are based outside the EEA.
To authorise your calls while roaming abroad data maybe passed to the foreign network operator.
How we protect your data
We use industry-standard technologies and processes to:
Please remember that third party websites are outside of our control and operate in line with their own privacy policies. Your personal data entered in such websites or your communications sent over the internet may therefore be at risk of unauthorised access or use.
How long we hold onto your data
We will hold data for a specific period of time for as long as reasonably necessary to fulfil the purpose we collected it for and in line with any legal obligations. We won’t hold your personal data longer than we need it. Then we’ll delete or anonymise it.
In some circumstances you can ask us to delete your data: see the section Your rights concerning the data we hold about you, below, for further information.
As set out above in this policy, 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.
Your rights concerning the data we hold about you
You have the following rights concerning your personal data.
We can still store your data. We may be entitled to refuse such request in some situations.
Please see the section headed, “Contact Us”, below, if you wish to exercise any of these rights.
Our marketing of services and products to you
We won’t send you marketing messages if you ask us not to. You can register your marketing preferences in my-account at www.audacious.co.uk; or by contacting us (see the section headed, “Contact Us”, below); or by unsubscribing on marketing emails or SMS we send you. We will add your name to a suppression list. You will still receive Service Messages.
We may use information that we hold about you to send information about our and our Group companies’ products and services. This may be by email or other electronic means available to us in the future. We may also use other information available to us in order to tailor our communications. If you’re an individual, we’ll usually only do this if we have your consent but there may be some situations where we have a legitimate interest in doing so, such as where you complete a purchase of our services.
If you’ve given your consent, you can withdraw this at any time, or if we’re reliant on our legitimate interests for sending you marketing you can object.
You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving that marketing.
We won’t give your details to third parties for them to market their products or services, or use your data ourselves to market third party products or services, unless you give us your consent.
How to contact us, including to complain
Data Protection Manager
Audacious Mobile Limited
University of Northampton Innovation Centre
01604 266 466
If you are not satisfied with our response, or believe we are breach data protection rules, you can make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at the contact details on their website: www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please do consider contacting us in the first instance.