At Wavecrest looking after the personal data you share with us is important to us. We want you to be confident that your data is safe and secure with us and understand how we use it to offer you a better and more personalised experience.

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We are committed to doing the right thing when it comes to how we collect, use and protect your personal data. That’s why we’ve developed this privacy policy (“Policy”), which:

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• Sets out the types of personal data that we collect

• Explains how and why we collect and use your personal data

• Details when and why we will share personal data within Wavecrest and with third parties; and

• Explains the rights and choices you have when it comes to your personal data

Wavecrest Networks Limited and Wavecrest Communications France SAS act as joint Data Controllers (collectively referred to as "we" or "us” in this Policy).

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We offer different products and services, so we want you to be clear about what the Policy covers. If you use our website (“our Website”) or our wholesale telecommunications network (the "Network") (collectively known as “our Services"), then this Policy applies to you. 

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This Policy also applies if you contact us or interact with us with regard to our Services.

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Our website may contain links to other websites operated by third parties that have their own privacy policies. Please make sure you read their terms and conditions and privacy policy carefully before you submit any personal data to a third-party website as we do not accept any responsibility or liability for these third party websites.

When you register for our Services, you may provide us with your personal details, for example your email addresses and phone numbers.

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How and why we use personal data

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We use personal data to:​ 

• Make our Services available to you and contact you regarding a website enquiry you may have submitted

• Contact and interact with you

• Investigate any complaints or questions you may raise and contact you in relation to our Services, for example by phone, email, online or post or responding to social media posts that you have directed at us - it is in our interest to provide any clarification or assistance in response to your communications to serve you better as a customer

Before we provide you with certain of our account based or pre-pay products, where you pay by debit or credit card we may undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you. We may undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.

 

The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity.

 

Details of the personal information that will be processed, for example: name, address, date of birth, contact details, financial information, employment details, device identifiers including IP address.

 

We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

 

We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services you have requested.

 

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

As part of the processing of your personal data, decisions may be made by automated means. 

 

This means we may automatically decide that you pose a fraud or money laundering risk or if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct; or is inconsistent with your previous submissions; or you appear to have deliberately hidden your true identity. 

 

You have rights in relation to automated decision making: if you want to know more please contact us using the details provided.

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services you have requested, or we may stop providing existing services to you.

 

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details provided.

Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area (EEA), they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the EEA. 

 

They may also require the recipient to subscribe to 'international frameworks' intended to enable secure data sharing.

Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data; request that your personal data is erased or corrected; request access to your personal data.

 

For more information or to exercise your data protection rights, please contact us using the contact details provided.

You also have a right to complain to the Information Commissioner's Office (ICO) which regulates the processing of personal data.

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Sharing Personal Data within Wavecrest

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We may share the personal data we collect within Wavecrest. For example, we share personal data with the following companies:

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Seapeak Telecoms Limited

Wavecrest Networks Limited

Wavcrest Communications France SAS

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Sharing personal data to third parties

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We may share your personal data with our service providers. When we share personal data with these companies we require them to keep it safe, and they must not use your personal data for their own marketing purposes.

Service Providers

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We work with carefully selected service providers that perform certain functions on our behalf. These include, for example, companies that help us with customer care services, network and technology services, storing and combining data, credit checks and payment processing.

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We only share personal data that enables our service providers to provide their services.

We may share personal data with other organisations in the following circumstances:

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• where we are required to do so by law or by public authorities

• credit reference agencies: We will share details of your credit agreement with us, the payments you make under it and any default or failure to keep to its terms. The credit reference agency will record details of our search of their database, whether or not your application proceeds

• fraud prevention agencies: If when placing an order with us false or inaccurate information is provided by you and fraud is identified or suspected, your details may be passed to fraud prevention agencies. Law enforcement agencies may access and use this information

• in order to establish, exercise or defend our legal rights (including providing data to others for the purposes of fraud prevention and reducing credit risk)

• to whom we sell or transfer (or enter into negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you. If the transfer or sale goes ahead, the transferee or purchaser may use your personal information in the same way as us

• to any other successors in title to our business

We know how important it is to protect and manage your personal data. We use computer safeguards such as firewalls and data encryption, and we enforce physical access controls to our buildings and files to keep this data safe. 

 

We only authorise access to those employees who require it to fulfil their job responsibilities. When you provide data to us through our websites or mobile apps, that data is protected by secure socket layer (SSL) encryption.

 

The personal data that we collect from you may be transferred to, and stored at, a destination outside the EEA. It may also be processed by companies operating outside the EEA who work for us or for one of our service providers. 

 

We will put in place appropriate safeguards to ensure that your personal data remains adequately protected and is treated in accordance with this Policy.

We will not keep your personal data longer than we need to depending on several factors, including:

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• Why we collected it in the first place

• How old it is

• Whether there is a legal/regulatory reason for us to keep it

• Whether we need it to protect you or us

We may send you relevant offers or marketing information about our products and services in a number of ways including push notification, email, post or SMS. 

 

If you don't want to receive offers or marketing information, you can opt out at any time.

We also like to hear your views to help us to improve our Services and we may contact you for market research purposes. 

 

You always have the choice about whether to participate in our market research.

You have a right to see the personal data we hold about you. This is called a Subject Access Request.

 

If you would like to obtain a copy of the personal data we hold about you, please contact us through the normal customer service channels for your product(s). You can also email us at: subjectaccess.request@wavecrest.eu

 

In certain circumstances, we may charge a fee before providing the information.

In relation to your personal data, you also have the right to:

 

In some circumstances, receive some of your information in a useable format and/or request we transmit that data to a third party where this is technically feasible. Please note that this right only applies to information which you have provided to us.

 

Ask that we update your information if it is inaccurate or incomplete.

 

Ask that we erase your information in certain circumstances. Please note that there may be circumstances where you ask us to restrict the processing of your information, but we are legally entitled to refuse the request.

 

The right to make a complaint with the Information Commissioner www.ico.org.uk if you think that any of your rights have been infringed.

 

The ICO website www.ico.org.uk contains more detail on the data protection rights mentioned above. Or if you would like to speak to us about these rights in more detail, complete the form on our Contact Us page, accessed on the top right hand side of our website.