Privacy Policy

UK, 01/05/2013

What is a privacy policy?

At Truphone we take privacy very seriously. Throughout the data collection process, all necessary steps are taken to ensure that data are used only for the purposes we clearly state.

This Privacy Statement is designed to assist you in understanding how Truphone uses and safeguards the information you provide in using Truphone's Services.

1.      Purposes for which information is collected

All data collected by Truphone for and through the use of the Service are regulated by the UK Data Protection Act 1998. Truphone Ltd, the company which owns and manages the Truphone Service, is duly registered as a data controller for various purposes under the Act. Data is collected and may be used for three main purposes. Truphone collects and processes, or has third party service providers who collect and process on Truphone's behalf, personal data relating to You, as permitted in order to

1.1.   Data is collected and may be used for three main purposes. Truphone collects and processes, or has third party service providers who collect and process on Truphone's behalf, personal data relating to You, as permitted in order to (1) provide the Truphone Service, in particular to convey the communications you make by means of the Truphone Software and/or the Truphone Service and Truphone network, (2) invoice you for your use of the Truphone Service and (3) carry out Truphone marketing activities.

1.2.   This implies that we may from time to time send you information about services and products in which we believe you may be interested. In accordance with the Data Protection Act 1998 you must actively give your consent for this at the time the information is collected. We will not use your information if this consent is not given.

2.      What is a Privacy Policy?

2.1.   Your privacy is very important to us. This policy explains which Personal Data we hold about you and for what purpose we use it. You should read this policy along with the terms and conditions of the other services we provide to you.

3.      What is Personal Data?

3.1.   In order to provide you with a service we need to have certain information about you. Personal Data are facts we collect about you when you sign up to the Service, when you access Services from the website or your mobile phone, and when you use the Services.

4.      What information do we hold about you?

4.1.   When you sign up to the Service we will ask you where appropriate for your Name, Address, Payment Method and details, Telephone Number, Mobile Phone Number & Email Address. We also hold data about which services of ours you have used, and when, including call times, routing and durations which are known as "traffic data".

4.2.   Under certain circumstances for regulatory purposes in some countries in order to provide the Truphone Services we may require copies of personal documentation (passport, ID document, etc) from you which will be held by us and made available to national regulators if they so request.

5.      What do we use it for?

We need this information so that we can confirm your identity and process your order when you first sign up for our Service. We may also use Your personal data for the following:

5.1    Regulatory Compliance

5.2    Credit Referencing

We may use your personal data for purposes of undertaking credit reference searches and analysing credit worthiness during the term of this Agreement.

5.3    Marketing activities

If you have consented to the use of personal data for marketing purposes then we may use your personal data to send you information about additional services that we provide.

5.4    Collecting traffic data

We may hold Data about the numbers and lengths of calls made in order to bill you for your services. We may also use it to identify some value added services we may offer you.

6.      Who else will see my information?

6.1    Transactions for Billing

We may use third party banking facilities and billing agencies to process your information. Third party network operators may also need access to your Data for regulatory compliance purposes. We will ensure that such agencies conform to the same or similar guidelines as we do.

6.2    Compliance with Laws codes and procedures

Sometimes we may have to provide your personal data to third parties to comply with legal codes and procedures. These include, but are not limited to, national regulators, reasons such as resolving a billing dispute, for use in legal proceedings or even national security. In these cases we will comply with whatever UK laws are in force at the time and provide such information as is required.

6.3    Emergency Services

If we provide you with Access to Emergency Services then we will provide all the necessary information to the Emergency Services that they require.

6.4    Third Parties for Administrative Purposes

We may sometimes contact other companies to assist with our administration. In these cases we will make sure these parties have the same or similar guidelines to ours.

6.5    Providing a directory enquires service

Unless you and/or your company have asked us not to enter your details into a directory services, we will enter your Truphone number into Truphone and third party directories, and our network will allow the display of your number on receiving devices. You have the option to opt out of these services.

Note that where Truphone provides You with Access to Emergencies Services, Your number and location of your device will always be sent if you are calling the emergency services.

6.6    Information Storage

Information collected on the Website or by using the Service may be stored and processed in any country in which Truphone maintains facilities. In this regard, or for purposes of sharing or disclosing data in accordance with this policy, Truphone reserves the right to transfer information outside of your designated home country. By using the Truphone Service You consent to any such transfer of information outside of your designated home country. Truphone may sell or buy subsidiary companies or business units. In such transactions as well as in the event Truphone or substantially all of its assets are acquired by a third party, personal information of Truphone users will generally be one of the business assets transferred. We reserve the right to include your personal information, collected as an asset, in any such transfer to a third party.

7.      How long will we hold your data?

There are strict guidelines in the UK which define for how long we may hold personal data about you. These include guidelines on data protection, privacy and anti-terrorism legislation. We will hold your personal data in accordance with the timescales detailed in these guidelines.

8.     Can I see the data you hold about me?

Yes. You may ask to see the information we hold on you by sending a letter to the Data Controller, Truphone Ltd, 4 Royal Mint Court, London, EC3N 4HJ.

9.     What are cookies and how do we use them?

9.1    Cookies are pieces of information that Truphone will transfer to your computer's hard drive through your browser to enable Truphone's systems to recognise your browser. Cookies also enable Truphone to gather information about the use of its website and to enhance the website accordingly to the preferences of the users.

9.2    The Help option on the toolbar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Truphone's cookies do not contain any identifying information. Please bear in mind that some personalised services may not be available if you choose to disable cookies.

10.    How does Truphone protect your personal information?

10.1  Truphone takes appropriate organisational and technical measures to protect the Personal Data and Traffic Data provided to it or collected by it, and does not retain it any longer than permitted in order to perform its services or as required under relevant legislation. Your Personal Data and Traffic Data can only be accessed by authorised employees of Truphone who need to access to these data in order to be able to fulfil their given duties.

Truphone takes appropriate technical measures to protect the confidentiality of the communications content via its Truphone Services, and observes applicable obligations and exceptions under the relevant legislation.

11.    Will this policy change?

This privacy policy may change from time to time for either legal or business reasons. In particular, you should check this Policy regularly for compliance purposes. If any changes are made a revised privacy policy will be published at www.truphone.com.