For XLN Pay services, XLN Pay Limited is the data controller for the purposes of the applicable data protection laws. For XLN Energy services, XLN Energy Limited is the data controller. For all other services, including landline, broadband, mobile and wifi, XLN Telecom Limited is the data controller. Each of these companies has its registered office is at First Floor, Millbank Tower, 21-24 Millbank, London SW1P 4QP. Our data protection officer is Keith Dewey who can be contacted at the above address or by email at firstname.lastname@example.org.
1. Information we collect from you
1.1 Information you give us
- When you place any orders for our services we will collect certain information to process your order including your name and business name, details of the services requested, your postal and email addresses and telephone number(s).
- When you submit a “call me back” request, request an energy quote or check your broadband speed via our website, we will collect information including your name, phone number, postcode and email address.
- When you use our “Quick Pay” service we may collect your email address and mobile number.
- When you contact us to discuss your services we may ask for certain information to confirm your identity and enable us to deal with your queries.
Without the information detailed above, we will not be able to process your order or payment or deal with your enquiry.
- Our field sales agents may collect information from you when visiting your premises including your name and business name, your postal and email addresses and telephone number(s).
- If you complete any voluntary survey or enter a competition we may ask for information about you.
1.2 Information we collect automatically
- When you use our services we automatically collect certain information relating to those services such as the length and destination of calls you make, your internet usage and the amount of energy you use which we use for billing purposes and to improve our services.
- When you visit our website we may collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions,;
- information about your visit, including the full Uniform Resource Locators (URL), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs),; and
- information about your usage by using “cookies” (see section 8 below).
1.3 Information we receive from other sources
- We may receive information about you from third parties such as other telecommunications companies, marketing organisations, credit reference agencies and other companies who provide services to us including
- Openreach and our other wholesale telecommunications network providers;
- SSE Energy Supply Limited, our wholesale energy supplier; and
- the merchant services provider with whom you enter into an agreement in connection with our card processing services.
2. How we use your information
2.1 We use your personal data for the following purposes:
- to allow us to enter into and/or perform our contract with you*;
- to enable us to comply with our legal obligations**;
- to pursue legitimate interests of our own or those of third parties***, provided your interests and fundamental rights do not override those interests; and/or
- Where you have consented**** to our use of your personal data for a specific purpose.
Further details of the purposes we will use your personal information are set out below.
2.2 We use information held about you in the following ways:
- to verify your identify when you use our services or contact us ***
- to process your orders and provision your services *
- to provide your services and manage your account(s)*
- to carry out credit checks (see section 3 below for more detail)***
- to process enquiries and/or complaints from you***
- to record calls with you and monitor emails and other written communications with you for training and legal/regulatory compliance purposes and to improve our customer service**/***
- to monitor and analyse use of our services to improve them***
- to tell you about changes to our services, terms and conditions and website***
- if you have consented or we are otherwise permitted under data protection laws, to provide you with information about other products, services or special offers that we and other members of the XLN group offer which we believe you may be interested in***/****.
- to carry out analysis to help us personalise the services we offer you and to understand what our customers want***
- to recover monies owed by you to us***
- to prevent or detect crime, fraud or misuse of our services and to investigate where we believe any of these have occurred**/***
2.3 We will not carry out any solely automated decision-making using information we hold about you.
3.1 When you sign up for our services, we will carry out a credit check against our own data and public data available at Companies House.
3.2 In addition, we sometimes carry out a credit check on our customers using a Credit Reference Agency, particularly when they are a ‘high usage’ customer. This means that your credit records will be searched, along with those of anyone who is financially associated with you such as your spouse or partner. The CRA will keep a record of this search and place a "footprint" on your credit file.
3.3 Credit Reference Agencies (CRAs) collect and maintain information about consumers' and businesses' credit behaviour. This includes data sourced from the Electoral Register, fraud prevention, and credit information - including details of previous applications and the conduct of your accounts - and public information such as County Court Judgements, decrees, and bankruptcies.
4.1 We use strict procedures and security features to protect your data and to prevent unauthorised access and all of the information you provide to us is stored on our secure servers. Any payment transactions will be processed using current, secure transport and encryption technology.
4.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk.
4.3 Where we have given you (or where you have chosen) a username and/or password which enables you to access certain parts of our website, you are responsible for keeping this username and/or password confidential.
5. Disclosure of your information
5.1 We value your privacy and understand that you don't want your details sold to third parties. We will not sell or rent in any form your information to a third party.
5.2 We will share your personal information with:
- Other companies within our group, namely, XLN Telecom Holdings Limited, XLN Telecom Limited, XLN Pay Limited, XLN Energy Limited and Onebill Telecom Limited to enable our group companies to inform you about their products and services (where permitted by law) and because some business functions are shared across the group;.
- Our suppliers to the extent necessary to provide your services, such as Openreach and other wholesale telecommunications network providers, SSE Energy Supply Limited, our wholesale energy supplier, Spire and Verifone who supply payment terminals, the merchant service providers you will engage with in connection with our card processing services and those involved in collecting money owing by you to us;
- Ombudsman Services, the alternative dispute resolution service, should you raise a complaint with them;
- Ofcom and law enforcement bodies when we are under a legal obligation to do so;
- Credit reference agencies for the purpose of assessing your credit score; and
- Our affiliate, Wizard E-Marketing Private Limited based in India, who assists us in engaging with new prospective customers. The contact details which we share with this affiliate are protected, as we have entered into standard contractual clauses with this Indian affiliate which require it to protect this data in the same way as is required by EU data privacy laws. You can obtain a copy of these standard contractual clauses by contacting email@example.com.
5.3 We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If XLN Telecom Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of business and other agreements; or to protect the rights, property, or safety of XLN Telecom Limited our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6. How long we hold your information
6.1 Where you become our customer, we will hold your personal information for as long as you are a customer plus a period of six years, to enable us to deal with any complaints or claims. We may hold it for longer where we deem it necessary for fraud prevention purposes.
6.2 The law requires us to keep certain ’communications data’ relevant to how you use our services for a period of 12 months. This information may be used by certain law enforcement agencies to prevent and detect crime and to protect national security. We will only disclose this information to them when we are legally required to.
7. Your rights and access to information
7.1 Additional Rights
Data Protection laws provide the following rights, to:
- request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see above).
- request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- request the transfer of your personal information to another party.
- lodge a complaint about the way in which your personal information is being used to a supervisory authority.
7.2 Right to Object -
You have the right to object to our use of your personal data, on grounds relating to your particular situation, to the extent the processing is based on our legitimate interests. If we receive an objection, then we will stop processing the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defence of legal claims.
7.3 To exercise your rights please get in touch with us using the contact details at the end of this policy.
7.4 You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
7.5 We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
7.6 Where we rely on your consent to use your personal information, you have the right to withdraw your consent at any time using the contact details at the end of this policy or by amending your preferences on our Marketing Preferences site. Once we have received notification that you have withdrawn your consent, we will stop processing your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
7.7 Our site may, from time to time, contain links to and from the websites of our partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
9. Changes to this policy
10. Contacting us
Please address any questions, comments and requests regarding our data processing practices to Quality Assurance, XLN Telecom Ltd at First Floor, Millbank Tower, 21-24 Millbank, London SW1P 4QP or firstname.lastname@example.org.