GOFIBRE PRIVACY NOTICE

This Privacy Notice covers your use of our website at https://www.gofibre.co.uk/ and your relationship with us as a customer. Any questions relating to this policy should be sent to [scott.walters@gofibre.co.uk].

References in this Privacy Notice to “we” or “us”, means Borderlink Broadband Limited a company incorporated in Scotland with registration number SC582522 and having its registered office at Blackadder West Farm, Blackadder, Duns, Scotland, TD11 3LX, trading as “Go Fibre”.

Please read this Privacy Notice, which explains how we use your personal information, in particular: What information is collected from you through our trading website(s) including social media and from you as a customer, how the information is used, with whom the information may be shared, and how you can correct any inaccuracies in the information. Once you choose to provide us with personally identifiable information (any information by which you can be identified), you can be assured that it will only be used to support your customer relationship with us. Please note, neither this website nor our services are intended for children and we do not knowingly collect data relating to children.

  • Personal data we collect

When you register as a consumer customer with us, you may be asked for the following details:

  • Identity Data: Includes first name, last name, website username, marital status, title, date of birth, gender.
  • Contact Data: Includes address (both service delivery and billing), e-mail address, contact telephone number(s), longitude and Latitude coordinates for the service delivery address.
  • Employment Data: Includes information about your employment and role with your employer (e.g. for business contacts).
  • Financial Data: Includes bank account and payment card details.
  • Account Data: Includes details about payments to us, services purchased from us, telephone call recordings.
  • Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Usage Data: Includes information about how you use our website and services.
  • Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • CCTV Data: Includes your image and vehicle registration information.

 

We will store your details safely and will not sell or share your details to third parties for marketing purposes unless you have given your prior consent. We will only share your information in the way described in this statement.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

  • How we collect your personal data

We use different methods to collect data from and about you including through:

Direct interactions: You may give us your Identity, Contact, Financial Data and Employment Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our services;
  • create an account on our website;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.

Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy for further details.

Third parties or publicly available sources: We will receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from the following parties:
    • analytics providers such as Google;
    • advertising networks such as Google, Facebook, LinkedIn, OpenWeb Display, Instagram, AdRoll. Youtube and
    • search information providers such as Google, Bing, Youtube
    • Digital Marketing service providers: Sopro (i)*
  • Identity and Contact Data from data brokers or aggregators such as We use Zoominfo however this is not gathered via the website, we gather this as part of our sales process so not part of a web based process.
  • Identity, Contact Data and Employment Data from publicly available sources such as Companies House, the Electoral Register, and LinkedIn.
  • Use of your data

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include and in addition to the above named providers:

*(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io.  Sopro is registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.”

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer

(a) Identity

(b) Contact

(c) Employment

Performance of a contract with you

To process and manage your account including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(c) Providing our online services

(d) For warranty and product safety requirements (e.g. manufacture recall of a batch of routers)

(e) To provide maintenance services

(f) To make an online booking for sales or raising a ticket due to a service delivery issue

(g) To monitor compliance with our terms and conditions

(a) Identity

(b) Contact

(c) Financial

(d) Account

(e) Transaction

(f) Usage

(g) Marketing and Communications

(a) Performance of our contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our Terms or Privacy Notice

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Usage

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Usage

(d) Employment

(e) Marketing and Communications

(e) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Employment

(e) Usage

(f) Account

(g) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)
Providing information to law enforcement agencies and regulators or to comply with any legally binding request for information

(a) Identity

(b) Contact

(d) Account

(c) Technical

(d) Usage

Compliance with our legal obligations.

Necessary for our legitimate interests (for the proper administration of our business and engagement with law enforcement and regulators)

For the operation of our CCTV network at our premises (a) CCTV Necessary for our legitimate interests (to keep our premises secure)
To monitor phone calls to us

(a) Identity

(b) Contact

(c) Account

(a)

For our legitimate interests (to monitor the service we provide, for training purposes)
To obtain credit information about you

(a) Identity

(b) Contact

(c) Account

(a)

For our legitimate interests (To assess the financial worthiness of those to whom we may provide services to assess their ability to pay any sums due for those services)

 

Marketing

We will contact you with reference to our duty of care for services delivered or where there is a contractual requirement for us to do so. We may use your personal details to contact you about news, new products available from companies within our organisation or third-party partner, and special offers that we think may be of interest to you as part of the contractual and consent process.

If you have agreed to receive marketing from us by form of consent you will have the option to select which form of marketing you would like to receive.

You may choose to amend your consent to receive such marketing from us and you can do this by sending an email to [details] or by written request to GDPR Request, BorderLink Broadband Limited, Blackadder West Farm, TD11 3LX, Scotland. We encourage you to use these methods to unsubscribe from our marketing services. Please also use these contact details to let us know if you would like us to delete any information from your records and we will do so at any time. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

If you are the representative of a business customer, you can also choose to opt-out of receiving marketing communications. Please use the details above if you wish to exercise this right.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  • Data sharing

We may pass your personal data to our service partners and contractors, if you request details about:

  • Voice over Internet Protocol (VoIP)
  • Fibre to the premise orders
  • Other copper line services
  • LTE broadband services
  • Satellite broadband services

We may also pass your data to the following external third parties, which may include if there is a legal or statutory requirement:

  • Data requests received under The Investigatory Powers Act 2016.
  • Data requests for cases of legal infringement, for example, piracy, copyright infringement.
  • Government agencies providing grants and or subsidies for your installation.
  • Employers paying for your service.
  • If you nominate a third party, such as an IT support company, or another family member to engage with us to discuss your account and service then we must have this request in writing clearly stating what personal data and service information we can share with them. We respectfully will decline any and all approaches from anyone other than the account holder without this authority. Authority requests and changes to authorised third party of family members should be made in writing to [details].
  • If we sell any of our businesses we may disclose your personal information to the prospective buyer of the relevant business.
  • In the event of a duty of disclosure due to compliance with legal obligation then your personal information may be shared.
  • Data may be shared with other organisations for purposes of fraud protection and credit risk reduction.
  • In the event of a data cleansing organisation being sourced under contract to ensure accuracy of data information.
  • Our service providers, including providers of email and data hosting providers used by us in the course of providing our products and services including those that provide us with live chat and ph.one calls.
  • Professional advisors including lawyers, bankers, auditors and insurers

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  • International transfers

[Note: We assume there will be no international transfers (i.e. no personal data will be transferred across international borders but please confirm or advise if otherwise?]

  • Personal information: collection and retention

Our data retention periods are reviewed on a regular basis and we will only hold your personal information as long as it deemed relevant for the required service/activity or as required for legal reasons or as stated in any relevant contract that we have in place with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

If you have registered your personal details with us in order to be connected to our network but we were unable to fulfil your order we will retain your details for a maximum of three years. This data will help shape the future growth of our network and potentially result in you being able to become a subscriber.

If we collect Aggregate Data (which is anonymised so that it can no longer be associated with you) for research or statistical purposes, we may use this information indefinitely without further notice to you.

  • Data security

The security of your personal information is important to us but remember that no method of transmission over the internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. After receiving your information, we will use clear procedures and security measures to try to prevent unauthorised access. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will never ask you to email your bank details, usernames, passwords, or ask you through an email or text for personal banking information. If you suspect you have become a victim of fraud please report this instance to the police through ‘Action Fraud’ via the website www.actionfraudpolice.co.uk or by calling 03001 232040. We also recommend contacting the Information and Commissioners Office (ICO) via the website www.ico.gov.uk.

  • Your rights

Under certain circumstances you have rights under data protection laws in relation to your personal data. You can exercise any of these rights at any time by contacting us.

  • Request access to your personal data (commonly known as a “data subject access request”).
  • Request correction of the personal data that we hold about you.
  • Request erasure of your personal data.
  • Object to processing of your personal data where we are relying on a legitimate interest.
  • Request restriction of processing of your personal data.
  • Request the transfer of your personal data to you or to a third party.
  • Withdraw consent at any time where we are relying on consent to process your personal data.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If there are any concerns that we are not using your information in accordance with our processes, and with legal precedence, or you are not satisfied with our response to your data request that are made you can refer to the Information Commissioners Office (ICO) – www.ico.gov.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

  • Links

Websites associated with us may contain links to and from the websites of our partner networks. In the event of you following these links, these websites will have their own privacy policies, we do not accept any responsibility or liability for these policies. We advise that you check these policies before you submit any personal information to these websites.

  • Social networks

The Websites associated with us may offer you opportunity to share or follow information about the business using third party social networking functionality; share, like or follow buttons. We offer this functionality in order to generate interest toward our website and services among members of your social networks. You should be aware that sharing personal information within a social network may result in that being collected by the social network provider. This could result in that information becoming publicly available in internet search engine results. We do no exercise or endorse controls, policies or practices or any third party social network that you may access through our websites. Please read the privacy policy of any social network with which you may share information with.

  • Updates to this Notice

We keep our Privacy Notice under regular review. This Notice was last updated on [date] March 2022. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.