Privacy Policy

BACKGROUND:

Trinity Maxwell Ltd. understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all our clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Information About Us

Trinity Maxwell.

A limited company registered in England under company number 07391869.

Registered address: Unicorn House, 221-222 Shoreditch High Street, London. E1 6PJ.

Data Protection Officer:

Email address: DPO@trinitymaxwell.com.

Postal Address: Unicorn House, 221-222 Shoreditch High Street, London. E1 6PJ.

We are registered with the ICO under reference Z2538955.

What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

  • The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
  • The right to access the personal data we hold about you. Part 10 will tell you how to do this.
  • The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
  • The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
  • The right to restrict (i.e. prevent) the processing of your personal data.
  • The right to object to us using your personal data for a particular purpose or purposes.
  • The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  • Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

What Personal Data Do You Collect?

We may collect some or all of the following personal data (this may vary according to your relationship with us and the products and services that are contracted:

Type of personal information Description
Personal Name, date of birth, gender, address, business name, job title
Banking Your bank account details for billing
Transactional Details about payments to and from your accounts with us
Financial Your financial position, status and history
Contact Where your place of work is and how to contact you including telephone numbers and e-mail addresses
Contractual Details about the products or services we provide to you
Usage Data Other data about how you the products and services we provide you, in order to provide accurate billing and reporting
Open Data and Public Records Details about you that are in public records, such as information held in Companies House, and information about you that is openly available on the internet
Technical Details on the devices and technology you use.
Communication What we learn about you from any communication with us by way of e-mail or telephone conversations

 

Your personal data is obtained from the following sources:

  • Third Party Suppliers;
    • We use a single, reputable data supplier for marketing data, that is cross referenced against CTPS. https://cognism.com/
    • Credit reference agencies
    • Companies and people that know you and pass us your details
  • We also obtain data from the public domain, for example, Companies House and any other information that is publicly available on the internet.

How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:

  • Providing and managing your account.
  • Supplying our products and services to you. Your personal details are required for us to enter into a contract with you.
  • Personalising and tailoring our products and services for you and managing customer proposals and tenders.
  • Communicating with you. This may include responding to emails or calls from you.
  • Supplying you with information by email (you may unsubscribe or opt-out at any time by clicking “unsubscribe” or “opt out”, or by e-mailing clientsupport@trinitymaxwell.com.
  • Prospecting for new customers for our legitimate interests.
  • Credit checks and protecting against bad debt.
  • Fault reporting.
  • Device management and repairs.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and telephone with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary considering the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods:

  • We may process personal data for up to 5-years if you are a prospective customer and for the length of your contract if you become an active customer. This is in keeping with our legitimate interests and contractual obligations.
  • We may store personal data for up to 5-years in order to respond to any questions or complaints.
  • We may store personal data for up to 5-years in order to maintain records to comply with our legal and contractual obligations.
  • We may store personal data In keeping with our legitimate interests.

How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.

In the case of our suppliers and business partners, some of the data that we collect from you may be transferred to and stored at a destination outside the European Economic Area (“EEA”).  It will also be processed by staff operating outside the EEA who are owned by and solely work for one of our suppliers or business partners. This includes staff engaged in, among other things, the fulfilment of your order, processing of call detail records, the processing of your payment details and the provision of support services.  We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and the General Data Protection Regulation (GDPR), and that the necessary legal contract in place to fulfil these services.

Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, unless it is required for the operation of your contract with us for products and services.

Those third parties will include

  • Network service providers and operators who provide the service agreed in your contract.
  • Service providers who deliver billing information as part of your contract.
  • Other service providers if products or services are purchased through us, for example, phone insurance or hardware leasing.
  • Debt collection agencies or other debt recovery organisations
  • If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets as part of the process to ensure continuity of service

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 14-days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: DPO@trinitymaxwell.com.

Postal Address: The Data Protection Officer, Trinity Maxwell Ltd. Unicorn House, 221-222 Shoreditch High Street, London. E1 6PJ.

Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available at www.trinitymaxwell.com