Last updated: 03/02/2020
Adept CTS Limited (ADEPTCTS) is committed to ensuring that your privacy is protected and will treat all information held about you in accordance with this policy, which is in line with current UK legislation. For these purposes, ADEPTCTS is a ‘data controller’ meaning that we decide how and why the personal data that we collect is used.
· How we collect personal information.
· How we use the information which we collect.
· Your rights and how you can manage the use of your personal information.
· How you can contact us or make a complaint.
- The Information We Collect
We only gather the personal information we need for business purposes in order to provide you with the services you have requested or to comply with our regulatory obligations. The personal information we typically collect includes:
· Your name and email address.
· Contact telephone numbers for you.
· Trading address
· Those of your employees.
- How We Use It
For the Provision of our Services
We use the information we gather to provide you with the services you have requested. Depending on which service you receive we may need to share your personal information with our subcontractors who are involved in the provision of our services. We need to process your personal information in this way to enter into and perform our obligations under the contract we have with you.
If our Business is sold
We will transfer your personal information to a third party:
· if we sell or buy any business or assets, we will provide your personal information to the seller or buyer (but only to the extent we need to, and always in accordance with data protection legislation); or
· if ADEPTCTS or the majority of its assets are acquired by somebody else, in which case the personal information held by ADEPTCTS will be transferred to the buyer.
We process your personal information for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your personal information in this way, the relevant seller or buyer of our business may not be able to provide services to you.
In some circumstances we may also need to share your personal information if we are under a duty to disclose or share it to comply with a legal obligation.
ADEPTCTS will only process your information if we have a business reason to do so. Generally, this occurs when you make a request of us, such as to adding to, changing, or removing information for your needs. Where we need to manage your account information we will do so in compliance with the obligations placed on us by law.
We do not sell or share your personal information to companies outside of ADEPTCTS, and we only share your personal information within ADEPTCTS as necessary.
We may, from time to time, contact you by post, e-mail or telephone to ask you for your feedback and comments on our services. If you no longer wish to receive these or other correspondences, please let us know. The simplest way to do this is to send an email message to firstname.lastname@example.org.
- How We Protect Your Information
The internet is not a secure medium, but we have put in place various security procedures to protect your data. We take the security and privacy of our customers’ personal information extremely seriously and we have strict internal procedures which cover the storage, access and disclosure of your information.
All information you provide to us is stored on secure servers.
- You and Your Information
You have certain rights in respect of the management of the personal data we hold about you. You can exercise any of these rights by contacting us. The easiest way to get in touch is likely to be by emailing us at email@example.com.
The Right of Access
You are entitled receive confirmation as to whether your personal information is being processed by us, as well as various other information relating to our use of your personal information.
You also have the right to access your personal information which we are handling.
The Right of Rectification
You have the right to require us to rectify any inaccurate personal information we hold about you. You also have the right to have incomplete personal information we hold about you completed, by providing a supplementary statement to us.
The Right to Data Portability
You have the right to receive the personal information we hold about you in a structured, standard machine readable format and to send this to another organisation controlling your personal information.
The Right of Erasure
You have the right to require us to erase your personal information which we are handling in the following circumstances:
we no longer need to use your personal information for the reasons we told you we collected it for;
where we needed your consent to use your personal information and you have withdrawn your consent.
You object to our use of your personal information and we have no compelling reason to carry on handling your personal information
Our handling of your personal information has broken the law
We must erase your personal information to comply with a law we are subject to.
- Your Right To Object
You have the right to object to us handling your personal information when we are handling your personal information based on our legitimate interests (as described in section 3 above). If you ask us to stop handling your personal information in this way, we will stop unless we can show you that we have compelling grounds as to why our use of your personal information should continue
- Data Retention
Where you have contracted with us for our services, we will retain your data as long as is required to comply with our regulatory and statutory obligations to ensure that we are able to assist you should you have any questions, feedback or issues in connection with any services we have provided to you.
Where we have processed your data for any other reason (such as where you have contacted us with an initial enquiry) we will retain your data for up to 12 months.
- Change To Policy
Cookies In Use on This Site
Cookies and how they Benefit You
Our cookies help us:
· Make our website work as you’d expect
· Improve the speed/security of the site
· Continuously improve our website for you
· Make our marketing more efficient (ultimately helping us to offer the service we do at the price we do)
· Collect any personally identifiable information (without your express permission)
· Collect any sensitive information (without your express permission)
· Pass data to advertising networks
· Pass personally identifiable data to third parties
· Pay sales commissions
You can learn more about all the cookies we use below
Website Function Cookies
Our own cookies
There is no way to prevent these cookies being set other than to not use our site.
Third party functions
Disabling these cookies will likely break the functions offered by these third parties
Anonymous Visitor Statistics Cookies
Turning Cookies Off
You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies (Learn how here). Doing so however will likely limit the functionality of our’s and a large proportion of the world’s websites as cookies are a standard part of most modern websites
It may be that you concerns around cookies relate to so called “spyware”. Rather than switching off cookies in your browser you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered to be invasive. Learn more about managing cookies with antispyware software.
The cookie information text on this site was derived from content provided by Attacat Internet Marketing https://www.attacat.co.uk/, a marketing agency based in Edinburgh. If you need similar information for your own website you can use their free cookie audit tool.
Telecoms and Broadband Specific Data Processing
AdeptCTS collects different kinds of information. Some of it is personally identifiable and some are non-identifying or aggregated. Here are the types of information we collect or receive:
· Account Information – This includes all the information under your account details. It includes names and full contact details for the individual or business that created the account. This is vital for accounting purposes and conforming to our regulatory provisions for providing accurate access to the emergency services.
· Call detail records (CDRs) – This is a record of the communication that has traversed the SIP provider network. It typically includes a source, destination and duration although it can also include quality metrics and fraud prevention data too. CDRs allow us to create an itemised bill for you which forms part of our accounting procedures.
· Payment Records – AdeptCTS retains a transaction history of purchases made for products and services. This is fundamental to our accounting processes.
· Radius Logs – AdeptCTS retains data on Broadband sessions such as the time the connection commenced and duration. AdeptCTS may also log metrics such as sync data and bandwidth used.
· Communicating with AdeptCTS – We operate systems which log details of calls, emails and web chat correspondence. This allows us to deal with our customers effectively.
· Call Recordings – Call recordings are disabled by default and are opt-in only.
Telecoms and Broadband Specific Data Retention
· Call Recordings – If activated are stored for 30 calendar days unless specified to be longer by you.
· Call Detail Records (CDRs) – Are stored for 12 calendar months and then deleted.
· Radius Data – Stored for 6 calendar months and then deleted.
· Account Data – If the authorised account holder chooses to deactivate the account. The data will be archived for no more than 15 years.
· Correspondence – This includes but is not limited to: emails, call-recordings, CDRs, webchats, Fax transmissions and post. The data may be kept for no more than 15 years.
· Payment Data – AdeptCTS does not process or retain card payment data. All sensitive transactional payment data is processed and stored in accordance with PCI-DSS regulations by payment providers such as Netbanx or PayPal. AdeptCTS does store Active Direct Debit details.
· LDAP Data – Customers are in control of LDAP (Hosted Address Directory) data which can be removed permanently via the web-portal.
Telecoms and Broadband Specific Sharing and Disclosure
There are times when communications and related content and other user information may be shared by AdeptCTS. With consent, to comply with legal process, or to protect AdeptCTS and our users. When we have your consent or if we believe that disclosure is reasonably necessary to comply with a law, regulation or legal request; to protect the safety, rights, or property of the public, any person, or AdeptCTS; or to detect, prevent, or otherwise address fraud, security or technical issues. If we receive a law enforcement or other third party request for information we will provide prior notice to the subject of the request where we are legally permitted to do so.
Examples of sharing and disclosure are below and but not strictly limited to the following:
Example: Telephone number subscriber information is shared between the companies involved in a telephone number port as validation. (Openreach/BT along with the RH, LCP and GCP)
Example: Fixed line services (Broadband and WLR) require installation addresses, therefore, disclose of this information is given to those involved in the provision and installation of these services.
Example: Fault finding such as UK PTSN based services sometimes require engineer visits in which case we would ask your permission to provide a contact telephone number and name. These can be from BT Group companies or subcontractors or LLU providers and their subcontractors.
Example: Direct Debit data is stored and processed with the BACSTEL interbank payment network.
Example: Some international telephone number rentals require the subscriber to provide official identity documents as a regulatory requirement in that country.