Personal Data is any information relating to an individual (also termed a ‘data subject’) if that person can be identified from the data that is being processed. It includes names; addresses; emails and bank details amongst others.
The information we have about you includes things like who you are and how you pay for your services.
Who you are includes:
• Your name, address, telephone and mobile numbers, ID card or passport details;
• Your debit or credit card details, bank details and other payment information.
• Your call and billing records.
• Details about your usage of any other products we supply to you, such as our apps.
• We don't look at the content of your messages or listen to your calls (unless you are talking to one of our customer service advisors)
We may process certain types of sensitive information about you for the provision of the Panic Button service that falls under the definition of "special categories of personal data". This includes data concerning physical and mental health.
We may obtain this information in various ways, these being;
• You may directly provide us with sensitive information for the provision of this service.
• Other authorised account contacts may provide us with sensitive information for the provision of the service.
We want to reassure you we never sell personal information to third parties. We will only use your information in ways we are allowed to by law, which includes only collecting as much information as we need.
We process your information for managing the service you or your representative has requested.
We disclose your information to other people or organizations such as essential services so that they can contact you when the alarm is triggered.
We collect and process information about you only where we have a legal basis for doing so under law. This means we collect and use your information on where;
• We need it to provide you with the Panic Button Service and to provide you with customer support.
• It satisfies a legitimate interest (which is not overridden by your data protection interests)
• We need to process your data to comply with a legal obligation.
• We may need to also process your data under a vital interest obligation in cases of emergency when an alarm is triggered.
For no longer than necessary, taking into account any legal obligations we have (such as to maintain records for fiscal or reporting purposes) and, any other legal basis we have for holding customers information (e.g. performance of a contract).
There are certain reasons we have to keep hold of your information.
We keep information while you are our customer or after you've left us, but only as long as we need it for the purposes described above. How long we keep it depends very much on the type of information and purpose. 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 for the purpose that it was obtained.
We feel very strongly about protecting and safeguarding our customers’ personal data. We adhere to industry best practice technical security measures to protect personal data and ensure no unauthorised or unlawful disclosure; accidental or unlawful damage or loss takes place. Only certain authorised employees at Gibtelecom have access to personal data. Gibtelecom protects its IT systems with firewalls and anti-virus and anti-malware software and other information security technology solutions.
You have a number of legal rights in relation to the data that we hold about you, including the right to:
• access the data we have about you. Please contact our DPO for further information.
• ask that we update your data if it is inaccurate or incomplete.
• ask that we delete or erase your information in certain circumstances. Please note that there may be circumstances where you ask us to delete or erase your information, but we are legally entitled to retain it.
• request that we restrict the processing of your information in certain circumstances. Again, there may be circumstances where you ask us to restrict the processing of your information, but we are legally entitled to refuse that request.
• receive and transmit that data in a portable format. Please note that this right only applies to the information which you have provided to us.
• withdraw your consent to the use of your information where we are relying on that consent. Please note that we may still be entitled to process your information if we have another legitimate reason (other than consent) for doing so.
• make a complaint with the Gibraltar Regulatory Authority (www.gra.gi) if you think that any of your rights have been infringed by us.
You can exercise your rights by contacting us using the details set out in the section below.
It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.
Should you require any further information please contact our Data Protection Officer Rachel Holgado via email at Rachel.firstname.lastname@example.org.
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