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Privacy and Cookie Policy

Privacy and Cookie Policy

1 About Us

Netomnia Limited (“Netomnia”, “we” or “us”) is a full fibre infrastructure company. We are a limited company registered in England and Wales under company number 12008248 and our registered office and main trading address is at c/o Sherborne Solicitors Ltd, 4 Royal Crescent, Cheltenham, England, GL50 3DA.

Netomnia is committed to protecting and respecting your privacy.

Our Privacy and Cookie Policy (“Privacy Policy”) lets you know how we collect and use your personal data and tells you about your privacy rights. When we refer to “personal data” in this Privacy Policy, we mean information which can identify you as an individual. It is important that you read this Privacy Policy so that you are fully aware of how and why we are using your data.

By (i) registering your interest in the network on our Website, or (ii) giving us your details for us to contact you in relation to our services or business development, (iii) contacting us via our website or email, you agree to the collection and use of your information under the terms of this Privacy Policy. If you do not agree to the data practices set out in this Privacy Policy, we will not be able provide you with our services.

2 Information we collect about you

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.

  • Contact Data includes address, email address, social media username (if given) and telephone numbers.

  • Usage Data includes information about how you use our services, our network and our Website.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share “Aggregated Data” (this means statistical or demographic data derived from your personal data). Aggregated Data is not considered personal data in law as this data does not directly or indirectly reveal your identity.

3 How we collect your personal data

(i) Identity Data and Contact Data

You may give us your Identity and Contact by corresponding with us by via our Website, systems or communicating with our team, by email, on the telephone or by post. This includes personal data you provide when you:

  • fill in paper forms or online forms on our Website

  • register to use our Website

  • record your registered interest in the network

  • give us your details for us to contact you in relation to our services

  • post any material on our Website

  • ask for help or advice or report a problem with our services

  • request marketing communications to be sent to you

  • enter a competition, promotion or survey

  • give us feedback

This also includes information you enter even when you only partially fill out an online form, and exit before completing it.

When you contact us (by phone, email or via our Website), we may keep a record of it and what you say to us.

(ii) Profile Data

We automatically collect Technical Data about your visits to our Website (including, but not limited to, traffic data, location data, weblogs and other communication data) and the websites and other products and services you access through it. We collect this personal data by using cookies, server logs and other similar technologies. Please see the Cookie Policy section below for more information about how we use cookies and how to change your browser settings to refuse some or all cookies.

(iii) Marketing and Communications Data

We will keep a record of whether you have opted out of receiving marketing from us. We will also keep a record of your communication preferences.

4.0 How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests

  • Where we need to comply with a legal or regulatory obligation

Performance of Contract means using your data as necessary for us to provide a quote to you or fulfill a contract to provide our services to you.

Legitimate Interest means using your data as necessary for the commercial interests of our business, allowing us to conduct and manage our business to give you the best possible service and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.

Comply with a legal or regulatory obligation means using your personal data to the extent necessary for us to comply with a legal or regulatory obligation that we are subject to.

We have set out below a description of the ways we use your personal data. Note that we may use your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data.

Purpose/ActivityType of dataLawful ground for processing
To monitor and record our communications with youIdentity Contact Usage TechnicalQuestions and Support; and Necessary for our legitimate interests (for training and quality purposes)
To manage our ongoing relationship with you which will include: Responding to any questions; Notifying you about changes to our services; and asking you to leave a review or complete a feedback surveyIdentity Contact Profile Marketing and CommunicationsPerform our contract with you; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated, maintain and develop our service provision and to understand how communities feel about our services)
To administer and protect our business, network and Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)Identity Contact TechnicalNecessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); and Necessary to comply with our legal obligations
To deliver relevant Website content and advertisements in the most effective manner to you and measure or understand the effectiveness of the advertising we serve to you.Identity Contact Profile Usage Marketing and Communications and TechnicalNecessary for our legitimate interests (to study how communities view our business, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Website, services, marketing, customer relationships and experiencesTechnical UsageNecessary for our legitimate interests (to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)
To register your interest in the networkIdentity Contact UsageTo keep you updated on the progression of the network

5.0 Marketing Communications

If you have registered interest in the network, we may also use your Identity, Contact, Technical, Usage, Profile, and Marketing and Communications Data to form a view on what services and offers may be relevant for you and to send you recommendations about services that we think may be of interest or to invite you to participate in prize draws or competitions ("marketing communications").

If you have given us your details to record your registered interest in joining the network in the future or for us to contact you in relation to our services or business development (including to receive our newsletter), we may use your Identity Data to keep you up to date about our services and coverage.

You will only receive marketing communications from us if you have registered an interest in connecting to the Netomnia network and requested information from us in relation to our services or our resident internet service providers services in each case, you have not opted out of receiving that marketing.

6 Disclosures of your personal data

We may sometimes need to share your personal data with the types of third party listed below:

  • Our partner organisations, our group companies and our subcontractors who provide some of the services on our behalf
  • Analytics and search engine providers that assist us in the improvement and optimisation of our Website
  • IT and system administration services service providers
  • Professional advisers including lawyers, auditors and insurers
  • Third parties to whom we may choose to sell, transfer or merge parts of our business with

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may also disclose your personal data to a third party if we are under a duty to do so in order to comply with a legal obligation or in order to enforce or apply our terms of use. This includes exchanging information with other companies and organisations for the purposes of law enforcement, fraud protection, and credit risk reduction.

7 International Transfers

We share your personal data to Netomnia's group companies which may involve transferring your data outside the European Economic Area (EEA). We will ensure your personal data is protected by requiring all our divisions to follow the same rules when processing your personal data to ensure its security. These rules are called "model clauses".

In addition, some of our third-party suppliers are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • The third party country has been deemed to provide an adequate level of protection for personal data by the European Commission; or
  • The service provider has provided adequate safeguards to ensure that individuals rights are enforceable and legal remedies are available.

8 Data Security

We have in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We also have in place procedures to deal with any suspected personal data breach and will notify you and the ICO (the UK supervisory authority) of a breach where we are legally required to do so.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or you have chosen) a customer ID, password(s) or log-ins to allow you to can access certain parts of our Website, you are responsible for keeping these confidential. You are responsible for how our services are used from your account and for keeping your account information secret. Please keep this information safe, and do not share it with others.

Unfortunately, sending information using the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of the data you send to our Website; you take the risk for this. Once we have received your information, we will try our best to keep it secure. This includes using strict procedures and security features to try to prevent unauthorised access.

Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and others associated with us. If you follow a link to any of these websites, please note that these websites have their own privacy and cookie policies. Netomnia accepts no responsibility or liability for these policies. Please check these policies before you send any personal data to these websites.

9.0 Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for at least 7 years after they cease being customers for tax purposes.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10.0 Your Legal Rights

You have various rights in relation to your personal data – these are set out in detail below. If you wish to exercise any of these rights, please email us: dataprotection@netomnia.com

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete your personal data when we no longer need it. You may also ask us to delete your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with a legal obligation. However, we may not be able to comply with your request of erasure, for example, if we are required to retain your personal data for legal reasons. We will let you know if this is the case.

Object to processing of your personal data where we are processing your personal data for direct marketing purposes. You also have the right to object where we are relying on a legitimate interest but you feel the processing impacts on your fundamental rights and freedoms.

Request restriction of processing of your personal data. You may ask us to suspend the processing of your personal data in the following scenarios: (a) if you do not think the data we hold is accurate, whilst we verify its accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process it but you require us to store it in relation to a legal claim; or (d) if you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will if feasible practically provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to information which we process by automated means and use to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data (for example, for marketing purposes). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

You will not have to pay a fee to access your personal data or to exercise any of your other rights. However, if we feel that your request is unfounded, repetitive or excessive, we may charge a reasonable fee or we may let you know that we are refusing to comply with your request. If we refuse your request, we will explain why and you will be entitled to raise the issue with the ICO.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We will respond to all legitimate requests within 30 days of receipt and, if possible, achieve a satisfactory resolution within that time period. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11.0 Changes to this Privacy Policy

Any changes we may make to this Privacy Policy in the future will be posted on this page. You should check this page from time to time for any changes we made. We may also email you about these changes, if you are a customer of Netomnia.

12.0 Contact

If you have any questions, comments and requests regarding this Privacy Policy, including any requests to exercise any of your legal rights under it, please contact us using the details set out below.

Email: hello@netomnia.com

Post: Netomnia Limited, c/o Sherbornes Solicitors Ltd, 4 Royal Crescent, Cheltenham, England, GL50 3DA

If you have any complaint about how we are using your personal data or otherwise in relation to this Privacy Policy, please contact us in the first instance and will we do our best to resolve it. If we do not resolve it to your satisfaction, you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues www.ico.org.uk.

13.0 Cookie Policy

Our Website uses cookies – these are small files of letters and numbers which we store on your browser or the device you use to access our Website. Some of the cookies we use are essential (our Website won't work without them) and others make our Website work more efficiently and help us to recognise you when you return to our Website.

13.1. How we use cookies

We use these types of cookies:

  • Essential (Necessary) cookies: These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website.
  • Preferences cookies: These are cookies we use to recognise you when you return to our Website. They enable us to personalise our content for you and save your preferences in a cookie on your device (for example, your choice of language or region or, if you select the 'Remember me on this computer' box, your username and password). This means that the next time you log on to our Website using that device you won't need to re-enter those details. We suggest you don't select the 'Remember me' box if you use a shared device or publicly available computer. The cookie file itself won't store your personal information.
  • Analytics (Statistics) cookies: These allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily. All information collected for these purposes and shared with our analytics providers is anonymous or collected in such a way that users cannot be identified from this data. This information allows us to improve our Website and our services, for example, to measure the effectiveness or success of our advertising campaigns and products. For more information about Google Analytics, please see their privacy policy at: google.com/policies/privacy.
  • Affiliate and advertising cookies: We use cookies to place adverts about Netomnia products on other websites and manage referrals from those websites to our Website. If you follow a link from another website then purchase our services, we may use cookies to tell the other website that you have made a purchase. Or if you click on a link to an advert, video or social media channel on our Website, we may use cookies to gather statistics about this.

13.2. Which cookies we use:

Cookie name and descriptionParty and TypeMore information
__cfruidThird party, NecessaryThis cookie is a part of the services provided by Cloudflare - Including load-balancing, deliverance of website content and serving DNS connection for website operators.
__zlcstoreThird party, NecessaryThis cookie is necessary for the chat box function on the website to function .
AWSALBCORSThird party, NecessaryRegisters which server-cluster is serving the visitor. This is used in context with load balancing, in order to optimize user experience.
ZD-suidThird party, NecessaryUnique id that identifies the user's session.
ZD-storeThird party, PreferencesRegisters whether the self-service-assistant Zen desk Answer Bot has been displayed to the website user.
youFibreCokkieConsentFirst party, PreferencesCookie consent cookie. Allows the system to know if the user is not first-time visitor in order not to repeat cookie consent.
_gaThird party, StatisticsGoogle analytics cookie. Registers a unique ID that is used to generate statistical data on how the visitor uses the website
_gidThird party, StatisticsGoogle analytics cookie. Registers a unique ID that is used to generate statistical data on how the visitor uses the website
_gatThird party, StatisticsGoogle Analytics cookie. Used to throttle request rate.
_hjAbsoluteSessionInProgressThird party, StatisticsThis cookie is used to count how many times a website has been visited by different visitors - this is done by assigning the visitor an ID, so the visitor does not get registered twice.
_hjFirstSeenThird party, StatisticsThis cookie is used to determine if the visitor has visited the website before, or if it is a new visitor on the website.
_hjIncludedInPageviewSampleThird party, StatisticsDetermines if the user's navigation should be registered in a certain statistical placeholder.
hjTLDTestThird party, StatisticsRegisters statistical data on users' behavior on the website. Used for internal analytics by the website operator.
_hjidThird party, StatisticsSets a unique ID for the session . This allows the website to obtain data on visitor behavior for statistical purposes.
zabUserIdThird party, StatisticsCollects data on the user’s navigation and behavior on the website. Th is is used to compile statistical reports and heatmaps for the website owner.
ZD-buidThird party, StatisticsUnique id that identifies the user on recurring visits.
zabVisitIdThird party, StatisticsCollects data on the user’s navigation and behavior on the website. Th is is used to compile statistical reports and heatmaps for the website owner.
_fbpThird party, MarketingThis cookie is used to provide you with more relevant advertising across Facebook.
__zlcmidThird party, MarketingPreserves users states across page requests.
frThird party, MarketingUsed by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.
ads/ga-audiencesThird party, MarketingUsed by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor's online behavior across
trThird party, MarketingUsed by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.
zte#Third party, MarketingSaves a Zopim Live Chat ID that recognises a device between visits during a chat session .

Except for essential cookies, all cookies will expire after 24 months.

13.3 How to block cookies

You can block cookies by activating the setting on your browser which allows you to refuse the setting of all or some cookies. If you want to stop cookies being stored on your computer in future, you should check your browser manufacturer's instructions by clicking "Help" in your browser menu. However, if you block all cookies (including essential cookies) you may not be able to access all or certain parts of our Website. Unless you've set your browser to refuse cookies, our system will issue cookies as soon you visit our Website.

If you want to delete any cookies that are already on your computer, you should check the instructions for your file management software to locate the file or directory that stores cookies.

You can learn about and opt out of a number of commercial third-party cookies (including some used by us) at www.networkadvertising.org. Some of the opt-outs used by our commercial service providers require a cookie to be placed on your computer. This "opt-out" cookie is only used to tell the relevant cookie servers not to send you any more cookies. If you keep deleting cookies (including "opt-out" cookies) from your temporary internet files, you might need to repeat the opt-out process, the next time you visit our Website.

For more information about deleting and controlling cookies visit www.youronlinechoices.com or www.aboutcookies.org.

14.0 Date

These Terms are effective from 6 June 2021.