Kooljett Privacy Policy

This is the Kooljett Privacy policy effective Jan 1 2022.

OVERVIEW

Kooljett Limited — otherwise referred to simply as Kooljett — is committed to protecting your right to privacy in compliance with UK laws.

For the purposes of this privacy policy, Kooljett is the data controller. For some contracts we may be the data processor which will be made clear in the contract. We are registered with the Information Commissioner’s Office under the registration number ZB313242.

This privacy policy relates only to personal data for which we are responsible under UK law.

We review this policy regularly to remain in compliance with UK and other applicable laws. The latest version will always be available here.

THE DATA WE COLLECT AND HOW WE USE IT

The personal data we process depends on how you interact with Kooljett, and your relationship with us. You are not required to provide any data to us to use this website but you will need to provide personal data to make use of our contracted services.

Kooljett Customers

To provide you with services; we need to use your personal data. This applies whenever you have an account with Kooljett. We use data the follwoing ways:

• Use your contact details and other information to confirm your identity. This includes details such as your name, address, telephone number, eMail address, passwords and other security credentials, payment and financial information. For your security, we do not retain credit card details;

• Retain any correspondence with us including eMail and telephone calls;

• Retain personal data (such as your eMail address) to enable you to access the Kooljett Portal and Kooljett Support Centre;

• Contact you for legitimate purposes relating to your account such as Invoices, Service Announcements, and Alerts that you have requested to receive;

• Provide your information to partners or other communication providers where necessary to provide services to you.

We use this information to perform our obligations under contract to provide services to you.

To market relevant products to you; we will use your personal data to send you marketing that may be of interest to you. We will do this if you have consented only, and you have the right to withdraw this consent at any time. We use data the following ways:

• Use your contact details – including your name, address, phone number, and eMail address – to effectively communicate with you. We may also use information from publicly available sources such as business directories.

• Use information about how you use our services to tailor the communications we send to you based on information held; and recommend other products or services that may be appropriate to you

• In each marketing message we send, we provide the means to opt-out from that type of message, or all further communication for marketing purposes. You may also do this at any time by contacting us.

• To prevent fraud. We will use personal data for the legitimate interest of detection and prevention of fraud.

• We will:

• Retain any information submitted in an account application including your name, address, telephone number, eMail address, IP address etc, even where that application for an account is unsuccessful;

• Where appropriate, disclose information identified as fraudulent to fraud prevention, law enforcement agencies, and other industry bodies.

• To recover debt. If you do not pay your invoices on time, we may instruct our solicitors or debt recovery agencies to recover what is owed. We will provide them with your personal data necessary to effect this. This processing is for the legitimate interest of running our business.

End Users of Kooljett Services

Kooljett is a provider of telecommunications services, and our customers are communications users providing services to others. To provide our services, we may need to process personal data relating to our customer’s end users or if you are an end user.

Because we have a legitimate interest; we process personal data if it is in our legitimate interests to do so which includes:

• Retain Call Data Records (CDRs) detailing calls made by or to an end user, including telephone numbers, which may be considered personal data. More information on CDRs is available below;

• Use End User information for the purposes of detection and prevention of fraud and to protect our network.

• Create aggregated and anonymised information for analysing the use made of our services and networks to inform business decisions and strategy.

• To comply with regulatory obligations.

Other Personal Data

As a communications provider, we may process personal data about those who are neither a customer nor end user of Kooljett services.

Because we have a legitimate interest; We process personal data if it is in our legitimate interests to do so. We will;

• Create aggregated and anonymised information to analyse the use made of our services and networks to inform business decisions and strategy;

• Monitor traffic on our network and trace nuisance or malicious calls; and

• Monitor our systems and services to detect and prevent unauthorised usage.

• For prevention and detection of crime, there is a legitimate interest to protect our business, network, and infrastructure from attacks and prevention of crime and fraud. We also share information with other organisations (such as other Communications Providers and industry bodies) to effect this.

CALL RECORDS (CDRS) & RECORDINGS

We process telephone call data records (“CDRs”). These are the records of communications to and from our customers’ end users on which billing depends.

CDRs contain the following information about each phone call:

• The calling party’s telephone number(s);

• The dialled telephone number;

• Any telephone number(s) involved in diverting the call;

• The date and time of the call;

• The duration of the call;

• The carrier that the call originated from

• CDRs are not call recordings, and convey no information about the nature of the call beyond the number of the called and calling parties.

We will only record telephone calls when agreed contractually with Kooljett as a data processor and the customer being the data controller. In this case the obligation for applying UK privacy is shared but any end user privacy queries need to be addressed with the relevant data controller. Kooljett can only accept instructions regarding data from the data controller but they would mirror the privacy obligations laid out here.

RECIPIENTS OF PERSONAL DATA

We share your personal information with other service providers to help provide our services, including to:

• Process payments, such as credit cards and Direct Debits;

• Provide customer services, such as support ticket tracking;

• Provide marketing services, such as our newsletter or other direct marketing;

• Keep you informed regarding issues or planned maintenance on our network;

• We may disclose customer, end user, or any other personal data, to third parties as may be required to comply with our legal obligations, or for the purposes of fraud prevention, and the prevention and detection of crime.

TRANSFERS OUTSIDE THE EEA

Kooljett does not normally transfer data outside the EEA. We take all reasonable steps to ensure that your personal information is only used in accordance with this privacy policy and applicable UK & EU data protection laws and is respected and kept secure. In rare operating circumstances, we may need to transfer data to the USA to ensure continuous service delivery. In this case all data privacy activities will be in accordance with regulations in force between the UK and USA.

DATA RETENTION

We will keep your data for no longer than is necessary for the purposes for which the data are processed. Specifically:

• Customer contact details for a period of six years after your account is closed.

• Details relating to any dispute for a period of six years after it is closed.

• CDRs in their full form for a period of six months, except where these are the subject of, or likely to become subject of, a dispute or as otherwise required.

• CDRs in anonymised form for a period of up to six years.

• Copies of correspondence as long as you are a customer, and then six years thereafter.

• Copies of your Invoices for as long as you are a customer, and then six years thereafter.

• In other cases we’ll store personal data only for the period required, or longer if required by law. Otherwise personal data will be deleted or anonymised.

COOKIES AND OTHER INFORMATION GATHERING TECHNOLOGIES

Please read this Kooljett cookie policy (“cookie policy”, "policy") carefully before using the website.

What are cookies?

Cookies are simple text files that are stored on your computer or mobile device by a website’s server. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier, website’s domain name, and some digits and numbers.

What types of cookies do we use?

• Necessary cookies: Necessary cookies allow us to offer you the best possible experience when accessing and navigating through our website and using its features. For example, these cookies let us recognize that you have created an account and have logged into that account.

• Functionality cookies: Functionality cookies let us operate the site in accordance with the choices you make. For example, we will recognize your username and remember how you customized the site during future visits.

• Analytical cookies These cookies enable us and third-party services to collect aggregated data for statistical purposes on how our visitors use the website. These cookies do not contain personal information such as names and email addresses and are used to help us improve your user experience of the website.

YOUR RIGHTS

You have the following rights in relation to your personal information:

• the right to be informed about how your personal information is being used;

• the right to access the personal information we hold about you;

• the right to opt-out of receiving direct marketing messages;

• the right to request the correction of inaccurate personal information we hold about you;

• the right to request the blocking or deletion of your personal information in some circumstances and;

• the right to request that we port elements of your data either to you or another service provider.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us. If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator.

CONSENT

We process some personal data on the basis of consent. We obtain this consent by opt-in means only at the time of creating your account, subscribing to one or more of our mailing lists, or by specific request. You may withdraw this consent at any time.

CONTACTING US

In the event of any privacy-related query, or to exercise your rights, please send an e-mail to admin@kooljett.com.