Privacy Policy

Last updated: February 2024

 

Voneus respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights.

 

This Privacy Notice applies (unless a different privacy notice is displayed to you) to personal information that we collect in the usual course of business, including when you:

  • visit our website at www.voneus.com (“Website”), visit our social media pages, receive communications from us, register for or attend one of our events including any community engagement events, engage in one of our surveys or market research initiatives;
  • when you enquire about our services, contact our sales and support team; and
  • when you purchase our services either via the Website, over the phone or in person.

These activities are collectively referred to as the "Services" in this Privacy Notice.

 

References to "you" in this Privacy Notice depend on the context of your interaction with us.

 

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details found at How to contact us.

 

What does Voneus do?

Voneus is a rural broadband provider, headquartered in the England. We provide broadband and fibre services to individuals in hard-to-reach areas. For more information about Voneus, please see the “About Us” section of our Website at Voneus | Fibre-powered broadband for rural homes & businesses - Voneus.

 

What personal information does Voneus collect?

The personal information that we collect about you (either directly or indirectly) will depend on your interaction with us and our Services. We collect information from the following sources:

  • Information you provide voluntarily: We collect personal information from you when you choose to provide us with this. Certain parts of our Services ask you to provide personal information voluntarily: for example, we ask you to provide your contact details when you purchase our Services, to register an account with us, to subscribe to marketing communications from us, and/or to submit enquiries to us, that you provide to our Sales teams or Community Engagement teams. If you contact us via social media or enter into a survey/competition via social media, we will collect your email from your social media account. Where you have a vulnerability you may choose to share details about that with us.

 

  • Information we automatically collect: When you visit our Website, we collect certain information automatically from your device. Some of this information is collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.

 

  • Information from third parties: We also collect your personal data from third party sources, i.e. our service providers that provide operational assistance, marketing analytics services, payment services, as well as lead providers. Information received from third parties will be checked to ensure that the third party either has your consent or is otherwise legally permitted or required to disclose your personal data to us.  

 

In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information.

 

The table below describes the categories of personal information we collect from and about you through the Services.

 

Personal Data Description

Source

Identity and Contact Data such as your name, email address and password, telephone number and address (including social media handle if you contact us via social media).
  • Directly from you
  • Third parties
  • Automatic collection

Customer Account Data such as your login information (email and password) and profile information (contact details including your name, surname, postcode, phone, your gender (includes 'prefer not to say' option), any accessibility requirements (for example if you need us to provide documents in an accessible format, or as part of our installation/set up) , details of your service subscriptions,  and other status relevant to your eligibility for discounts.
  • Directly from you
  • Third parties

Transaction Data such as truncated credit or debit card details, payment method, transaction statements, your billing address, payments and orders to and from you and credit checks.

We do not collect or store your full credit or debit card details (which are processed by payment service providers who are separate controllers of your data. Please refer to your payment service provider's privacy notice for further details on their data collection practices).
  • Directly from you
  • Third parties
  • Automatic collection

Communications Data such as your feedback on our Services or the performance of our Services and other communications with us (including when you interact with our customer service agents offline), any queries you raise, competition and survey entries, chat, email or call history with us or with third party service providers.  This will include information as to how you contact customer services and the channel of communication that you use or any information that you send to us (for example, if you complain about the performance of our Services and send us screenshots).
  • Directly from you
  • Third parties
  • Automatic collection

Advertising and Marketing Data such as your interests based on your use of our Services, your purchases, survey responses, promotions you enter, preferences in relation to receiving marketing materials from us, communication preferences, your preferences for particular services and your subscription details.
  • Directly from you
  • Third parties
  • Automatic collection

Device Data collected using tags and pixels, including your IP address, your ISP, and the browser you use to visit our Website, device type, unique device identification numbers or other identifiers [including advertising identifiers].
  • Automatic collection

Website Usage Data such as activity and Website page interaction, information that we capture using cookies and similar technologies (see the "Cookies and similar tracking technology"  section  [www.voneus.com/cookie-notice] below). This will include page views and searches, log-in information, clicks, operating system, information about content viewed, watched or downloaded for offline access, length of visits to certain pages, length of Website use, purchase history and other functional information on Website performance (for example, application version information, diagnostics, and crash logs).
  • Automatic collection

Location Data some customer traffic data is collected about volumes , e.g., technical information that  data identifies volumes of use at any time to ensure we balance our network use
  • Automatic collection

Vulnerability Data Disabilities, illness, physical capabilities, age, personal circumstances, financial circumstances
  • Directly from you

 

How we use your personal information and our legal basis for processing it

We use the personal information that we collect from and about you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your information. Depending on our purpose for collecting your information, we rely on one of the following legal bases:

 

  • Contract - we require certain personal information in order to provide the goods and support the services you purchase or request from us;
  • Consent – in certain circumstances, we may ask for your consent (separately from any contract between us) before we collect, use, or disclose your personal information, in which case you can voluntarily choose to give or deny your consent without any negative consequences to you;
  • Legitimate interests – we will use or disclose your personal information for the legitimate business interests of either Voneus or a third party, but only when we are confident that your privacy rights will remain appropriately protected. If we rely on our (or a third party's) legitimate interests, these interests will normally be to: operate, provide and improve our business and Services; communicate with you and respond to your questions; improve our Services or use the insights to improve or develop marketing activities and promote our services; detect or prevent illegal activities (for example, fraud); and/or to manage the security of our IT infrastructure, and the safety and security of our employees, customers, vendors and visitors. Where we require your data to pursue our legitimate interests or the legitimate interests of a third party, it will be in a way which is reasonable for you to expect as part of the running of our business and which does not materially affect your rights and freedoms; or
  • Legal obligation – in instances where we must process and retain your personal data to comply with laws or to fulfil certain legal obligations.

 

The table below describes the categories of personal information we collect from and about you and the purposes of which we process such personal information and the grounds on which we process this information.

 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer and sign you up for our Services
  • Identity and Contact Data
  • Customer Account Data
  • Transaction Data
  • Vulnerability Data
  • Performance of a contract with you;
  • Explicit consent in respect of any processing of health data for the purposes of providing additional assistance/protect vital interests of the data subject
  • Legitimate interests to support our customers

To process and deliver your order including:

  1. Delivery of any equipment or other items to you;
  2. Arranging installation if required;
  3. Managing payments, fees and charges; and
  4. Collecting and recovering money owed to us.
  • Identity and Contact Data
  • Transactions Data
  • Communications Data
  • Performance of a contract with you
  • Necessary for our legitimate interests (to recover debts due to us)

 

To manage our relationship with you which will include:

  1. notifying you about changes to our terms or privacy policy;
  2. communicating with you about the services including send you service updates, confirmations, invoices, technical notices, updates, security alerts, support and administrator messages, respond to your enquiries, requests or complaints; and
  3. asking you to leave a review.
  • Identity and Contact Data
  • Customer Account Data
  • Advertising and Marketing Data
  • Communications Data
  • Performance of a contract with you
  • Necessary to comply with a legal obligation 
  • Necessary for our legitimate interests (to keep our records updated and to study how customers use our Services)

For those completing the postcode availability checker and not submitting any personal details, the search itself is recorded.
  • Postcode Data

  • Performance of a contract with you

  • Otherwise, as necessary for our legitimate interests (to operate, provide and improve our business)

To contact individuals who have expressed an interest in our Services.
  • Identity and Contact Data
  • Necessary for our legitimate interests (to keep our records updated and to study how customers use our Services)

To respond to your communications regarding our Services.
  • Identity and Contact Data
  • Customer Account Data
  • Transaction Data
  • Communication Data
  • Device Data
  • Website Usage Data
  • Performance of a contract with you.
  • Otherwise, as necessary for our legitimate interests (to operate, provide and improve our business; to communicate with you) – where our communications are not necessary to perform or enter into a contract with you.

To make suggestions and recommendations to you or contact prospective customers about services, sector developments and events we think may be of interest to you
  • Identity and Contact Data
  • Customer Account Data
  • Transaction Data
  • Device Data
  • Website Usage Data
  • Communication Data
  • Marketing Data
  • Necessary for our legitimate interests (to develop our Services and grow our business) (where consent is not required by marketing laws)
  • If required by law, we seek consent before sending marketing materials to individuals and, in such cases, consent is our lawful basis for sending marketing to you.

Handling contact and support requests including reviewing such communications for quality assurance and training and recordkeeping.
  • Identity and Contact Data
  • Customer Account Data
  • Transaction Data
  • Device Data
  • Website Usage Data
  • Communication Data
  • Performance of a contract with you
  • Necessary for our legitimate interests (to keep our records updated and to engage with our customers)

Keep our business, including our Services threats to your safety or the safety of others; to detect and prevent fraud (online and in store). For example, online we use malware and spyware monitoring tools to detect suspicious activity and algorithms to detect

unauthorised access.
  • Identity and Contact Data
  • Customer Account Data
  • Transaction Data
  • Device Data
  • Website Usage Data
  • Communication Data
  • Location Data
  • Necessary for our and our third parties' legitimate interests (to operate and provide our business, including our Website; to detect or prevent illegal activities (e.g. fraud) and/or to manage the security of our IT infrastructure, and the safety and security of our employees, customers, vendors, and visitors).

To manage compliance with our terms of service, Acceptable Use Policy and related internal reporting.
  • Identity and Contact Data
  • Customer Account Data
  • Communication Data
  • Transaction Data

 
  • Performance of a contract with you.
  • Otherwise, as necessary for our legitimate interests (to operate, provide and improve our business, including our Website; to detect or prevent illegal activities (e.g. fraud) and/or to manage the security of our IT infrastructure, and the safety and security of our employees, customers, vendors, and visitors.
  • Legal obligations [refer to specific obligations].

To use data analytics to improve our Website, Services, marketing, customer relationships and experiences
  • Device Data
  • Website Usage Data.
  • Necessary for our legitimate interests (to define types of customers for our Services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To administer and protect our Website and our systems (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • Device Data
  • Website Usage Data
  • Necessary for our legitimate interests (for security and running of our Website)

To manage our use of tracking

technologies such as cookies (including enabling you to manage your cookie preferences) and analyse collected data to learn about our Website, to improve our Website, and to develop new Services. This includes website analytics, identifying browsing / purchasing trends and patterns and evaluating this information on an aggregated, group(s) basis (Social media, Marketing Data) and individual basis (Account Data, Device Data, Location Data and Website Usage Data).
  • Customer Account Data
  • Device Data
  • Website Usage Data
  • Location Data
  • Advertising and Marketing Data
  • Communications Data
  • Consent (where required under applicable law – see cookie consent tool on our website).
  • Otherwise (for strictly necessary cookies) our legitimate interests to operate, provide and improve our business, including our Website, to improve our Website or use the insights to improve or develop marketing activities and promote our Services.

To analyse data including metrics related to consumer transactions and behaviour (online and offline), to assess trends and the effectiveness of our advertising and marketing campaigns, to help us understand your needs and provide you with better service and offers, to drive customer engagement, promote our brand, and inform other business decisions by

understanding consumer behaviour.
  • Customer Account Data
  • Transaction Data
  • Device Data
  • Website Usage Data
  • Communication Data
  • Marketing Data
  • Consent (where required under applicable law).
  • Otherwise, our legitimate interests (to operate, provide and improve our business, including our Website, to improve our Website or use the insights to improve or develop marketing activities and promote our Services).

To personalise and customise your experience, including to provide local or otherwise targeted content and information for customers, and to tailor the content and advertising served on our Website.
  • Customer Account Data
  • Marketing Data
  • Website Usage Data
  • Device Data

 
  • Consent (where required under applicable law).
  • Otherwise, our legitimate interests (to operate, provide and improve our business, including our Website, to use the insights to improve or develop marketing activities and promote our Services).

To analyse social media performance metrics to evaluate and execute social media campaigns, including to interact with our current and prospective customers on various social media channels to promote our Services, run contests and promotions, answer questions and otherwise drive and monitor customer engagement and satisfaction.
  • Customer Contact Data
  • Account Data
  • Marketing Data
  • Communication Data
  • Website Usage Data
  • Device Data
  • Consent (where required under applicable law).
  • Otherwise, our legitimate interests (to improve our business, to promote our Services and to use the insights to improve or develop marketing activities).

To administer sweepstakes,

Competitions or surveys.
  • Identity and Contact Data
  • Customer Account Data
  • Communication Data
  • Uploaded Content Data
  • Social media
  • Our legitimate interests (to drive customer engagement and to collect user perceptions and measure satisfaction).

To comply with legal and regulatory obligations to which we are subject, including our obligations to respond to your requests under data protection law.
  • Identity and Contact Data
  • Customer Account Data
  • Transaction Data
  • Website Usage Data
  • Location Data
  • Communication Data
  • Legal obligation.

To protect our legal rights (including where necessary, to share information with law enforcement and others), for example to defend claims against us and to conduct litigation to defend our interests.
  • Identity and Contact Data
  • Customer Account Data
  • Transaction Data
  • Location Data
  • Website Usage Data
  • Communication Data
  • Our legitimate interests to protect our business interests.

To support our vulnerable customers.
  • Health Data
  • Financial Data
  • Sensitive Personal Circumstances
  • Consent.
  • Our legitimate interests to support our customers.
  • Legal obligation to comply with the regulators' requirements.

 

If we ask you to provide personal information to comply with a legal requirement (for example, when arranging for a service call or installation appointment, we might ask for additional personal contact details in order to be able to fix an issue) or to perform a contract with you (for example, to provide you with the services), we will set out at the relevant time what minimum information must be provided and the consequences if you do not provide it. 

 

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, including how we balance our legitimate interests against your rights and freedoms where applicable, please contact us using the contact details found at How to contact us.

 

Who does Voneus share my personal information with?

 

We share your personal information with the following categories of recipients:

  • our group companies, who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Notice;
  • third party service providers and partners who provide data processing services to us as necessary to provide you with our services (to support the delivery of, provide functionality on, or help to enhance the security of our Website and Services), or who otherwise process personal information for purposes described in this Privacy Notice. The following lists the main third-party service providers or categories of services providers we engage to process your personal information and the services they provide:
    • third-party engineers to assist with support or installation for our customers, integrating new functionality and diagnostics;
    • payment processors to deal with payments from customers;
    • credit check providers;
    • review sites and Customer Feedback services;
    • website services including third-party review platforms, hosting services and marketing support;

 

  • our investors

 

  • any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;

 

  • an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice; or

 

  • any other person with your consent to the disclosure (obtained separately from any contract between us).

 

We shall ensure that information obtained to support our vulnerable customers is recorded and shared only as is necessary for the purposes set out in our Vulnerable Customers Policy to make it visible to all appropriate frontline staff on internal systems, with appropriate access controls in place.

 

Cookies and similar tracking technology

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you, including to serve interest-based advertising.  For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice.

 

How does Voneus keep my personal information secure?

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include systems and processes to prevent unauthorised access or disclosure of your data. For example, we protect your data by using varying levels of encryption and perform quality checks on team activities to ensure compliance. We also make sure that any third parties that we deal with keep all personal data they process on our behalf secure.

 

Where you have created an Account and unique password to enable you to access our Website, it is your responsibility to keep this password secure and confidential.

 

International data transfers

In some cases, where your personal information is transferred to third parties, it may be processed in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, our Website servers are located in London, and our third party service providers and partners operate around the world. This means that when we collect your personal information we will process it in any of these countries.

Where we transfer your personal information to countries and territories outside of the UK, which have been formally recognised as providing an adequate level of protection for personal information, we rely on the relevant “adequacy regulations” from the Secretary of State in the UK.

Where the transfer is not subject to an adequacy regulations, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice and applicable data protection law.

 

Data retention

We retain the personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). 

 

When we have no ongoing legitimate business need or legal reason to process your personal information, we will either delete or anonymise it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

Your data protection rights

Depending on your location, you may have the following data protection rights. To exercise any of them see specific instructions below or the How to contact us section.

 

  • You may access, correct, update or request deletion of your personal information. 
  • You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
  • You have the right to opt-out of marketing communications we send you at any time.  You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.  To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us. If you choose to opt out of marketing communications, we may still send you non-promotional emails, such as emails about your account or our ongoing business relations.
  • If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a supervisory authority about our collection and use of your personal information. For more information, please contact your local supervisory authority– the UK's contact details are here .

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

 

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if, and where, required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

 

How to contact us

If you have any questions or concerns about our use of your personal information, please contact us using the following details: dpo@voneus.com. 

The data controller of your personal information is Voneus Limited which is registered with the Information Commissioner's Office with registration number ZA022496.

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