Privacy Policy

Privacy Policy Version D

This Privacy Policy is dated 9 July 2024 and supersedes all previous published.

Contents

In this Policy
About Us
Information we may collect about You
a. Information you give to us
b. Types of Information We May Collect from You
Identity Data
Contact Data
Financial Data
Transaction Data
Usage Data
Technical Data
Profile Data
Marketing and Communications Data
Tracking Data
Cookies
Session-based cookies
Persistent cookies
Google Analytics
Aggregated Data
Childrens Personal Data
Our Use of Your Information
Sharing Your information
How we retain your information
Your rights
Access to Personal Data
Correction of Personal Data
Removal of Personal Data
Request Restriction of Processing
Transfer Request
Object to Processing
Withdrawal of Consent
Our rights to change this policy
Contact Information
Complaints

1. In this Policy

This Privacy Policy is dated and supersedes all previous versions published.

About Us
Information we may collect about You
Childrens Personal Data
Our Use of Your Information
Sharing Your information
How we retain your information
Your rights
Our rights to change this policy
Contact information
Complaints

2. About Us

County Broadband (“County Broadband Limited”, “we” “us”, and “ours”) is an internet service provider (“ISP”) and infrastructure company. We are a limited company registered in England and Wales under company number 04666043 and our registered office and main trading address is at Old Bourchiers Hall, New Road, Aldham, Colchester, Essex, CO6 3QU. Our VAT number is 295 3657 59.
We are regulated in the UK by Ofcom and are registered with Ombudsman Services (www.ombudsman-services.org) who are our Alternative Dispute Resolution Provider.

3. Information we may collect about You

There are several methods in which we may collect data from you. In general, we collect this data to allow us to provide You with a service or product that you require or have asked for, or to support you with a problem or issue with a product or service which we provide to you.
Additionally to this, we may need to engage with you to discuss applications for voucher build subsidy schemes (such as, but not limited to “Gigabit Broadband Vouchers”). If we do so, we may also collect and retain the information collected during that engagement.

Aside from the County Broadband website, phone lines or in person sales, we may also collect information about you from artificial intelligence chatbots, Meta, LinkedIn, TikTok, X (formerly Twitter) or Google, where you provide your information.

a. Information you give to us

The ways in which you provide us with information about yourself may include:

i) Placing an order for a product or service provided by us, on our website, via telesales or in person or on paper with a sales agent; or
ii) Part placing an order for a product or service provided by us, on our website, via telesales or in person or on paper with a sales agent; or
iii) Registering interest to potentially become a customer of Ours in the future, either on our website via telesales or in person or on paper with a sales agent; or
iv) Competing a direct debit mandate with one of our payment providers; or
v) Giving us consent to contact you to send marketing information about our products and services, or about our network build and sales activities in your area; or
vi) If you respond to any marketing messages or promotions that we may send via postal services from time to time; or
vii) By applying for any advertised job roles on our website; or
viii) Giving us your details in relation to our services, products, or business development. Including email addresses and phone numbers that you contact us from.

b. Types of Information We May Collect from You

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data
This includes your name and any identities that you may have been created to use our services (such as usernames, Wi-Fi station id, and so on).

Contact Data
This includes billing address, delivery address, email address, social media username (if given) and telephone numbers.

Financial Data
This includes bank account and payment card details.

Transaction Data
This includes details of the services that you subscribe to, and any equipment that we have supplied to provide those services. It also includes any information that we obtain during our installation process, such as photos of the installation and any information that you give to our engineers at your property. It also includes information on any financial transactions in relation to services we provide to you, such as invoices and payments against those invoices.

Usage Data
This includes information about how you use our services, our network and our websites. It also includes records of telephone calls made and received by you through our telephone service.

Technical Data
This includes internet protocol (IP) addresses, 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 our websites and our network. It may also include details of any of your devices registered with equipment provided to you as part of our service. It also includes information generated by any of the equipment that we use to provide our service and to ensure that it is correctly functioning.

Profile Data
This includes your username and password (if made available to us), orders made by you, your interests, preferences, feedback and survey responses, and a history of any consents that you have given us in relation to how we use your personal data. It also includes information that relates to how you use our services, in relation to each other. For example, the order in which you view the information on our web site, or information about which of our marketing messages you might have responded to before you registered an interest in our services. This allows us to predict the activities, products, services and promotions that would be most beneficial to you.

Marketing and Communications Data
This includes your preferences in receiving marketing from us and our third parties, and any information that we retain regarding which emails and printed material that we might have sent you.

Tracking Data
We may use the following types of campaigns and tracking to collect data about you and use it to assess effectiveness of our campaigns as well as to build user profiles. These campaigns and tracking activities include unique tracking codes (UTM data) and are as follows:

AdWords
AdSense
Meta
Microsoft Clarity
Aklamio Referral

Cookies
We may obtain information about your usage of our websites by using a cookie file which is stored on your browser or the hard drive of your computer. Cookies contain information that’s transferred to your computer’s storage. We never store personal information in cookies, but we do use them to store session or login identifiers to allow us to recognise your browsers between pages of our web sites.
If you register with us or continue to use our websites, you agree to us using cookies. Cookies are widely used to make websites work (our website won’t work without some of the cookies we use) or work more efficiently. They also provide useful information to website owners. A cookie is a small text file that’s passed to your computer’s hard disk through your web browser, so the website remembers who you are when you return.
We use the several types of cookies, including essential and optional cookies in our Website, some placed by third party services that may appear on our pages, to give you a more personalised web service. These include:

Session-based cookies
This type of cookie is allocated to your computer only for the duration of your visit to our website. It helps us to pass your personal information from one page to another, for example when you are you using our registration pages to express an interest in our service, or our sales pages to place an Order. This cookie automatically expires when you close your browser.

Persistent cookies
This type of cookie stores information between visits. For example, we may show you a ‘Remember me on this computer’ option, when entering a username and password, and save a cookie on your computer if you select it. This means that the next time you log on to our website using that computer you won’t need to re-enter those details. We suggest you don’t select the ‘Remember me’ box if you use a shared computer (for example, if you access the internet at a cafe, or at a shared or publicly available computer). The cookie file itself won’t store your personal information, but a subsequent user might be able to access your personal information if you hadn’t explicitly logged first.

Google Analytics
We also use Google Analytics to track use of our website. This helps us see how our website is used by those who visit it. Google Analytics uses cookies to gather information about our visitors, such as which website you came from and which website you move on to afterwards. Google will use this information to evaluate your use of our website, compile reports on this and provide other services relating to website activity. Information collected in this way is anonymous and individuals can’t be traced; we never get access to your personal information from other web sites. We use Google Analytics to improve our website and our services, for example, to measure the effect or success of our advertising campaigns and products.
The information generated by the Google Analytics cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google may also transfer this information to others, where they’re required to do this by law, or where these others process the information on Google’s behalf. Google undertakes not to associate your IP address with any other data held by Google.
For more information about Google Analytics, please see their privacy policy at: www.google.com/policies/privacy.
We may also use such services as Google AdSense to place adverts about our products on other websites and manage referrals from those websites to our website. If you arrived at our website via one of those other websites, AdSense uses cookies to gather statistics about this.
We can use “remarketing” with Google analytics whereby we upload the data we collect about you to Google AdWords. Google may then choose to use that data to create targeted personalised advertising campaigns or use it in their intelligence.
Except for essential cookies, all cookies will expire after 12 months.
You can block cookies by activating the setting on your browser which allows you to refuse the setting of all or some cookies. If you want to stop cookies being stored on your computer in future, you should check your browser manufacturer’s instructions by clicking “Help” in your browser menu. However, if you block all cookies (including essential cookies) you may not be able to access all or certain parts of our website. Unless you’ve set your browser to refuse cookies, our system will issue cookies as soon you visit our website.
If you want to delete any cookies that are already on your computer, you should check the instructions for your file management software to locate the file or directory that stores cookies.
You can learn about and opt out of a number of commercial third-party cookies (including some used by us) at optout.networkadvertising.org. Some of the opt-outs used by our commercial service providers require a cookie to be placed on your computer. This “opt-out” cookie is only used to tell the relevant cookie servers not to send you any more cookies. If you keep deleting cookies (including “opt-out” cookies) from your temporary internet files, you might need to repeat the opt-out process, the next time you visit our website.

For more information about deleting and controlling cookies visit www.youronlinechoices.com or www.aboutcookies.org.

Aggregated Data
This means statistical or demographic data derived from your personal data, or your usage of our services. Aggregated Data is not considered personal data in law as this data does not directly or indirectly reveal your identity.

4. Childrens Personal Data

We do not knowingly collect any Personal Data from children under the age of 16. If you are under the age of 16, please do not submit any Personal Data through our websites or services. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce this notice by instructing their children never to provide Personal Data through our services or websites without their permission. If you have reason to believe that a child under the age of 16 has provided Personal Data to us through our websites or services, please contact us and we will endeavour to delete that information and terminate the child’s account from our databases.

5. Our Use of Your Information

We will only use your personal data when we have legal grounds to do so, which will be in one of the following circumstances:

a. Where you have given us explicit consent, in relation to allowing us to communicate with you.
b. Where you are considering entering or have entered into a contract with us to take our products or services.
c. Where it is necessary for our legitimate interests and where your interests and fundamental rights do not override those interests.
d. Where we need to comply with a legal or regulatory obligation.

Consent means that you have explicitly granted us permission to use your personal data to contact you. We may ask you for consent when you register an interest or place an order for our services on our web site. We may also ask you for consent when you speak with us, either in person, or on the phone. You can withdraw your consent at any time by emailing consent@countybroadband.co.uk and requesting an email which allows you to adjust your personal communication preferences.

Contract means that we are using your personal data as necessary to provide a quote to you or fulfil a contract to provide our products or services to you. Once you have placed a pre-order or order with us, we will use your personal information on the legal basis of Contract to communicate with you about how we intend to deliver the service to you. We will contact you using any Contact Information that you have provided us with to deliver your service, and subsequently communicate with you about the billing and support aspects of that service. You may opt out of any Consent that you have previously granted us if you want to stop receiving marketing information. You may not opt out of service-related correspondence in relation to the Contract. You may, however, let us know your preferences on how you would like to be contacted.

Legitimate Interest means using your data as necessary for the commercial interests of our business, allowing us to conduct and manage our business to give you the best possible service and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.

Comply with a legal or regulatory obligation means using your personal data to the extent necessary for us to comply with a legal or regulatory obligation that we are subject to.

6. Sharing Your information

We may sometimes need to share your personal data with the types of third party listed below:

a. Our partner organisations and subcontractors who provide some of the services on our behalf.
b. Credit reference agencies (to carry out credit checks) and debt recovery agencies (if you do not pay your bills).
c. IT and system administration services service providers.
d. Emergency Services (including police, fire, and ambulance services).
e. Professional advisers including lawyers, auditors, and insurers.
f. Third parties to whom we may choose to sell, transfer or merge parts of our business with.
g. Regulators, ombudsmen, government/industry bodies and authorities for the purposes of resolving disputes, complying with regulatory requirements, and reporting and in connection with obtaining grants or funding directly or on your behalf.

7. How we retain your information

We will only keep your personal data on file whilst we need it for the purposes we collected it for. As well as for servicing your contract, we might also need to retain it to satisfy 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.

By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for at least 7 years after they cease being customers for tax purposes.

In some circumstances, we may 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.

8. Your rights

You have various rights in relation to your personal data – these are set out in detail below. If you wish to exercise any of these rights, please contact us by telephone on 01376 562002 or email us: support@countybroadband.co.uk

Access to Personal Data

You have the right to access the personal data we hold on you (commonly known as a “data subject access request”).

Correction of Personal Data

You have the right to request correction of the personal data that we hold on you. If you are aware of any information that we hold that is incorrect or incomplete, please let us know and we will correct it. We may first need to verify the accuracy of the new data you provide to us, and then we will make the correction.

Removal of Personal Data

You have the right to request the erasure of your personal data (commonly known as “the right to be forgotten”). This enables you to ask us to delete your personal data when we no longer need it. You may also ask us to delete your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with a legal obligation. However, we may not be able to comply with your request of erasure, for example, if we are required to retain your personal data for legal reasons, or if that data is required to provide you with a service you have requested. We will let you know if this is the case.

Request Restriction of Processing

You have the right to request we restrict processing your personal data. You may ask us to suspend the processing of your personal data in the following scenarios:

a) if you do not think the data we hold is accurate, whilst we verify its accuracy; or
b) where our use of the data is unlawful, but you do not want us to erase it; or
c) where we no longer need to process it, but you require us to store it in relation to a legal claim; or
d) if you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Transfer Request

You have the right to request your personal data is transferred to you or to a third party. We will if feasible practically provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to information which you have provided us, and which we process by automated means and use to perform a contract with you.

Object to Processing

You have the right to object to us processing your personal data for direct marketing purposes. You also have the right to object where we are relying on a legitimate interest, but you feel the processing impacts on your fundamental rights and freedoms.

Withdrawal of Consent

You have the right to withdraw consent at any time where we are relying on consent to process your personal data that is not related to providing a service you have requested (for example, for marketing purposes). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

You will not have to pay a fee to access your personal data or to exercise any of your other rights. However, if we feel that your request is unfounded, repetitive, or excessive, we may charge a reasonable fee or we may let you know that we are refusing to comply with your request. If we refuse your request, we will explain why and you will be entitled to raise the issue with the ICO (www.ico.org.uk).

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We will respond to all legitimate requests within 30 days of receipt and, if possible, achieve a satisfactory resolution within that time period. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Our rights to change this policy

Any changes we may make to this Privacy Policy in the future will be published on our main website (www.countybroadband.co.uk) and made available via the ‘legal’ link at the bottom of the homepage. You should check that link from time-to-time for any changes we may have made. We may also email you about these changes if you are a customer of County Broadband.

10. Contact Information

If you have any questions, comments, and requests regarding this Privacy Policy, including any requests to exercise any of your legal rights under it, please contact us using the details set out below:

Email: info@countybroadband.co.uk
Telephone: 01376 562002
Post: County Broadband, Old Bourchiers Hall, New Road, Aldham, CO6 3QU.
If you have any complaint about how we are using your personal data or otherwise in relation to this Privacy Policy, please contact us in the first instance and will we do our best to resolve it. If we do not resolve it to your satisfaction, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

11. Complaints

In the unfortunate event that you wish to complain about the way we’ve processed your data you can contact the regulator below:
The Information Commissioner’s Office (ICO), Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
0303 123 1113.