conduitglobal.co.uk or www.conduitglobal.com (the Website) is operated by Conduit Global, which is the trading name of 118 Limited (Company No: 3951948; Registered office: Fusion Point, Dumballs Road, Cardiff CF10 5BF) (Conduit Global or we, us or our). We are part of the kgb group of companies, which includes 118 118, The Number and 118 118 Money, all together the Group.
- If you wish to contact our Data Protection Office, please contact them via firstname.lastname@example.org. Other ways to get in touch with us are set out in the Contacting us section below.
Protecting your personal information:
Personal information about you is protected by law which includes the General Data Protection Regulation and the Data Protection Act 2018.
The law regulates how we may process personal information relating to you and grants you various rights in respect of your personal information.
- The aim of this Policy is to tell you how we will collect, use and retain any personal information you provide to us, or which is provided to us by our customers.
What the law says:
Under data protection law, we can only use your personal information if we have a lawful reason to do so. We must have one or more of the following lawful reasons:
We have your consent;
We are entering into or are performing a contract with you;
It is in our legitimate interests;
When we are under a legal duty.
When we rely on your consent, we will either gain your consent directly, or we will act on our customer’s behalf and rely on the consent that you provided to them. We will not collect or use any of your personal information that we receive from our customers without first confirming that our customers properly gained your consent.
When we rely on our legitimate interests we mean our:
- pursuit of our commercial activities and objectives, or those of a third party;
- compliance with applicable legal and regulatory obligations and any codes of conduct;
- improvement and development of our business operations and service offering, or those of a third party; or
- protection of our business, shareholders, employees and customers, or those of a third party.
What is personal information?
Personal information is information about you and other individuals. It is information which identifies you such as your name, address and email address. The personal information which we collect about you may include:
- personal information provided to our customers that we are asked to process on their behalf;
- personal information included in communications between us (including telephone calls and e-mails);
- contact information you provide to us via our website or otherwise,
- recordings of calls between us; and
- telephone numbers.
We also collect (automatically) some information about your device when you visit the Website. For example, we will collect session data, including your IP address, Web browser software, and referring website. We may also collect information about your online activity such as content viewed and pages visited. To the extent that this information constitutes personal information, its use by us will be covered by this Policy.
Who is responsible for the personal information we collect?
118 Limited, or any Group company processing your data on 118 Limited’s or a customer’s behalf, is the data controller for the purposes of the GDPR. This is because we dictate the purpose for which your personal information is used and any personal information you give us about other individuals.
How we collect and use your personal information:
- You do not have to give us any personal information in order to use our Website.
- In some circumstances we may need to collect your personal information for example, by law or to perform a contract with you. If you decide not to give us your personal information, we may not be able to fulfil our obligations.
- References to you in this Policy mean the person who is using our Website or whose information is provided to us by our customers included.
- We have set out our reasons for using your personal information in the table below under the heading Legal Basis. Where we rely on our legitimate interests, we have set out those interests in the table below.
- You have the right to object to our use of your personal information at any time. A summary of your right to object and details of who to contact if you want to exercise this right can be found at the Contacting us section below.
- For further information on your rights please see the Your Rights section below.
|To communicate with you and other individuals:
In emails, SMS and telephone calls (which we may record and/or monitor for quality checks and staff training);
Please note that these recordings may also be used to help us combat fraud, when registering for our products and services, in customer surveys, when you participate in competitions and promotions, through our Group company websites, resolve complaints, provide refunds and collect customer opt-in consent;
To tell you about other products or services we, other members of our Group or our partners can offer you which may be of interest to you; and
Administer offers, competitions, rewards and promotions.
Consent, performance of a contract we have with you and/or legitimate interests: we require your personal information in order for you to receive our products and services.
|To manage your relationship with us (including to keep a record of the products and services you order from us).||Performance of a contract we have with you and/or Legitimate interests: we require your personal information in order for you to receive our products and services.|
|To improve the quality of our service including:
||Legitimate interests: we require your personal information in order for you to receive our products and services.|
|To perform services as a subcontractor on behalf of our customers with whom we have a contractual relationship in place.||Consent.|
|To enable us to publish your reviews, ratings and other content to the Website.||Legitimate interests: we require your personal information in order for you to receive our products and services.|
|To comply with legal and regulatory obligations and to prevent potentially prohibited or illegal activities.
Administer, update, consolidate, improve and manage the accuracy of our records and our business including meeting legal, regulatory and compliance requirements and operating rules (such as anti-money laundering, regulatory reporting requirements and record maintenance); and
Monitor and analyse the use of the Website to detect, prevent, investigate, prosecute and/or report fraud, terrorism, misrepresentation, security incidents or crime.
|Necessary for compliance with a legal obligation to which we are subject.|
|To investigate and respond to any complaints, refund requests, feedback and queries and handle/resolve disputes.||Legitimate interests: to enable us to deal with any issues you may have in relation to our products and services.|
|If you download our mobile application(s) or use our Website, we may collect information about your use of them including, where available:
||Performance of a contract we have with you and our legitimate interests to enable you to receive our products and services in certain formats.|
- Your personal information will be held securely so that we and any other companies in our Group that you have dealings with, either now or in the future, can manage your relationship with us. This will include personal information you provide when you complete forms on our Website, and any additional personal information provided by you or others.
- Who do we share your personal information with?
- Our Group companies
- By sharing your personal information it enables us, and other companies within our Group, and our service providers and agents to better understand your needs. We will always treat your personal information as private and confidential.
Our other service providers and agents
We will share your personal information with:
- third parties who carry out hosting, maintenance, call centre operation, or provide other services in relation to the Website;
- our suppliers of telecommunication services;
- business process outsourcing providers;
- HM Revenue & Customs or other authorities;
- third parties where we are required to do so by law or by our regulatory bodies or if we require or are required by others to investigate or prevent crime (this may include foreign authorities to help them in their fight against crime and terrorism); and
- third parties who may be connected with you.
We will also share your personal information:
- with any person to whom we sell, merge or transfer (or enter into negotiations to sell, merge or transfer) our business or part or all of our business or assets or enter into a merger with it;
- to a potential buyer, transferee, or merger partner or seller and their advisers so long as they agree to keep it confidential and to use it only to consider the possible transaction;
- if the transaction goes ahead, the buyers, transferee or merger partner may use or disclose your personal information in the same way as set out in this Policy.
- We will always ensure your information remains safe and secure.
- Why we may process special categories/sensitive personal information about you:
- Some personal information under data protection law has special protection. This information is known as special categories of personal information but it may also be called sensitive personal information. This type of personal information includes information which relates to your racial or ethnic origin, political opinions, religious beliefs or philosophical beliefs, trade union membership, genetic or biometric data or data concerning your health, sex life or sexual orientation.
- If we collect this type of personal information, we will only do so to provide the product or service you require or help to manage your products and services.
- If we need to obtain special categories of personal information, we will ask for your explicit consent first.
- Where will we transfer your personal information?
- There will be times when we share your personal information within our Group and with our third party providers who are located in countries outside of the European Economic Area (EEA).
- Your personal information will be transferred to countries outside the EEA (such as the USA and the Philippines) that do not have a similar standard of data protection laws to the UK. When we transfer your personal information outside the EEA, we will take reasonable steps to ensure that your personal information is protected. To do this we use a set of standard data protection clauses which have been approved by the European Commission.
- The above approach is compliant with data protection law (being Article 46.2 of the GDPR). For further information about these transfers and the safeguards in place, please get in touch via the Contacting us section below.
Retention of your personal information
- How long we keep your information for depends on the basis for which it was provided.
- Generally, however, we will keep the information that is necessary to enable us to provide you with the relevant products or services you have requested for as long as it takes us to provide that product or service, or, in the event we receive your personal information from our customer in the performance of a contract, as otherwise requested by our customer.
- If you have asked that we do not use your details for marketing purposes, we may still need to keep them to ensure our systems reflect your preferences.
- We will keep records of any transactions you enter into on this Website for a minimum of 6 years from the end of our relationship with you. This is so that we can respond to any complaints or disputes that arise in that period.
- If you would like to know more about how long we hold your personal information please get in touch using the Contacting Us section below.
- You have certain rights with respect to your personal information. The rights will only apply in certain circumstances and are subject to certain exemptions.
- Please see the table below for a summary of your rights and who to contact to exercise them.
What this means
Who to contact
|Right of access to your personal information||You have the right to receive a copy of your personal information that we hold about you, subject to certain exemptions.||Write to us at:
The Data Protection Office 118 Limited, Fusion Point, Dumballs Road, Cardiff CF10 5BF
|Right to rectify your personal information||You have the right to ask us to correct your personal information that we hold where it is incorrect or email@example.com|
|Right to erasure of your personal information||You have the right to ask that your personal information be deleted in certain circumstances. For example:
|Right to restrict the use of your personal information||You have the right to suspend our use of your personal information in certain circumstances. For example:
|Right to data portability||You have the right to obtain your personal information in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible.
This right only applies:
|Right to object to the use of your personal information (including to object to direct marketing, automated profiling and decision making)||You have the right to object to the use of your personal information in certain circumstances. For example:
||Write to us at:
The Data Protection Office
118 Limited, Fusion Point, Dumballs Road, Cardiff CF10 5BF
|Right to withdraw consent||You have the right to withdraw your consent at any time where we rely on consent to use your personal information.||Write to us at:
The Data Protection Officer The 118 Limited, Fusion Point, Dumballs Road, Cardiff CF10 5BF
|Right to complain to the relevant data protection authority||You have the right to complain to the Information Commissioner’s Office (ICO), where you think we have not used your personal information in accordance with data protection law.||Contact the ICO:
· ICO Telephone: 0303 123 1113
· ICO website: www.ico.org.uk
Links to third party websites:
- The Website may contain links to other websites over which we have no control.
- We are not responsible for privacy policies or practices of other websites to which you choose to link from the Website. We encourage you to review the privacy policies of those other websites so you can understand how they collect, use and share your information.
- From time to time, we may wish with your agreement to contact you by e-mail, SMS, post or phone with information about other products or services which may be of interest to you. These communications may be from us or other members of our Group or it may be from other organisations whose products or services we think may be of interest to you. We will only transfer your personal data to third parties for marketing purposes with your express opt-in consent to do so. You may opt-out by Contacting us as set out at the end of this Policy.
- Where appropriate we will give you reasonable notice of any changes.
- If you have any questions about this Policy or your personal information and/or if you wish to see what information we hold about you, please contact the Data Protection Office on firstname.lastname@example.org.
- If you no longer wish to receive any marketing communications or wish us to stop using your personal information, please contact us:
- By phone: 02920550000 which is free from UK landlines and mobiles.
- By mail: 118 Limited, Fusion Point, Dumballs Road, Cardiff, CF10 5BF
- By email: email@example.com
How to complain:
- If you think there is a problem with how your personal information is being handled, you have a right to complain to the Information Commissioner’s Office (ICO).
- The ICO can be contacted on 0303 123 1113 or please visit their website at ico.org.uk.