House, 1 Cambridge Road, Hale, Cheshire, WA15 9SY. We provide full fibre FTTP broadband and
controller of your personal data, and our commitment to protected the privacy and
confidentiality of your personal data. .
We are responsible for your personal data as data controller.
We have appointed a data protection officer (“DPO”) under the UK General Data Protection
Regulation (“GDPR”) and the Data Protection Act 2018 (“DPA”). Our DPO is responsible for all of
our issues relating to the protection of personal data. The data protection officer can be
contacted by email at email@example.com or in writing at the below:
The Data Protection Officer.
Suite 3 Beech House,
1 Cambridge Road,
Customers who have a contract or are discussing arrangements with us for access to your property to
install our network;
Prospective customers who may enter into a contract with us for our Full Fibre broadband or other
additional services who have communicated with us at an event, by phone, email or other means.
Individuals that use our websites;
Nominated users or individuals acting under a power of attorney; and
Our services are not intended for or otherwise aimed at children, unless we expressly state otherwise,
and we do not knowingly collect or process personal data relating to children or anyone aged under 18
It is important that the personal data we hold about you is accurate and current.
It’s your responsibility to keep us up to date if you make any changes to your personal data by
contacting us via phone or email to firstname.lastname@example.org
3. WHAT INFORMATION DO WE COLLECT?
Personal data is any information that can identify a natural person. The personal data we collect will
depend on the type of the services we are providing and what we are contracted to do for you or on your
behalf. Depending on the services, we may collect, use, store and transfer different categories of
personal data to enable us to deliver our services, this might include the following:
Data about your Identity including title or salutation, first name, last name, date of birth
and gender. For businesses or the self-employed it may include business name, business address,
company registration number, VAT number and HMRC UTR details
Data about your contact details iincluding title or salutation, first name, last name, date
of birth and gender. For businesses or the self-employed it may include business name, business
address, company registration number, VAT number and HMRC UTR details
Financial data including your bank account details for a direct debit and payment card
details and your credit rating
Data relating to a transaction Including details about payments to and from you and about the
products and services that you have purchased from us
Technical data including IP address, your login data, browser type and version, time zone
setting and location, browser plug-in types and versions, operating system and platform, registered
email addresses used to create a T4U profile within the ‘My Account’ sections on website and Mobile
App, online chat logs and other information on the devices you use to access our services
Data about your T4U profile including your My Account username and password, your interests,
preferences, feedback and survey responses
Data about your usage of our products and services including the amount of time you spend
online, the channels and programs you watch and record, websites you visit
Data relating to your marketing and communications preferences including what method you
would like to receive marketing and how frequently
Special categories of personal data including information about your health that we may need
to know to provide you with the best service for you and biometric data that you may give us to gain
quicker access to your account information.
We may also collect and use non-personal data such as statistical or demographic data. This data may be
derived from your personal data but is not considered personal data as this data cannot be used to
4. HOW DO WE COLLECT INFORMATION?
Information you give us
When you place an order with us for any of our services (for example over the Mobile App, online through
the www.the4thutility.co.uk or through a third party building management affiliate), we will need
certain information to process your order..
When you contact us to discuss your services, we may ask for certain information to be able to confirm
your identity, check our records and answer your questions quickly and accurately..
If you take part in any trials, complete any survey or enter any competitions we may ask for information
about you, which we will make clear to you at the time and for the purpose we will be using this
Information we automatically collect
When you use our services;
When you visit our websites or use our mobile applications, we may collect and process information
about your usage of these by using “cookies” and other similar technologies to help us make
improvements to the websites and to the services we make available.
When you download or use mobile applications created by us and, where applicable, have requested or
consented to location services, we may receive information about your location and your mobile
device, including a unique identifier for your device.
WWe may use this information to provide you with location-based services, such as search results, and
other personalised content. Most mobile devices allow you to turn off location services. Our mobile
application does not collect precise information about the location of your mobile device.
Information we receive from other sources
We may receive personal data about you from third parties or publicly available sources in the course of
providing our services. Typically, these sources may include:
Third-party companies contracted by us to help us provide services to you;
Other telecommunications operators when transferring services;
Credit reference agencies or fraud prevention agencies.
Public sources where this relates to you or your organisation.
5. HOW DO WE USE INFORMATION?
The information we collect helps us to better understand what you need from us and to improve the
provision of our services to you.
We use the information collected for example to:
Verify your identity when you use our services or contact us
Process your enquiries, orders or applications, for example when assessing an application, we may
use automated decision-making systems
Carry out credit checks and to manage your accounts
Monitor, record, store and use any telephone, e-mail or other electronic communications with you for
training purposes, so that we can check any instructions given to us and to improve the quality of
our customer service, and in order to meet our legal and regulatory obligations
Where you have agreed, provide you with information about other T4U services, offers or products
which you may be interested in
To notify you about changes to our service
To tell you about changes to our websites, services or terms and conditions
To notify you about network maintenance, planned and unplanned outages
With your consent, carry out any marketing analysis, profiling or create statistical or testing
information to help us personalise the services we offer you and to understand what our customers
Recover any monies you may owe to us for using our services
Analyse our services with the aim of improving them e.g. to monitor the performance of our civils
Prevent or detect a crime, fraud or misuse of, or damage to our network, and to investigate where we
believe any of these have occurred
Monitor network traffic from time to time for the purposes of backup and problem solving, for
example our automated system may monitor email subjects to help with spam and malware detection
To carry out our obligations and to enforce our rights arising from any contracts entered into
between you and us and to provide you with the information, products and services that you request
To comply with any legal obligations we have because we run a business and because we are an
Internet Service Provider and an Electronic Communications Provider
To ensure that content from our site is presented in the most effective manner for you and for your
computer or device; and
Your data may also be used for other purposes for which you give your specific permission or, in very
limited circumstances, when required by law..
We may supplement the information directly collected by us with data from third parties (for example
socio-demographic data) to further improve the services or products we offer customers.
We may combine this information with information you give to us. We will use this information:
to allow us to deliver our services to you (including any associated functionality such as parental
controls on Internet access, maintenance, assistance or troubleshooting) and to allow us to
understand and manage traffic flows on our network
to administer our site and for internal operations, including troubleshooting, data analysis,
testing, research, statistical and survey purposes
to improve our site to ensure that content is presented in the most effective manner for you and the
device through which you are viewing the site
to allow you to participate in interactive features of our service, when you choose to do so
as part of our efforts to keep our site and our services safe and secure
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver
relevant advertising to you
6. WHEN WILL WE SHARE YOUR DATA WITH OTHERS?
We may need to share your information with organisations outside T4U e.g.; to help us provide our
services to you. The categories of non-T4U parties that we would share your details with are:
Third party suppliers who help T4U to perform our services;
Law enforcement agencies;
Other companies as part of the process of selling one or more of our businesses or part of those
Regulators (such as OfCOM, DCMS or the ICO).
Where instructions in respect of the use of your personal information and they must comply with all
applicable UK data protection laws to protect your information and keep it secure.
7. PROTECTING INFORMATION
We take protecting your data seriously, and will do our utmost to employ appropriate organisational and
technical security measures to protect you against unauthorised disclosure or processing.
The data that we collect from you is primarily stored and managed in the UK, but some of our systems and
other suppliers may transfer, and store your information outside the European Economic Area (“EEA”). We
will take all steps reasonably necessary to ensure that your data is treated securely and to the same
standards as if it were being processed inside the EEA in a way that is compliant with the legislation
governing data protection.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we
will do our best to protect your information, we cannot guarantee the security of your data transmitted
to our site; any transmission is at your own risk. Once we have received your information, we will use
strict procedures and security features to try to prevent unauthorised access.
Unfortunately, we cannot guarantee the security of transmitting information via the Internet. We have
tried to create a secure and reliable website and mobile application for our users in line with industry
standards. However, we have no responsibility or liability for the security of personal information
transmitted via the Internet.
8. WHY DO WE PROCESS YOUR DATA?
We process each type of personal data for one the following reasons:
We need to process the data under our contract with you for our services, or to take steps prior to
entering into a contract with you
We have a legitimate interest as a business in processing your data. We also use your information to
enable us to run our business and to ensure the quality of our work. It is in our legitimate
business interests to do this where this does not materially impact on your freedoms or rights. This
would include using your information to assist the good governance of our business, including the
management, accounting and auditing of our business and for example, to monitor the service provided
to us by third parties or when analysing traffic flows on our network to ensure all our customers
have optimal service. We will only rely on those legitimate interests to process personal data where
those legitimate interests are not overridden by your interests or fundamental rights and freedoms.
We will use your information to inform our quality control and management of our business and as
part of our duties to promote health and safety at work.
To comply with any legal obligations we have as an Internet Service Provider and an Electronic
We have your consent (which you can withdraw at any time).
If you communicate with us about our network build we will use your contact information to
communicate with you and where necessary to ensure that our contractors communicate with you to
investigate a complaint or rectify an issue.
Where it is necessary in order to comply with laws or regulatory requirements.
It is important that you are aware that if you don’t provide us with the data we need then we may not be
able to perform our contract with you and may need to terminate the contract. If this happens, we will
notify you as set out in our Terms and Conditions of Service.
9. TRANSFERS OF DATA OUTSIDE THE EEA
Your personal data is processed and stored in the UK. However, from time to time, there may be occasions
where we need to send data to the third parties based outside the UK in countries that have not been
recognised by the UK Government has having the the same standard of data protection laws as the UK.
As some third parties may be in countries outside the UK, we will ensure that any transfers of personal
data outside the UK is only undertaken once we have put in place the international data transfer
agreement (“IDTA”) or the UK Addendum to the new EU Standard Contractual Clauses to ensure that your
data is protected with appropriate technical and organisational controls., and have undertaking an
assessment of the level of protection afforded in the relevant jurisdiction considering the nature and
sensitivity of the personal data in question. Where possible, we will make sure that any transfers are
not repetitive and only limited to the minimum amount of information possible.
10. HOW LONG DO WE HOLD YOUR INFORMATION FOR?
Unless there is a specific regulatory or legal requirement for us to keep your information longer, we
will only keep your information, usually in computer or manual files, for as long as it is necessary to
fulfil the purposes for which the information was collected; or as required by law; or as long as is set
out in any relevant contract you may hold with us.
To determine the appropriate retention period for personal data, we consider the amount, nature, and
sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data and whether we can achieve those
purposes through other means, and the applicable legal requirements.
11. YOUR RIGHTS
As a data subject you have a number of personal rights under data protection laws in relation to your personal data. These are:
Subject access requests-You have a right to access all personal data that we hold as a data controller and to be informed about how your personal data is being used.
Right to be forgotten - In certain circumstances you have a right to request that your personal data be erased from the systems within our control.
Rectification - You have a right to correct your personal data that we hold as a data controller.
Withdraw consent – Where we have offered you the right to consent to giving us your data, for instance with your marketing preferences, you have the right to withdraw your consent at any time.
Objection and restriction of processing - In certain circumstances, you have a right to object to or request we restrict our processing of your personal data, such as direct marketing.
Data portability – you have the right to request us to send a copy of the personal data we hold about you to another organisation for your own purposes, for example, when you are dealing or moving to a different service provider. If you would like us to move, copy, or transfer your information then please let us know.
Automation – we do not use your information for any automated decision making.
Where you have requested us to restrict or stop processing your data this may impact on our ability to provide our services. Depending on the extent of your request we may be unable to continue providing our services to you. In these circumstances, you would remain liable for the charges incurred to date for our services.
If you would like more information about these rights or how to apply them, please contact us via phone or email.
If you would like to make a complaint about our use of the personal data we hold about you, you should contact our Data Protection Officer by writing to the Data Protection Officer, 4th Utility, Suite 3 Beech House, 1 Cambridge Road, Hale, Cheshire, WA15 9SY or emailing email@example.com. We will aim to respond to you within the statutory time frame of a month, however, there may be instances where our investigations take longer and we need more time to obtain information from you regarding your complaint.
If we are not able to resolve your complaint or believe we are processing your personal data not in accordance with the relevant data protection laws, you have the right to lodge a complaint to the UK data protection regulator, the Information Commissioner’s Office (ICO) (www.ico.org.uk).
Please note that the ICO will require you to have exhausted our internal GDPR complaints process before you are able to lodge a complaint directly. We would, therefore, appreciate the chance to deal with and resolve your concerns before you approach the ICO, so please contact us in the first instance.