We are Spectrum Fibre Limited and our trading name is Ogi.
What this policy does and doesn’t cover
This policy applies to information we collect about:
- Visitors to our websites
- Customers – people who consume our services
- People who enquire about our services
- People who consume our content e.g., who subscribe to our newsletters, download our videos or request a publication from us.
It does not cover:
This website is not intended for children and we do not knowingly collect data relating to children.
Information 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 don’t collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary. Below you’ll see the different kinds of personal data about you that we may collect, use, store and transfer:
Identity Data includes first name, middle name, last name, username, title, marital status, date of birth, gender, and any other personal information we receive to show that you’re eligible to order or receive our services.
Contact Data includes billing address, delivery address, registered address, email address, telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details of order, quotes, payments, communications in relation to enquiries and services, any equipment we will supply, and any services you have subscribed to.
Technical Data includes Internet protocol (IP) address, your login data, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform, devices used and other technology on the devices.
Profile Data includes orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our products, services, network and our website.
Marketing and Communications Data includes your preferences in receiving marketing and communications from us and third parties. Event attendance and Website usage. Please note that operational information (e.g. invoices, product updates, security alerts) are not marketing communications and so our customers will receive operational information regardless of whether they have opted into marketing communications.
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 services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
Visitors to our website
When someone visits our websites, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the website. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
Categories of Data: Technical Data, Marketing and Communications Data
Legal Basis: N/a as data is pseudonymised
Retention: N/a as data is pseudonymised
Collecting data via our website
Occasionally we ask for personal and company information from our website visitors to consume our content, but there will always be an option to opt out of further communications from us. We will store your data in a secure environment, and will not share it with a third party, unless required as part of a customer contract e.g., to be able to provide you with a service you pay for.
Categories of Data: Identity Data, Contact Data, Technical Data, Profile Data, Marketing and Communications Data
Legal Basis: Consent
Retention: Until consent is withdrawn – refreshed at appropriate intervals
Collecting data face-to-face or via telephone
From time to time, we will speak to customers, potential customers, stakeholders and partners face to face, for example at events or at offices. Any data collected will only be used to inform future dealings with those parties and will not be shared with any third party unless it is necessary for the provision of services.
Categories of Data: Identity Data, Contact Data, Profile Data
Legal Basis: Legitimate Interest
Retention: Until future dealings have been informed
Interacting with us via social media
We use a third-party provider, Hootsuite to manage our social media interactions. If you send us a private or direct message via social media, the message will be stored by Hootsuite for six weeks. It will not be shared with any other organisations.
Categories of Data: Contact Data
Legal Basis: Legitimate Interest
Retention: Three months
Data received from a third party
Categories of Data: Identity Data, Contact Data.
Legal Basis: Mirror of Collectors (e.g. Public Task, Consent etc.)
Retention: No longer than collector’s policy, however we may dispose of data sooner if no longer required to inform future dealings.
People who use our service
We offer various services to businesses and residents in the UK.
Please Note: We are under contractual obligation to hold the details of the people who have requested the services in order to provide them. However, we only use these details to provide the service the person has requested and for other closely related purposes.
We also share your information with our 3rd Party Suppliers and Partners, but only for the express purpose of providing your service. For example, a courier service for delivery, or a telecoms provider for provision of service.
Our customers will receive operational information (e.g., invoices, product updates, security alerts) regardless of whether they have opted into Marketing Communications.
You should also be aware that we are obliged to collect certain information for statutory purposes. This includes financial information for HMRC and technical data for Law Enforcement Authorities. The retention period for this information varies, retained information will be only used for these purposes.
Categories of Data: Identity Data, Contact Data, Financial Data, Technical Data, Profile Data, Usage Data, Transaction Data, Marketing and Communications Data
Legal Basis: Contract
Retention: 12 months after Cease of Contract
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Please see the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purpose for which we will use your personal data
We have 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||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity (b) Contact||Performance of a contract with you|
|To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)|
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical||(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||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||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||(a) Technical (b) Usage||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 services that may be of interest to you||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications||Necessary for our legitimate interests (to develop our products/services and grow our business)|
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.
Third party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
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 as a result of a service purchase, service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table, Purposes for which we will use your personal data above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
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.
We do not transfer your personal data outside the UK.
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 closely monitor and regularly review the security of our data storage and processing environment, taking any remediation actions as and when required. 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.
How long will we retain 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 your legal rights below 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.
Your Legal Rights
Under certain circumstances, you have right of access to personal information which we hold about you. If you wish to exercise any of your legal rights in relation to your personal data, including making enquiries about this information, having it corrected or requesting us to stop processing it, please contact us via the details below.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
If you want to make a complaint about the way we have processed your personal information, you can contact us. Please see our Complaints Policy for further details.
You can also complain directly to the UK supervisory authority (ICO).
Changes to this Privacy Notice and your duty to inform us of changes
We keep our privacy notice under regular review. This privacy notice was last updated on 22 April 2022.
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.
How to Contact us
Email: [email protected]
By Post: FAO: The Data Protection Officer, Tŷ Ogi, Hodge House, 114-116 St. Mary Street, Cardiff, CF10 1DY
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service 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.
Internal Third Parties
Other companies in group [acting as joint controllers or processors] and who are based in the United Kingdom and provide [IT and system administration services and undertake leadership reporting].
External Third Parties
- Service providers based in England and Wales who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers based in England and Wales who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
Your Legal Rights
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 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 local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will 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 automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.