Cymru 1 Cookie and Privacy Policy

Revised: 24/05/2018

Privacy Policy Introduction

We are committed to safeguarding the privacy of our website visitors and our customers to the best of our ability.

In this document we explain what information we collect, including Personal Data, what we do with it, and who we might share it with.

It also outlines how we protect it and your rights under the GDPR, including your right to find out what personal data we hold about you, and your right to ask us to stop processing your personal data or to delete your personal data.

In this policy we also discuss our use of cookies, and it is important to note that by we will obtain your consent before setting any cookies that might affect your privacy.

 

About us

We are Cymru 1 Limited, registered in England and Wales under registration number 4262212, and our registered office is at St David's Building, Porthmadog, Gwynedd LL49 9AP.

We are registered as a data controller with the UK Information Commissioner's Office. Our data protection registration number is Z7320155.

 

Contacting Us

You can contact us with any questions you have in any of the following ways:
By post: Cymru 1 Limited, PO Box 30, Porthmadog, Gwynedd LL49 9ZR
By email: sales@cymru1.net; or
By telephone: 08000 112244.

 

When this policy applies

This policy applies where we are acting as a Data Controller of your personal data; in other words, where we determine the purposes and means of the processing of that personal data.

For example, this policy applies to you if you are a customer or become a customer of ours, or if you contact us to enquire about our products and services. It also applies to visitors to our website.

 

Information for Website visitors & users of our online control panels

If you visit one of our websites or use one of our online control panels, we may collect data about your use of them. The website usage data may include your IP address, along with your geographical location, browser type and version, operating system, the referral source, length of visit, pages viewed and website navigation paths as well as information about the timing, frequency, amounts and patterns of your service use. We may also store information about the configuration changes you make if you use one of our online control panels. The source of the usage data is our internal logging systems and, in some cases, anonymous data via Google Analytics ( https://www.google.co.uk/analytics )

This data may be processed for the purposes of analysing the use of our websites and services and for helping to secure them. The legal basis for this processing is our legitimate interests, namely monitoring, securing and improving our website and services.

 

Personal Data we collect and what we do with it

In this section, we explain what other data we collect, where it comes from, and what we do with it. We also explain which legal basis we rely on for the processing of the data.

a) If you become or want to become a customer:
To set up and manage your account, we will need certain information from you. This may include your name, address, company name, telephone numbers, email addresses, domain name and payment details including bank account information. Once you are a customer we will also store and process transaction information relating to your bills.

This data will be used for the purposes of providing and billing for our products and services, supporting their use, communicating with you about them. The legal basis for this processing is the performance of a contract between you and us and (or taking steps, at your request, to enter into such a contract).

We may also use the information you provide to perform a credit check on your company. The legal basis for doing this is our legitimate interests, namely protecting us from financial loss.

While you are a customer we may also want to use this data for the purposes of sending you marketing emails. The legal basis for doing so is our legitimate interests, namely expanding our business.

Needless to say, you may opt-out of receiving such marketing emails at any time simply by asking us to remove you from our marketing mailing list, or by clicking on any Unsubscribe link that may be included in the message we send you.

b) If you are a connectivity customer
If you are a connectivity customer (including broadband), we may use a wholesale supplier to assist us in providing you with the service. In this situation, the wholesale supplier may provide us with information about your use of the service. This information may include how much data you transfer and when, how many times you connect to the service and how long for, along with your IP address.

This usage information data may be processed for the purposes of billing and for providing you with technical support. The legal basis for this processing is the performance of a contract between you and us, namely the billing and support for the service.

c) General communications
If you communicate with us, through any means, we may process information contained in any communication you submit to us. This data may contain any type of Personal Data that you include in your enquiry or which we may require in order to deal with your enquiry, such as your name, company name, address, telephone number, email address, IP address and domain name.

This data will be processed for the purposes of dealing with your enquiry. The legal basis for this processing is our legitimate interest, namely dealing with your enquiry, even if you are not a customer.

 

d) Opt-in Marketing communications
If you specifically ask to be added to one of our mailing lists, we may process information that you provide to us for the purpose of sending you marketing emails about our products and services, or those provided by third party companies that we promote.

This marketing data may include your name and email address and, if you optionally provide them to us, may also include your appellation, company name and domain name. The legal basis for this processing is your explicit and informed consent.

You may opt-out of receiving such emails at any time simply by asking us to remove you from our marketing mailing list or clicking on any Unsubscribe link that may be included in the message we send you.

 

e) Data from third parties
From time to time, we may promote or recommend certain products and services provided by third parties. If you sign up with them, in some cases they may provide us with information about your use of those products or services. This data may include your username, purchase history, bill amounts, name, address, phone number, email address, company name, your IP address, as well as information about the timing, frequency, amounts, types and patterns of your service use.

This usage data will be processed for the purposes of analysing the use of the products or services. The legal basis for this processing is our legitimate interests, namely better understanding customer needs.

Note that any third parties that provides us with such information should make it clear in their own Privacy Policy, which you should have seen and agreed to when you signed up with them, what data they share and who they share it with.

 

f) Suppliers
If you are a supplier and you communicate with us, we will process your name, company name, address, email address, telephone numbers, IP address and any transaction details included in your communication.

The Legal Basis for this processing is the performance of a contract between you and us and (or taking steps to enter into such a contract).

 

g) Other ways we process your data
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure, including debt collection. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

 

h) Other people's data

Please do not supply any other person's personal data to us, unless we prompt you to do so.

 

Automated decision-making

We will not use your personal data for the purposes of automated decision-making, other than to endeavour only to send you product and service notifications that are relevant to you based on which of our products and services that you currently use.

 

Providing your personal data to others

It goes without saying that we will not share or disclose your personal data with any third parties unless there is a good reason to, as outlined below. 

We may disclose your personal data to our insurers and/or professional advisers or support providers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice or support, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure, including debt-collection.

We may disclose your personal data to certain wholesale suppliers, insofar as is reasonably necessary to provide you with, or arrange to provide you with (or a quotation for) the products and services you request.

We may share your personal data with our payment services providers but only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

When we require technical support from a third party, to help us with a fault or problem on one of our systems or services, the third party may potentially temporarily have access to some of the personal data we store in the course of performing their duties. Before allowing any such third party access to our systems we will, however, ensure there is staturary or contractual obligations of confidentiality in place.

Without your explicit agreement, we will not otherwise disclose your personal data to third party suppliers of goods and services. Should we do so with your agreement, for example if we register a domain name through a third party on your behalf (at your request and with your agreement), any such third party will act as a Data Controller in relation to the data that we supply to it; such third party will supply to you a copy of its own privacy policy which will govern that third party's use of your personal data.

In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

 

International transfers of your personal data

As a general rule, we store your personal data in the UK. However, under certain circumstances we may need to transfer your data to a different country. But unless we have your consent, we will not transfer your personal data to countries outside the EEA except if the transfer is:

(i) to countries that are determined by the European Commission as having an "adequate level of data protection" (see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en ); or
(ii) to the USA as long as the Data Processor or sub-Processor involved is certified to comply with the EU-US Privacy Shield (or its successor) (see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en ); or
(iii) to any country as long as your personal data is protected by a transfer mechanism that complies with the GDPR, such as standard contract clauses approved by the European Commission (Model Contract Clauses) or Binding Corporate Rules.
In restricting transfers in this way, your personal data will still be protected under the provisions of the GDPR, just as it would be if it remained in the UK.

 

Retaining your personal data

Personal data that we process for any purpose shall not be kept for longer than is necessary for that purpose.
Notwithstanding the above, we may retain your personal data for as long as might be necessary to comply with our legal obligations. We may also need to store your personal data for as long as necessary to protect your vital interests or the vital interests of another natural person.

 

Security of your personal data

While it is in our care, we will do our best to keep your personal data safe and secure. To do so we will do the following:

• We will take appropriate technical, physical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
• The following personal data will always be stored by us in encrypted form: your bank account details, if provided electronically. Credit and Debit card details are never stored by us.
• When we transfer or share your data with a third party (as outlined in this policy) we will endeavour to ensure they are GDPR compliant.
• When we transfer bank account details to a third party, it will always be done securely.
• We employ connection security (SSL certificates) to encrypt communications on all parts of our website that request that you enter any personal or financial data (as long as you ensure that you visit the correct secure https website address and the "lock" icon is visible in your web browser).

We cannot protect your personal data if it is outside out control, however. You must acknowledge that the transmission of unencrypted or inadequately encrypted data over the internet is inherently insecure, and we cannot guarantee the security of such data sent over the internet.

And you must ensure that your passwords for use with our products and services are not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the passwords confidential, not re-using the same passwords elsewhere, and ideally changing them regularly. Please note that we will not ask you for your password (except when you log in).

 

Amendments

We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.

 

Your rights

In this section we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under data protection law are:

• The right to access;
• The right to rectification;
• The right to erasure;
• The right to restrict processing;
• The right to object to processing;
• The right to data portability;
• The right to complain to a supervisory authority; and
• The right to withdraw consent.

(i) Access
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

(ii) Rectification

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

(iii) Erasure

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

(iv) Restricting

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

(v) Objecting

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

(vi) Data Portability

To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

(vii) Complaints

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
In the UK, the supervisory authority is the ICO https://www.ico.org.uk

(viii) Withdrawing consent

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

Exercising your rights

You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this section.

 

Third party websites

Our website includes hyperlinks to, and details of, third party websites.
We have no control over, and are not responsible for, the privacy policies and practices of third parties.

 

Personal data of children

Our website and services are targeted at persons over the age of 18. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

 

Updating information

Please let us know if the personal information that we hold about you needs to be corrected or updated.

 

Cookies and our Cookie Policy

About cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser on your computer, phone, tablet or other device. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may potentially be linked to the information stored in and obtained from cookies.  
Some cookies require your consent before they can be stored and we will always endeavour to do so.

Cookies that we use (also known as First Party cookies)
We use cookies for the following purposes:
Personalisation - we may use cookies to store information about your preferences and to personalise our website for you. Cookies used for this purpose are: style;
Security - we may use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally. Cookies used for this purpose are: redacted for security;
E-Commerce – we use cookies to assist in keeping track of items in your shopping cart, whether you are logged in and certain other information that is necessary for the functioning of the shopping cart. Cookies used for this purpose are: redacted for security.

Cookies used by our service providers (also known as Third Party cookies)
On some of our websites we use third party service providers for certain functions. Some of these service providers use cookies which may be stored on your computer, phone, tablet or other device when you visit the website in question.

One such service that we use is Google Analytics, which helps us analyse the use of our website. Google Analytics gathers information about website use by means of cookies.

Google's privacy policy is available at: https://www.google.com/policies/privacy/.

Any data that might be gathered through this service which might be considered Personal Data, such as your IP address, is anonymized before being transferred to Google's systems.

The relevant cookies are: _utma, _utmb, _utmc, _utmt and _utmz

Google's Privacy Policy

Opt-out of all Google Analytics cookies on all websites

Please note that we do not currently use Google Analytics on the Cymru1.net website itself.

 

Managing cookies
Most web browsers allow you to refuse to accept some or all cookies and to delete any cookies already stored. The methods for doing so vary from browser to browser, and from version to version.

Note that blocking some or all cookies will have a negative impact upon the usability of many websites, including ours.