GK Telecom

PRIVACY POLICY

Effective Date: 03/12/2024
Document No: GKT/PP/2024/12
Version: 1.3
Policy Owner: Risk & Compliance Division
Classification: Private and Confidential

This document and its contents are owned by GK Telecom (GKT). Unauthorized sharing, distribution, or duplication is strictly prohibited.

Contents

1. Privacy Policy
2. Introduction
3. Definitions
4. Data Collection
5. Retention of Personal Data
6. Processing Your Personal Information
7. Credit Check
8. Disclosing Your Personal Information
9. Transferring Personal Information
10. Consumer Rights

1. Privacy Policy

At GK Telecom, when you use our services, enter into a contract with us, or visit our website, it may be necessary for us to collect, process, and retain certain information about you. This policy explains why we collect this information, the types of data we may gather, how we manage and process it, and other essential details.

Our commitment to you is that any data we collect will always be gathered with your knowledge, stored securely, and kept only for as long as it is needed.

2. Introduction

We are GK Telecom Limited. Throughout this policy, any mention of “we,” “us,” or “our” refers to GK Telecom Limited.

GK Telecom Limited serves as the data controller for any personal information gathered through your use of our services, websites, and applications in compliance with UK data protection laws. We ensure that your information is handled strictly in accordance with this policy and relevant data protection and privacy regulations.

We collect personal data through various channels, including:

• Website: esim-mobile.co.uk, www.gktelecom.com, iotmobile.co.uk
• Mobile Applications: GKT eSIM App, GKT Partner App
• Other Channels: Digital Kiosk

Registered Office:
GK Telecom Limited, Alpha House, 296 Kenton Road, Harrow, England, HA3 8DD.

Business Registration Number: 07002607
Registered with the ICO: ZA829484

If you have any queries regarding how we handle your personal data or need assistance in exercising your rights, you can reach out to our Data Protection Officer (DPO):

• Email: DPO@gktelecom.com
• Post: Data Protection Officer, GK Telecom Limited, 135 Bath Road, Slough SL1 3UX.

3. Definitions

“Your personal information” refers to details about you that can identify you. This information is collected and processed by GK Telecom Limited when you use our services. Throughout this policy and related sections of our website, terms such as ‘your information,’ ‘your data,’ ‘personal data,’ and ‘personal information’ all have the same meaning as “your personal information.”

GK Telecom Services include a range of offerings provided directly by us or on our behalf. These services cover, but are not limited to, calling, internet access, messaging, data storage, premium features, and age-restricted services.

4. Data Collection

To provide our services, manage your account, and fulfill contracts, we must collect, process, and store certain personal information.

You must ensure the information you provide is accurate and up to date, notifying us promptly of any changes. Inaccurate or false information may result in delays or suspension of GK Telecom services until investigated.

If you share another person’s information, you must have their consent or legal authority.

The information we collect depends on the services and products you use:

1. Personal Details

   • Name, current and previous addresses, length of time at these addresses.
   • Email address, phone number, gender, and date of birth.

2. Employment and Lifestyle Information

   • Employment status and history.
   • Lifestyle-related information.

3. Financial Information

   • Payment card and/or bank details for billing purposes.

4. Communication Records

   • Notes from interactions with Customer Services (via phone, email, or chat).
   • Call recordings or chat transcripts, stored according to retention policies.

5. Device and Usage Information

   • Call details, location data, enabling connectivity and accurate billing.
   • Unique codes identifying your phone and SIM card.

6. Online Interaction Data

   • Information shared through website use, collected via cookies.

7. Account Management Information

   • Account number, billing details, and contact history.

8. Security Information

   • Passwords or similar data to validate and protect your account, securely stored.

9. Personal information collected from other sources

   • Credit reference agencies (credit bureaus).
   • Fraud prevention agencies.
   • The Electoral Register.

5. Retention of Personal Data

We retain your personal information only as long as necessary to provide services, fulfill legitimate business interests, or meet legal obligations. Communication data is typically held for up to one year or longer if required for legal proceedings or disputes.

6. Processing Your Personal Information

We may need to collect and process your personal information for various purposes, including:

• Processing applications or registrations.
• Providing requested products, services, and information.
• Monitoring or recording communications for quality and training.
• Complying with legal and regulatory requirements.

The lawful basis for processing your information will be:

• Your consent for specific purposes.
• Necessity for contract performance.
• Legitimate interests that do not override your rights.

7. Credit Check

If you apply for a Pay Monthly contract, we will share your personal information with credit reference agencies (CRAs) to conduct credit and identity checks. CRAs will provide us with information to assist in making an automated decision.

8. Disclosing Your Personal Information

To provide our services and meet legal requirements, we may need to share your personal information with others in certain situations, including:

• To carry out tasks required by our contract with you.
• To support our business operations.
• To prevent and detect fraud, money laundering, or criminal activities.

Your information may be shared with:

• Our business partners, suppliers, and contractors.
• Professionals like accountants or lawyers.
• Law enforcement or government agencies.

9. Transferring Personal Information

Your personal information will primarily be collected in the UK or EEA and stored on servers in India. If your data is transferred outside the EEA, we ensure it receives the same level of protection as required under UK GDPR, through appropriate safeguards.

10. Consumer Rights

You have several rights regarding your personal information, including:

• Access: Request a copy of the personal information we hold about you.
• Rectification: Ask us to correct inaccurate or incomplete data.
• Erasure: Request the deletion of your personal data in specific circumstances.
• Restriction: Limit the use of your personal data in certain situations.
• Objection: Object to the use of your data for specific purposes, such as direct marketing.
• Withdraw Consent: Revoke consent for data processing at any time.

To exercise your rights, contact us via:

• Email: DPO@gktelecom.com
• Post: Data Protection Officer, GK Telecom, 135 Bath Road, Slough SL1 3UX.

For complaints, visit the ICO at ico.org.uk or call 0303 123 1113.