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What does this Privacy Policy Cover?
Welcome to the LookAfterMyBroadband.uk's Privacy Policy.
LookAfterMyBroadband.uk respects your privacy and is committed to protecting
your
personal data. This Privacy Policy will inform you as to how we look after your
personal data when you visit our website (regardless of where you visit it from)
and tell you about your privacy rights and how the law protects you.
With that in mind, this Privacy Policy is designed to describe:
- Who we are.
- What we do.
- Cookies.
- What are “Your Rights” over your Personal Data
- What Personal Data we collect.
- How we collect your Personal Data.
- How we use your Personal Data and why.
- Who we share your Personal Data with.
- Marketing
- Lawful basis.
- How we keep your Personal Data secure.
- International Data Transfers.
- How long we store your Personal Data.
- Our policy on children.
- Changes to this policy.
- Third party Links.
- Contact Us.
Incoming, EU-wide data protection legislation known as the “General
Data Protection
Regulation” or “GDPR” (a copy of
which is posted here),
took effect from May 25th, 2018. This website Privacy Policy is intended to meet
our duties of Transparency under the GDPR and all other applicable privacy laws.
We will post any modifications or changes to this Privacy Policy on this page.
Who we are.
LookAfterMyBroadband.uk is owned and operated by Tomorrow Gaming Ltd, a Maltese
company. Our registered address is: Cali House, 3rd Floor, Vjal ir-Rihan, Triq
tal-Balal, San Gwann SGN9016, Malta. When we refer to
“we” or “us” in this Privacy
Policy, we are referring to Tomorrow Gaming Ltd
We have appointed a “Data Protection Officer”, this is a person who is
responsible for overseeing and advising us in relation to our compliance with
the GDPR and our compliance with this Privacy Policy. If you want to contact our
Data Protection Officer directly, you can email: info@tomorrowgaming.com.
Our ICO registration number is: ZA627493
What we do.
Tomorrow Gaming Ltd is a data controller under the definitions of the GDPR.
This site is designed to help you with options around broadband switching,
collecting information and then sharing that information with other data
controllers who might be able to offer you a product or service to fit your
needs.
Cookies.
Google Analytics is a simple, easy-to-use tool that helps website owners measure
how users interact with website content. As a user navigates between web pages,
Google Analytics provides website owners JavaScript tags (libraries) to record
information about the page a user has seen, for example the URL of the page. The
Google Analytics JavaScript libraries use HTTP
Cookies to
"remember" what a user has done on previous pages / interactions with the
website.
Important: Read the Google
Analytics
privacy document for more details about the data collected by
Google Analytics.
Google Analytics supports three JavaScript libraries (tags) for measuring website
usage: gtag.js, analytics.js,
and ga.js.
The following sections describe how each use cookies.
What are “Your Rights” over your Personal Data.
Under data protection law you have rights regarding how we process your data.
You are not required to pay any charge for exercising your rights. We have one
month to respond to you, and you may be asked for ID to confirm your identity.
To exercise any of the following rights, please use the contact details listed at
the bottom of this section:
Your Individual Rights as a Data Subject
- Right of access - you have the right to ask
us for copies of your personal information. This right always applies. There
are some exemptions, which means you may not always receive all the
information we process. You
can read more about this here
- Right of rectification - You have the right
to ask us to rectify information you think is inaccurate. You also have the
right to ask us to complete information you think is incomplete. This right
always applies. You
can read more about this here
- Right to be forgotten - in certain
circumstances you can ask for the data we hold about you to be erased from
our records. You
can read more about this here
- Right to restriction of processing - where
certain conditions apply you have a right to restrict the
processing. You
can read more about this here
- Right of portability - you have the right to
have the data we hold about you transferred to another organisation. You
can read more about this here
- Right to object - you have the right to
object to certain types of processing such as direct marketing. You
can read more about this here
By Email – info@tomorrowgaming.com
In Writing – The Data Protection Officer, Tomorrow Gaming Ltd, Viewpoint Block D,
No. 130, Triq Andre` Maurois, St. Julians, STJ 1575, Malta
Our UK GDPR representative is the point of contact for all questions concerning
the data protection of UK citizens and the contact for data protection
supervisory authorities. Their contact details are as follows:
Ian
Cruickshank - Lead 365 Ltd
6th Floor, Alexandra Warehouse, West Quay,
Llanthony Rd, Gloucester, GL1 2LG
dataprotection@lead365.co.uk
You can also withdraw your consent for live or automated calls from anyone by
registering your telephone number on the Telephone Preference Service. Details
can be found at www.tpsonline.org.uk
Right to lodge a complaint – If we cannot deal with your
complaint to your satisfaction you have the right to complain to the relevant
supervisory authority who, in the UK is the Information Commissioner’s Office
(ICO) are their contact details are:
The Information Commissioner’s Office
Wycliffe House, Water Lane,
Wilmslow, Cheshire,
SK9 5AF
https://ico.org.uk/make-a-complaint/
Tel: 0303 123 1113
What Personal Data we collect about you.
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 to enable us to provide you with our price comparison, switching or other
services, which we have grouped together as follows:
- Identity Data includes first name, last name, internet
protocol (IP) address and postcode.
- Contact Data includes email address and telephone numbers.
- 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 could be derived from your personal data
but is not considered personal data in law as this data
will 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 policy.
We do not collect any Special Categories of Personal Data about you (this
includes 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). Nor
do we collect any information about criminal convictions and offences.
If you fail to provide personal data 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 goods or
services). In this case, we may have to cancel a product or service you have
with us, but we will notify you if this is the case at the time.
How we collect your Personal Data
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us personal data by
filling in forms or by corresponding with us by post, phone, email or
otherwise. This includes personal data you provide when you:
- fill in forms on our website;
- search for a comparison;
- enter into a contract for the supply of services;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- correspond with us by phone, email or live chat; or
- give us feedback or contact us.
- Third parties or publicly available sources. We will
receive personal data about you from various third parties including the
following:
- analytics providers such as Google based outside the UK
and EEA;
- advertising networks based inside OR outside the UK and
EEA; and
- search information providers based inside the UK or the
EEA.
- Identity and Contact Data from data brokers or
aggregators, such as Lead 365 - https://www.lead365.co.uk/privacy-policy/
based in the UK.
How we use your Personal Data and why.
We will only use your personal data when the law allows us to. We will obtain
your consent before sending third party direct marketing communications to you.
You have the right to withdraw consent to marketing at any time by contacting
us.
Purposes for which we will use your personal data is set out below, in a table
format, 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 where more than one ground has been set out in
the table below.
|
Purpose/Activity
|
Lawful basis for processing including basis of legitimate
interest
|
|
To register you as a new customer
|
Performance of a contract with you
|
|
To provide our services and fulfilling your requests
|
(a) Performance of a contract with you
|
|
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
|
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records
updated and to study how customers use our products/services)
|
|
To administer and protect our business and this website
(including troubleshooting, data analysis, testing, system
maintenance, support, reporting and hosting of data)
|
(a) Necessary for our legitimate interests (for running our
business, provision of administration and IT services, network
security, to prevent fraud and in the context of a business
reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|
|
To deliver relevant website content and advertisements to you and
measure or understand the effectiveness of the advertising we
serve to you
|
Necessary for our legitimate interests (to study how customers
use our products/services, to develop them, to grow our business
and to inform our marketing strategy)
|
|
To use data analytics to improve our website, products/services,
marketing, customer relationships and experiences
|
Necessary for our legitimate interests (to define types of
customers for our products and services, to keep our website
updated and relevant, to develop our business and to inform our
marketing strategy)
|
|
To make suggestions and recommendations to you about our services
that may be of interest to you
|
Necessary for our legitimate interests (to develop our
products/services and grow our business)
|
|
To share your data with third party advertisers who will send
relevant adverts to you
|
Your consent
|
Who we share your Personal Data with.
We may share your personal data with the external third parties set out below for
the purposes set out in the table in the How we use your Personal Data and
why section above.
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 policy.
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.
When you complete an enquiry, you consent to us disclosing your personal
information to the following parties:
- Tomorrow Gaming Ltd: to communicate with you, including sending you
information about products and services which may be of interest to you
within the switching sector and other money saving sectors listed below; in
accordance with its privacy policy.
- Trusted third parties but only where you have opted in to allow us to do
so, are detailed below or have a legitimate interest established in areas
such as switching to include Phone, TV, Broadband or Gas & Electric. You
can opt out at any time from receiving these communications.
Third Parties listed below:
Marketing
We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising. We have established the following
personal data control mechanisms:
Promotional offers from us and partners
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 used our services and you have not opted out of receiving
that marketing.
We may share your data with other companies for carrying out/putting in place the
product / services that we recommend and for reporting purposes.
Third-party marketing
We will get your express opt-in consent before we share your personal data with
any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any
time by following the opt-out links on any marketing message sent to
you OR 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 to enable us to provide our price comparison,
switching or other services to you.
Lawful basis
Legitimate Interest means the interest of our business in conducting and managing
our business to enable us to give you the best service/product and the best 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. We do not use your personal
data for activities where our interests are overridden by the impact on you
(unless we have your consent or are otherwise required or permitted to by law).
You can obtain further information about how we assess our legitimate interests
against any potential impact on you in respect of specific activities by
contacting us.
Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your
request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is
necessary for compliance with a legal obligation that we are subject to.
How we keep your Personal Data secure.
We have put in place appropriate security measures to prevent your personal data
from being accidentally lost, used or accessed in an unauthorised way, altered
or disclosed. In addition, we limit access to your personal data to those
employees, agents, contractors and other third parties who have a business need
to know. They will only process your personal data on our instructions, and they
are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach
and will notify you and any applicable regulator of a breach where we are
legally required to do so.
International Data Transfers
External third-party service providers who may process personal data on our
behalf may be based outside the UK or EEA so their processing of your personal
data will involve a transfer of data outside the UK or EEA.
Whenever we transfer your personal data out of the UK or EEA, we ensure a similar
degree of protection is afforded to it by ensuring that appropriate safeguards
are implemented. For example, we will only transfer your personal data to
countries that have been deemed to provide an adequate level of protection for
personal data, where we have adopted standard contractual clauses approved for
use in the UK and EEA to safeguard the data, or where a derogation applies (for
example, if you have given consent to the transfer).
How long we store your Personal Data.
We will only retain your personal data for as long as reasonably necessary to
fulfil the purposes we collected it for, including for the purposes of
satisfying any legal, regulatory, tax, accounting or reporting requirements. We
may retain your personal data for a longer period in the event of a complaint or
if we reasonably believe there is a prospect of litigation in respect to our
relationship with you.
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, regulatory, tax, accounting or
other requirements.
In some circumstances you can ask us to delete your data: see the What
are “Your Rights” over your Personal Data section above for further
information.
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.
Our policy on children.
Our websites, products and services are not intended for use by children under
the age of 16. We do not knowingly collect data relating to children under the
age of 16.
Changes to this Privacy Policy.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on
17/11/2021. 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.
Third Party Links.
This website may include links to third-party websites, plug-ins and
applications. Clicking on those links or enabling those connections may allow
third parties to collect or share data about you. We do not control these
third-party websites and are not responsible for their privacy statements. When
you leave our website, we encourage you to read the privacy policy of every
website you visit.
External Third Parties
- Service providers acting as processors based in the UK who
provide IT and system administration services.
- Professional advisers acting as processors or joint
controllers including lawyers, bankers, auditors and insurers based in the
UK.
- HM Revenue & Customs, regulators and other authorities
acting as processors or joint controllers based in the UK.
- Third party advertisers with whom you have given your consent
to us sharing your personal data for marketing and advertising purposes.
- Institute of Chartered Accountants England & Wales
Contact Us.
If/when you contact us. We will use this information (ONLY) to respond to and/or
resolve your query/question. We will not share this with third parties for
marketing purposes.
LookAfterMyBroadband.uk is owned and operated by Tomorrow Gaming Ltd, a Maltese
company. Our registered address is: Viewpoint Block D, No. 130, Triq Andre`
Maurois, St. Julians, STJ 1575, Malta
ICO Registration number : ZA627493
Please contact us via email: info@tomorrowgaming.com
This Privacy Policy was last updated on
22nd February 2022
