• Information you’ve provided to us about you, where you live and how to contact you, provided through our website or when you access our services through applications on websites operated by other organisations (Facebook for example).
• Information about our content, products and services you’ve ordered or enquired about.
• Information provided by other organisations who’ve obtained your permission to share information about you with us.
• Information, uploads, user-generated content and comments that you make about products and services you use.
• Information we collect, via cookies and related technology, from the devices you use to access Origin content and services, about your or your households use of Origin content and services, and/or third-party content, product or services. This may include data classed as digital ‘fingerprint’ information that relates to your device, machine or browser so that we can make sure you get the products and services that are applicable to you. For more information on cookies, please see our Cookies Policy [Insert hyperlink]. IP Addresses, identification numbers, online identifiers, browser information, location data and other similar identifying information required for your devices to communicate with websites and application on the internet.
• Technical information from the devices you use to receive our products and services, for example the collection of diagnostics and traffic or location information. Note that devices and applications have their own privacy settings and notices under which they collect your information, so please check and manage your device and application settings.

Communication Monitoring

We may also monitor, record, store and use communications we have with you to improve the quality of our customer service, to confirm any instructions you give us, and/or for training and operational compliance purposes.

We need your information so that we can, in accordance with the contract you have with us, provide you with content, products, services, tailored and personalised recommendations, general account management, the management of our products and services and traffic across our network. Origin uses your information to facilitate the operation of its network by choosing the most efficient route to transmit your requests for a communications service through various part of its network equipment and systems.

This information may include use of your IP address, MAC address, port information, logical network address or similar operational or technical information about your equipment or of each device you use to access Origin’s services. This information is held securely within restricted areas accessible only by authorised personnel and in accordance with our data retention, deletion and acceptable use policies.

In addition to using your information for such necessary purposes, we may also use your information to improve our products, services and customer experiences, in the following ways:

• To monitor, improve and protect our content, products and services, work with our agents and business partners to improve the product and services we offer, and develop new content, products and services.
• To help us define groups of audiences to send adverts to, based on factors like interests, age, location and more, so we can show adverts to the people most likely to be interested in the products and services being promoted.
• For Market Research
• To send you periodic newsletters and other information about content, products and services you have chosen or are entitled to receive

We may give you choices on how we use your information

To send you direct marketing. This may include communications by post, telephone, SMS, email or other electronic means, using the contact details you have provided, about us and our business partners’ content, products and services, events and special offers.

• We may use and share your information with credit reference, fraud prevention agencies, entities in which we hold a share of the ownership and other companies for use in credit decisions, for the detection and prevention against fraud and other crimes, and debt recovery purposes. If false or inaccurate information is provided and fraud is identified the details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering for example when: checking details on applications for credit and credit related or other facilities; managing credit and credit related accounts and facilities; recovering debt; other types of financial services; or checking details of job applications and employees. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies. Please contact us if you want to receive details of the relevant fraud prevention agencies.
• We may use and share your information with third parties to enable us to comply with any legal or regulatory requirements; to protect or enforce our rights or the rights of any third party such as analysing activity on our network to help block unauthorised or illegitimate content, publication of, or access to it; and for the purpose of safeguarding an individual’s vital interests, national security, responding to statutory obligations or requests from courts and enforcement agencies.
• We may use and share your information with third parties to enable us to comply with our contractual requirements or to process the legitimate interests of Origin. Examples of these include: ensuring the efficient provisioning of your products and services with us; to ensure timely and effective billing; and to allow us to enhance the performance of product and services that we provide you.
• We may transfer your information to our data processors within and outside the European Economic Area, with appropriate measure and controls in place to protect your information in accordance with GDPR or other applicable data protection laws and regulations and regulatory guidance. In all instances, we will take into account the nature of the information we are transferring, and the level of protection provided by those processors.

We will retain a record of your personal information in order to provide you with a high quality and consistent service from Origin. We will always retain your personal information in accordance with law and regulation and never retain your information for longer than is necessary and in accordance with our data retention policy.

We endeavour to protect your data by storing it on secure servers and by using technical and organisational security measures to safeguard your personal data and to reduce the risk of loss, misuse and unauthorised access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls, and information controls. Where we have given you (or where you have chosen) a password which enables you to access restricted areas of our Customer Portal, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

You have the following rights with regards to your personal information:

• Access: You have the right to access data that we hold about you. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide this information to you (or someone else on your behalf), we will provide it to you or them free of charge in the first instance. After this time, each additional request will cost a fixed fee of £20.00 to cover the administration of your request.
• Rectification or Erasure: You have the right to request that we rectify or delete any personal data that we hold about you (unless we have a legal right or obligation to retain i.e. to fulfil our contract with you).
• Restriction: You have the right to restrict your use of personal information if the data is inaccurate, our use of the information is unlawful or if we no longer need to use the data for the purposes for which we hold it.
• Change your preferences: You can change your marketing preferences at any time. Details of how to request this can be found under ‘Managing your Marketing Preferences’.
• Automated decision making: You can contact us at any time to request how we use any of your personal data to make automated decisions.
• Data Portability: You have the right to obtain personal data we hold about you, in a structured, electronic formation, and to transmit such data to another data controller, where there is (a) personal data which you have provided to us and (b) if we are processing that data based on your consent (such as your marketing preference information) or to perform a contract with you.
• Complaints: If for any reason you are not happy with the way that we have handled your personal data, please contact us. If you are still unhappy, you have the right to make a complaint to the Information Commissioner’s Office.

Before providing information to you, or rectify or erasing data for you, or another person on your behalf, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. To exercise any of the rights above, please contact us via the details in our Updating your data section.

You may notify us of any updates, amendments and corrections to your information, or restrict or delete your data (where applicable) on 0330 024 17 77.

Please note that we may need certain information to enable us to provide you with products, goods and services you ask for, so changes you make to your data or restrictions you ask us to make on how we use your data may affect what services we can provide.

Direct Marketing and tailored advertising

You can always choose not to receive direct marketing or tailored advertising and service from Origin Broadband Ltd in the following ways:

• Clicking on the unsubscribe link in any electronic marketing information from us.
• By calling us on 0330 024 17 77.

Consent – Freely given, specific, informed and explicit consent by statement or action signifying agreement to the processing of their personal data.

Data Controller – Determines the purpose for which and the manner in which any personal data are, or are to be, processed.

Data Processor – An entity that processes data on behalf of a data controller.

Data Subject – A natural person whose personal data is processed by a data controller or processor.

Encrypted Data – Personal data that is protected through technological measures to ensure that the data is only accessible/readable by those with specific access.

Personal Data – Any information related to natural person or ‘Data Subject’, that can be used to directly or indirectly identify the person.

This policy will be regularly reviewed to ensure we maintain transparency with you. The last published updated occurred on 08/05/2018.