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EFAR LIMITED
PRIVACY NOTICE
Welcome to Efar Limited’s privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
What Is The Purpose Of This Document?
Efar Limited is committed to protecting the privacy and security of your personal information. This
privacy notice aims to give you information on how Efar Limited collects and processes your personal
data through your use of our website and during and after the supply of products or use of any of the
services provided by us and our group companies.
This notice applies to anyone who uses our website or who buys or uses any of our products and / or
services. We may update this notice at any time.
It is important that you read this privacy notice together with any other privacy notice or fair processing
notice we may provide on specific occasions when we are collecting or processing personal data about
you so that you are fully aware of how and why we are using your data. This privacy notice supplements
the other notices and is not intended to override them.
Controller
Efar Limited (Company Number: 03949538 whose Registered Office is at Glebe Farm, Down Street,
Dummer, Basingstoke, Hampshire, RG25 2AD (collectively referred to as Company, we, us, our in
this privacy notice) is the controller and responsible for your personal data. This means that we are
responsible for deciding how we hold and use personal information about you. We are required under
data protection legislation to notify you of the information contained in this privacy notice.
Third-Party Links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links
or enabling those connections may allow third parties to collect or share data about you. We do not
control these third-party websites and are not responsible for their privacy statements. When you leave
our website, we encourage you to read the privacy notice of every website you visit.
2. THE KIND OF INFORMATION WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that
person can be identified. It does not include data where the identity has been removed (anonymous
data).
The personal information we collect about you will depend on the products and services you use and
subscribe to.
We will collect, store, and use the following categories of personal information about you as follows:
Identity Data including personal contact details such as name and title.
Contact Data including addresses, telephone numbers, and personal email addresses.
Financial Data including bank account details, your debit or credit card information, your credit
rating information (which we acquire from credit reference agencies) and other banking
information.
Transaction Data including your billing history and products and services you use and anything
else relating your account.
Profile Data including information you provide to us in your communications with us, information
you provide to us when entering prize draws or competitions or participate in surveys.
Marketing and Communications Data including your preferences in receiving marketing from us
and our third parties and your communication preferences.
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We may also collect technical data and information on how you use our products and services,
including:
Your activity on our website.
The date, time, duration and cost of your communications including your phone location at the time
these communications are made.
The phone numbers that you call and send messages to (and the phone numbers that you receive
calls and messages from).
Your phone or device usage.
Your data usage.
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 products or services). In this case, we
may have to cancel a product or service you have with us but we will notify you if this is the case at the
time.
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.
3. HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about you through:
Direct interactions. You may give us your Identity, Contact, Financial and Transaction Data when
you use our website, when you purchase our products and services and during the sales process.
Third parties or publicly available sources. We may sometimes receive personal data and
additional information from third parties including credit reference agencies or other background
check agencies; our partners; and business directories.
We will collect additional personal information in the course of performing our contract with you and in
providing our products and services to you throughout the period of your contract with us.
4. HOW WE WILL USE INFORMATION ABOUT YOU
We will only use your personal information when the law allows us to. Most commonly, we will use your
personal information in the following circumstances:
1. Where we need to perform the contract we have entered into with you.
2. Where we need to comply with a legal obligation.
3. Where we have your consent.
4. 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.
We may also use your personal information in the following situations, which are likely to be rare:
1. Where we need to protect your interests (or someone else’s interests).
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2. Where it is needed in the public interest.
Situations In Which We Will Use Your Personal Information
We need all the categories of information in the list above primarily to allow us to perform our contract
with you. In some cases we may use your personal information to pursue legitimate interests of our own
or those of third parties, provided your interests and fundamental rights do not override those interests.
The situations in which we will process your personal information are listed below.
Purpose/Activity Type of data Lawful basis for processing
including basis of legitimate
interest
To process and deliver your
order including:
(a) Carrying out our obligations
arising from any contracts
entered into between you
and us;
(b) To confirm that your orders
have been received and to
process them;
(c) To provide our products and
services;
(d) To provide you with the
information and services
that you request from us;
(e) For billing purposes, to
manage payments, fees and
charges
(f) To collect and recover
money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications
(a) Performance of a contract with
you.
(b) Necessary for our legitimate
interests (to recover debts due to
us).
To validate you as a registered
customer when using our
services and calling our
customer services.
(a) Identity
(b) Contact
(a) Performance of a contract with
you.
To notify you about changes to
our services and to make
suggestions and
recommendations to you about
goods or services that may be of
interest to you.
(a) Identity
(b) Contact
(c) Technical
(d) Profile
(a) Necessary for our legitimate
interests (to develop our
products/services and grow our
business).
For the administration of files and
records; business management
and planning, including
accounting and auditing.
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate
interests (for running our
business, provision of
administration and IT services).
(b) Necessary to comply with a legal
obligation.
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To prevent fraud.
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Technical
(a) Necessary for our legitimate
interests (to prevent fraud).
(b) Necessary to comply with a legal
obligation
To send certain communications
(including by email and SMS) to
you including service
announcements and
administrative messages and
other communications relating to
our services.
(a) Identity
(b) Contact
(c) Technical
(a) Performance of a contract with
you.
(b) Necessary for our legitimate
interests (for running our
business, provision of
administration services, network
security and in the context of a
business reorganisation or group
restructuring exercise)
To ensure security for you and
our staff, and help maintain
service quality (calls to our
customer services may be
monitored and/or recorded for
authentication, security, quality
and training purposes).
(a) Identity
(b) Contact
(a) Performance of a contract with
you
To help the emergency services.
(a) Identity
(b) Contact
(a) Where we need to comply with a
legal obligation.
To comply with applicable laws,
regulations, court orders,
government and law
enforcement agencies’ requests,
to operate our systems properly
and to protect ourselves, our
users and customers and to
solve any customer disputes.
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(a) Where we need to comply with a
legal obligation.
Some of the above grounds for processing will overlap and there may be several grounds which justify
our use of your personal information.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising. We have established the following personal data control mechanisms:
Promotional Offers From Us
We may use your Identity, Contact, Technical and Profile Data to form a view on what we think you may
want or need, or what may be of interest to you. This is how we decide which products, services and
offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or
purchased products or services from us or if you provided us with your details when you entered a
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competition or registered for a promotion and, in each case, you have not opted out of receiving that
marketing.
Third-Party Marketing
We will get your express opt-in consent before we share your personal data with any company outside
the Southern Communications group of companies for marketing purposes.
Opting Out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the
website and checking or unchecking relevant boxes to adjust your marketing preferences or by following
the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided
to us as a result of a product/service purchase, warranty registration, product/service experience or
other transactions.
COOKIES
Our website uses cookies to distinguish you from other users of the website. This helps us to provide
you with a good experience when you browse the website and also allows us to improve the website.
For detailed information on the cookies we use and the purposes for which we use them see our Cookie
policy.
If You Fail To Provide Personal Information
If you fail to provide certain information when requested, we may not be able to perform the contract
we have entered into with you.
Change Of Purpose
We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.
Automated Decision-Making
Automated decision-making takes place when an electronic system uses personal information to make
a decision without human intervention. We are allowed to use automated decision-making in the
following circumstances:
1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
2. Where it is necessary to perform the contract with you and appropriate measures are in place to
safeguard your rights.
3. In limited circumstances, with your explicit written consent and where appropriate measures are in
place to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated
decision-making, unless we have a lawful basis for doing so and we have notified you.
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5. DATA SHARING
We may have to share your data with third parties, including third-party service providers and other
entities in our group.
We require third parties to respect the security of your data and to treat it in accordance with the law.
Sharing Personal Information With Third Parties
We will share your personal information with third parties where required by law, where it is necessary
to administer our contract with you or where we have another legitimate interest in doing so.
Third-Party Service Providers Who Will Process Your Personal Information
“Third parties” includes third-party service providers (including our partners BT, TTB, Virgin and
Entanet) and other entities within our group. A full list is available on request.
All our third-party service providers and other entities in the group are required to take appropriate
security measures to protect your personal information in line with our policies. We do not allow our
third-party service providers to use your personal data for their own purposes. We only permit them to
process your personal data for specified purposes and in accordance with our instructions.
Sharing Personal Information With Other Entities In Our Group
We will share your personal information with other entities in our group as part of a business
reorganisation or group restructuring exercise, for system maintenance support and hosting of data.
We may share your personal information with other third parties, for example in the context of the
possible sale or restructuring of the business. We may also need to share your personal information
with a regulator or to otherwise comply with the law.
International Transfers
We will not transfer your personal information outside the European Economic Area (EEA).
If this changes, and we do transfer your personal data out of the EEA, we ensure a similar degree of
protection is afforded to it by ensuring that we only transfer your personal data to countries that have
been deemed to provide an adequate level of protection for personal data by the European
Commission.
6. DATA SECURITY
We have put in place appropriate security measures to prevent your personal information from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit
access to your personal information to those employees, agents, contractors and other third parties
who have a business need to know. They will only process your personal information on our instructions
and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you
and any applicable regulator of a suspected breach where we are legally required to do so.
7. DATA RETENTION
How Long Will We Use Your Information For
We will only retain your personal information for as long as necessary to fulfil the purposes we collected
it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial
and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances we may anonymise your personal information so that it can no longer be
associated with you, in which case we may use such information without further notice to you. We will
retain and securely destroy your personal information in accordance with applicable laws and
regulations.
8. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your Rights In Connection With Personal Information
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a “data subject access
request”). This enables you to receive a copy of the personal information we hold about you
and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to
have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove
personal information where there is no good reason for us continuing to process it. You also
have the right to ask us to delete or remove your personal information where you have
exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate
interest (or those of a third party) and there is something about your particular situation which
makes you want to object to processing on this ground. You also have the right to object
where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask
us to suspend the processing of personal information about you, for example if you want us
to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the
processing of your personal data, or request that we transfer a copy of your personal information to
another party, please contact our Data Protection Officer in writing (see contact details below).
No Fee Usually Required
You will not have to pay a fee to access your personal information (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or
excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your
right to access the information (or to exercise any of your other rights). This is another appropriate
security measure to ensure that personal information is not disclosed to any person who has no right
to receive it.
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9. RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing
and transfer of your personal information for a specific purpose, you have the right to withdraw your
consent for that specific processing at any time. To withdraw your consent, please contact our Data
Protection Office in writing (see contact details below). Once we have received notification that you
have withdrawn your consent, we will no longer process your information for the purpose or purposes
you originally agreed to, unless we have another legitimate basis for doing so in law.
10. DATA PROTECTION OFFICER
We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. If
you have any questions about this privacy notice or how we handle your personal information, please
contact the DPO.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the
UK supervisory authority for data protection issues (www.ico.org.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.
11. CHANGES TO THIS PRIVACY NOTICE
This version was last updated on 21st June 2018 and historic versions can be obtained by contacting
us.
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy
notice when we make any substantial updates. We may also notify you in other ways from time to time
about the processing of your personal information.
If you have any questions about this privacy notice, please contact info@Efar.co.uk
12. GLOSSARY
Lawful Basis
Legitimate Interest means the interest of our business in conducting and managing our business to
enable us to give you the best service/product and the best and most secure experience. We make
sure we consider and balance any potential impact on you (both positive and negative) and your rights
before we process your personal data for our legitimate interests. We do not use your personal data for
activities where our interests are overridden by the impact on you (unless we have your consent or are
otherwise required or permitted to by law). You can obtain further information about how we assess our
legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a
contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is
necessary for compliance with a legal or regulatory obligation that we are subject to.