Privacy Policy

Predict Mobile is committed to protecting your privacy. Please read our policy to understand how we will use and protect your personal information.  This policy explains when and why we collect personal information about people who use our website, how we use it, the conditions under which we may share it with others and how we keep it secure.

We may update this policy from time to time, so please check this page occasionally to ensure that you are happy with any changes.

Where Predict Mobile collects any personal information from you, the data controller (the company that is responsible for your privacy and determining how personal information collected is used) is the North Swell Technologies Limited (company number SC502996).

How we collect information from you

We will collect information, including personal information, about you when you interact with us.  This could include using our website or other services, like corresponding with us by phone, email or live chat, or where you sign up to receive emails from us.    This includes information that you provide when you register for an account, provide information and/or responses with a view to entering into a tender process through our website, search for price comparisons or similar information, or enter into a contract for the supply of services.

When you use our website, we automatically collect information about your device including your IP address, information about your visit and how you use our services.  We may combine this information with other information you have provided to us or which we have received from other sources.

What information we collect

The personal information that you provide may include the following:-

• your name, address and contact details
• name, address and contact details of staff members whom we should contact on your behalf
• financial information regarding your existing mobile services account and/or your service requirements
• information about the services we provide to you
• your account details, such as username, login details (for both our website and for your account with your existing mobile services supplier)

How we use the information

We may process your personal information in several different ways.  The main reasons are (i) to fulfil a contract with you, (ii) to comply with legal obligations, (iii) for our legitimate business interests (but only where your rights and interests do not override our legitimate interests) and (iv) where you have provided consent.  If you choose not to share your personal information with us or refuse certain contact permissions, we may not be able to provide you with the services you have asked for.

In particular, we may use your personal information to do the following (and have set out alongside each of these the principle reasons and the legal basis upon which we are using such personal information):

1. to register you as a user of our website and to provide information on our services to you (consent);

2. to provide you with services through our website, principally matching a customer of mobile services with a provider thereof (performance of a contract);

3. to assist with the conclusion of a contract for the supply of mobile services between the customer and supplier thereof (performance of a contract);

4. to provide you with information and predictions in respect of optimisation of mobile tariffs (performance of a contract);

5. to provide you with information that we or our associated companies offer, and which may be of interest to you (consent);

6. to customise or enhance your experience of our services (legitimate interests);

7. to administer our website and for internal business purposes (including, for example, data analysis and troubleshooting) (legitimate interests); and/or

8. to manage and operate your account and/or contract with us (performance of a contract).

Where you have provided sensitive personal information, we will only process this information where you have explicitly agreed for us to so.

From time to time, we may also use your information to contact you for market research purposes where you have consented to us contacting you for this purpose.

Security

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way.

We limit access to your information to those who have a genuine business need to know it.  Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We have procedures in place to deal with any suspected data security breach.  We will notify you and any applicable regulator of a suspected security breach where we are legally obliged to do so.

Data retention

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.

In some circumstances you can ask us to delete your personal information: see section on Your Rights below for further information.

In some circumstances we may anonymise your personal information (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.

Predictions

We will provide customers of Predict Mobile with email alerts on an ongoing basis containing predictions and guidance regarding their mobile usage and related contractual arrangements.  If you wish to opt out of these emails at any time then please contact us on unsubscribe@predictmobile.com.

Please note that, should you choose to opt out of prediction emails, we may still contact you with customer service information and important information about your account.

Sharing your personal information

Except as set out in this policy, we will only disclose your personal information to third parties in order to provide the services set out above to you.  We do not sell, rent or trade your personal information to third parties for marketing purposes without your consent.

We may share your personal information with other third parties in the following circumstances:

• where we undergo a change of control or sell or transfer our business or assets, we may disclose information to a third party buyer as part of the sale and purchase process;
• where we have a duty to disclose or share your personal information to comply with a legal obligation;
• to prevent or detect fraud or crime; or
• to customers and/or suppliers of Mobile Services for the purpose only of providing tendering and/or matching services through our website, or facilitating the conclusion of a contract between such customers and suppliers.

We may also share data with third parties where it has been anonymised (meaning you are no longer able to be identified from the information).

We will get your express opt-in consent before we share your personal information with any company outside our group of companies for marketing purposes.

Links to Third Party Websites

Our website may contain links to other websites.  This policy does not apply to those other websites and we do not accept liability for the content of any other website.  Please check the privacy policy of any other website before submitting any personal information to it.

Cookies

Predict Mobile uses cookie technology to track or record information about visitors to our site. Please see our Cookie Policy for more details.

Your Rights

You have a number of important rights in respect of your personal information which can be exercised free of charge. In summary, those include rights to:

• fair processing of information and transparency over how we use your use personal information
• access to your personal information and to certain other supplementary information that this policy is already designed to address
• require us to correct any mistakes in your information which we hold
• require the erasure of personal information concerning you in certain situations
• receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• object at any time to processing of personal information concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• object in certain other situations to our continued processing of your personal information
• otherwise restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you would like to exercise any of those rights, please contact us using the details below.  Although there is no specific method you should use to exercise these rights, we will need sufficient information to identify you and we might request further information to verify your identity if we reasonably require.

Contact

Should you have any questions regarding our Privacy Policy or the ways in which we process your personal information, please contact us at:

Predict Mobile

Flux

1 Water’s Edge

Camperdown Street

Dundee

DD1 3HY

07500900700

Email: datacontroller@predictmobile.com

If you have a concern or wish to make a complaint about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (“ICO”). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.