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PRIVACY POLICY

Privacy Policy

The purpose of this Privacy Policy is to set out how Totterdells Communications (Ireland) Limited ("Totterdells" "us" "we" or "our") obtains and uses your personal information ("Data") and how we comply with applicable data protection and privacy laws. You should read this policy in conjunction with any the terms and conditions of any service that you use, or, that is provided by Totterdells to you, including for example, our Pay monthly service, Online Shop and our Website. Each Totterdells services is subject to terms and conditions which detail how we use your Data collected in the course of providing these services. By using such services you agree that Totterdells may process your Data as set out in those terms and conditions.

 

1. How we obtain your Data

1.1 Totterdells obtains Data relating to you through your dealings with us. The include, for example; when you become a customer; when you shop on our Online Shop; when you register your details with us; when you submit enquiries to us/contact us; when you participate in promotions, competitions or prize draws; when you use Totterdells products and services; and, when you submit information to us by participating in Totterdells surveys.

1.2 We will collect your Data lawfully and fairly and we will advise you at all times when we are collecting your Data and the purposes for which it is collected.

 

2. How we use your Data

2.1 We will use your Data for the purpose for which it was originally provided and where we intend to use it for any other the purpose we will explicitly notify you in advance.

2.2 Your Data will be accurate and complete and, where necessary, kept up to date.

2.3 Data will be adequate, relevant and not excessive in relation to the purposes for which it was obtained.

2.4 Data will be kept only for clear and legal purposes.

 

3. Disclosure of Information

3.1 Data will not be disclosed in any manner incompatible with the purposes for which it was obtained.

3.2 We will only disclose your Data to third parties who are our employees and for purposes relating to the services we provide to you.

3.3 We will disclose Data where we are compelled to do so by law.

3.4 We will share your information with carefully selected third parties who provide services to you on our behalf. In these circumstances we will ensure that adequate contractual and technical safeguards are in place to protect your Data and that such third parties only use your Data in accordance with our instructions this Privacy Policy and all applicable laws. The information you provide to us may occasionally be passed to third parties located outside the European Economic Area. Countries outside the European Economic Area do not always have strong data protection laws. However we will always take steps to ensure adequate contractual and technical safeguards are in place to protect your Data and that such third parties only use your Data in accordance with our instructions, this Privacy Policy and all applicable laws.

 

4. Retention

4.1 While you are a user of the Totterdells services, Totterdells will acquire and process information about your use of the Totterdells services. Totterdells will retain this information for the primary purpose for which it was obtained and for other legitimate purposes including, where required by law.

4.2 Totterdells may, but is not obliged except where we are required by law as specified below, retain the following specific data types for the periods and purpose set out below:

Traffic Data

Data processed for the purpose of the conveyance of a communication (e.g. connecting a voice call, sending an sms etc.) on our network and/or for billing you with the cost of such a communication.

 

Processing

Period

For market research, product development, marketing, customer profiling and relationship management.

Two years.

Billing (Pay monthly only)

Six years plus the current year in the event that the bill is legally challenged.)

Interconnection payments (Payments made to third party network operators for the transmission of communication on their network)

Six years plus the current year in the event that the bill is legally challenged.

Retention exclusively for the purpose of Totterdells complying with its legal obligation to retain traffic data for the purpose of State law enforcement investigations and prosecutions.

Three years

 

Data Services Records

Data processed for the purpose of providing data services including Totterdells active, i-mode, website browsing and downloading content. Data records do not include content of the data. (Note i-mode® and WAP logs show the URL accessed, but not any images or text)

Processing

Period

For market research, product development, marketing, customer profiling and relationship management.

Two years.

Billing

Six years plus the current year in the event that the bill is legally challenged.

Interconnection payments (Payments made to third party network operators for the transmission of communication on their network)

Six years plus the current year in the event that the bill is legally challenged.

 

Location Data

Data processed, indicating the geographic position of the phone or other device of a user of Totterdells’s services based on network cell identification.

 

Processing

Period

Obtaining, storage and disclosure for the purpose of providing value added location-based services in accordance with subscriber’s instructions. The value added location-based service may be provided by Totterdells or by third parties with whom the subscriber has contracted to provide the service.

For the period from receipt of the subscriber’s instructions until such instructions expire or are revoked by the subscriber.
Subscriber may suspend this processing during this period on request free of charge.

Retention exclusively for the purpose of Totterdells complying with its legal obligation to retain traffic data for the purpose of State law enforcement investigations and prosecutions.

Three years

5. Access to your Data

5.1 You have a right to receive a copy of your Data, which personally identifies you, held by Totterdells. We may charge you an administration fee to cover the cost of carrying out your request. You should write to the Totterdells Communications (Ireland) Limited, Unit 45, Southern Cross Business Park, Boghall Road, Bray, Co. Wicklow marked "Data Access Request". You should include adequate information to identify yourself and, such other relevant information that you may have that will reasonably to assist us in fulfilling your request. Your request will be dealt with as soon as possible and will take not more than 40 days to process.

5.2 You also have a right to have inaccurate information corrected. If you discover that Totterdells holds inaccurate information about you, you may instruct us to correct that information. Your instruction should be in writing to the address at 5 (i) above. A request will be dealt with as soon as possible and will take not more than 40 days to process.

5.3 You have expressed a preference as to the manner in which Totterdells may contact you in relation to Totterdells marketing and promotional information. You may change your preference in this regard at any time by phoning us on 1890 276 276, by writing to the address specified at 5 (i), or where we have contacted you by email, by using the opt-out facility to indicate your preference not to be contacted subsequently by email.

 

6. Cookies

6.1 A "cookie" is a piece of information, like a tag, which some websites create on your PC which identifies your PC whenever you visit that website. In order to provide you with the best possible online experience, Totterdells may create cookies when you visit the Totterdells site. Cookies may be used to help you in the following ways: to limit the frequency with which you will see particular advertisements or Totterdells announcements on the site; to identify your defaults if you have set up a customised homepage; to keep track of how many times you do specific things whilst using Totterdells, to track where you have come from if you were referred to our website; to provide you with self-help information; and to make our email offers more relevant to you by taking into account your response to previous email offers.

6.2 Our cookies will not be used to analyse your visits to other sites. Agents of Totterdells, who assist in the serving, and targeting of advertisements, promotions and other marketing messages may use cookies to collect anonymous data such as how many people have viewed a particular page each day. Data collected by cookies will not otherwise be passed to any third party. You have the ability to accept or decline cookies. Most PCs automatically accept them but you can modify your browser settings to decline if you so wish. If you decline cookies, some aspects of the Totterdells site may not work on your PC and you may not be able to access areas you want on the website. For this reason we recommend that you accept cookies. Totterdells will not store any sensitive information relating to you or your user account in a cookie.

 

7. General

7.1 We reserve the right to amend this Privacy Policy to reflect changes in Totterdells practices and the legal and regulatory environment in which we operate.