WILDFIRE PRIVACY NOTICE

Last updated May 2018

Protecting Your Privacy

At Wildfire, we are 100% committed to protecting the privacy and security of our suppliers, clients and site visitors. We appreciate and respect how important privacy is. If you have any questions about how we protect your information, please email: quiller.hawkins@wildfirephones.com.

Our Privacy Policy outlines how we use your personal data, whether you are a client/user of our service, a supplier or you are visiting our website.

In order to either continue working with you or start a new relationship there is some personal data that we need to use. This depends on the type of data and the reason we are processing it, however, if you refuse to provide us with this data, we might not be able to fulfil our contractual requirements or, in some cases, might not be able to continue with our relationship.

It is important for you to know that we may make alterations to this Privacy Policy from time to time. Please visit this page if you want to stay up to date, as we will post any changes here.

Clients

We use information to aid mutual business between our organisations but treat all information securely and confidentially.

The kind of contact information that we use includes: company name, contact names, email addresses; fixed addresses; landline numbers, mobile numbers and general contact details, this is all to ensure that our relationship can continue.

We hold information such as contracts pertaining to new connections, upgrades, new energy contracts, landline contracts

If you are not yet a client but are on our system as potential client, we will possibly hold information such as contact details, contract end dates and preferences but will ensure we contact you with consent to continue using your data in line with our retention policy.

Wildfire want to ensure that our organisations continue to trade mutually and beneficially.  The data will either come from you or your organisation, where you have contacted us to discuss our service, this could be via telephone or email.  Alternatively, we contact you via one of our company representatives whom will either call or email you.

Wildfires purpose to you is to manage your account and offer you new mobile phone, landline and energy tariffs as and when you need these services.  We will manage your data in the following ways:

  • We may store your details on a CRM system, so we can contact you about any company business and keep notes on our dealings, updating your details when we need to.
  • Using your information to send you new tariffs, contracts and to share with any third-party suppliers, i.e. EE, o2, Fidelity, Gamma and Sprint Communications etc.
  • Possibly using the information, you have given us in relation to marketing emails.

We may use your personal data for the above reasons if we feel it necessary to do so for our legitimate interests. If you are not happy regarding this, in some circumstances you have the right to object by contacting us at quiller.hawkins@wildfirephones.com.

We will use your information internally to provide you with a professional and user-friendly service.

Unless you object, we may share your information with any companies within our group in order to provide the best possible service to you.

We will delete your personal information from our systems if we have not had any significant contact with you, your company or other company representatives, after a 12-month period has passed.  Significant contact could be either verbal or written contact.

Suppliers

If you are a supplier, we collect the following kind of data from you. We collect name; email address; addresses; landline numbers, mobile numbers, bank details (for payments to you) and general contact details. This may also include any contracts that we have arranged together.

The information we collect is, so our organisations can mutually work together.

Wildfire want to ensure that our organisations continue to trade mutually and beneficially. The data will either come from you, where you have contacted us to discuss supplying our business, this could be via telephone or email. Alternatively, we contact you by telephone or email to discuss your services.

  • We may store your details on a CRM system, so we can contact you about any services that you are currently providing or could provide, updating your details when we need to.
  • To use services from you

We may use your personal data for the above reasons if we feel it necessary to do so for legitimate interests. If you are not happy regarding this, in some circumstances you have the right to object by contacting us at quiller.hawkins@wildfirephones.com.

In order for you to deliver a service to us we, unless you object, may share your information with any companies within our group in order to for you to provide wider services.

We will delete your personal information from our systems if we have not had any significant contact with you, your company or other company representatives, after a 12-month period has passed. Significant contact could be either verbal or written contact.

Website Users

Personal data, or personal information, means any 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 may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 notice.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with paving products). In this case, we may have to cancel an order you have with us but we will notify you if this is the case at the time.

  • We use different methods to collect data from and about you including through:

    • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • apply for our paving products;
    • subscribe;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us some feedback.
    • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.
    • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
    • Technical Data from analytics providers such as Google based outside the EU and including their Adwords conversion tracking, Maps and reCaptcha facilities
    • Social networks, for example, Twitter retweets, favourites and comments, Facebook Likes and comments and LinkedIn
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
    • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data 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 interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

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 you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below 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.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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 which 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 paving products from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

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

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration or other transactions.

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. For more information about the cookies we use, please see our Cookie Policy.

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. 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.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties.
  • External Third Parties.
  • 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 a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. 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. 

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Wildfires legal bases for processing your information

Wildfire confirm that ‘legitimate interest’ (Article 6(1)(f) of GDPR) is the most appropriate way for us to process and control your data.  We have looked and assessed where we process the data and for what purpose.  In the areas below, we feel that by using legitimate interest, it will enhance the service we provide and will not impact on your rights.

Clients 

In order to run your account and give you a reliable service, we need your corporate information as well as some of your employee’s personal details such as numbers, emails etc.  Without this information it is extremely unlikely that we could offer you a coherent service.  We also need your information to send invoices for our services, to setup any contractual obligations between our organisations and discuss general business between our companies.

Suppliers

In order to run our business, we need you!  Without certain information that our two organisations share between each other, we will not be able to use your services.  Therefore, to ensure we help you grow your business and for us to use your expertise, products or services we need some personal details to make the relationship work.

Consent

Sometimes we will ask you for your consent to use your data, however, we feel that most of the data we process is processed under legitimate interest.

We will contact you and make it clear if we feel that we need consent to use your data. The consent part of the regulation means that:

  • Wildfire need gain your consent freely – we cannot false you into it
  • We need to let you know what you are consenting to
  • We will allow you to have control over which data we use and what data you do not want us to process.
  • To give consent to us, you will need to make it clear – this could be replying to a correspondence, email, letter or completing a registration form.

All the above consent will be stored on our systems. You can withdraw your consent at any time.

Your Rights

The GDPR regulation allows the data subject (you) lots of rights in relation to your personal data and information.  Below outlines your rights, how to get in touch with us and if you are not happy, who to contact.  Any requests made by you will be actioned quickly and within a one-month period.

Every citizen of the EU has the following rights with respect to the personal data held or used:

  • the right to be informed (about: what information is being used, how it is used, for how long it is used, and your rights)
  • the right to access (to see it)
  • the right to rectification (to be able to correct it if incorrect)
  • the right to have it erased once there is no longer a legitimate basis to use it (also known as the right to be forgotten)
  • the right to restrict processing
  • the right to data portability (to be able to share the information with other organisations)
  • the right to object to use
  • rights regarding automated decision making and profiling

If you would like to exercise any of your rights, have a complaint, have any questions or wish to withdraw your consent to the processing of your personal information (where consent is our legal basis for processing your personal information), please contact us at quiller.hawkins@wildfirephones.com.

You have the right to complain to your data protection regulator — in the UK, the Information Commissioner’s Office (ICO). The contact details are: Wycliffe House, Water Lane, Wilmslow SK9 5AF, 0303 123 1113 and casework@ico.org.uk.

International Data Transfers

We may have to send your data to a country that is outside the EU or to a state that meets the ICO commissions list of countries with the same level of data protection or better data laws than in the EU.

If we do not have a contract in place with you, we will we will ask for your consent to send your personal data to another party. We will make it clear to you that your data will be sent outside the EU and to a country that does not have the same kind of data laws in the UK.

IT Security

All IT information held by Wildfire is securely sorted using the latest IT security software and password protection including firewalls and virus protection.

Our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised individuals have access to the information provided by our candidates, clients and suppliers.

Changes to Privacy Page

We may make changes to this page, this might be in relation to how we are processing your information.

If we make significant changes, we will make that clear on the Wildfire website.

Cookies

We may place a text file called a “cookie” in the browser files of your computer. The cookie itself does not contain Personal Information although it will enable us to relate your use of this site to information that you have specifically and knowingly provided. But the only personal information a cookie can contain is information you supply yourself. A cookie can’t read data off your hard disk or read cookie files created by other sites. Wildfire uses cookies to track user traffic patterns (as described above). In general, cookies are used to retain user preferences, store information for things like shopping baskets, and provide anonymised tracking data to third party applications like Google Analytics.  Our advertising system delivers a one-time cookie to better track ad impressions and click rates.

You can refuse cookies by turning them off in your browser. If you’ve set your browser to warn you before accepting cookies, you will receive the warning message with each cookie. We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers. You do not need to have cookies turned on to use this site. However, you do need cookies to participate actively in message boards, forums, polling and surveys.

Want to contact us?

You can contact us via email at quiller.hawkins@wildfirephones.com or you can write to us at:

Inneo Ltd, t/a Wildfire Phones

4th Floor, The Gateway Building

10 Elmer Approach

Southend-on-Sea

ESSEX

SS1 1LW