Contents

Introduction
Personal Data
Why does Columbus need to collect and store Personal Data
What Personal Data will Columbus collect?
How will Columbus use the Personal Data it collects?
Will Columbus share Personal Data with anyone else?
Will Personal Data be transferred abroad?
Under what circumstances will Columbus contact you?
How do we use your Personal Data for marketing purposes?
How do we use Cookies?
How is your Personal Data protected?
How long do we keep your Personal Data for?
How do you update or delete your Personal Data?
How do we use your Personal Data for monitoring and recording of calls?
What are your Data Protection rights?
Privacy Policy updates
How to contact us

Introduction

Columbus takes data privacy and data security very seriously. We fully recognise the need to ensure that any Personal Data that we may collect is properly protected and that we are transparent and responsible in the way we handle it.  In this Privacy Policy you will find information about what Personal Data we collect as a Data Controller, what we do with it and how you can contact us if you have any questions or need any further information. The Columbus Privacy Policy applies to all of the contracts, services and websites offered by Columbus Telecom Ltd. The term ‘Customer’ refers to customers, new customers (prospects), previous customers, visitors to our websites, visitors to our events, shows or conferences and recipients of our digital services including marketing.  Columbus offers different contracts, services and websites for different business purposes. These are collectively referred to as ‘Contracts’, ‘Services’ and ‘Websites’ throughout this Privacy Policy.

Personal Data

Under the EU’s General Data Protection Regulation (GDPR), Personal Data is defined as:

“Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”

Why does Columbus need to collect and store Personal Data?

In order for us to provide you with a service we need to collect Personal Data to provision the service, provide billing for the service and communicate with you for the purpose of service changes, service updates and the reporting of issues in relation to the service. We are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

What Personal Data will Columbus collect?

For the purposes of this Privacy Policy, ‘Personal Data’ means any information that identifies you, that could be used to identify you or that relates to you, and that you submit about you when interacting with us and/or is otherwise collected by us when you visit the websites, by phone, by writing through order forms or in another manner. During our relationship with you we may collect and process your Personal Data, such as your name, address, telephone, email and other contact details, and any other information relating to you which you may provide, in the following cases:

  • Visit our websites and look at our products and services
  • Enquire about our products and services or contact us
  • Enter into a Contract with us and purchase our products and services
  • Participate in a promotion, event, survey or other campaign we organise
  • Sign up for our newsletters and other promotional materials.

Personal Data that you provide us
The types of Personal Data we may obtain include:

  • Your name, address and other contact details (such as telephone and mobile numbers, email address, function / job role)
  • Services provided, including online services
  • Online account details including username, password and other credentials used to access Columbus products and services
  • Financial and payment data such as banking details, invoices and payment terms as well as any Personal Data for fulfilling and legitimate processing of billing information.

Personal Data collected by automated means
When you visit our websites or use our services, subject to your prior consent where applicable by law, we may collect Personal Data by automated means, using technologies such as cookies, web server logs and similar technologies as described below. The types of Personal Data that we may collect through your visits to the websites or use of the services include, to the extent permitted under applicable law and, where required, subject to your express consent, are:

  • The date and time of visit, referring address (location from which a visitor comes to the websites such as a link followed from another website)
  • Type of Internet browser, device operating system and device details
  • Visitor’s IP address (a unique number that is assigned to any computer that connects to the Internet for identification purposes)
  • Traffic data for calls or Internet sessions when you use our phone or Internet services, including dialled numbers, identification of phone numbers, duration of calls, date, duration and data volume of Internet sessions
  • Location data generated during calls or Internet sessions.

Personal Data collected by third parties
Columbus may also receive information about Customers from other sources, including third parties from whom we have purchased data. This helps us to identify new customers, and create more tailored advertising to provide products and services that may be of interest to you. We ensure that any marketing campaigns and third party suppliers are GDPR compliant. Additionally Columbus may receive Personal Data from the suppliers we contract with for the purpose of providing services to you which may include: IP address data, details of phone calls you have made and Internet sessions carried out.

How will Columbus use the Personal Data it collects?

We collect and use your Personal Data to administer our relationship with you, including to respond to your enquiries or complaints, to provide our products and services to you, to manage our Contracts with you and to inform you about our products and services, partners, promotions and events, to administer and improve our websites and services, to respond to requests from authorities, to comply with our contractual and legal obligations, and for other legitimate business purposes. Columbus does not share, sell, rent or trade Personal Data with third parties for promotional purposes.

When you express an interest in obtaining additional information about the services, or register to use the websites or services, or register for an event, you may provide Columbus with personal contact information such as name, company name, address, phone number, and email address (‘Required Contact Information’). In addition, when you purchase the services or register for an event, Columbus may also require you to provide us with means of financial qualification and billing information, such as billing name and address, and the number of employees within the organisation that will be using the services (‘Billing Information’) which is not considered Personal Data.

We may ask you for information to enable us to provide a service to you and we collect this information by telephone, written/digital correspondence or via the websites. We may share your Personal Data with third party providers that we engage to process data on our behalf, when such sharing is required by law or other situations as permitted by law. In accordance with applicable law, you have the right to access Personal Data we hold about you, to rectify, delete or erase inaccurate data, to object, at any time and free of charge, to the processing of your Personal Data for direct marketing purposes, as well other rights under applicable law.

Columbus shall only process your Personal Data for the purposes described in this Privacy Policy or as otherwise permitted under applicable law. The processing of your Personal Data by Columbus for the purposes described hereunder is based on your explicit consent or on the necessity to process your Personal Data for the purposes of our legitimate interests, as provided by Article 9, 2., (a) and (f) of the General Data Protection Regulation (EU) 2016/679 of 27 April 2016 (‘GDPR’). Your personal information may be processed by Columbus for purposes including:

  • Administer our relationship with you, including to respond to your enquiries or complaints
  • To provide any goods, services or information you have requested and information about our products and services
  • To administer, operate, maintain, and improve the websites and our services
  • To manage your accounts, orders, invoices and payments
  • To manage and provide after-sales service
  • To administer accounting and taxes
  • To respond to requests from administrative or judicial authorities
  • To comply with applicable laws and regulations

Providing Personal Data for these purposes is necessary and refusal would make it impossible for Columbus to manage the Contract with you or to comply with its contractual and legal obligations. Subject to your consent where required by law, we may also use your Personal Data in order:

  • To keep improving the way our website works
  • To count how many persons visit our websites, where they come from, when they visit, how long they stay and what pages they look at
  • To associate your activity on our website in order to give us insights into products and services you might like and measure how our advertising performs
  • To note browser, operating system and device details used to ensure you enjoy a good online experience when you access our websites
  • To provide you access to Columbus internet-based information and services
  • To market and improve the services that we offer and to conduct promotional campaigns, surveys and other marketing initiatives pursuant to the ‘How do we use your Personal Data for marketing purposes?’ section
  • Let you know about offers and discounts
  • Understand how you use products and services, and to develop improved versions of our products and services
  • Carry out research and statistical analysis including to monitor how customers use our network, products and services on an anonymous or business by business basis
  • Prevent and detect fraud or other crimes, recover debts or trace those who owe us money

Columbus will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Columbus is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of Personal Data should be kept may also be governed by specific business sector requirements and agreed practices. Personal Data may be held in addition to these periods depending on individual business needs.

Will Columbus share Personal Data with anyone else?

We may pass your Personal Data on to third-party service providers contracted to Columbus in the course of providing a service to you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they are contracted to provide. Our policy is to not give, sell or otherwise distribute Personal Data we collect to third parties outside of Columbus, except to those suppliers we Contract with for the explicit purpose of providing the service, or where required with your express consent, or where this is necessary and in accordance with applicable law. In line with this, we share Personal Data with the recipients listed below.

Third party service providers
Your Personal Data may be disclosed to third party service providers, acting on our behalf, in connection with managing services, data analytics, finance, accounting or other administrative services and information technology support. These third party service providers will have access to and process Personal Data only on our behalf and under our instructions and will be held to appropriate security obligations

Columbus business partners
Personal Data may be passed to business partners for the purpose of account management and business support activities

Other data recipients
For the above purposes or where otherwise required by law, we may also need to make Personal Data available to third parties such as advisors, banks and financial institutions, professionals, independent consultants, potential or existing investors and/or acquirers (in connection with a merger, acquisition, or sale involving Columbus or other change in corporate control, regulatory and/or administrative authorities, courts and police authorities).

Columbus may provide information, in response to properly made requests, for the purposes of the prevention and detection of crime, and the apprehension or prosecution of offenders, when required to do so by law, for example under a court order, or in response to properly made court or administrative demands. Columbus may also provide information for the purpose of safeguarding national security. In either case, Columbus will act in accordance with applicable Data Protection Law. When you order products and services from Columbus, Columbus may make enquiries about you for credit reference purposes. These enquires include searching your records held by a credit reference agency. At all times where your information is disclosed to us we will protect it in accordance with this policy and keep it secure.

Will Personal Data be transferred abroad?

In the performance of our Contract with you or in providing our Services or Websites to you, no data is transferred outside of the European Economic Area (“EEA”).

Under what circumstances will Columbus contact you?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. We may contact you in relation to the service provided by Columbus and for billing and account management. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

How do we use your Personal Data for marketing purposes?

We may use your Personal Data to conduct marketing, promotional and informational activities and to perform business analytics, satisfaction surveys or market research and direct marketing purposes in general, including sending notifications about updates to the websites, information on our services we think may be of interest to you, initiatives or events by mail, e-mail, phone, fax, SMS, MMS or other electronic means. However, we will only do so in accordance with GDPR requirements prior to being contacted in this way and/or subject to relevant legal requirements. If you no longer wish to receive marketing information, please inform us by using the opt-out options available on our communications.

How do we use Cookies?

Subject to your consent where required by law, we use cookies and other technologies to track the use of our websites and services. Cookies are a small piece of data sent from a website and stored on a user’s computer while the user is browsing the website.  Cookies cannot carry any virus.  Cookies help us understand which sections of our websites are the most popular as they help show which pages are being visited and for how long. This helps us adapt our websites to provide more relevant and accessible information. For example, cookies allow us to ensure that the information displayed on your next visit to our websites will match up with your user preferences. You may configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Please note, however, that disabling cookies might affect your online experience and/or prevent you from taking full advantage of our site and some of its functionality. If you choose to restrict cookies you will have to provide certain information each time you visit our website and reset your preferences. To learn more about our use of cookies and your rights please review our Cookie Policy.

How is your Personal Data protected?

Columbus has appropriate policies and technical and organisational measures in place to safeguard and protect your Personal Data against unlawful or unauthorised access, accidental loss or destruction, damage, unlawful or unauthorised use and disclosure. We take all reasonable precautions to ensure that our staff and employees who have access to Personal Data about you have received adequate training.

How long do we keep your Personal Data for?

Columbus has a Retention Policy for Personal Data that we adhere to, in line with legal and statutory requirements. For further details regarding this please contact the Data Protection Officer using the email address dpo@columbusuk.com. We may retain your information for the period of time needed for Columbus to pursue legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

How do you update or delete your Personal Data?

In accordance with applicable data protection laws, you have the right to access Personal Data we hold about you and request the correction or erasure of any inaccurate data. You may exercise such rights by contacting us as described under the ‘What are your data protection rights?’ section below. If you close your account we may, for limited periods and in accordance with applicable law, retain some Personal Data in order to comply with legal obligations or for other proper purposes, such as legal retention obligations, collecting outstanding debts or resolving legal disputes.

How do we use your Personal Data for monitoring and recording of calls?

Your telephone calls to and from us may be recorded for the purposes of service quality and staff training, as well as evidence of a commercial transaction, subject to applicable law. You will be informed about this in a recorded message before your call is put through to a member of staff. Calls that are recorded for these purposes will be kept secure, will not be disclosed outside of Columbus and will be destroyed in accordance with our Retention Policy.

What are your Data Protection rights?

In accordance with applicable data protection law, you have a right to:

  • Obtain confirmation of the existence of, and to request a written copy of, the Personal Data Columbus holds about you
  • Have any inaccurate information about you corrected
  • Have Personal Data we hold about you deleted, blocked or removed
  • Withdraw your consent where relevant, without affecting the lawfulness of processing based on your consent before its withdrawal
  • Restrict the processing we make in relation to your Personal Data
  • Receive your Personal Data in a structured, commonly used and machine-readable format
  • Object to the use of your details for marketing activities and other promotional activities, as described under the ‘How do we use your Personal Data for marketing purposes?’ section previous
  • Lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your Personal Data infringes applicable data protection law.

In the event you wish to exercise any such rights, please send a written and signed request to Columbus as described under the ‘How to contact us’ section below.

Privacy Policy updates

We reserve the right to review this Privacy Policy at any time. Where appropriate or required by law, we will notify you about the new Privacy Policy by posting appropriate notice on our services or websites or by e-mail. We encourage you to periodically review this Privacy Policy to stay informed about our practices.

How to contact us

If you have any questions about this Privacy Policy, or if you wish to exercise your rights under applicable data protection laws, please contact us through our websites or contact the Data Protection Officer:

Data Proection Officer
Columbus UK
Milngavie Enterprise Centre
Ellangowan Court
Glasgow
G62 8PH

Email: dpo@columbusuk.com
Telephone: 0333 240 7755