1. Introduction
02PHONE (“we”, “us”, “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store and share information about you when you visit our website or call us for mobile phone upgrade guidance, and it sets out your rights under the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003 (PECR).
Please read this policy carefully. By using our website or contacting us, you acknowledge the practices described below.
2. Who we are
02PHONE is an independent advisory service offering mobile phone upgrade solutions to people in the United Kingdom. For the purposes of UK data protection law, 02PHONE is the data controller responsible for the personal data described in this policy.
3. The data we collect
Depending on how you interact with us, we may collect the following categories of personal data:
- Identity data: your name and, where relevant, title.
- Contact data: your telephone number and, if you choose to share them, your email address and postal address.
- Upgrade preference data: information you share about your current phone, usage habits, data needs, budget and preferred features.
- Call data: the date, time and duration of calls, the number you call from and, where applicable, call recordings.
- Technical data: IP address, browser type and version, device type, operating system, time zone and similar information collected when you visit our website.
- Usage data: information about how you use our website, such as pages viewed and links clicked.
We do not intentionally collect special category data (such as information about health, religion or ethnicity). Please do not share such information with us during a call. We do not ask for or store full payment card details.
4. How we collect your data
- Directly from you when you call us on 0330 059 6377 and speak with an advisor.
- Automatically when you browse our website, through cookies and similar technologies.
- From advertising and analytics partners who may tell us how you found our website, for example which advert or search result you clicked.
5. How we use your data
We use your personal data to:
- Answer your enquiry and provide mobile phone upgrade guidance;
- Understand your needs so we can explain suitable handset and plan options;
- Call you back where you have asked us to;
- Maintain records of our conversations for quality, training and dispute resolution;
- Operate, maintain and improve our website and services;
- Measure the effectiveness of our advertising;
- Detect and prevent fraud, misuse and security incidents;
- Comply with our legal and regulatory obligations.
6. Our lawful bases for processing
Under UK GDPR, we must have a lawful basis for each use of your data. We rely on:
- Legitimate interests – to respond to your enquiry, run and improve our service, keep records and protect our business, where these interests are not overridden by your rights;
- Consent – for non-essential cookies and for any direct marketing that requires consent. You may withdraw consent at any time;
- Steps prior to entering a contract – where you ask us for information before deciding on a service;
- Legal obligation – where we must process data to comply with the law.
7. Call recording
Calls to and from 02PHONE may be recorded and monitored for quality assurance, staff training, record-keeping and to resolve any disputes. You will be informed of this at the start of the call. If you do not wish your call to be recorded, please tell your advisor and we will discuss alternative options with you.
8. Sharing your data
We do not sell your personal data. We may share it with:
- Service providers who support our business, such as telephony, call-recording, hosting, IT and analytics providers, acting under contract and only on our instructions;
- Advertising partners who help us measure and improve campaigns, in line with your cookie choices;
- Third parties you ask us to connect you with, only with your knowledge and agreement;
- Professional advisers such as lawyers, accountants and insurers;
- Law enforcement, regulators or courts where required by law or to protect our rights;
- A successor business in the event of a merger, acquisition or sale of assets.
9. International transfers
Some of our service providers may process data outside the United Kingdom. Where this happens, we ensure appropriate safeguards are in place, such as UK adequacy regulations, the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.
10. How long we keep your data
We keep personal data only for as long as necessary for the purposes set out above. As a general guide, call records and enquiry notes are kept for up to 24 months, and call recordings for up to 12 months, unless a longer period is required for legal, regulatory or dispute-resolution reasons. Website analytics data is retained in line with our analytics providers' settings. When data is no longer needed, we securely delete or anonymise it.
11. How we protect your data
We use appropriate technical and organisational measures to protect your personal data, including encrypted connections (HTTPS), access controls, staff confidentiality obligations and careful selection of service providers. While no system is completely secure, we work to protect your information and will notify you and the Information Commissioner's Office where required by law in the event of a data breach.
12. Your data protection rights
Under UK data protection law you have the right to:
- Access – request a copy of the personal data we hold about you;
- Rectification – ask us to correct inaccurate or incomplete data;
- Erasure – ask us to delete your data in certain circumstances;
- Restriction – ask us to limit how we use your data;
- Data portability – receive your data in a structured, commonly used format;
- Object – object to processing based on legitimate interests and to direct marketing at any time;
- Withdraw consent – where we rely on consent, at any time, without affecting earlier processing.
To exercise any of these rights, please call us on 0330 059 6377. We will respond within one month, and there is usually no fee. We may need to verify your identity before acting on your request.
13. Cookies and similar technologies
Our website uses cookies to function properly, understand how visitors use it and measure advertising performance.
- Strictly necessary cookies – required for the website to work and cannot be switched off;
- Analytics cookies – help us understand site usage so we can improve it;
- Advertising cookies – help us measure the effectiveness of our adverts.
Non-essential cookies are only set with your consent. You can also manage or delete cookies through your browser settings at any time, although disabling some cookies may affect how the website works.
14. Marketing
We will only send you marketing communications where the law allows and, where required, with your consent. You can opt out at any time by telling your advisor or calling us on 0330 059 6377. We respect the Telephone Preference Service (TPS) where applicable.
15. Children's privacy
Our services are intended for adults aged 18 and over. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.
16. Third-party links
Our website may contain links to third-party websites. We are not responsible for the privacy practices of those websites, and we encourage you to read their privacy policies before sharing any information.
17. Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in our practices or the law. The latest version will always be published on this page, with the “last updated” date shown at the top.
18. Contact us and complaints
If you have any questions about this Privacy Policy or how we handle your personal data, please call us on 0330 059 6377.
If you are unhappy with how we have handled your data, you have the right to complain to the UK's data protection regulator, the Information Commissioner's Office (ICO), at ico.org.uk or by calling 0303 123 1113. We would, however, appreciate the chance to address your concerns first.