1. What do you do with my personal data?
We use your data to provide you, and other giffgaffers, great services. That includes doing things like:
- Improving our products and services for you and other giffgaffers including managing the network to ensure everyone gets the best experience, performing market research to understand our members views and personalising our experiences to make our service more intuitive & engaging;
- Providing you with the products and services you have selected, keeping you up-to-date and informed and responding to your enquiries such as notifying you when you are running low in your goodybag, confirming your payback rewards or highlighting giffgaff promotions and competitions we think you will be interested in;
- Legal, regulatory or business reasons such as assisting with crime and fraud prevention, assessing credit risk when provisioning loans and ensuring we provide the products and services you have selected.
We may use information about you to:
Improve our products and services
- Enhance and personalise the products and services that we offer you and to develop new products and services;
- Perform analysis and research and monitor usage behaviour;
- Manage our network and your use of our network;
- Aggregate information about you, your spending and your use of the services with information about other users of the services in order to identify trends;
- Analyse information about you including your calling, searching, browsing and location data on a personalised or aggregated basis.
Provide you with services and information
- Provide you with the products and services you have selected and to manage your account with us;
- Provide you with access to parts of this site;
- Contact you if necessary;
- Tell you about any new services or functionality (eg: the introduction of a new messaging service);
- Market our products and services to you;
- Send you information about our products and services by email or other means if you have opted in to receiving relevant marketing communications;
- Send you information about products and services offered by other companies that we think you might be interested in if you have opted in to receiving relevant marketing communications.
Satisfy our legal, regulatory and business requirements
- Help us keep your account safe, eg: checking your identity;
- Investigate any complaints or other enquiries that you raise;
- Check whether you or members of your household qualify for credit (this may be because you and/or one of your family members has applied for a loan through giffgaff gameplan or you have chosen to purchase a device on giffgaff.com with a loan through giffgaff gameplan);
- Assess credit risk, assess the provision of loans, debt tracing, debt recovery, credit management and crime, fraud and money laundering detection and prevention.
We may also disclose your personal information or information about your usage of our services to certain third parties. This data may identify you personally or may be included in aggregated and anonymised data (which means you will not be identified). These third parties may use this information:
- To provide you with targeted giffgaff or third party offers, promotions, adverts or commercial communications if you have opted in to receiving relevant marketing communications;
- To give them a better understanding of our business; and/or;
- To provide you with products and services or to improve the products or services you are already receiving.
See “Who do you share my personal information with (and why)” for further details about the types of third parties your information may be disclosed to.
We are allowed to use your information in these ways because:
- We need it to provide you with products and services and to manage your account with us;
- We need to use some of your information to comply with legal and regulatory obligations (such as legal obligations to keep details of calls made by customers for a certain period of time);
- We have a legitimate business interest in some uses of your information (such as conducting market research); and/or;
- You may have given your consent to us to use your data for certain activities, eg: marketing communications.
2. How long will you keep my personal data?
We keep information while you're our customer and after you've left us.
We use your information to provide you with the products and services you have selected and for a variety of other reasons.
For example, we might need to sort out disagreements, stop fraud and abuse, prove that you had an account with us or follow our legal obligations. Or the police may need it as evidence. We may also keep information about how you use our products or services.
In each case, the length of time that we need to keep the information may be different, but we will only keep the information for as long as we need it.More info
We have a legal obligation to keep data about your communications (calls and texts) for 12 months. This includes the number calling, the number called and the time and duration of the call. We do not retain the content of the call or text. Law enforcement agencies are entitled to access this data in support of the investigation, detection and prosecution of serious crime.Hide more info
3. Who do you share my personal data with and why?
We will share your information in the following situations:
- With partners, suppliers, agents and subcontractors who help us deliver the products and services you've chosen to use;
- When you have provided your consent;
- When we have legal or regulatory requirements such as a request from the competition authority, law enforcement agency or a credit reference agency.
We may share your information:
- With our current and prospective partners, agents and subcontractors (for example, advertisers and content providers) who are involved in delivering products or services used or ordered by you;
- With other companies in the giffgaff group, including their respective partners, agents and sub-contractors;
- With any relevant public authority or law enforcement agency;
- With any debt collection agency or credit reference agency;
- Where there is a change (or prospective change) in the ownership of giffgaff to new or prospective owners. In these circumstances we would require them to keep it confidential;
- Where we (or an affiliate processing your data on our behalf) are required to do so by law, regulation or legal proceedings;
- Where we believe it is necessary to protect giffgaff or third-party rights and property;
- Where you give us false or inaccurate information and/or we identify or suspect fraud;
- In response to a valid, legally compliant request by a competent authority;
- During emergencies when we believe physical safety is at risk;
- In response to a complaint that you have breached the services terms & conditions or any other product or service terms.
4. What data do you hold about me? (and how do you get it?)
We collect information in three ways:
- Directly from you, such as information filled in within application or registration forms, surveys and community posts;
- From the products and services you use, such as the calls you make on the giffgaff network, your browsing history including the websites you visit and your location data;
- From 3rd parties, such as information from credit reference agencies and fraud protection agencies.
We collect such information as:
- Your contact information including name, address, email address and telephone number;
- Your order history including top-ups and goodybag purchases;
- Your payment details including debit or credit card details, banking details and Paypal details;
- Your account settings including adult content, auto top-up and recurring goodybags;
- Your Community interactions including posts and comments;
- Your communications with us including requests and complaints;
- Your activity/interactions on our website;
- Your device location data and Internet Protocol (IP) address;
- Your use of our services including but not limited to;
- Phone numbers and/or email addresses of calls, texts, MMS, emails and other communications made and received by you and the date, duration, time and cost of such communications;
- Usage data to check compliance with our fair usage policy;
- Credit report information if you have taken up the credit check service through our website or applied for a loan through giffgaff gameplan;
- Loan information and loan application data including employment details, relationship details and homeowner status if you have applied for a loan through giffgaff gameplan or you have chosen to purchase a device on giffgaff.com with a loan through giffgaff gameplan);
- Bank transaction data if you have signed up to this service within giffgaff gameplan;
- Product application data if you have accessed products through product comparison services via giffgaff gameplan.
How we collect information:
We collect information directly from you when you are asked to provide personal details about yourself, including but not limited to when you:
- Purchase products or services from us;
- Register to become a giffgaff customer;
- Submit enquiries or comments to us or contact us;
- Enter any promotions, competitions or prize draws via the services;
- Join any of our schemes including our Participation scheme;
- Use any giffgaff products and services (including where you participate in the giffgaff community by posting on our Blogs and Forums);
- Take part in market research; and/or;
- When you make changes to or terminate your account with us.
We collect information about you indirectly:
- When you use any giffgaff products and services, including but not limited to when you visit orbrowse this site or use our mobile network;
- From third parties including but not limited to those who provide our financial services, take payments and manage product orders and dispatch;
- We may also collect information about you from other sources, including but not limited to: credit reference agencies, fraud prevention agencies and business directories and other commercially or publicly available sources;
- Our website uses a website recording service which records mouse clicks, mouse movements and page scrolling. Data collected by this service is used to improve our website usability. The information collected is stored and anonymised and then used for aggregated and statistical reporting. You will not be personally identified;
5. What rights do I have?
You have the following rights:
- To update your personal data. You can update or amend your information by visiting the My Details section of my giffgaff. For data not updateable through My giffgaff, you will need to contact us;
- To ask us to delete your personal data. However, there may be circumstances where we are legally entitled to retain it;
- To get a free copy of your personal data. A subset of your data (limited to data that you have provided to us) is available in a machine-readable format if required;
- To object to the processing of your data and have it restricted. There may be circumstances where you ask us to restrict the processing of your information, but we are legally entitled to refuse that request;
- To review some automated decision-making or profiling (automated processing to determine certain things about you);
- The right to make a complaint to the Information Commissioner (www.ico.org.uk) if you think that any of your rights have been infringed by us.
To exercise any of your rights, you will need to contact our member services team (on-line request forms for this will be available from the 25th May 2018). You will need to provide the following information so that we can verify your identity:
- a colour copy of the account holder's passport, driving licence, birth certificate or utility bill;
- SIM serial number (SSN) (if your request is related to your phone account).
giffgaff are required to respond to your request within 1 month. Where requests are complex and excessive, giffgaff is permitted an additional 2 months to process your request. However, in these circumstances we would provide an update on your request within 1 month of receiving it.
When requesting a copy of your personal data, you can also do this via post.
giffgaff reserve the right to charge an admin fee or refuse a request where requests for data are clearly unreasonable or excessive, particularly if they are repetitive.Hide more info
6. How do I change my marketing preferences?
You can opt in and out of marketing communications at any time by changing your preferences within my giffgaff. You will be able to choose to receive marketing communications about the products and services you have chosen, all marketing communications from giffgaff or options from selected partners.
You can also opt out of marketing communications by following unsubscribe links at the bottom of any marketing emails or text messages received from giffgaff.
We will never give your personal data to a third party for marketing unless you have expressly given us your permission.
7. How do you ensure my data is secure?
giffgaff is committed to keeping your data secure. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure.More info
Security of Communications
Please be aware that communications over the Internet, such as e-mails and webmails, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered - this is the nature of the World Wide Web/Internet. giffgaff cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
giffgaff Blogs, Chat rooms and Forums
You are reminded that chat rooms and opinion forums are for public discussion. Any personal information that you choose to supply when you participate in these discussions is widely accessible. Never reveal any personal information such as your telephone number, postal or email address when you participate in these discussions.
Users 13 and under
If you are aged 13 or under, please get your parent or guardian's permission before providing any personal information or before taking part in any www.giffgaff.com discussion. Users without this consent are not allowed to provide us with personal information.
Co-Branded Micro Sites and Third Party Sites
Some web pages and Micro Websites included within giffgaff's websites may be co-branded with third party names, logos, or properties. These Micro Websites are operated or maintained by or on behalf of giffgaff. While such third parties are sponsors of these web pages or Micro Websites, the third parties do not share in any personally identifiable information collected within those web pages or Micro Websites unless otherwise stated.
Non-EEA Use of Information
The information you provide to us may be passed to third parties located outside the European Economic Area. Countries outside the European Economic Area do not always have strong data protection laws. However, we will always take steps to ensure that your information is used by third parties in accordance with this policy. This can be done in a number of different ways, for instance:
- The country that we send the data to might be approved by the European Commission;
- The recipient company might have signed up to a contract obliging them to protect your information; or;
- The recipient is located in the US and is a certified member of the EU-US Privacy Shield scheme.
In other circumstances the law may permit us to otherwise transfer your information outside the EEA. In all cases, however, we will ensure that any transfer of your information is compliant with data protection law.Hide more info
8. What else can I do to ensure my data is secure?
Along with a section on Privacy, Get Safe Online has plenty of other good advice about protecting yourself online
9. How can I contact you?
If you would like more information or would like to raise any queries with us in relation to your information, you can contact us by writing to the Data Protection Officer at:
Data Protection Officer
11 Vine Street
We will check this policy from time to time and post any changes here.
We may also let you know about these changes by email, voicemail, text or media message or via a national advertising campaign.
11. Resolving Privacy Issues
We will always try our best to resolve any data privacy issue you may have. You have the right to refer any data privacy issue to the Information Commissioner's Office at any time.