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PLAN.COM PRIVACY POLICY

a. introduction

WHO WE ARE

Plan Communications Limited (“Plan”, “we”, “us”, or “our”) is committed to protecting personal data. This privacy policy describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by Customers themselves, by our Business Partners or which is collected by us when we conduct our business including through our products, services, content, websites, online portals and user applications (the “Sites”). We may use personal data provided to us for any of the purposes described in this privacy policy or as otherwise stated at the point of collection.

WHAT WE DO

We deliver market-leading voice and data connectivity across a converged mobile, VoIP and broadband platform together with software solutions to business customers in the UK (“Customers”) together with instant access to tools and real-time data insights that allow businesses to manage their people and productivity and minimise their costs. In this privacy policy:
  • “third party” means someone who is not you or us
  • “Plan Group” means Plan Communications Limited and any company or other organisation which is a “holding company” or a “subsidiary” of Plan Communications Limited as those terms are defined by the Companies Act 2006.

Our registered office is IOMA House, Hope Street, Douglas IM1 1AP. We are registered in the Isle of Man with company number 010273V and registered with (i) the Isle of Man Information Commissioner’s Office (IOMICO), registration number N003321 and (ii) the UK Information Commissioner’s Office (UKICO), registration number ZA082663. Although the IOMICO is our primary regulator, we endeavour to comply with the UKICO as far as possible.

Personal data is any information relating to an identified or identifiable living person.

B. categories of personal data

The information we collect and how we collect it can vary depending on the products and services that you use and subscribe to, how you have used the products and services, and how you have interacted with Plan even if you are not a customer, or what we have obtained from a third party with permission to share it with us.

Plan collects and processes personal data under four primary heads:

  • Customers
  • Customer End Users
  • Business Partners

When collecting and using personal data, our intention is to be transparent about why and how we process personal data. To find out more about our specific processing activities, please go to the relevant sections of this statement.

CUSTOMERS

What we collect

If you are a director, partner, owner or authorised signatory of one of our Customers or a sole trader then, Plan may collect and process the following data about you:

  • name, address, phone and/or mobile number
  • date of birth, email address
  • your contact with us, such as a note or recording of any call you make to us, an email or letter sent, or other records of any contact with us
  • address location for billing, delivery, installation or as provided by individual, phone location
  • how you conduct and manage your account(s) with us
  • whether you are considered vulnerable for the purpose of the Ofcom General Conditions
  • if you are a sole trader, debit or credit card details, banking details and other payment information

How we collect

We collect your personal information directly from you when you, for example:

  • register to become a Plan customer
  • submit enquiries to us or contact us (via phone, email, letter, chat or any other form of communication)
  • enter any promotions, competitions or prize draws via the Services;
  • use Plan products and Services
  • take part in market research
  • when you terminate your account with us

We may also collect information about you from other sources, including but not limited to:

  • credit reference agencies
  • fraud prevention agencies
  • our partners.

How we use personal data

We will use our personal information for the following purposes:

1. To enter into a contract and provide the services:

Processing your order and providing you with your products and services

  • To verify your identity and confirm that we are dealing with an Authorised User/Signatory
  • To process the products and services you’ve bought from us, and keep you updated with the progress of your order.
  • To provide the relevant product or service to you.
  • To monitor and manage the quality of our customer service and to identify training and development needs and for evidential purposes if required to resolve a dispute or enquiry

Billing and customer care

  • To bill you for using our products and services, or to take the appropriate amount of credit from you.
  • Contact you if the billing information you provided us with is about to expire or we’re not able to take payment.
  • To respond to any questions or concerns you may have about our network, products or services.

Service messages

  • We will contact you with customer service messages to keep you updated with current information about products and services you’ve taken. For example, changes to our terms and conditions or service interruptions.

2. To improve our service

Improving and innovating our products and services

  • We collect anonymous, anonymised or aggregate information in order to improve the service we offer to everyone.

Managing our networks and understanding network usage

  • To understand how you use our networks, products and services. That way we can seek to review and improve these, and develop more interesting and relevant products and services, as well as personalising our products and services.

3. Marketing and tailoring our service to you

Marketing

  • We may contact you to keep you informed about new and existing products and services, competitions, prize draws and other promotions. We may also send you newsletters or white papers and occasionally invite you to participate in market research. We may tailor these messages based on the products and services you’ve bought from us in the past.
  • We may also contact you to let you know about products and services of other companies which we think may interest you.
  • There are various ways that we may do this – including by email, post, phone, message or notifications through our apps.
  • You can control your marketing permissions and the data we use to tailor these communications at any time. We will include opt-out options in any marketing email.

4. Research and analytics

We use a variety of data analytics methods. These data analytics are mathematically driven analysis techniques on large and varied data sets to uncover hidden patterns and hitherto unrevealed trends.

We use our analytics to, for example:

  • Conduct market research and to carry out research and statistical analysis, including to monitor how customers use our networks, products and services;
  • Frame our marketing campaigns and determine how we might personalise those;
  • Provide reports to third parties (such reports don’t contain information which may identify you as an individual).

5. Credit checks, fraud prevention and security

We will sometimes need to profile you, for credit, fraud and security purposes.

Credit checks and ID

  • We will carry out a credit check when you apply for a contract for any products or services with us.
  • We will also use your personal information for identity verification purposes, for access to your account and for general account management. We sometimes supplement the information we collect about you with information from other sources (for example, the electoral roll and credit reference agencies) to assess the accuracy of the information that we hold.
  • On occasion this process may involve automated decision-making and profiling which utilises a series of key data points that (if passed) we consider sufficient to justify entering into a contract. If any of those data points are not passed, we will introduce a manual, human-managed check. As the automated decision process only approves, not rejects, we do not consider that it can negatively affect you.

CUSTOMER END USERS

Customer End User Data

Where our customer is a body corporate, partnership, charity or other entity that is not an individual (a “Business Customer”), then we process the personal data collected in accordance with the instructions of that Business Customer.

Our Business Customers may use the Sites and Services to better understand how their own users (for example their employees) (“Customer End Users”) engage with and use our products and services (including our networks). The Personal Information that we may process regarding Customer End Users is referred to as “Customer End User Data.”

Our Business Customers choose the type of Customer End User Data processed through their use of our Sites. The collection of Customer End User Data is governed by our Business Customers’ own privacy policies and notices, and if you are provided with access to our services by one of our Business Customers then you should review that Business Customer’s privacy policy to learn more about that Business Customer’s data handling practices.

As an individual you have the right to access, delete and amend the data collected about you. As we act as the data processor of your data on behalf of the relevant Business Customer, you need to contact the Business Customer directly if you would like to access, amend or delete your data.

What we collect

If you are an employee, consultant, agent or director of one of our Business Customers or a sole trader then Plan may collect and process the following data about you:

  • name and mobile number
  • traffic data (data, voice and messaging);
  • data, voice and messaging traffic data, for e.g. the numbers you call or message, the time and duration of the call or SMS using our network
  • voice and messaging content data, for e.g. the content of a call you make or SMS you send using our network
  • the time and duration of network data usage for e.g. the duration of your internet browsing and the volume of any file downloads or streaming whilst connected to our network
  • network data usage, for e.g. your internet browsing history (including web sites you visit, apps you use) and classification of content visited, in order to apply blocks and filters
  • location data. This can be precise where it uses Global Positioning System (GPS) data or by identifying nearby mobile phone masts and you enable location-based services or features. Or less precise where, for example, a location is derived from your data such as a post code or name of a town or city
  • your contact with us, such as a note or recording of any call you make to us, an email or letter sent, or other records of any contact with us
  • if you are a sole trader, account information, such as dates of payment owed or received, subscriptions you use, account numbers or other information related to your account or your use of our Services.
  • your searching, browsing history (including web sites you visit and the time and duration of such browsing) and location data, internet PC location
How we collect

We collect information indirectly from you when you use the Services, including but not limited to when you:

  • visit or browse the Sites or other Plan Group websites or online portals
  • browse or otherwise access the Internet sites and/or the mobile internet via the Services
  • download any software that allows us to view your broadband setup functionality and to proxy on to your computer
  • use our networks (mobile/broadband/wifi or other)
  • call or contact (via email, letter, chat or any other form of communication) to us, including recording conversations on the phone, as well as the capture of additional information about these interactions e.g. telephone numbers that you can call us from and information about the devices and software you use

How we use personal data

We will use your personal information for the following purposes:

1. To provide the services: Providing our Customer with products and services
  • To provide the relevant product or service to our Customer by identifying the user of a connection (e.g. via a SIM) to our network
  • To provide the Customer with network usage data and content for our Customer’s training, quality, productivity monitoring, compliance monitoring (e.g. health and safety) or other purposes
  • To monitor and manage the quality of our customer service and to identify training and development needs and for evidential purposes if required to resolve a dispute or enquiry
Service messages
  • We will contact you with customer service messages to keep you updated with current information about products and services. For example, service interruptions.
2. To improve our service Improving and innovating our products and services
  • We collect anonymous, anonymised or aggregate information in order to improve the service we offer to everyone.
Managing out networks and understanding network usage
  • To understand how you use our networks, products and services. That way we can seek to review and improve these, and develop more interesting and relevant products and services, as well as personalising our products and services.
  • To ensure that we’re meeting our commitments around fair use, to detect and resolve fraudulent use of our networks (and our partners’ roaming networks) and to solve technical issues
3. Marketing and tailoring our service to you Marketing
  • We may contact you to keep you informed about new and existing products and services, competitions, prize draws and other promotions. We may also send you newsletters or white papers and occasionally invite you to participate in market research. We may tailor these messages based on the products and services you’ve bought from us in the past.
  • We may also contact you to let you know about products and services of other companies which we think may interest you
  • There are various ways that we may do this – including by email, post, phone, message or notifications through our apps.
  • You can control your marketing permissions and the data we use to tailor these communications at any time. We will include opt-out options in any marketing email.
4. Research and analytics

We use a variety of data analytics methods. These data analytics are mathematically driven analysis techniques on large and varied data sets to uncover hidden patterns and hitherto unrevealed trends.

We use our analytics to, for example:

  • Conduct market research and to carry out research and statistical analysis, including to monitor how customers use our networks, products and services;
  • Frame our marketing campaigns and determine how we might personalise those;
  • Provide reports to third parties (such reports don’t contain information which may identify you as an individual).

PARTNERS

Typically, our Partners are body corporates, limited liability companies or partnerships or other entity that is not an individual. However, some are sole traders and we may in the course of interacting with our Partners, collect personal data relating to individual employees, agents, directors, shareholders of such partner or an individual who is a sole trader.

What we collect

If you are an employee, consultant, agent or director of one of our Business Customers or a sole trader then Plan may collect and process the following data about you:

  • name, address, phone and/or mobile number
  • date of birth, email address
  • your contact with us, such as a note or recording of a call you make to us, an email or letter sent, or other records of any contact with us
  • address location for billing, delivery, installation or as provided by individual, phone location;
  • how you conduct and manage your account(s) with us
  • if you are a sole trader, debit or credit card details, banking details and other payment information
How we collect

We collect your personal information directly from you when you, for example:

  • register to become a Plan partner
  • submit enquiries to us or contact us (via phone, email, letter, chat or any other form of communication)
  • enter any promotions, competitions or prize draws;
  • use or sell a customer any Plan products and Services
  • take part in market research
  • when you terminate your account with us
We collect information indirectly, including but not limited to when you:
  • visit or browse the Sites or other Plan Group websites or online portals
  • call or contact (via email, letter, chat or any other form of communication) our Sales or Partner Support teams, including recording conversations on the phone, as well as the capture of additional information about these interactions e.g. telephone numbers that you call us from and information about the devices and software you use
We collect information about you from other sources, including but not limited to:
  • credit reference agencies
  • fraud prevention agencies
  • business directories and other commercially or publicly available sources
How we use personal data

We will use your personal information for the following purposes:

1. To register and administer your account with us

Processing orders and providing you or Customers with products and services

  • To verify your identity and that you are an authorised user
  • To process the products and services you use or sell, and keep you updated with the progress of your orders.
  • To provide the relevant product or service to you.
Commission and clawback
  • To pay you commission for (i) introducing new customers to Plan; and (ii) undertaking customer service and management of those customers.
  • To invoice you for any amounts owed by way of the clawback of commission paid to you in respect of customers who subsequently leave plan or cancel services before the end of their contract
  • Contact you if the billing information you provided us with is about to expire or we’re not able to take payment.
  • To respond to any questions or concerns you may have about our network, products or services.
Service messages
  • We will contact you with Customer or Partner service messages to keep you updated with current information about products and services. For example, changes to our terms and conditions or service interruptions.
2. To improve our service

Improving and innovating our products and services

  • We collect anonymous, anonymised or aggregate information in order to improve the service we offer to everyone.
  • Investigating any queries or complaints that you may raise in respect your account of the account of a Business Customer.
3. Marketing and tailoring our service to you

Marketing

  • As a Partner, we may contact you to keep you informed about new and existing products and services, competitions, prize draws and other promotions. We may also send you newsletters or white papers and occasionally invite you to participate in market research.
  • We may also contact you to let you know about products and services of Plan Group companies and those of other companies which we think may interest you
  • There are various ways that we may do this – including by email, post, phone, message or notifications through our apps.
  • You can control your marketing permissions and the data we use to tailor these communications at any time. See ‘Access to personal data’ within the ‘Your rights’ section of this privacy policy.
4. Research and analytics

We use a variety of data analytics methods. These data analytics are mathematically driven analysis techniques on large and varied data sets to uncover hidden patterns and hitherto unrevealed trends.

We use our analytics to, for example:

  • Conduct market research and to carry out research and statistical analysis, including to monitor how customers use our networks, products and services;
  • Frame our marketing campaigns and determine how we might personalise those;
  • Provide reports to third parties (such reports don’t contain information which may identify an individual).
5. Credit checks, fraud prevention and security

We will sometimes need to profile you or your directors, shareholders or other officers, for credit, fraud and security purposes.

Credit checks and ID
  • We will carry out a credit check when you apply for a contract for any products or services with us.
  • We may also use personal information of your directors, shareholders or other officers for identity verification purposes, for access to your account and for general account management. We sometimes supplement the information we collect about you with information from other sources (for example, the electoral roll and credit reference agencies) to assess the accuracy of the information that we hold.
Fraud prevention and security
  • We will process your personal and traffic data in order to protect against and detect fraud, to protect and detect misuse or damage to our networks, to recover debts or trace those who owe us money resulting from the use of our services.

C. our lawful basis for processing

We have set out below, in a table format, a description of the primary ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Legal basisType of processing

Legitimate interests

Our legitimate interests are:

  • to run, grow and develop our business;
  • marketing, market research and business development;
  • to provide goods and services to our customers, make and receive payment, provide customer services and to know the customer that we are providing goods and services to.

  • processing account applications, managing changes to personal data, and responding to queries from you as a customer, customer end user or partner;
  • processing data you give us as a customer, customer end user or partner;
  • placing orders;
  • providing our services;
  • managing payments;
  • monitoring account activity;
  • marketing;
  • for profiling and statistical analysis;
  • for market research;
  • prevention of fraud and other criminal activities;
  • to verify the accuracy of data that we hold about you as a customer, customer end user or partner and create a better understanding of you as a customer, customer end user or partner;
  • to correspond or communicate with you;
  • to comply with a request from you as a customer, customer end user or partner in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
  • assess and improve our service through recording calls with you as a customer, customer end user or partner; and
  • management of queries, complaints, or claims.

Performance of a contract

The personal information you provide may be processed when it is necessary in order for us to:

  • enter into or perform a contract with you;
  • supply you with any products or services, or
  • where you are in discussions with us about any new product or service.

  • processing account applications, managing changes to personal data, and responding to queries from you as a customer, customer end user or partner;
  • processing data you give us as a customer, customer end user or partner;
  • placing orders;
  • providing our services;
  • when you enter an on-line competition or promotional feature, to administer the competition or promotion and notify winners.

Compliance with legal obligations

Where we are under a duty to disclose or share your personal information in order to comply with a request from government or law enforcement officials.

  • to meet national security or law enforcement requirements or to prevent illegal activity;
  • to identify you when you contact us;
  • to verify the accuracy of data we hold about you as a customer, customer end user or partner.

Consent

Where we rely on your consent as the legal basis for processing your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this Privacy Statement. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

  • when you browse our website, we will use cookies to identify visitor traffic and behavior;
  • contacting you with marketing information about our services and those of our group companies.

D. Security

Data Hosting

We take the security of all the data we hold very seriously. We have policies, procedures and training in place covering data protection, systems access, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

Plan’s IT infrastructure is located in secure data centres in the United Kingdom and Isle of Man, and personal data will be stored in those data centres. All datacentres contracted by Plan are accredited by the following ISO standards – ISO-IEC 27001 and ISO 9001. As well as ISO 14001 for Environmental Management.

Further we have organisational protections in place including (i) management approval for access to systems; and (ii) tiered access to systems depending on job type.

Security of Communications

Please be aware that communications over the Internet, such as e-mails and web-chats, 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 Internet. Plan cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

Media Messaging If you are registered with Plan, any Media Messages you send to an email address, including Media Messages from your phone and messages from Plan, may include personal details such as your registered first name and last name, your phone number or email address which will be displayed in the ‘from’ field of the message.

E. transfers of personal data

hOW WE SHARE PERSONAL DATA

Where applicable, we share personal data with:

  • Companies in the Plan Group
  • Business Partners, suppliers or agents involved in delivering our products and services to Business Customers including sharing Customer End User data where a Business Customer has explicitly consented to a specific Business Partner being provided with third party access to the Plan account of that Business Customer
  • Companies who are engaged to perform services for, or on behalf of, Plan Communications Limited, or the Plan Group for example third party software developers or third party software providers such as Zendesk.
  • Credit reference, fraud-prevention or business-scoring agencies, or other credit scoring agencies
  • Debt collection agencies or other debt-recovery organisations
  • Law enforcement agencies, government bodies, regulatory organisations, courts or other public authorities if we have to, or are authorised to by law
  • A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement
  • Emergency services (if you make an emergency call), including your approximate location
  • Other third parties when you are signing up to their service and it is used by them for authentication and fraud-prevention purposes
  • Third parties that we use to serve you marketing, for example, MailChimp

Plan will use reasonable endeavours to ensure that any supplier that is provided with or has access to personal data provides assurances that they will protect that personal data with at least the same level of privacy protection as is required by this Policy. Where Plan has knowledge that a supplier is using or sharing personal information in a way that is contrary to this policy, Plan will take reasonable steps to prevent or stop such processing.

Fraud management and law enforcement

We will release information if it’s reasonable for the purpose of protecting us against fraud, defending our rights or property, or to protect the interests of our customers.

We also may need to release your information to comply with our legal obligation to respond to the authorities’ lawful demands. Your personal data shall only be provided when we in good faith believe we are obliged to do so in accordance with the law and pursuant to an evaluation of all legal requirements.

Mergers and acquisitions

If we’re reorganised or sold to another organisation, we will provide your information to that organisation.

Third parties that we work with

Where you’ve purchased Plan products and services using a third party or partner organisation, we often need to exchange information with them as part of managing that relationship and your account – for example, to be able to identify your order and be able to pay them.

If we have a contract with a service provider or contractor to provide us with services or provide a service on our behalf, and they may have access to your personal information, we don’t authorise them to use or disclose your personal information except in connection with providing their services.

We collect and combine information in order to monitor your use of products and services, and that of our other customers, as well as to help us to improve the quality of our products and services.

Third-party products that you buy through your Plan account

Where you buy a third-party product or service through your Plan account (such as Office365 from Microsoft), the contract for it is with the party selling that product or service. Plan is only charging the amount directly to your bill as part of its arrangements with the seller (or with a third party authorised by the seller). As part of this, you’re agreeing that Plan may pass certain personal information to such parties to complete your purchase.

The seller’s terms and conditions and privacy and cookies policies will apply to how it uses your personal information – please read them carefully.

F. retention of data

We retain information only for as long as we need it. In relation to the following information we are required to retain it for not less than six months and not more than two years after you have been a customer of Plan in order to ensure that this information is available for the purpose of the investigation, detection and prosecution of serious crime:

  • User ID and telephone number allocated to any communication entering the public telephone network
  • name and address of subscriber to whom an Internet Protocol (IP) address, user ID or telephone number was allocated at the time of a communication
  • user ID or telephone number of the recipient of an Internet telephony call
  • name and address of subscriber and user ID of the intended recipient of a communication
  • date and time of log-in and log-off of our Internet access service, IP address and user ID of the subscriber
  • internet service used
  • calling telephone number for dial-up Internet access of the originator of a communication and
  • digital Subscriber Line (DSL) or other end point of the originator of a communication

G. children's information

We do not provide services to children or proactively collect their personal information. If we obtain information about children while addressing a service request or query the information in the relevant part of this notice applies to children as well as adults.

H. international data transfers

We may need to transfer your information to other Plan Group companies or partners or service providers in countries outside the European Economic Area (EEA). The EEA consists of countries in the European Union, Switzerland, Iceland, Liechtenstein and Norway: they are considered to have equivalent laws when it comes to data protection and privacy. This kind of data transfer may happen if our servers (i.e. where we store data) or our suppliers and service providers are based outside the EEA, or if you use our services and products while visiting countries outside this area.

Plan may send your data to its head office in the Isle of Man. The European Commission has recognised the Isle of Man has offering an adequate level of data protection.

If Plan sends your information to a country that is not in the EEA and is not recognised by an adequacy decision, we will make sure that your information is properly protected. We will ensure that there is a proper legal agreement that covers the data transfer.

In addition, if the country is not considered to have laws that are equivalent to EU data protection standards then we will ask the third party to enter into a legal agreement that reflects those standards.

I. call recording

We record calls made to and by us across our business. These recordings are made for a number of purposes including staff training and quality control. Each recording is encrypted and stored on a secure server. Access to the call recordings is tightly controlled in accordance with our internal policies and can only be obtained on the authority of our Data Protection Officer.

j. your rights

Access to personal data

You have a right of access to personal data held by us. You have the right to:

  • information about how your personal data is processed
  • a copy of your personal data
  • an immediate correction to your personal data
  • raise an objection about how your personal data is processed
  • request that your personal data is erased if there is no longer a justification for it
  • ask that the processing of your personal data is restricted in certain circumstances

How to exercise your rights

If you are a registered with my.plan and are an Authorised User for the account of a Business Customer, you may verify, update or amend the personal information you have provided to Plan online at any time by clicking on “My details”.

This right may also be exercised by emailing us at dataprotection@plan.com. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits (currently 1 month).

Correction of personal data

To update inaccurate personal data submitted to or held by us, you may email us at dataprotection@plan.com or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant portals or applications with which you registered.

When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.

Withdrawal of consent

Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We do not generally process personal data based on consent (as we usually rely on another legal basis). Nevertheless, to withdraw consent or instruct us to stop processing of your personal data please email us at dataprotection@plan.com or, to stop receiving emails from a Plan marketing list, please click on the unsubscribe link in the relevant email received from us.

Right to data portability

You have the right to be able to take with you the personal data you provided to us in certain circumstances. Plan ensures that you can take your data with you by allowing you to download your monthly bills, at the click of a button. In order to do this, log in to my.plan and go to your billing area.

Other data subject rights

This privacy statement is intended to provide information about what personal data we collect about you and how it is used. As well as rights of access and amendment referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure/deletion, to restrict or object to our processing of personal data and the right to data portability.

If you wish to exercise any of these rights, please send an email to dataprotection@plan.com.

Marketing

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by contacting us via email at any time. Where you opt out of receiving these marketing messages, this will not apply to service messages.

We will not sell or rent your data to third parties or share your data with third parties for marketing purposes. We may use third party software to send you information for marketing or service purposes.

If you receive an email which claims to come from us but does not use our domain, or if you are suspicious that an email may not be approved by us, then please send a copy of the email to dataprotection@plan.com so we can investigate.

K. changes to this privacy statement

We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review.

This privacy notice was last updated on 13th July 2020 when we changed the layout and sought to set out examples of the information that was contained in the previous version of the notice.

l. data controller and contact information

The data controller is Plan Communications (registered in (i) Isle of Man with registration no. 010273V with its registered office IOMA House, Hope Street, Douglas IM1 1AP) and (ii) the UK Information Commissioner’s Office (ICO), registration number ZA082663.

Our Data Protection Officer is Gregg Knowles. You can contact him at dataprotection@plan.com or to our postal address below.

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Data Protection Office
Plan Communications Limited
IOMA House
Hope Street
Douglas
Isle of Man
IM1 1AP

Email: dataprotection@plan.com

M. complaints

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to dataprotection@plan.com. We will investigate and respond to any complaints we receive.

You also have the right to lodge a complaint with the Isle of Man Information Commissioner’s Office (“ICO”) (the Isle of Man data protection regulator). For further information on your rights and how to complain to the ICO, please refer to the ICO website.

This privacy policy was last updated on 13th July 2020