Global Privacy, Data Protection, and Cookies Policy

Fibreplus Telecommunications College Limited

The term "Fibreplus" used in the following document refers to

Fibreplus Ltd (04677135)
Caithness House
Western Way
Melksham,
SN12 8DZ

Fibreplus respects your right to privacy. This policy summarizes what personal information is collected, how this information is used, and other important topics relating to your privacy and data protection.

This Policy applies to all Internet sites and services operated by or on behalf of Fibreplus. It also applies to personal information Fibreplus may collect:

• through products and services;
• when you interact with Fibreplus by means other than a Fibreplus Online Services or Apps, for example, in person, by telephone, or at a trade show or training; and
• from customers, distributors, suppliers, vendors, and other business partners (collectively “Business Partners”).

General Principles of Collection, Use and Disclosure of Personal Information

To the extent required by applicable law, whenever Fibreplus collects personal information, Fibreplus will:

• provide timely and appropriate notice to you about data practices;
• collect your personal information only for specified and legitimate purposes. The information Fibreplus collect will be relevant, adequate and not excessive for the purposes for which it is collected;
• process your personal information in a manner consistent with the purposes for which it was originally collected or to which you have subsequently consented;
• take commercially reasonable steps to ensure that your personal information is reliable for its intended use, accurate, complete, and, where necessary, kept up-to-date;
• not use your personal information for marketing purposes without giving you an opportunity to “opt-out”; and
• take appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party, including transfers within Fibreplus.

Personal Information Collection

Fibreplus collects the following types of personal information:

• Information You Provide
  Fibreplus collects personal information you provide us, which may include:
  • contact information, such as your name, company details, job title, address, e-mail address, and phone number;
  • additional information about you to help Fibreplus get to know you better, such as your gender, age, date of birth, nationality, and registration numbers, information about how you use Fibreplus' products and services, and demographic information;
  • comments, questions, requests and orders you may make;
  • financial information needed to process payments if you make purchases, such as credit card or account information (not stored or recorded) or tax identification number;
  • log-in credentials, including, if applicable, social media account information for login purposes; and
  • information about your preferences, such as your preferred methods of communication and product types in which you are interested.


• Information Automatically Gathered from Your Device
  

  Device and browser information. Fibreplus may collect technical information about your device, such as device type, browser type, IP address, operating system, and device identifier. Fibreplus collects this information automatically from your device and web browser through cookies and similar technologies.

  Information about how you interact with us. Fibreplus may collect technical data about your usage of Fibreplus Online Services or Apps and how you interact with them, such as content viewed or downloaded, features used, links clicked, Fibreplus promotional emails opened, and dates and times of interactions. Fibreplus collects this information using cookies and similar technologies.

  Location information. Fibreplus may collect location information, including precise real-time location information from your device and imprecise location information derived from, for example, your IP address or postal code. Fibreplus will NOT access precise-real time location information from your device unless you grant permission to do so.



• Cookies and Similar Technologies
  

  A “cookie” is a file of information placed on your device when you visit a website. Cookies and similar technologies can enhance your user experience by saving your preferences, personalizing your online experience, and sometimes providing you with advertising which is tailored to your interests.

  Fibreplus Online Services or Apps use “session cookies”. A session cookie does not identify you personally and expires after you close your browser.

  Fibreplus Online Services or Apps also use “persistent cookies”. These cookies do not expire when you close your browser. Persistent cookies stay on your device until you delete them or they expire. By assigning your device a unique identifier, Fibreplus are able to create a database of your previous choices and preferences which can be provided by Fibreplus automatically, saving you time and effort on future visits.

  If you access Fibreplus Online Services or Apps, you will be presented with information regarding this policy. Please note that by continuing to use the services/apps you agree to receive cookies that are strictly necessary for the service delivery.



• Analytics and Advertising
  

  Fibreplus uses third-party analytics services to better understand how users engage with Fibreplus Online Services or Apps, including services provided by Google.
  Please use the following links for more information about how Google collects and uses data when you visit their partners’ websites or apps: www.google.com/policies/privacy/partners/



• Information from Business Partners and other Third Parties
  

  Fibreplus may also obtain personal information from other third-party sources, including publicly and commercially available sources. Fibreplus may combine the information received from Business Partners and other third-party sources with information collected from you or your device, as described above.

You have choices about the personal information you provide Fibreplus. You may choose not to provide information that Fibreplus request, but if you do so, Fibreplus may not be able to provide you a relevant service or a particular feature for a Fibreplus Online Service, App, or product.

Use of Your Personal Information

Fibreplus may use your personal information to:

• Develop and manage relationships with you and Business Partners. This may include:
  • delivering services or carrying out transactions that you or Business Partners have requested;
  • providing information about Fibreplus products, services, and transactions, and advertisements, that may be of interest to you;
  • providing you and Business Partners a more consistent experience in interacting with Fibreplus, including by learning more about you and how you use and interact with Fibreplus Online Services, Apps, products, and services; and
  • planning, managing, and performing under contractual relationships with Business Partners.


• Communicate with you or your company. This may include:
  • informing you of Fibreplus products, services, and promotional activities that may be of interest to you or your company - if such permission has been granted;
  • providing information about relevant Fibreplus products, services, and transactions, including, for example, pricing information, technical data, invoice, shipping, or production information, warranty or recall information, or information about product or service improvements;
  • responding to questions or inquiries that you make, including customer service requests; and


• Provide and improve Fibreplus Online Services, Apps, products, and services. This may include:
  • customizing them to your preferences or interests, making them more compatible with your technology, or otherwise making them easier to use;
  • maintaining the security of and otherwise protecting them; and
  • developing new Fibreplus Online Services, Apps, products and services.


• Address legal issues. This may include:
  • complying with Fibreplus' obligations to retain certain business records for minimum retention periods;
  • establishing, exercising, or defending legal claims;
  • complying with laws, regulations, court orders, or other legal process;
  • detecting, preventing, and responding to fraud, intellectual property infringement, violation of contracts or agreements, violations of law, or other misuse of Fibreplus Online Services, Apps, products or services; and
  • protecting Fibreplus’ rights or property, or yours or others’ health, safety, welfare, rights, or property.

Fibreplus may also use your personal information for other uses consistent with the context in which the information was collected or with your consent.

Fibreplus may anonymize or aggregate any of the information collected and use it for any purpose, including for research and product-development purposes. Such information will not identify you individually.

When Fibreplus May Share Your Personal Information

Fibreplus will not disclose your personal information except as described here:

• Fibreplus may share your personal information with other Fibreplus entities. When Fibreplus do so, these other Fibreplus entities will use your information in a manner consistent with this Policy, and all applicable privacy and data protection laws.
• Fibreplus may also share your personal information with third parties hired to perform support services for us. These third parties are required to use the personal information Fibreplus share with them only to perform services on behalf of Fibreplus, and to treat your personal information in compliance with all applicable privacy and data protection laws.
• In some cases, Fibreplus may share your personal information with third parties who partner with Fibreplus to provide products and services to customers, such as distributors. If so, Fibreplus will require Business Partners to use that information in a manner consistent with this Policy, and all applicable privacy and data protection laws.
• Fibreplus may share your personal information with third parties in a good faith belief that disclosure is necessary:
  • to comply with a law, regulation, court order, or other legal process;
  • to detect, prevent, and respond to fraud, intellectual property infringement, violation of contracts or agreements, violation of law, or other misuse of Fibreplus Online Services, Apps, products or services;
  • to protect Fibreplus rights or property or yours or others’ health, safety, welfare, rights, or property; or under similar circumstances. If such an event occurs, Fibreplus will take appropriate steps to protect your personal information.
• Fibreplus may share your personal information with third parties in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of Fibreplus, or under similar circumstances. If such an event occurs, Fibreplus will take appropriate steps to protect your personal information.
• Fibreplus may share your information with your permission or at your request.
• Fibreplus may share anonymized or aggregated information internally and with third parties for any purpose. Such information will not identify you individually.

Security of Your Personal Information

Your personal information will generally be stored in Fibreplus databases or databases maintained by service providers. Many of these databases are stored on servers located in the United Kingdom.

Fibreplus maintains reasonable safeguards to protect the confidentiality, security and integrity of your personal information. Although Fibreplus use security measures to help protect your personal information against unauthorized disclosure, misuse, or alteration, as is the case with all computer networks linked to the Internet, Fibreplus cannot guarantee the security of information provided over the Internet and will not be responsible for breaches of security beyond reasonable control.

Links to Third Party Internet Sites and Plugins

Fibreplus Online Services or Apps may contain links to websites or mobile apps that are not operated by Fibreplus and plugins from social media platforms and other third parties. Fibreplus provide these links and plugins as a service and do not imply any endorsement of the activities or content of the related websites, apps, or social media platforms, nor any association with their operators. To learn about the information collected by these third-party websites, apps, and plugins, please visit their privacy policies.

Access to Your Personal Information

You may review, correct and update personal information you provide to Fibreplus by completing a request form (link below) and sending it to gdpr@fibreplus.co.uk

Retention of Your Personal Information

How long Fibreplus keep your personal information will vary and will depend on the purpose and use of information collected. There are legal requirements that Fibreplus keep some types of data for specific periods. Otherwise, Fibreplus will retain it for no longer than is necessary for the purposes for which the data was collected.

Children

Most Fibreplus Online Services or Apps are not intended for children under 13 years of age. Fibreplus will not knowingly solicit or collect personal information from or about children under 13, or the relevant minimum age under applicable local legal requirements, except as permitted under applicable law.

Fibreplus B2B Services

Some Fibreplus products, services, Online Service, and Apps are intended for use by Business Partners, including business customers (“Fibreplus B2B Services”), and your use of them is administered by your company. In such cases, authorized personnel at your company may have access to your personal information collected by these Fibreplus B2B Services, and your company may have policies applicable to your use of them. Fibreplus is not responsible for Business Partners’ policies and practices related to data privacy and security, which may be different from this Privacy Policy and any applicable Specific Privacy Statements. If your company is administering your use of a Fibreplus B2B Service, please contact your company with any privacy questions related to your use of that Fibreplus B2B Service. If there is a conflict between this Policy and an agreement between Fibreplus and its Business Partner for a Fibreplus B2B Service, then the agreement between Fibreplus and its Business Partner will control.

Additional Information

• Data controller and contact information The controller for personal data collected under this Privacy Policy is Fibreplus
• Processing on the basis of performance of a contract. Examples of situations in which Fibreplus process personal information as necessary for performance of a contract include transactions in which you purchase a product or service from Fibreplus, on your own behalf, through a Fibreplus Online Service or App.
• Processing on the basis of consent. Examples of processing activities for which Fibreplus uses consent as its legal basis include:
  • collecting and processing precise location information from your mobile device;
  • sending promotional emails when consent is required under applicable law; and
  • processing personal data on Fibreplus Online Services or Apps through cookies and similar technologies when consent is required by applicable law.
• Processing because Fibreplus is under a legal obligation to do so. Examples of situations in which Fibreplus must processes personal data to comply with its legal obligations include:
  • payment of taxes and other government levies;
  • providing your personal data to law enforcement agencies and other governmental bodies when required by applicable laws;
  • retaining business records required to be retained by applicable laws; and
  • complying with court orders or other legal process.

Additional information about the retention of your personal data

To determine the period for which your personal data will be retained in accordance with this Policy, Fibreplus consider criteria such as:

• any applicable legal requirements to retain data for a certain period of time;
• any retention obligations related to actual or potential litigation or government investigations;
• any retention requirements in relevant agreements with Business Partners - such as Awarding Bodies;
• the date of your last interaction with Fibreplus (including with Fibreplus Online Services, Apps, communications, etc.);
• the length of time between your interactions with Fibreplus;
• the sensitivity of the data; and
• the purposes for which the data was collected.

Your individual rights

In accordance with the applicable laws in the European Union, you have the following rights with respect to your personal data, which apply differently in different circumstances: right of access, right to rectification, right to erasure, right to restriction of processing, right to data portability and right to object to processing. Most of these rights are not absolute. If you make a request to exercise your rights, Fibreplus will respond within one month, but have the right to extend this period by two additional months, where necessary. If Fibreplus extend the response period, you will be informed within one month from your request. You can exercise your rights by completing the request form (link below) and sending it to gdpr@fibreplus.co.uk

CCTV Policy

• Fibreplus use closed circuit television (CCTV) and the images produced to prevent or detect crime and to monitor the company buildings and grounds, in order to provide a safe and secure environment for customers, staff and visitors, and to prevent loss or damage to property.
• The system comprises a number of fixed and dome cameras;
• The system does not have sound recording capability;
• The CCTV system is owned and operated by Fibreplus;
• The CCTV is monitored centrally from the office;
• Access to the images is controlled by Fibreplus and is password protected
• The introduction of, or changes to, CCTV monitoring will be subject to consultation with staff and members of Fibreplus;
• Fibreplus is registered with the Information Commissioner under the terms of the Data Protection Act 1998;
• The use of CCTV, and the associated images are covered by the Data Protection Act 1998.
• All authorised operators and employees with access to images are aware of the procedures that need to be followed when accessing the recorded images.
• Through this policy, all operators are made aware of their responsibilities in following the CCTV Code of Practice. The Data Controller will ensure that all employees are aware of the restrictions in relation to access to, and disclosure of recorded images by publication of this policy.
• CCTV warning signs are clearly and prominently placed at the main external entrance to the building, including further signage in other areas in close proximity to camera positions.
• In areas where CCTV is used, Fibreplus will ensure that there are prominent signs placed within the controlled area.
• The original planning, design and installation of CCTV equipment endeavoured to ensure that the scheme will deliver maximum effectiveness and efficiency but it is not possible to guarantee that the system will cover or detect every single incident taking place in the areas of coverage.
• Cameras are sited so that they only capture images relevant to the purposes for which they are installed (described above) and care will be taken to ensure that reasonable privacy expectations are not violated.
• Individuals have the right to request access to CCTV footage relating to themselves under the GDPR; if such footage exists.
• Fibreplus reserves the right to refuse access to CCTV footage where this would prejudice the legal rights of other individuals or jeopardise an on-going investigation.
• Complaints and enquiries about the operation of CCTV within the building should be directed to the Data Protection Officer in the first instance.

Questions about this Policy or Privacy Statements

If you have any questions about this Policy or use of your personal information, please contact Fibreplus data protection officer at:

Changes to this Policy and Privacy Statements

Changes to this Privacy Policy will be posted on this site, along with information on any material changes. Fibreplus reserves the right to update or modify this Policy and any Specific Privacy Statements at any time and without prior notice.

This Policy was last revised in December 2018.