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How we use your data

Like you, we care about your privacy.  This privacy notice explains how, when, where and why we use your information.  It also provides you with advice on your rights regarding how your information is used.

In this privacy notice, “we”, “us”, or “our” means:

ASK4 Limited
Devonshire Green House
14 Fitzwilliam Street
Sheffield, S1 4JL
United Kingdom.

We can be contacted at: data-protection@ask4.com.

We are responsible as ‘the controller’ for the personal information about you that we collect or use. We also determine the purposes for which and how your personal information is processed.

If you are accessing our services and live or work outside of the UK, we may share this responsibility with one of our local branches or group companies. The details of these entities are set out at the end of this policy.

In addition, we share this responsibility with ASK4 Solution Limited if you are taking IT support or similar IT solution and with ASK4 Data Centres Limited if you take data centre products for us.

This policy does not apply to information we collect as part of our recruitment processes or about our employees or shareholders. Neither does it apply to how we handle the personal information of the employees of our IT support customers when we provide IT support or a similar IT solution. Our customer’s internal privacy policies shall apply to this processing.

Our collection and use of your personal data

The information we collect about you will depend on how you interact with us and the type of products and services you take. We have explained the different ways we use your personal information below.

Information we collect if you browse our website

Information we collect:

To provide our websites, we must process certain automatically transmitted information about you so that your browser can display our website and you can use the websites. The following information is automatically collected for each visit to our websites and stored in our server log files:

  • Date and time of the visit to our site.
  • Content of the requirement.
  • Access Status / HTTP status code.
  • Browser and operating system used.
  • Language and version of your browser.
  • How you interact with our site (such as which areas are clicked on).

We use cookies to make our websites available to you. Cookies are text files stored in the internet browser or by the internet browser when you visit a website on your computer system. Details on the cookies we use are set out in our cookie policy. 

We collect information if you register to use our service via one of our websites. Further details on this are set out in the “If you are using a residential, student or business service” section below.

We will also collect information if you post material on our website or social media pages, or complete customer surveys and other forms. The information we collect in these scenarios is limited to the personal information provided by you. This information includes:

  • Your name.
  • Your email address.
  • The other information that you send us in the context of your post, message or survey completion.

How we use your information:

When you browse on our websites, we process your personal information for the following purposes:

  • The information collected via your browser is necessary to enable you to visit the website, to improve our website and to ensure the security of our website. We do not collect your IP address.
  • When you register for our services, the information we collect will be used as set out in the “If you are using a residential, student or business service” section below.
  • We will typically use information collected via surveys or forms on our website for market research or to improve our products and services.

Legal basis for this collection:

Whatever we do with your information, we need a legal basis for doing it.

We process your personal information collected our website on the following legal grounds:

  • Where we collect information as part of an enquiry about our service or as part of the registration process for our services, the legal basis for this collection is that it is necessary to take steps, at your request, to enter into a contract. If you do not provide the required information, it will not be possible to enter into a contract with us.
  • We collect information to make the website technically available to you. The legal basis for using this information is that we have a legitimate interest to offer you an appealing, technically functioning, user-friendly and secure website. We have assessed that our use of your information is fair and not override your right to privacy.
  • Where we collect information for market research or to improve our products and services via our website, the legal basis applicable is that it is in our ‘legitimate interests’ to use the information in a particular way. We have assessed that our use of your information is fair and does not override your right to privacy. The processing is not mandatory, and for this reason, you have a right to object.

Information we collect if you are using a residential, student or business service

Information we collect about you:

During sign-up or service initiation, we ask for some basic information about you to enable us to provide you with a service. This information includes your full name, location, phone number and email address. If we need to take a payment, we’ll also collect your card details for card payments and bank account number and sort code for direct debit payments.

We may also collect some information, such as the MAC address, about devices you connect to our service, and this may be associated with identifiable information we hold about you.

If you use our diagnostic app, we may collect: information on how your device is interacting with our network; location information; your IP address; MAC address; the number of devices you have connected to your account; make/model of the router used; the type of mobile phone you are using our app on; speed test information; connection quality to the devices connected to your account; port tests; traceroutes; ping tests; DNS lookups; and multicast configuration information.

We also record telephone calls to our help desk.

How we use your information:

We use this information:

  • To provide and fix issues with our services.
  • To authorise your access to our network.
  • To notify you by email when we are undertaking service-affecting maintenance.
  • To confirm your identity when you call our support team.
  • To deal with support issues you raise.
  • To take and process payments.
  • To improve our services but where possible we will use anonymised or aggregated data.
  • To identify returning customers.
  • To help us grow our business or to develop better products, including carrying out product and trend analysis.
  • To allow us to complete financial audits.
  • To comply with any legal or regulatory obligations (such as demonstrating we have billed you and dealt with any complaints correctly).
  • To ensure our network and services are kept secure (for example, to protect our network against cyber-attacks).
  • Where we have appropriate permission under applicable data protection laws, to carry out the marketing of our products and services. We will not use any information collected via the diagnostic app or any other traffic or location information for this purpose.
  • To manage our agreement and resolve any disputes relating to it.
  • Call recordings are only used to monitor and train our operators and enhance the quality of the service we provide you, and to resolve disputes between us. We only process recordings containing personal information where necessary. We use the minimum amount of required information and delete calls as soon as possible.

Legal basis for this collection:

We rely on the following legal basis for our collection of personal information as part of the provision of our services:

  • That it is necessary for the performance of a contract (i.e. so that we can provide, support and bill that service).
  • Where we process information to fulfil legal obligations that we are subject to, we are entitled to process your information for these purposes
  • We are also entitled to process your personal information to make legal claims or defend ourselves in legal disputes or prevent or clarify criminal offences.
  • We may process your personal information for the other purposes listed above that are not related to performing the contract, meeting a legal obligation or defending or making legal claims. Where we do so, the legal basis applicable is that it is in our ‘legitimate interests’ to use the information. We have assessed that our use of your information is fair and does not override your right to privacy. The processing is not mandatory, and for this reason, you have a right to object.
  • Where we record your calls, our legal basis for processing your information will either be based on our legitimate interest to listen to calls for training and quality purposes or your explicit consent, depending on the country you call from and the locally applicable data protection laws.

Information we collect if you work for our corporate customers

Information we collect:

If you work for a company that receives our services, we will collect contact details, such as your email address and phone number, and information on your job role as part of our day-to-day dealings with you.

How we use your information:

We use this information:

  • To administer and provide our services.
  • To prepare for and to carry out service reviews.
  • To dispatch and ensure the payment of invoices relating to our services.
  • In accordance with applicable data protection laws, to discuss our services and any future or further services you may wish to purchase from us.
  • To manage our agreement and resolve any disputes relating to it.
  • To respond to or raise general queries relating to the services.
  • To comply with any legal or regulatory obligations.
  • As part of our market research to understand the market for our services.
  • Where permitted under applicable data protection laws, to contact you about other services you might be interested in.

Legal basis for this collection:

We rely on the legal basis that it is necessary for the performance of a contract or to take steps at your request to arrange the entry of the contract. If you do not provide the required information, it will not be possible to enter into a contract with us or for us to meet our contractual obligations.

We are also entitled to process your personal information to make legal claims or defend ourselves in legal disputes or prevent or clarify criminal offences.

We may process your personal information for the other purposes listed above that are not related to performing the contract, meeting a legal obligation or defending or making legal claims. Where we do so, the legal basis applicable is that it is in our ‘legitimate interests’ to use the information in a particular way. We have assessed that our use of your information is fair and does not override your right to privacy. The processing is not mandatory, and for this reason, you have a right to object.

Other times we collect information

  • We may collect or purchase publicly available online information to generate leads and build up our understanding of the markets we operate in. This information may include personal information such as names, job roles and contact details.
  • At industry and trade events, we may also collect personal information on people who express an interest in our products and services. In compliance with applicable data protection laws, we may use this information to generate leads and market our services.
  • We may also collect identification documents such as photos or CCTV footage if you visit our premises, particularly secure areas such as our data centre. Identification documents such as photos are used to check people requesting access have the appropriate authorisation. CCTV footage is only used to prevent, detect and investigate unauthorised access. It is only reviewed where such unauthorised access is suspected of having occurred.
  • In each of these scenarios, we assessed that our use of your information would be fair and does not override your right to privacy due to its limited scope. Accordingly, we have a legal basis for processing your personal information as it is in our ‘legitimate interests’ to use the information in a particular way. We have assessed that our use of your information is fair and does not override your right to privacy. The processing is not mandatory, and for this reason, you have a right to object.

If we collect information in other ways, we will provide a specific privacy notice for that collection.

Who we share your information with

We share information with the following recipients:

Suppliers

We use companies and individuals to perform functions on our behalf. These third-party service providers may access personal information needed to perform their functions but may not use it for other purposes. Details of the suppliers we use routinely to process personal information are set out below:

  • We share information with payment providers. If we take a card payment as part of the sign-up process, the payment is processed by Stripe. If you set up a direct debit, your details will be shared with Smart Debit.
  • We may use a third-party system (Mailjet) to process support notifications. We use a third-party system (MailChimp) to send email marketing and manage our email suppression lists.
  • We use Chartered Developments to provide outsourced outbound marketing support.
    RouteThis provide our diagnostics app.
  • We use Amazon Web Services (AWS) to host our sign-up portal for our student and residential services. They do not store or capture any payment information; all personal information is removed after sign-up is completed.

We may also occasionally employ other companies and individuals to perform functions on our behalf. All our suppliers are risk assessed and subject to written agreements with us to ensure they are compliant with applicable data protection laws.

Service providers

If you are having issues accessing or using a third-party service via a service we provide or resell, we may share your information with that provider. We do this so we can jointly resolve the issue you are having. We aim to share as little personal information as possible. If you don’t wish us to do this, just let us know.

Accommodation providers

If you are a resident in managed accommodation, we may share your name, location and information about your support issues with your accommodation provider.  We do this so your accommodation provider can check we are providing you with a quality service and we are meeting our contractual obligations to you and them.

We may also share details with your accommodation provider where we feel that your service experience is impacted by something and we’re unable to reach you. We do this so your accommodation provider can also reach out to you to help us resolve, or make you aware of, the potential service issues.

In very limited situations, we may share information with an accommodation provider that is not solely service-related. We will assess the potential benefits and risks of sharing or not sharing. Following this assessment, we will only share your personal information where it is fair, necessary, and proportionate.

We require all accommodation providers to handle information we share securely and to only use it for the above purposes.

Law enforcement agencies

We will share your data with law enforcement, other authorities or authorised third parties if required by applicable law or court order, or where we feel a criminal act is being committed.

Other group companies

We will share information across different parts of our group as part of the administration of our business.

A new business owner

If there is a change (or expected change) in who owns us or any of our assets, we might share personal information with the new (or prospective) owner. If we do, they will have to keep it confidential and handle it in accordance with applicable data protection laws.

If we transfer your data to another country

We guarantee that we will take the necessary measures to protect the personal information in compliance with applicable data protection laws in case of transfer of your personal information to another country. Where data is collected from an individual within the European Union, this may include executing the standard contractual clauses approved by the European Commission to ensure your information is still protected and handled according to EU data protection laws.

You can ask us to demonstrate that these data transfers are carried out in a compliant manner unless doing so would undermine the security of the personal information transferred.

How long we keep your data for

When you visit our website

When using our website for information purposes only, we store your personal information on our servers exclusively for the duration of your visit to our website. After leaving our website, we will delete your personal information immediately, but we may retain non-identifiable information for a more extended period.

Cookies installed by us are usually also deleted after leaving our website. However, this does not apply to Google Analytics. These remain stored for 24 months. You also have the option to delete cookies yourself at any time.

If you are a customer

If you’re a customer, we need to retain your data while you are a customer of ours to provide you with our services. We also keep your personal information, other than payment records, for 21 months after you cease to be a customer. We retain your data to:

  • Allow us to complete financial audits.
  • Identify returning customers.
  • For product and trend analysis.
  • To meet and demonstrate our compliance with our legal and regulatory obligations.
  • To ensure that we can defend and manage any legal claims.

We retain payment records for seven years after the payment was made or any longer period required by locally applicable law. This information only contains your name and transaction details. It is retained for financial auditing purposes and to ensure that we can defend and manage any legal claims or disputes regarding those payments.

If you work for a corporate customer, we’ll keep your personal information whilst we manage your account and for the duration of the limitation period after that, which is usually up to six years after we have ceased providing your service.

Prospective customers

If you’re a prospective customer or enquire about our services, we’ll process your details whilst we deal with your enquiry, and we’ll keep you on our marketing list for two years unless you object to this.

How we keep your information secure

We have taken technical and organisational measures to ensure data security. Among other things, these measures serve to prevent unauthorised access to the technical equipment used by us and ensure the protection of your personal information against unauthorised access by third parties.

The technical and organisational measures we use are constantly being developed and adapted to the current industry best practice.

Your rights

You have several important rights under applicable data protection laws.

In summary, your rights allow you to access your personal information, ask us to correct your information, ask us to stop processing your information or to request the deletion of your information. We have provided more detail on each right below.

We may ask you for proof of identity when you exercise any of these rights. We do this so we know we’re dealing with the right individual.

We’ll not ask for a fee unless we think your request is unfounded, repetitive or excessive. Where a fee is necessary, we’ll inform you before proceeding with your request.

We aim to respond to all valid requests within one month. However, it may take us longer if the request is particularly complicated or you have made several requests.

We may not always be able to do what you have asked. For example, we might not be able to provide you information where doing so would impact another person’s right of privacy or delete information where we have a legal obligation to retain it.

Accessing personal information

You can ask us to:

  • Confirm whether or not we have and are using your personal information.
  • Provide a copy of your personal information.

You can also ask us to provide this information in a machine-readable form to you or another company but only where we use your personal information to perform a contract with you or where we asked for your consent to use your personal information. This right does not apply to any personal information that we hold or process based on our legitimate interest or is not held in digital form.

Withdrawing consent

Where you have consented to us using your personal information (which generally you don’t have to do), you’ll always have the right to withdraw such consent.

Correcting/erasing personal information

You can ask us to:

  • Correct inaccurate personal information about you, but we will need to verify the accuracy of it first.
  • Erase your personal information if you think we no longer need to use it for the purpose for which we originally collected it.
  • Erase your personal information. However, you cannot do this where we need the information to perform our contract with you.

We may not always be able to comply with your request, for example, if we need to keep using your personal information to comply with our legal obligations or where we may need to use it as part of legal claims.

Restricting our use of personal information

You can ask us to restrict our use of your personal information whilst we investigate if the information you think is inaccurate actually is or where the information is no longer required for the purposes it was collected.

We can continue to use your personal information following a request for restriction if we have your consent to use it; or you need to use it to establish, exercise or defend legal claims, or use it to protect the rights of another individual or a company.

Objecting to the use of personal information

You can object to the processing of your data where you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information.

If you object, we may continue to use the personal information where we can demonstrate that we have compelling legitimate interests to use the information.

Objecting to direct marketing

You can also object to the use of your personal information for direct marketing purposes at any time.

To do this, please write to Devonshire Green House, 14 Fitzwilliam Street, Sheffield, S1 4JL if you live in the UK or Pinar 5, Madrid, Comunidad de Madrid, 28006 if you live in the EU.

Alternatively, use the unsubscribe function on any communications that are sent to you.

Rights around automated decision making

We don’t currently make any decisions about you solely by automated means (i.e. with no human intervention) that would produce a legal effect concerning you or would significantly affect you.

If we were to make any such decision, you might have the right to contest that decision, express your point of view and ask for a human review.

Right to dispose of your data

Where permitted under applicable data protection laws in the event of death, the rights listed above relating to your personal information may be exercised by those who have an interest in your personal information or are acting on your behalf as an agent, or for family reasons worthy of protection. You may expressly prohibit the exercise of some of the rights listed above by sending us a written declaration at the email address indicated below. The declaration may subsequently be revoked or modified in the same manner.

Links to third party sites

Some sections of our website contain links to the web pages of third parties.

These websites are subject to their data protection policies. We are not responsible for their operation, including the data handling practices of their operators; you should review the privacy statements or policies of those sites before you submit any personal information.

Contact information

You can contact us by phone, email, live chat, and post via the details at: support.ask4.com/other/contact-us/ or at hello@ask4.com

You can also contact our Data Protection Officer at: data-protection@ask4.com.

We hope that we can resolve any query or concern you raise about our use of your information.

If you do not believe we have managed to resolve your query or concern, you also have the right to complain to the data protection regulator. For the UK, that’s the Information Commissioner.

If you live or work in the European Economic Area, you can file a complaint with the local data protection regulator in either the member state where you live or where the suspected infringement took place.

Our legal entities

The ASK4 branch or entity within your local country (as listed below) is responsible as a ‘data controller’, jointly with ASK4 Limited, for processing your personal information and for complying with applicable data protection laws.

However, if you live in a country within the European Economic Area where we do not have a local establishment, ASK4 Internet Services Europe Limited, a company established in the Republic of Ireland, shall act as our EU representative.

UK
ASK4 Limited – For residential internet services
ASK4 Solution Limited – For IT support and other business to business services
ASK4 Data Centres Limited – For Data centre and co-location services

Austria
ASK4 Internet Services Europe Limited

Denmark
ASK4 Nordics Limited via its Branch Office: C/O DLA Piper Danmark Rådhuspladsen 4, 4

France
ASK4 France Limited via its Branch Office: 17 rue de la Vanne Montrouge 92120 France

Germany
ASK4 Germany Limited via its Branch Office: Leipziger Platz 15 10117 Berlin, Germany

Ireland
ASK4 Internet Services Europe Limited via its Branch Office: Pinar 5, Madrid, Comunidad de Madrid, 28006

Italy
ASK4 Italy Limited via its Branch Office: Via Libero Temolo 4, Milan (Mi) Cap 20126

Netherlands
ASK4 Netherlands Limited via its Branch Office: Pilotenstraat 39 A, 1059CH Amsterdam

Poland
ASK4 Poland Limited via its Branch Office: C/O Domański Zakrzewski Palinka sp. K, Rondo 1 Building – 21st floor, 00-124 Warszawa

Portugal
ASK4 Portugal Limited via its Branch Office: R. Castilho 39, 8E, 1250-068, Lisboa, Portugal

Spain
ASK4 Internet Services Europe Limited via its Branch Office: Pinar 5, Madrid, Comunidad de Madrid, 28006

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Policy updated: 01.07.21. Changes made are: The addition of entity information for processing in France and Italy. Additional rights added related to the right to dispose of your data added. Scope of legitimate interest-based processing clarified.