Privacy Policy

Effective Date: 24/04/2024

Document No: GKT/PP/2024/04

Version: 1.0

Policy Owner: Risk & Compliance Division

Classification: Private and Confidential

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. Data Breaches and Security
10. Transferring Personal Information
11. Consumer Rights
12. Changes to This Privacy Policy

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 the following:

• Website: www.gktelecom.com, iotmobile.co.uk, eroaming.global
• Mobile Applications: GKT Partner App, eROAMING eSIM 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 under registration number: ZA829484

To learn more about your rights concerning your personal information, please refer to the “Your Rights” section of this policy. 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) via email at DPO@gktelecom.com, or by post at: 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 fulfil 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.
• Location data.

6. Online Interaction Data

• Information shared through website use, collected via cookies.

Managing Non-Essential Cookies

You can opt out of non-essential cookies at any time by adjusting your preferences in the Cookie Preferences section at the bottom of our website. Non-essential cookies include functional, performance, and targeting cookies, which require your consent before being placed on your device.

By selecting ‘Allow essential cookies only’, only essential cookies required for the basic functioning of the website will be placed.

If you choose ‘Accept all cookies’, you consent to all cookie categories, including sharing data with third parties like advertising partners, which may involve data processing outside the EU/EEA.

To block or delete cookies, you can adjust your browser settings. However, this may impact your browsing experience, prevent certain functionalities (like account logins or product purchases), and require manual adjustments for site preferences during each visit.

For more details on browser cookie management, please contact us at info@gktelecom.com.

7. Account Management Information

• Account number, billing details, and contact history.
• Preferences for products or services, based on your input or usage patterns.

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.
• Commercial partners providing goods or services to us.

This information is collected as necessary to provide services, manage your account, and comply with legal requirements.

5. Retention of Personal Data

We retain your personal information only as long as necessary to provide services, fulfil 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. Account information may be retained after your relationship with GK Telecom ends to comply with legal and regulatory requirements.

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.
• Administering accounts and managing complaints or queries.
• Complying with legal and regulatory requirements.
• Conducting credit checks, fraud prevention, and recovering debts.
• Supporting traffic analysis, billing management, and product development.
• Fulfilling contractual obligations and notifying you of updates or changes.
• Contacting you for market research or providing marketing updates (based on your preferences).

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.

If you are aged 13 or under, you must have parental or guardian consent to share your personal information.

Marketing Communications

We may use your personal information to send you marketing communications about our products, services, promotions, and offers via email, SMS, or other electronic means.

We will only send you marketing communications where:

• You have given your explicit consent, or
• We are permitted to do so under applicable laws (e.g., soft opt-in for existing customers).

You have the right to opt out of marketing communications at any time by:

• Clicking the “unsubscribe” link in any marketing email,
• Replying STOP to SMS messages, or
• Contacting us at DPO@gktelecom.com.

Once you opt out, we will stop sending you marketing communications, although we may still contact you regarding service-related or transactional matters.

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 about whether we can enter into a contract with you.

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, such as credit checks and surveys.
• 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.
• Other companies in our group.
• Professionals like accountants or lawyers.
• Law enforcement or government agencies, such as the National Crime Agency.

We may also share your information if required by law, to enforce agreements, or to protect the safety and property of our customers, employees, or others.

Third-Party Service Providers

We may use trusted third-party service providers (data processors) to support our business operations. These providers process personal data on our behalf and only in accordance with our instructions.

These may include:

• IT and system hosting providers
• Customer support and communication platforms
• Analytics and website optimisation providers
• Fraud prevention and identity verification services
• Credit reference agencies

9. Data Breaches and Security

We take the security of your personal information seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, loss, misuse, or alteration.

We have procedures in place to detect, investigate, and respond to personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:

• Notify the Information Commissioner’s Office within the legally required timeframe, and
• Inform affected individuals where required by law.

We will also take appropriate steps to minimise the impact of any breach and prevent similar incidents from occurring in the future.

10. Transferring Personal Information

Your personal information will primarily be stored on servers in the United Kingdom (UK) or European Economic Area (EEA). If transferred outside the EEA, we ensure it receives the same level of protection through recognised safeguards, such as:

• Transferring to countries with approved data protection standards, recognised by the Information Commissioner’s Office (ICO) or the European Commission.
• Using ICO-approved contracts that require recipients to protect your data to the same standards as in the United Kingdom or Europe.
• Applying equivalent protections for transfers to the United States.

For more details about international data transfers, please contact customer services at info@gktelecom.com.

11. 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.
• Automated Decision Review: Request human review of decisions made solely through automated processing.
• Withdraw Consent: Revoke consent for data processing at any time.
• Complain: Report concerns to the Information Commissioner’s Office (ICO).

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.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in legal requirements, technology, or our business operations.

Any updates will be published on our website, and where appropriate, we will notify you by email or through our services.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information.

The “Effective Date” at the top of this policy indicates when it was last updated.