Last updated: 24th May 2018.

WAVE MOBILE LTD (registered number 04780898, address 29 Castle Street KT1 1ST).

Data Protection Lead can be contacted at dpl@wavemobile.com.

We have produced this privacy notice in order to keep you informed of how we handle your personal data.

All handling of your personal data is done in compliance with the General Data Protection Regulation (EU) 2016/679 (“Data Protection Legislation”).

The terms “Personal Data”, “Special Categories of Personal Data”, “Personal Data Breach”, “Data Protection Officer”, “Data Controller”, “Data Processor”, “Data Subject” and “process” (in the context of usage of Personal Data) shall have the meanings given to them in the Data Protection Legislation.

“Data Protection Lead” is the title given to the member of staff leading our data protection compliance programme in lieu of a requirement for a Data Protection Officer.

What are Your Rights

When reading this notice, it might be helpful to understand that your rights arising under Data Protection Legislation include:

• The right to be informed of how your Personal Data is used (through this notice);
• The right to access any personal data held about you;
• The right to rectify any inaccurate or incomplete personal data held about you;
• The right to erasure where it cannot be justified that the information held satisfies any of the criteria outlined in this policy;
• The right to prevent processing for direct marketing purposes, scientific/historical research or in any such way that is likely to cause substantial damage to you or another, including through profile building;
• The right to object to processing that results in decisions being made about you by automated processes and prevent those decisions being enacted.

You can exercise your right to access personal data held about you by emailing dpl@wavemobile.com with the subject line: “Subject Access Request”. When you submit a ‘subject access request’, you will need to provide confirmation of your identity by including your phone number for us to contact you to confirm your identity. This is provided free of charge and our response will be made within thirty (30) days unless our Data Protection Lead deems your request as being excessive or unfounded. If this is the case, we will inform you of our reasonable administration costs in advance and/or any associated delays, giving you the opportunity to choose whether you would like to pursue your request. If you believe we have made a mistake in evaluating your request, please see the section ‘Who can you complain to?’.

If you have questions about any of the rights mentioned in this section, please contact our Data Protection Lead at dpl@wavemobile.com.

Who is the
Data Controller?

If we have collected your personal data directly from you for our own purposes, we are the Data Controller.

If your data has been passed to us by a third party for processing under their instruction, that third party is the Data Controller. They should have notified you that they would be passing your personal data to us, WAVE MOBILE LTD, at the time they collected your data and within their own privacy notices/standards. For a list of Data Controllers that we process personal data for, the section below ‘Third Party Interests’.

What are the lawful bases for processing personal data?
Under Data Protection Legislation, there must be a ‘lawful basis’ for the use of personal data. The lawful bases are outlined in Article 6, Section 1 of the GDPR. They are sub-sections:

‘your consent’;
‘performance of a contract’;
‘compliance with a legal obligation’;
‘protection of your, or another’s vital interests’;
‘public interest/official authority’; and
‘our legitimate interests’.

What are Wavemobile
LTD’s Legitimate
Interests?

Legitimate interests are a flexible basis upon which the law permits the processing of an individual’s personal data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible by our Data Protection Lead. You can object to our processing and we shall consider the extent to which this affects whether we have a legitimate interest. If you would like to find out more about our legitimate interests, please contact dpl@wavemobile.com.

About our Processing
of Your Data

We might collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

• Identity Data such as names, usernames or similar
• Contact Data such as addresses; email addresses and telephone numbers.
• Financial Data such as bank account and payment card information.
• Transaction Data such as information about payments and details of purchases you have made.
• Technical Data such as IP addresses; login data; browser info; time zone; location; browser plug-ins; operating systems; platforms and other technology on the device used to access this website.
• Profile Data such as usernames; passwords; security answers; purchases/orders; interests; preferences; feedback and responses to surveys, blogs and messages.
• Usage Data such as analytics relating to how you use the website
• Marketing and Communications Data such as your preferences about receiving communications from us or third parties.

Reference

What happens if I
refuse to give
WaveMobile Ltd my
Personal Data?

If your personal data is used for any of our services (and subsequently processed under ‘Legal’), your personal information has been collected as part of a statutory obligation arising under statutory regulations relating to mobile communications. Failure to process your data could result in us being unable to fulfil the provision of services. The information about you that we have collected for the performance of our contracts is required for us to successfully fulfil our obligations to you. If you choose not to provide the personal data requested, we will not be able to enter into a contract with you to provide the services we offer. If we are already processing your personal information under a contract, you must end our contractual relationship (as/where permitted) to exercise some of your rights.

The information about you that we have collected for the performance of our contracts is required in order for us to successfully fulfil our obligations to you. If you choose not to provide the personal data requested, we will not be able to enter into a contract with you to provide the good and services we offer.