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‍‍‍‍‍‍sales@xoomtalk.com

+44 (0) 1273 900090

Want to get started?

Contact one of our friendly team

sales@xoomtalk.com

+44 (0) 1273 900090

Want to get started?

Contact one of our friendly team

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Copyright © xoomtalk 2016. All rights reserved.

OUR TRUSTED PARTNERS

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Introduction

‍‍‍For the purpose of this Privacy‍‍‍ Policy "you" or "your" means any end user accessing our App or our Website (as defined below) or using any of our communication services, which could be the personnel of our business customers or the end users of one of our resellers and their personnel     (or end users or personnel of prospective customers or resellers).

xoomtalk is the trade name of Xoom Limited, a limited company incorporated in England and Wales registered under Number 03997742 whose registered office is at Elm Park House Elm Park Court Pinner, Middlesex HA5 3NN (“Xoom”, "we" or “our” or “us”).  

This Privacy Policy together with our cookies policy (the "Cookies Policy"), xoomtalk website terms (the "Website Terms") and any other documents referred to on it sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by us. This Privacy Policy also sets out how you can instruct us if you prefer to limit the use of that Personal Data and the procedures that we have in place to safeguard your privacy.  

Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.  

For the purpose of this Privacy Policy, Data Protection Legislation means: (i) the General Data Protection Regulation 2016/679 (the “GDPR”) applicable in the European Union, including the UK until any UK data protection legislation replaces or adopts the GDPR in the UK and; (ii) then such UK data protection legislation replacing the GDPR once in force and applicable. For the purpose of the Data Protection Legislation, the data controller is Xoom.  

By using our communications services or xoomtalk’s or our supplier’s applications, such as portals, desktop clients or soft phone solutions (the "App") or by accessing our Website at www.xoomtalk.com (the "Website") or any other related apps or websites or submitting information to us (through or in connection with the App or the Website), you signify your consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy.  If you do not agree with this Privacy Policy, you must not use our communication services, the App, access the Website or submit information to us through or in connection with the App, the Website or otherwise.

1 Personal Data we may collect from you

1.1 Personal Data you give us (“Submitted Personal Data”):

(a) Personal Data that you provide to us by subscribing to any one of our services, or by requesting further services (e.g. when you register with us to have access to our communication services as the representative of a business end user or as a reseller), filling in forms, submitting information by email, through the Website or the App or through surveys;  

(b) the information you give us may include your:

(i) name and address;

(ii) e-mail address;

(iii) Username and password;

(iv) your phone number;

(v) your IP address (this is your computer's individual identification number for internet connection); and

(vi) financial information (e.g. when you purchase any hardware from us or pay for our services).

(c) records of communications between you and us relating to services provided by us to you.  If you contact us, whether through the App, the Website or otherwise we may keep a record of that correspondence.  For example, if you submit a query, a complaint, report a problem with our service, Website or App, or otherwise liaise with our customer service, technical support or any other department in our company; and  

(d) we may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.  

1.2 Personal Data we collect about you and your devices. Each time you visit our Website or use our App or use our services we may automatically collect the following information:

(a) technical information including:

(i) the type of PC you use and your IP address is automatically logged by our web server;

(ii) device information (mobile devices or computers) ("Device Personal Data"):

1.2.1 the type of device you use, a unique device identifier (for example, your device's IMEI and IMSI number, the MAC address of the device's wireless network interface, or the mobile phone number used by the device), network information, your device’s operating system, the type of browser you use and time zone setting;

1.2.2 your mobile device’s IMEI and IMSI, collected to identify individual devices for the purposes of collating information about testing, but this data is not used to identify individual users; and

1.2.3 information about your mobile device performance, such as your service provider, the strength of the radio signal, and what type of connection (e.g. 3G, 4G, Wi-Fi, etc.) service you have;

(iii) this data may be stored on your device in a protected private area for the App which may periodically be uploaded to our servers. Older data may also periodically be deleted from your device;

(b) details of your use of our App or your visits to our Website including, but not limited to traffic data, weblogs and other communication data ("Log Personal Data");

(c) Personal Data regarding:

(i) your use of our services including but not limited to telephone numbers, SMS, MMS, emails and other electronic communications received or made by you and the date, time, cost and duration, of such communications, your browsing history (including web sites you visit) and location data, internet PC location for broadband, address location for billing, delivery, installation or your phone location and other records of use made by you of services provided by us to you; and

(ii) calling line identification/connection logs when you connect to our remote access servers;

“Communications Data”

(d) location information. We may also use GPS technology or similar technologies, to determine your current or past location (e.g. to enable us to provide our communication services (the "Location Personal Data")). Some of our services require your Personal Data to work efficiently;

(e) Personal Data we receive from other sources ("Third Party Personal Data"), such as communications data that we receive from other communication providers for the purposes of providing our communication services. When required by Data Protection Legislation, we will notify you when we receive information about you from them and the purposes for which we intend to use that information;

(f) unique application information: when you install or uninstall an App or when such App searches for automatic updates, the information about your installation, for example, the type of operating system, may be sent to us ("Unique App Information");

(g) your account name and account numbers held by financial institutions from which your payments for services provided by us are made; and

(h) Personal Data obtained as a result of credit checks which you authorise us to carry out.

1.3 We may check some of the information that you provide against third party databases to confirm that it is accurate.

1.4 We will process and manage payments from our customers or resellers directly via direct debit, BACS or cheques. If we decide to accept credit card payments or alternative payment means and we use third party payment agents to manage payments, you will be asked by the payment agent for your card details and billing address, or your bank account details, and other information necessary to complete any transaction.  This information will held by the third party payment agent, and you will be asked to agree to their terms and conditions, including their Privacy Policy, in completing the payment steps.

1.5 We have no access to your credit or debit card details, but we may have access to your billing address and payment history in order to assist with customer service enquiries.  Under no circumstances are these details disclosed to any third parties other than those who need to know this information for the performance of the services requested by you.

2 How we may use Personal Data collected from you

2.1 We may process this information for the purpose of:

(a) providing you with electronic communications services including and without limitation to: (i) provisioning or connecting your service and update you on when we’ll deliver, connect or install your products and services; (ii) network routing; (iii) investigating and fixing faults in relation to the services; (iv) web and email services; and (v) investigating complaints. Lawful Basis: your consent, performance of our contract with you or necessary for our legitimate interests;

(b) send you product or service-information messages to confirm your order and tell you about any changes that might affect your service.  Lawful Basis: your consent, performance of our contract with you or necessary for our legitimate interests;

(c) following up any payments that you may owe us. Lawful Basis: performance of our contract with you or necessary for our legitimate interests;

(d) administering contractual agreements or arrangements necessary to provide services to you. Lawful Basis:  your consent, performance of our contract with you or necessary for our legitimate interests;

(e) informing you about services and events provided or organised by us that may be of interest to you. Lawful Basis:  performance of our contract with you or necessary for our legitimate interests;

(f) enhancing and personalising the services that we offer to you. Lawful Basis:  performance of our contract with you or necessary for our legitimate interests;

(g) providing you access to all parts or features of our services (including our customer portals) or the Website. Lawful Basis:  performance of our contract with you or necessary for our legitimate interests;

(h) communicating with you on any matter relating to the provision generally of our services. Lawful Basis:  performance of our contract with you or necessary for our legitimate interests;

(i) dealing with your inquiries and requests, including contacting you if necessary. Lawful Basis:  performance of our contract with you or necessary for our legitimate interests;

(j) carrying out our obligations arising from any contracts entered into between you and us. Lawful Basis:  performance of our contract with you or necessary for our legitimate interests;

(k) administering accounts records. Lawful Basis:  performance of our contract with you or necessary for our legitimate interests;

(l) processing your payments. Lawful Basis:  your consent, performance of our contract with you or necessary for our legitimate interests;

(m) contacting you for your views on our services and notifying you occasionally about important changes or developments to our services or the Website. Lawful Basis:  performance of our contract with you or necessary for our legitimate interests;

(n) carrying out market research campaigns. Lawful Basis: your consent, performance of our contract with you or necessary for our legitimate interests;

(o) improving and developing our services or the Website. Lawful Basis: necessary for our legitimate interests;

(p) ensuring that content from our Website is presented in the most effective manner for you and for your computer or mobile device. Lawful Basis: performance of our contract with you or necessary for our legitimate interests;

(q) debt recovery or debt tracing, crime, fraud and money laundering compliance. Lawful Basis: performance of our contract with you or necessary for our legitimate interests, or to comply with laws and regulations; and

(r) help prevent and detect fraud and crime and prevent and detect criminal attacks on our network or against your or our equipment.  We monitor traffic over our network, trace nuisance or malicious calls, and track malware and cyber-attacks. Lawful Basis: performance of our contract with you or necessary for our legitimate interests, or to comply with laws and regulations.

2.2 If you are an existing customer, and you have not opted out of this, we will only contact you by electronic means (e-mail, SMS or push notifications) with information about goods and services similar to those which were the subject of a previous sale to you. You will be entitled to opt out from this by contacting us or by clicking "unsubscribe" or “opt-out” in the electronic communication you receive.

2.3 We may also gather this information and statistics for the purposes of monitoring the usage of our services, the App or the Website and may provide such aggregate information to third parties such as the communication operators. For instance, we will collect aggregated data (i.e. aggregated statistics that describe broadband performance).

2.4 You may ask us to provide you with information about our services or services offered jointly with or on behalf of other organisations by sending us an e-mail to hello@xoomtalk.com or writing to us at the following address: Level 6, Vantage Point, New England Road, Brighton, BN1 4GW.

2.5 If you choose to post messages on any online forum or other message platforms that we may make available for this purpose on the App or the Website, we may collect that information you provide to us.  We may retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.

2.6 If you stop using our services, the App or our Website or your permission to use the App, the Website or our services is terminated, we may continue to use and disclose your personal information in accordance with this Privacy Policy (as amended from time to time) and as permitted by Data Protection Legislation.  

3 Personal Data security

3.1 The Internet is not a secure medium. However, we have put in place various security procedures with regards to the App and the Website and your electronic communications with us, as set out in this Privacy Policy.  

3.2 Where relevant, with respect to online payments, all your payment details will be passed from your browser for processing using encryption. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology or other suitable encryption technology.

3.3 Where you have been allocated a user admin area or access to portals (an "Account"), this area is protected by your user name and password, which you should never divulge to anyone else. You are responsible for keeping this password confidential. We ask you not to share a password with anyone.

3.4 Please be aware that communications over the Internet, such as emails/webmails are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered – this is the nature of the World Wide Web/Internet.  

3.5 We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.  

3.6 We believe that we have appropriate policies, rules and technical measures to protect the Personal Data that we have under our control (having regard to the type and amount of that Personal Data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.  

3.7 All of our employees and data processors that have access to, and are associated with, the processing of your personal information are obliged to respect the confidentiality of our users’ information.  

3.8 We ensure that your information will not be disclosed to government institutions or authorities except if required by law or when requested to by regulatory bodies or law enforcement organisations.  

3.9 Certain services may include social networking, chat room or forum features. When using these features please ensure that you do not submit any Personal Data that you do not want to be seen, collected or used by other users.

4 To whom will your Personal Data be disclosed?

4.1 Your information may, for the purposes set out in this Privacy Policy, be disclosed for processing to:

(a) our employees;

(b) any member of our group companies and their employees, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006;

(c) successors in title to our business;

(d) a prospective seller or buyer if we sell or buy any business or assets, in which case we will disclose your Personal Data to such business or assets;

(e) a buyer, if xoomtalk or substantially all its assets are acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets;

(f) third party consultants, contractors or other service providers who may access your personal information when providing services (including but not limited to IT support suppliers) to us or to our relevant and/or mutual customers and/or prospective customers;

(g) government bodies and law enforcement agencies and in response to other legal and regulatory requests, if we are under a duty to disclose or share your Personal Data to comply with any legal or regulatory obligation or request. For instance, under investigatory powers legislation, we may need to share Personal Data about you to government and law-enforcement agencies, such as the police, to help detect and stop crime, prosecute offenders and protect national security;

(h) auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes;

(i) any third party where such disclosure is required in order to enforce or apply our end user terms, Website Terms and/or other agreements; and

(j) protect the rights, property or safety of xoomtalk, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

4.2 We may contract out part of our communications services as well as other ancillary services such as mailing, credit checking, provisioning, billing, regulatory compliance checks printing, web or email services, marketing, verification of sales and fault fixing to external service providers. We may disclose your personal information to these organisations but only so that they can provide you with the services that we have contracted out.  

4.3 We may disclose your personal information to other telecommunications service and equipment providers, resellers of communication services, credit providers, credit reporting agencies and organisations to whom we outsource services purpose of the services we provide to you or for fraud or crime prevention purposes.

4.4 At your request, we may disclose your information to directory providers so that your information can appear in telephone directories.

5 Your rights of access in relation to your Personal Data

5.1 Please note that these rights do not apply in all circumstances. You are entitled to:

(a) request access to your Personal Data (commonly known as a "data subject access request");

(b) request correction of the Personal Data that we hold about you;

(c) request erasure of your Personal Data. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;

(d) object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;

(e) request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:

(i) if you want us to establish the data's accuracy;

(ii) where our use of the data is unlawful but you do not want us to erase it;

(iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;

(f) request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information (i.e. not to hard copies) that you initially provided consent for us to use or where we used the information to perform a contract with you; and

(g) withdraw consent at any time where we are relying on consent to process your Personal Data. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

(h) Please write to contact details below.

5.2 Please quote your name and address and brief details of the Personal Data that you would like a copy of or which you would like to be corrected (this helps us to more readily locate your Personal Data).

5.3We will require proof of your identity before providing you with details of any Personal Data we may hold about you.

5.4You can write to us at any time to obtain a copy of your information and to have any inaccuracies corrected. Where appropriate under Data Protection Legislation, you may have your personal information erased, rectified, amended, ported or completed.  Please see our contact details below.

5.5 We try to respond to all legitimate requests within 1 (one) month. Occasionally, it may take us longer than 1 (one) month if your request is particularly complex or you have made a number of requests. In this case, we will notify you within 1 (one) month of the receipt of your request and keep you updated.

5.6 We may charge you a reasonable fee to you when a request is manifestly unfounded, excessive or repetitive, or we receive a request to provide further copies of the same information. Alternatively, we may refuse to comply with your request in these circumstances.

6 Cookies

6.1 We use cookies to distinguish you from other users of the App, or our Website. This helps us to provide you with a good experience when you use the App or browse our Website and also allows us to improve the App and our Website. For detailed information on the cookies, the way we use them and the purposes for which we use them, see our cookie policy.

7 Where we store and process your Personal Data

7.1 The Personal Data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or affiliates. Such staff may be engaged in, among other things, the provision of the services, the processing of your payment details and the provision of support services. By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy. We may implement the following safeguards for Personal Data transfers outside the EEA:

(a) Personal Data will only be transferred to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission; or

(b) we will use specific contract clauses approved by the European Commission, which give Personal Data the same protection it has in Europe; or

(c) when we use providers based in the US, we will transfer Personal Data to them if they are part of the Privacy Shield, which requires them to provide similar protection to Personal Data shared between the Europe and the US.

8 Your consent and changes to this Privacy Policy

8.1 By submitting any personal information (including, without limitation, your payment details) to us or by accessing our Website or downloading and/or using the App you consent to the use of information as set out in this Privacy Policy. We reserve the right to amend or modify this Privacy Policy and if we do so we will post the changes on the App and/or our Website. It is your responsibility to check the Privacy Policy every time you submit information to us.  Use will signify that you agree to any such changes.

8.2 In the event the purposes for processing personal information change, then we will contact you as soon as practicable and seek your consent where such notification relates to a new additional purpose for processing which is not compatible or similar to the originally specified purposes.  

9 Use of your Personal Data submitted to other Apps

9.1 We are not responsible for the privacy policies and practices of other apps or websites even if you accessed the third party app using links from our Website or App or by means of our services.  

9.2 We recommend that you check the policy of each app or website you visit and contact the owner or operator of such app if you have concerns or questions.  

10 Personal Data Retention

10.1 We will only retain your Personal Data for as long as you have consented or when it is necessary for us to provide you with our services or fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, reporting or regulatory requirements. For instance, by law we have to keep basic information about our customers (including contact, identity, financial and transaction data) typically for 6 (six) years after they cease being customers for tax purposes.

10.2 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.

10.3 In some circumstances you can ask us to delete your Personal Data.

10.4 In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

11 Further Personal Data

11.1 If you would like to let us know about something we have done, or failed to do, whether positive or negative, please let us know. Your comments enable us as an organisation to learn and continuously improve our services.

11.2 We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below:

email: dpo@xoomtalk.com

Post: xoomtalk DPO, Level 6, Vantage Point, New England Road,  Brighton, BN1 4GW

Telephone: 01273 900090

11.3 If you think there is a problem with the way we are handling your Personal Data, you have the right to complain to the Personal Data Commissioners Office at: https://ico.org.uk/

12 Updates to your Personal Data

12.1 If your personal details change, please help us to keep your information up to date by notifying us at dpo@xoomtalk.com.‍‍‍