We are Lightning Fibre Ltd of 7 – 9 The Avenue, Eastbourne, East Sussex, United Kingdom, BN21 3YA. Where we refer to ‘we’, ‘us’ or ‘our’, this means Lightning Fibre and our group companies. Lightning Fibre Ltd is regulated by the Information Commissioner’s Office as a data controller and by Ofcom as a provider of Electronic Communications Services. We are a member of the Internet Service Providers Association. Lightning Fibre is committed to protecting and respecting your privacy.
You are an individual about whom we hold information for one of the following reasons:
- You are a customer or prospective customer of Lightning Fibre or one of our group companies who enters into a contract with us for our broadband services;
- You have a contract or are discussing arrangements with us for access to your property to install our network;
- You visit Lightning Fibre.co.uk (our “site”);
- You have communicated with us at an event, by phone, email or other means.
This policy sets out how we use any information we collect from you, or that you provide to us. This may be personal data such as your name, phone number and email address or other information, such as the personal details of representatives associated with your business if you are a business customer.
Please read this policy carefully to understand what data we collect and how we will treat it. By visiting our site and/or buying services from us, you are accepting and consenting to the practices described in this policy.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
- Information you give us. You may give us information about you by filling in forms on our site or in person or by corresponding with us by phone, email or otherwise. This includes information you provide when you purchase any of our services, participate in social media functions on our site, enter a competition, promotion or survey, register to attend any events hosted by us and when you report a problem. It also includes information you provide when you engage with us to discuss access to your property or when you report a problem with our communications equipment or the network build crews who are installing our network.
- Type of information. The information you give us may include your name, any relevant business name, address, email address and phone numbers, financial information, health information and information about special requirements for vulnerable customers.
- Information we collect about you. When you visit our site, we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) you access, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.
- Information we receive from other sources. We may obtain information about you from the following sources:
- public sources such as the Land Registry
- if you use any of the other websites we operate or the other services we provide – in this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site.
- third parties we work with, including, for example, business partners, sub-contractors, suppliers, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies
- Communications data. We may collect and retain certain types of communications data for any of the following purposes:
- Traffic management;
- Customer and prospect enquiries;
- Anti-fraud measures.
We do not monitor what you do on the internet, ie. what web sites you visit or the content of your emails or messages sent via other messaging services. The only exception to this is where we are required to provide certain information in order to enable us to comply with any requirements imposed on us by law or court order.
Information collected by third parties
Our site may, from time to time, contain links to and from the websites of our partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal or confidential data to these websites.
OUR USE OF YOUR INFORMATION
This section explains how we will use your information and the legal basis we rely on to allow us to do that. We use information held about you in the following ways:
Information you give to us. We will use this information:
to carry out our obligations and to enforce our rights arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- with your consent, to provide you with information about other services we offer, upgrades, special offers and other promotions;
- to notify you about changes to our service;
- to notify you about network maintenance, planned and unplanned outages;
- to notify you about network maintenance and to request access to your property for essential maintenance and repair;
- to monitor the performance of our civils contractors;
- to ensure that content from our site is presented in the most effective manner for you and for your computer or device; and
- to comply with any legal obligations we have because we run a business and because we are an Internet Service Provider and an Electronic Communications Provider.
We rely on the fact that we have a contract to deliver our service to you to process your data and for additional marketing information, we rely on your consent. We also rely, where relevant, on our various legal obligations.
Information our prospective customers give to us. When you ask us to keep in touch with you, we will use this information:
- to provide you with information about goods or services we feel may interest you.
- With your specific consent, to permit selected third parties to provide you with information about goods and services; and
- to ensure that content from our site is presented in the most effective manner for you and for your computer or device; and
We rely on your consent to keep in touch with you. You can manage your communications preferences at any time by contacting us or clicking on the ‘manage preferences’ link in our emails.
Information we collect about you. We may combine this information with information you give to us. We will use this information:
- to allow us to deliver our services to you (including any associated functionality such as parental controls on Internet access, maintenance, assistance or troubleshooting) and to allow us to understand and manage traffic flows on our network;
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and the device through which you are viewing the site;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site and our services safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
The legal basis of our use of your information. When using your information, we do so primarily to fulfil our contractual and legal obligations. Where we require your consent, we will use your information in accordance with that consent.
We also use your information to enable us to run our business and to ensure the quality of our work. It is in our legitimate business interests to do this where this does not materially impact on your freedoms or rights. This would include using your information to assist the good governance of our business, including the management, accounting and auditing of our business and for example, to monitor the service provided to us by third parties or when analysing traffic flows on our network to ensure all our customers have optimal service.
If you communicate with us about our network build we will use your contact information to communicate with you and where necessary to ensure that our contractors communicate with you to investigate a complaint or rectify an issue. We will use your information to inform our quality control and management of our business and as part of our duties to promote health and safety at work.
SHARING YOUR INFORMATION
We may share your information with any member of our group, which means our subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We will not share your information for marketing purposes with companies outside our group unless we have specifically asked for your consent to do this.
We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with you. This includes our installation partners who will connect you to our broadband service and operatives who may enter your property to install or repair our network. Third party suppliers will only be given access to your information for the purpose and the duration necessary and will be required to comply with our requirements with regard to confidentiality and security of your information.
- Our professional advisers, to enable them to provide legal, accountancy and insurance services to our business;
- Analytics and search engine providers that assist us in the improvement and optimisation of our site;
- Credit reference agencies for assessing your credit score where this is a condition of us entering into a contract with you.
We may disclose your information to third parties:
- If we sell or buy any business or assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets.
- If Lightning Fibre or substantially all of its assets are acquired by a third party, in which case the information we hold about our customers will be one of the transferred assets.
- If we are under a duty to disclose or share information to comply with any legal obligation, or to enforce or apply our standard terms and other agreements; or to protect the rights, property, or safety of Lightning Fibre, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- To comply with any legal obligations we have as an Internet Service Provider and an Electronic Communications Provider.
STORING YOUR INFORMATION
All information you provide to us is stored on our secure servers. Any payment transactions will be made using authorised 3rd party payment gateways using appropriate encryption. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
The data that we collect from you is primarily stored and managed in the UK, but some of our systems and other suppliers may transfer, and store your information outside the European Economic Area (“EEA”). We will take all steps reasonably necessary to ensure that your data is treated securely and to the same standards as if it were being processed inside the EEA in a way that is compliant with the legislation governing data protection.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
RETENTION OF YOUR INFORMATION
We will only keep your data for as long as is necessary depending on the purpose for which we collected it. At the end of that period, we will either delete the information completely or anonymise it for statistical analysis and business planning.
If you have a Network Access Agreement with us, we need to keep details of our agreement for as long as the equipment remains installed in your property. We also keep contact details for you in case we need to access your property for repairs or maintenance. We ask that you help us to keep that information accurate and up to date and if you sell your property, we request that you inform the new owner of our agreement (as it will apply to them) and ask them to get in touch with us.
You have the following rights in relation to your information that we collect and process:
- Access – you have the right ask us what information we hold, free of charge, in most cases
- Correction – you have the right to ask us to correct inaccurate information
- Erasure – you have the right to ask us to erase the information we hold about you. This is sometimes called the right to be forgotten. However, there are some circumstances where this right does not apply, or where we are not required to comply with your request.
- Restrict – as an alternative to erasure, you may ask us to restrict certain processing
- Object – you can object to certain aspects of our processing of your information. This might include withdrawing your consent where we rely on that to process information. It may also be relevant if we are processing your information for our business interests and you feel that this should not override your fundamental rights and freedoms
- Transfer data – this is sometimes known as ‘data portability’ and enables you to have a copy of your data given to you or transferred securely to another data controller
For more information or to exercise any of these rights please contact us at the address below.