Last updated: 12th of March 2021
PLEASE READ THIS POLICY CAREFULLY
Protecting your data, privacy and personal information is very important to thumbtel limited (“our”, “us” or “we”). This policy sets out the basis on which any personal data about you will be processed and applies to (i) activities on or through our public Website www.thumbtel.com (the “Website”) (ii) our direct marketing activities and (iii) your use of our Another Number or HulloMail services.
Identity and contact information of the Data Controller
For the purposes of data protection legislation in the European Union, the data controller (i.e. the person that determines the purposes and manner in which your personal data are processed) is Thumbtel Ltd. Thumbtel Ltd is a company incorporated and registered in England and Wales (company number 06504172) with its registered office at 2nd Floor, College House, 17 King Edwards Road, Ruislip, London, HA4 7AE, United Kingdom.
Personal information we may process about you
A breakdown of the personal data we may process is set out in a table at the end of this policy, together with the other information we are required to provide.
|Another Number and HulloMail service||We process personal information in order to provide you with the Another Number / HulloMail service.
If you are a Team Administrator, you will be asked to provide information about your team to enable them to use the Another Number service. You must have obtained the requisite permission from the individuals whose data you provide us with before sharing that data with us.
If you are a user of the Another Number Team service, we may have received information about you from the Team Administrator.
Please note that payment details (such as credit card information) are not processed by us and are instead handled by our payment providers like Stripe.
|Website||Our Website operates primarily to market our Another Number and HulloMail services. To the extent we collect personal data via our Website, our main purpose is to better serve our customers and to improve the function of the Website.|
|Direct marketing||Where we send electronic marketing communications, we will provide an option to unsubscribe or opt-out of further communication or you may opt out by contacting us at email@example.com.
We will not sell your personal data (or any other data you provide us with) to third-parties for marketing purposes.
How personal data are collected
We may obtain personal data about you in three main ways:
- You provide us with your personal data (such as when you register to use our Another Number / HulloMail service).
- Personal data is collected automatically (such as the automatic recognition of your IP address or placement of cookies on your device).
- Personal data is collected, and provided to us, by a third party (such as (i) information provided by communications providers when you make and receive voice calls or SMS (ii) if you are a user of our Another Number Team service, we may have received information about you (including your name and mobile telephone number) from the Team Administrator or (iii) when you use the Another Number or HulloMail service, we may collect and process data that is contained in SMS / instant messages, voicemails and other electronic communications.
Where we store your personal information
The personal data that we collect from you may be transferred to and stored at a destination outside of the European Economic Area (“EEA”). This data may also be processed by staff operating outside of the EEA who work for us or for one of our business partners or service providers. Further information is provided in the table at end of this policy. Please contact us at firstname.lastname@example.org if you would like further details on the specific safeguards applied to the export of your personal data outside the EEA.
International transfer of personal information
Your personal information may be collected, transferred to and stored by us in the UK or the EEA and by affiliates and third-parties that are based in other countries.
Therefore, your personal information may be processed outside your jurisdiction, and in countries that are not subject to an adequacy decision by the European Commission or your local legislator or regulator, and that may not provide for the same level of data protection as your jurisdiction. We ensure that the recipient of your personal information offers an adequate level of protection and security, for instance by entering into appropriate data processing agreements and, if required, standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission (Art 46 GDPR) or other applicable regulator.
How long we store your personal information
Details of how long we store your personal information are set out at the end of this policy. Please note that some personal data may need to be retained for longer than this to ensure we can comply with applicable laws and internal compliance procedures, including retaining your email address for marketing communication suppression if you have opted not to receive any further marketing.
Disclosure of your information
Details of who we disclosure your personal information to are set out at the end of this policy. We may also disclose your personal information to third parties in the following circumstances:
|Purpose of disclosure and third party(s) to which disclosure might be made||Use Justification|
|If you request we do so.||You have provided your consent.|
|To a member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006||Legitimate interests (i.e. for business administration).|
|If we sell any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets.||Legitimate interests (i.e. to buy or sell business assets).|
|If thumbtel or substantially all of its assets are acquired by a third party, personal information about our customers will be one of the transferred assets.||Legitimate interests (i.e. to dispose of our business).|
|If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of thumbtel, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.||Processing is necessary for compliance with a legal obligation, or processing is necessary in order to protect the vital interests of a natural person|
|We may disclose your personal information with our contracted service providers who provide services such as IT and system information and hosting, research and analytics and marketing.||Legitimate interests (i.e. to perform our contract with you and improve our services)|
|We may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.||Legitimate interests (i.e. to cooperate with law enforcement and regulatory authorities)|
We may also share anonymous or de-identified data with our contracted service providers for the purpose of helping us in such analysis or improvements to our services.
Under the General Data Protection Regulation (EU) 2017/676, you have the following rights (subject to certain limitations):
|Right of access||You have the right to obtain from us confirmation as to whether your personal data are being processed, and, where that is the case, access to such personal data.|
|Right to Rectification||We will use reasonable endeavors to ensure that your personal data is accurate. In order to assist us with this, you should notify us of any changes to the personal data that you have provided to us by sending us a request to rectify your personal data where you believe the personal data we have is inaccurate or incomplete.|
|Right to erasure / ‘Right to be forgotten’||Asking us to delete all of your personal data will result in us deleting your personal data without undue delay (unless there is a legitimate and legal reason why we are unable to delete certain of your personal data, in which case we will inform you of this in writing).|
|Right to restriction of processing||You have the right to ask us to stop processing your personal data at any time.|
|Right to data portability||You have the right to request that thumbtel limited provides you with a copy of all of your personal data and to transmit your personal data to another data controller in a structured, commonly used and machine-readable format, where it is technically feasible for us to do so.|
|Right to complain||You have the right to lodge a complaint to a supervisory authority such as the Information Commissioner’s Office in the UK (see www.ico.org.uk). Although we encourage our customers to engage with us in the event they have any concerns or complaints. You can do so by writing to us at email@example.com.|
All of these rights can be exercised by contacting us at firstname.lastname@example.org.
thumbtel limited will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above. However, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the personal data this will usually be free of charge. However, any further copies requested may be subject to reasonable fees based on administrative costs.
Where you request us to rectify or erase your personal data or restrict any processing of such personal data, we may notify third parties to whom such personal data has been disclosed of such request. However, such third party may have the right to retain and continue to process such personal data in its own right.
Children under the age of 13
Neither the Website nor our Another Number or HulloMail services are aimed at children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are under 13, please do not use our services or provide any information to us through the Website. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at email@example.com.
Changes to this policy
|Personal data collected||Why personal data are collected||Legal basis for processing||Period for which your data will be stored||Will your personal data will be shared with third parties?||Transfers outside the European Economic Area|
|1.||The unique device identifier of your mobile device.||To provide you with the Another Number / HulloMail service and for account administration purposes.||Processing is necessary for the performance of our contract with you.||For as long as you use the Another Number / HulloMail service, plus 90 days.||We may share this data with Google (crashlytics) to help us diagnose issues and improve the service.||Google may store this data in the USA. We rely on the fact that Google is certified as complying with Privacy Shield.|
|2.||Your full name, email address, and mobile phone number.||To provide you with: (1) an Another Number / HulloMail account; (2) support services; and (3) important information about our services; (4) voicemail / missed call notifications.||Processing is necessary for the performance of our contract with you.||For as long as you use the Another Number / HulloMail service, plus 90 days.||We may share your email address with Amazon Web Services so that we can provide you with missed call / voicemail notifications by email.
We may also share your mobile number with Google (crashlytics) to help us diagnose issues and improve the service.
|Amazon and Google may process your personal information in the USA. We rely on the fact that Amazon and Google are certified as complying with Privacy Shield.|
|3.||Any personal data contained in your voicemail greeting||To provide you with our enhanced voicemail greeting function.||You have provided your consent. You can disable this functionality at any time.||Until (1) you disable the personal voicemail greeting functionality or (2) you cease using the Another Number / HulloMail service, plus 90 days – whichever is shorter.||No. However, anyone may call and listen to your voicemail greeting.||No|
|4.||The full name, email address and mobile number of any third-party contact that you add to the address book of the Another Number app.||To improve user-experience, caller information and back-up / sync across devices.
|Processing is necessary for our legitimate interests (i.e. to improve the services) and/or the legitimate interests of the Another Number Teams account holder.||Until (1) you delete the contact or (2) 90 days after the termination of the appropriate Another Number Team / individual account – whichever is shorter.||If you are a user of Another Number Teams, third party contacts are made available to your Team Administrator.||No, unless the Team Administrator accesses this information outside the EEA.|
|5.||The full name, email address and mobile number of any third-party contact that you add to the address book of the HulloMail app, if you allow HulloMail Sync.||To improve user-experience, caller information and back-up / sync across devices.
|Processing is necessary for our legitimate interests (i.e. to improve the services) and/or the legitimate interests of the HulloMail account holder.||Until (1) you delete the contact or (2) 90 days after the termination of the appropriate HulloMail individual account – whichever is shorter.||No||No|
|6.||Details of voice calls that you make and receive (including missed calls). This includes the called number; calling number; redirected number (if a voicemail); and date, time and call duration.||To provide you with the Another Number service.||Processing is necessary (1) for the performance of our contract with you and (2) to comply with our legal obligations.||For 7 years, as required by law.||To make / receive a voice call, it is necessary to share your personal data with other communications providers (such as Brainstorm Mobile Solutions Limited (t/a EngageHub) and VoxBone S.A.).
If you are a user of Another Number Teams, details of the calls that you make / receive are made available to your Team Administrator.
We may be required by law to disclose the details of any calls you make / receive.
|If you make or receive a call to / from a destination outside the EEA, it is necessary to share your personal data with other communications providers. This might involve a transfer to a country where no adequate safeguards exist.|
|7.||Voicemails that you receive.||To provide you with the Another Number / HulloMail service.||Processing is necessary for the performance of our contract with you.||For your use of the Another Number / HulloMail service, plus 90 days.||It is necessary to share your voicemails with our transcription provider, Nuance Communications Inc.||No.|
|8.||SMS / instant messages that you send and receive||To provide you with the Another Number service.||Processing is necessary (1) for the performance of our contract with you and (2) to comply with our legal obligations.||For 7 years, as required by law.||It is necessary to share your personal data with other communications providers to (1) send or receive an SMS and (2) receive SMS notifications.
If you are a user of Another Number Teams, details of the SMS / instance messages that you send or receive are made available to your Team Administrator.
We may be required by law to disclose the details of any SMS / instant messages you send or receive.
|If you send or receive an SMS to / from a destination outside the EEA, it is necessary to share your personal data with other communications providers. This might involve a transfer to a country where no adequate safeguards exist.|
|9.||The IP address of the device you used to access our Website.||To improve the function of the Website.||Processing is necessary for our legitimate interests (i.e. to understand who is visiting the Website).||30 days||Unless we are otherwise legally required, we may share this data with Google Analytics to help us improve our Website.||Google Analytics may store this data in the USA. We rely on the fact that Google is certified as complying with Privacy Shield.|
|10.||Your name, email address and phone number, but only if you provide it to us.||To enable us to contact you / send information that you have requested.||You have provided your consent.||For as long as we send you relevant information.||No.||No.|
|To enable us to engage in direct marketing (such as newsletters or marketing emails for products and services provided by us that we believe will be of interest to you).||Processing is necessary for our legitimate interests (i.e. direct marketing activities).||Until such time as you inform us you don’t want to continue receiving marketing communications – you have the right to unsubscribe at any time.||No.||No.|
|11.||A record of any communication / correspondence you have with us (e.g. when you contact us by email, telephone or post).||To enable us to maintain records with our potential and actual clients.||Processing is necessary for our legitimate interests (i.e. to understand who contacts us).||6 years||No.||No.|
|12.||Any personal data provided on a CV / resume provided to us (e.g. via email or through our “jobs” webpage).||To enable us to consider your application.||You have provided your consent.||We will keep your details on file for 24 months in case any other relevant positions become available.||No.||No.|
|13.||Any personal data that you provide to us as part of a survey.||To improve our Website or services.||Processing is necessary for our legitimate interests (i.e. to understand the requirements of our potential and actual clients).||24 months||No.