Privacy Notice For The Sure Group Of Companies

Sure is committed to protecting your privacy.  We take our responsibility to safeguard and secure your personal information very seriously.  This Privacy Notice, together with our website terms of business and any other documents referred to in it, and this Privacy Notice has been created to explain how we use your data, why we use it and who we share it with in relation to our services, as well as what rights you have under relevant Data Protection legislation.

Sure comprises a group of companies which operates in a number of jurisdictions worldwide. More information on the subsidiaries within the Sure group of companies can be found here.

For the purposes of this Privacy Notice, the following are the Sure data controllers in the Channel Islands and Isle of Man:

This Privacy Notice is issued on behalf of the members of the Sure Group in the Channel Islands and Isle of Man so when we mention Sure, "we", "us" or "our" in this Privacy Notice, we are referring to the relevant company in the Sure Group responsible for processing your personal information.

Data Protection Officer

Sure has appointed a designated Data Protection Officer to have oversight of data protection.  Their contact details are as follows:

Address:              

The Data Protection Officer

Sure 

The Powerhouse

Queens Road

St Helier

Jersey

JE2 3AP

Email: dataprotection@sure.com

Types of Personal Data we Process

• Account Information: contact details including name, gender, date of birth, installation address, land line and mobile phone numbers and email addresses, proof of identity (including a copy of your passport/passport number and address taken from a utility bill) and billing address, passwords and usernames.
• Information about the services you contract for with Sure;
• Traffic data: i.e. details of your use of our services (for example, where you contract for telephony services we may record the date that calls were placed by you as well as the duration of each call).
• Billing information such as number of calls, duration, category of call, numbers of SMS, roaming usage and other service information used to calculate your bill.
• Financial information such as bank account details and credit and debit card information for receipt of payments, copies of credit checks. Card information is not stored by Sure.,
• When you visit our registered office in each relevant jurisdiction, our retail shops, or other Sure sites, we may collect details of the visitors who attended, the time and date of the meeting and their image via CCTV footage as well as production of photographic visitor passes.
• Recordings of phone calls to our Customer Service Centre and Service Operations Centre as well as other communications such as email and electronic messaging which may be used for staff training and audit purposes as well as resolution of complaints and queries.
• Information regarding the employees, contractors and agents of our Enterprise customers, their roles and contact details, as well as other information on data subjects where we act as a processor for these Enterprise clients.
• Marketing and Communications Data: including your preferences in receiving marketing from us and your communication preferences, as well as your responses to our surveys.
• Refer a Friend – details of introducers and those introduced to Sure for the purpose of administering the rewards scheme.
• Directory Information Data: including for inclusion in printed and online telephone directories where relevant.
• Generic location data related to mobile services such as mobile sites with which phone has connected, countries visited when roaming.
• Passwords and credentials to access My Sure account online, MySure App, or any other online service operated by, or for Sure, as well as other data collected from our websites, which may be considered personally identifiable information in some cases, such as IP addresses and MAC addresses.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

Purpose and Legal Basis for Processing

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. 

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to providing some Directory Information Services for mobile customers and for marketing to new customers.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  If we need to use your personal data for an incompatible purpose, we will notify you and we will explain the legal basis which allows us to do so or gain your consent if required to do so by law.  Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Sources and Recipients of Personal Data

Sure may disclose your personal data to other Sure group companies, within the Channel Islands and Isle of Man, and carefully selected business partners and third party suppliers to whom we engage to provide services set out in this Privacy Notice, including Directory Services. However, other than as set out in this Privacy Policy, Sure will not disclose or share your personal data with any third party without your express consent unless this is necessary to provide the service or products you requested, to undertake the legitimate interest of Sure, or as required by law.

Transfers of Personal Data to Third Countries

As Sure is part of an international group of companies operating globally we may store your personal data in your home country and/or we may transfer your personal data to other Sure group companies and carefully selected business partners and third party suppliers in other countries around the world where it has your consent or where it is necessary to do so in order to conclude or perform a contract on your behalf.  In all cases we will ensure the security of the transfer of your data.

These may include:

• Suppliers who support our services to you such as billing and directory services.
• Suppliers who support the security of our telecommunications infrastructure and services we provide to you
• Our parent company.
• Audit firms and certification bodies working for ourselves and / or our parent company.
• Debt collection services,
• Third parties to whom you have authorised your data to be disclosed.

In the event that a third party is outside the European Union and where the data being transferred include personal data we will ensure that the relevant requirements of applicable data protection laws are met.

Period Data Will be Stored

Sure Group only keeps data for as long as necessary to fulfil the purpose it was collected including for the purposes of satisfying any legal, accounting, or reporting requirements. In most cases no personal data will be held on an individual who is no longer a Sure customer after 10 years. There may be limited exceptions where some information is required to be kept longer such as if there was an ongoing legal dispute or we were required to hold your data longer by law.

Any requests for further information in relation to the continued processing of specific data, or requests for destruction of data should be made to the Sure Data Protection Officer. 

Rights of Data Subjects

Data subjects in the European Union or jurisdictions with equivalent data protection laws (to The European Data Protection Regulation) have certain rights in respect to their personal data. These rights include:

• to withdraw consent to processing previously given as appropriate,
• to access to your data (please see the heading 'Subject Access Requests' below),
• to have your data corrected, or updated, 
• to have your data deleted in certain circumstances,
• to restrict, in certain circumstances, processing for a specified period of time,
• to have your data provided to a third party (also known as data portability) in certain circumstances,
• to object, in certain circumstances, to certain types of processing e.g. direct marketing (please see the heading 'Opting Out' below),
• to make a complaint to a Supervising Authority,

Any request to relating to the above rights should be addressed in the first instance to the Sure Data Protection Officer at dataprotection@sure.com

Please note that by exercising some of the above detailed rights, Sure may, in certain circumstances, be unable to provide you some or all of the services you have requested from Sure. We will inform you of this at the time you seek to exercise the right.

Subject Access Requests

Under relevant data protection laws, you have the right to access your personal data held by Sure. This is known as a Subject Access Request (SAR). The process you should follow to do this is set out below.

You can make a SAR to receive your own personal data. Or a third party can make a SAR for you, with proof they have your permission.

If you’re a Sure customer you may be able to access your bills online, or you can request copies through our customer service team.

Only information considered to be your personal data will be released under a SAR. We won't be able to provide information that may also relate to other data subjects such as:

• Content of any communications including text messages, calls or voicemail;
• Information about your incoming and/or outgoing calls or texts (unless provided in your standard bill);
• Any data held on your phone e.g. photos, contacts which we would not normally hold. 

We may need to request specific information from you to help us confirm your identity, and/or the identity of any person acting on your behalf, and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances

Complaints

If you wish to raise a complaint in regard to our processing of your data you may do so by writing to our Data Protection Officer at the address above, or emailing dataprotection@sure.com. You may also complain directly to the relevant data protection regulator.  Contact details and instructions for making a complaint and other useful information may be found on their websites as set out below:

Guernsey: www.odpa.gg

Isle of Man: www.inforights.com

Jersey: www.jerseyoic.org

Version 11.0    December 2022