This privacy and cookies policy (Policy) refers to Total Telecoms websites, portals and applications (individually a Website and, together, the Websites). The Websites are operated by Top Telecoms Limited trading as Total Telecoms Limited (we, our or Total Telecoms). This policy also applies, to the extent applicable, to personal data provided by you pursuant to a phone call to our call centre, engagement with our staff and/or where you engage with one of our services. This Policy applies to all products and services offered by Total Telecoms.
The Policy sets out the basis on which any personal data which we collect from you, or that you provide to us,or that is provided to us by a third party, will be processed by us. In this Policy, the term personal data means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into our possession, and includes personal data as described in Data Protection Legislation (as defined below).
Please read the following carefully. Entering into this Website, or providing personal data to Total Telecoms over the phone, and accepting the terms of this Policy, indicates that the user (either user or you) has reviewed this Policy and has agreed to be bound by it. You will be required to expressly accept and consent to this Policy before we process your personal data. We will keep a record of your consent in this regard. If you do not agree to these terms you must leave the Website immediately, or not provide any personal data to us over the phone or via our Service.
We will handle your personal data in accordance with Data Protection Legislation. Data Protection Legislation means the Data Protection Acts 1988 to 2018 and Directive 95/46/EC, any other applicable law or regulation relating to the processing of personal data and privacy (including the E-Privacy Directive and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011), as such legislation shall be amended, revised or replaced from time to time, including by operation of the General Data Protection Regulation (EU) 2016/679 (GDPR) (and laws implementing or supplementing the GDPR or the E-Privacy Regulations)
If you have any queries related to the basis upon which we process your personal data please contact us at firstname.lastname@example.org.
What information do we gather from you?
You may be asked to provide the following categories of data:
- C.V details
- Email address
- Phone number
- Physical address
- Details of complaints being submitted to Total Telecoms
- Financial information
- Account details
- Credit card details
- Technical information
- Details of previous convictions
We may also ask for additional information, including the nature of any enquiries or complaints you may make. We endeavour to only collect data that is relevant to your request.
We endeavour to keep all personal data that you provide to us, accurate and up-to-date. As such, you must tell us about any changes to such information as soon as possible. You can do this by contacting us using the contact details in our ‘Contact Us’ section of this Policy.
You may unsubscribe from emails and other updates by selecting the Unsubscribe button at the foot of every communication. When registering with us, you will be asked whether or not you consent to us sending you electronic communications/direct marketing. We may ask different questions for different services.
There may be other instances in which we collect “general information” from you. This may include information recorded by our server logs from your browser such as your Internet Protocol (IP) address which enables us to identify your computer or device on a Transmission Control Protocol/Internet Protocol (TCP/IP) network like the internet, and the specific website page you requested. General information, including cookies may be collected from you whenever you access or use the website.
If you are aged 16 or under, please get your parent/guardian’s permission before you provide any of your data to us.
A cookie is a small text file that is placed on your device by a web server which enables a website and/or mobile application to recognise repeat users, facilitate the user’s ongoing access to and use of a website and/or mobile app and allows the website and/or mobile app to track usage behaviour and compile aggregate data that will allow content improvements and targeted advertising. We collate information in relation to the Service which is represented in aggregate format through cookies. They help us to improve our service and to deliver many of the functions that make your browser experience more user friendly.
Necessary cookies are absolutely essential for the website to function properly. This category only includes cookies that ensure basic functionalities and security features of the website. These cookies do not store any personal information.
The ‘Help Menu’ on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also disable or delete similar data used by browser add-ons, such as flash cookies, by changing the add-ons settings or visiting the website of its manufacturer.
You should also be aware that there are cookies which are found in other companies’ internet tools which we may use to enhance the website. You may see ‘social buttons’ during your use of the Website, including but not limited to Linked-In and Facebook, which enable you to share or bookmark certain web pages. These websites have their own cookies, which are controlled by them.
How will we use the information we gather?
We will use the information we collect from you to:
- Fulfil our legal, regulatory and risk management obligations
- Respond to your enquiry or complaint
- Provide information requested by you e.g quotation for services
- Manage and administer our relationship with you in a manner relevant to our legitimate interests
- Understand how visitors interact with our Websites
- Produce statistics to improve and develop our Website and Service
- If you agree, to email you about other products and services and information we think may be of interest to you.
The personal data that we collect from you may be transferred to, and stored by Total Telecoms. It may also be processed by our staff. By submitting your personal data, you agree to this transfer, storing or processing of your personal data by Total Telecoms for the purposes set out in this Policy.
Are there cases where we may use your information to contact you?
We may contact you:
- for administration reasons related to the service to which you have signed up (e.g.quotation for services, or in response to a question that you ask us);
- to provide you with information about our services, activities or online content. We will only contact you if we have a legitimate business interest to do so or where you have provided your consent to us to contact you. It will be made clear to you when we are requesting your consent to contact you, for example, by providing tick boxes for you to decide whether you wish to receive e-newsletters;
- to invite you to participate in surveys about our services (participation is always voluntary).
Where we wish to use your personal information in any other way, we will ensure that we have a legitimate business interest to use your personal data or we will notify you and get your consent first. You will be given the opportunity to withhold or withdraw your consent for the use of your personal information for purposes other than those listed in this Policy.
What rights do you have?
As a data subject, you have the following rights under the Data Protection Legislation:
- the right of access to personal data relating to you;
- the right to correct any mistakes in your personal data;
- the right to ask us to stop contacting you with direct marketing;
- rights in relation to automated decision taking;
- the right to restrict or prevent your personal data being processed;
- the right to have your personal data ported to another data controller;
- the right to erasure; and
- the right to complain to the DPC if you believe we have not handled your personal data in accordance with the Data Protection Legislation.
These rights are explained in more detail below, but if you have any comments, concerns or complaints about our use of your personal data, please contact us (see ‘How to contact us’ below). We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex or cumbersome, in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond). Where a response is required from us within a particular time period pursuant to Data Protection Legislation, we will respond within that time period.
Right to access to personal data relating to you
You may ask to see what personal data we hold about you and be provided with:
- a summary of such personal data and the categories of personal data held;
- details of the purpose for which it is being or is to be processed;
- details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those overseas transfers;
- details of the period for which it is held (or the criteria we use to determine how long it is held);
- details of your rights, including the rights to rectification, erasure, restriction or objection to the processing;
- any information available about the source of that data;
- whether we carry out automated decision-making, or profiling, and where we do, information about the logic involved and the envisaged outcome or consequences of that decision making or profiling; and
- where your personal data are transferred out of the EEA, what safeguards are in place.
Requests for your personal data must be made to us (see ‘How to contact us’ below) specifying what personal data you need access to, and a copy will be retained on our files. To help us find the information easily, please give us as much information as possible about the type of information you would like to see.
If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible.
There are certain types of data which we are not obliged to disclose to you, which include personal data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations.
We are entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the personal data requested, we may charge you a reasonable fee to account for administrative costs of doing so), or (ii) we are entitled to do so pursuant to Data Protection Legislation.
Right to update your personal data or correct any mistakes in your personal data
You can require us to correct any mistakes in your personal data which we hold free of charge. If you would like to do this, please:
- email, call or write to us (see ‘How can you contact us’ below);
- let us have enough information to identify you (e.g. name, registration details); and
- let us know the information that is incorrect and what it should be replaced with.
If we are required to update your personal data, we will inform recipients to whom that personal data have been disclosed (if any), unless this proves impossible or has a disproportionate effort.
It is your responsibility that all of the personal data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see ‘How to contact us’ below).
Right to ask us to stop contacting you with direct marketing
You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please:
- email, call or write to us (see ‘How can you contact us’ below). You can also click on the ‘unsubscribe’ button at the bottom of the email newsletter. It may take up to 5 days for this to take place; and
- let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).
We will provide you with information on action taken on a request to stop direct marketing – this may be in the form of a response email confirming that you have ‘unsubscribed’.
Unsubscribing from direct marketing does not unsubscribe you from essential electronic communications in respect of the administration of any relevant account.
Right in relation to automated decision taking (if applicable)
Pursuant to GDPR, you may ask us to ensure that, if we are evaluating you, we don’t base any decisions solely on an automated process and have any decision reviewed by a member of staff.
Profiling may occur in relation to your personal data for the purposes of targeted advertising and de-targeting you from specified advertising. This allows us to tailor our advertising to the appropriate customers and helps to minimise the risk of you receiving unwanted advertising. We do not currently carry out any profiling. If there is a change to our procedures in this regard we will update this Policy.
These rights will not apply in all circumstances, for example where the decision is (i) authorised or required by law, (ii) necessary for the performance of a contract between you and us, or (ii) is based on your explicit consent. In all cases, we will endeavour that steps have been taken to safeguard your interests.
Right to restrict or prevent processing of personal data
In accordance with Data Processing Legislation, you may request that we stop processing your personal data temporarily if:
- you do not think that your data is accurate (but we will start processing again once we have checked and confirmed that it is accurate);
- the processing is unlawful but you do not want us to erase your data;
- we no longer need the personal data for our processing; or
- you have objected to processing because you believe that your interests should override the basis upon which we process your personal data.
If you exercise your right to restrict us from processing your personal data, we will continue to process the data if:
- you consent to such processing;
- the processing is necessary for the exercise or defence of legal claims;
- the processing is necessary for the protection of the rights of other individuals or legal persons; or
- the processing is necessary for public interest reasons.
Right to data portability
In accordance with Data Protection Legislation, you may ask for an electronic copy of your personal data that you have provided to us and which we hold electronically, or for us to provide this directly to another party. This right only applies to personal data that you have provided to us – it does not extend to data generated by us. In addition, the right to data portability also only applies where:
- the processing is based on your consent or for the performance of a contract; and
- the processing is carried out by automated means.
Right to erasure
In accordance with Data Protection Legislation, you can ask us to erase your personal data where:
- you do not believe that we need your personal data in order to process it for the purposes set out in this Policy;
- if you had given us consent to process your personal data, you withdraw that consent and we cannot otherwise legally process your personal data;
- you object to our processing and we do not have any legal basis for continuing to process your personal data;
- your data has been processed unlawfully or have not been erased when it should have been; or
- the personal data have to be erased to comply with law.
We may continue to process your personal data in certain circumstances in accordance with Data Protection Legislation.
Where you have requested the erasure of your personal data, we will inform recipients to whom that personal data have been disclosed, unless this proves impossible or involves a disproportionate effort. We will also inform you about those recipients if you request it.
Rights to complain to DPC
If you do not think that we have processed your personal data in accordance with this Policy, please contact us in the first instance. If you are not satisfied, you can complain to the DPC or exercise any of your other rights pursuant to Data Protection Legislation. Information about how to do this is available on the DPC website at https://www.dataprotection.ie.
If you post or send content which may reasonably be deemed to be offensive, inappropriate or objectionable anywhere on the Website or otherwise engage in any disruptive behaviour on any Website or the Service, we may remove such content.
Where we reasonably believe that you are or may be in breach of any applicable laws, for example on hate speech, we may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet provider. We would only do so in circumstances where such disclosure is permitted under applicable laws, including Data Protection Legislation.
Do we protect your personal information?
We do our utmost to protect user privacy through the appropriate use of security technology. We restrict access to personal data to employees and agents who need to know such personal data in order to operate, develop or improve the services that we provide. We ensure that we have appropriate physical and technological security measures to protect your information; and we ensure that when we outsource any processes that the service provider has appropriate security measures in place. However, the Website contains hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, including cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
We will implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks that are presented by the processing of your personal data. In particular, we will consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of any data transmitted to our Website and any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We are not responsible for any delays, delivery failures, or any other loss or damage resulting from (i) the transfer of data over communications networks and facilities, including the internet, or (ii) any delay or delivery failure on the part of any other service provider not contracted by us, and you acknowledge that the Website may be subject to limitations, delays and other problems inherent in the use of such communications facilities. You will appreciate that we cannot guarantee the absolute prevention of cyber-attacks such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorised disclosure, loss or destruction of your personal data arising from such risks.
We will notify serious data breaches to the DPC without undue delay, and where feasible, not later than 72 hours after having become aware of same. If notification is not made after 72 hours, we will record a reasoned justification for the delay; however, it is not necessary to notify the DPC where the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. A personal data breach in this context means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
We will keep a record of any data breaches, including their effects and the remedial action taken, and will notify you of any data breach affecting your personal data (which poses a high risk to you) when we are required to do so under Data Protection Legislation. We will not be required to notify you of a data breach where:
- we have implemented appropriate technical and organisational measures that render the personal data unintelligible to anyone not authorised to access it, such as encryption; or
- we have taken subsequent measures which ensure that the high risk to data subjects is not likely to materialise; or
- it would involve disproportionate effort, in which case we may make a public communication instead.
Withdrawal of consent
Who we share data with
We may disclose your personal information to any business unit, company or other corporate entity under the control and direction of Total Telecoms.
We may use a third party service provider to send out our newsletter and administer our mailing list.
We may also use service providers to help us run the Website or services available on the Website. We may use service providers to assist us in recruitment competitions. Any third parties who access your data in the course of providing services on our behalf are subject to strict contractual restrictions to ensure that your data is protected, in compliance with Data Protection Legislation.
Where we store your personal data
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Retention of personal data
Any information that you provide to us will be kept and stored for such period of time as we deem necessary taking into account the purpose for which it was collected in the first instance, and our obligations under Data Protection Legislation. This may include retaining your personal data as necessary to administer your account (as applicable), comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business and statutory operations and to continue to develop and improve our Service.
Where we retain information for Service/website improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Service/websites, not to specifically analyse personal characteristics about you.
Changes to the policy
This Policy may be updated or changed from time to time at the Total Telecoms sole discretion. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to use this Website to submit personal information. If material changes are made to the Policy, we will notify you by placing a prominent notice on the Website or sending you a notification in relation to this. We will not process your personal data in a manner not contemplated by this Policy without your consent.
Legal information and how to contact us
The data controller (as defined in Data Protection Legislation) for the Website and services provided through the Website is the Total Telecoms
If you need to contact us with regard to any of your rights as set out in this Policy, all such requests should be sent by email to email@example.com or in writing to:
Data Protection Officer
Total Telecoms Ltd
Waterfront Industrial Estate