Privacy statement and information clause
August 08, 2023
This Privacy Policy explains our practices and processes regarding the collection, use, and disclosure of certain information, including your personal information, by TP Global Operations Limited (from now on referred to as “1GLOBAL”). This policy has been written in line with our obligations under the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 as they apply in the UK. This privacy policy applies to the products and services we provide to you, namely our mobile communications services and associated products, our apps and our websites (“1GLOBAL Services” or “Services”).
DATA CONTROLLER
The data controller (the entity that determines the purposes and means of the processing of your personal information) is TP Global Operation Limited, registered in England and Wales, Company Registration Number 04187081, registered office: 109 FARRINGDON ROAD, LONDON, EC1R 3BW, UNITED KINGDOM VAT No. GB 418425009, Company Registration 14109189. 1GLOBAL is a trading name of TP Global Operations Limited.
CONTACTING US
If you have any question regarding the Services, you can contact us at business.help@1global.com . If you have questions about this Privacy Policy or have any questions regarding your personal data processed by 1GLOBAL you can contact our data-protection officer by email at dpo@1global.com
At 1GLOBAL we are committed to the privacy and securing of the data we hold about you therefore please note that to protect your personal information we may need to authenticate your identity before providing any assistance.
COLLECTION OF INFORMATION
We receive your personal data from you when you register for your 1GLOBAL account and subscribe to the Services, and later, while using the Service. Information about you can be retrieved from cookies collected by 1GLOBAL and similar mechanisms for saving information on the devices of website users when possible.
In addition, we receive information about you from payment operators, i.e. entities that enable you to make online payments for services purchased from 1GLOBAL. We receive information from them about the status of your payment for the service.
If you log in to your 1GLOBAL account via another platform - verifying and authenticating you - we receive this data from entities providing such a service, i.e. Facebook, Google or Apple.
We receive and store information about you such as: your name, surname, email address, contact of physical address, payment method(s), telephone number and device id number connected to our Services. We also hold data about which of our services you have used, and when. This will include call times and lengths, SMS sent/received, network usage made, routing and durations which are known as "traffic data". We will also, for a short period of time, hold data in relation to the websites, and IP addresses that your devices have used. This information is stored by 1GLOBAL only when you use 1GLOBAL’s voice, data, or SMS services. It is not stored by us if we are merely providing remote SIM provisioning services or if you have installed a 1GLOBAL eSIM profile to your device but are not using our network for their voice, SMS, or data service (for example, if you are using WiFi or another SIM card). Under certain circumstances for regulatory purposes in some countries in order to provide the Services we may require copies of personal documentation (Passport, ID document, etc) from you which will be held by us and made available to national regulators if they so request. We may collect this information in a number of ways, including when you enter it while using our service, interact with our customer service, or participate in surveys or marketing promotions as the case may be.
COOKIES
Cookies are pieces of information that 1GLOBAL will transfer to your device's hard drive through your browser to enable 1GLOBAL’s systems to recognise your browser. Cookies also enable 1GLOBAL to gather information about the use of its website and to enhance the website accordingly to the preferences of the users. The Help option on the toolbar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Please bear in mind that some personalised services may not be available if you choose to disable cookies. For more information on our use of cookies please visit our cookie policy.
PURPOSE AND BASIS FOR THE PROCESSING OF PERSONAL DATA
Providing personal data by you is a statutory requirement from the provisions of tax or accounting law as well as from telecommunication law. It is also required to enter into the agreement with 1GLOBAL. If you do not provide us with all this information about yourself, we will not be able to set up your account and you will not be able to purchase and use the Services.
1GLOBAL processes your personal data to enable you to use Services, ensure the functionality of the services offered, including solving technical problems, enable payment for services, handle complaints and perform obligations resulting from legal provisions, including tax, accounting and telecommunication regulations.
1GLOBAL is entitled to process your personal data because it is necessary to perform Services, as well as on the basis of legal provisions, e.g. when these provisions require us to process your data for tax, accounting or telecommunication purposes.
The legal basis for the processing of personal data is also the legitimate interest of 1GLOBAL. It includes improving services, ensuring the best quality, informing our users, ensuring the maintenance of your 1GLOBAL account, conducting research and analysis, conducting direct marketing, protecting or pursuing claims, creating statistics and ensuring accountability.
If you have consented to the use of personal data for marketing purposes, then we may use your personal data to send you information about additional services that we provide.
EXERCISE OF INDIVIDUAL RIGHTS
You can request from 1GLOBAL access to your personal data, rectification, deletion, restriction of processing or transfer and you have the right to object to the processing of your personal data. If we have collected and process your personal information based on your consent, then you can withdraw your consent at any time; withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. Where possible and such request is not in a contradiction with the law, we will process such request however depending on the nature of the request from time to time this may impact your ability to use the service. To process your right to erasure (‘right to be forgotten’) or to obtain confirmation whether or not we are processing your personal data please contact us at dpo@1global.com
DISCLOSURE OF INFORMATION
In order to deliver the Service, we disclose your information for certain purposes and to third parties, as described below:
The TP Global Operations Limited group of companies: We share your information among the TP Global Operations group as needed for: data processing and storage; providing you with access to our services; providing customer support; making decisions about service improvements; content development and for other purposes described in this Privacy Policy. For further details of TP Global Operations group companies please visit www.1global.com.
Third Party Service Providers: We may use other companies or contractors (“Third Party Service Providers”) to perform services on our behalf or to assist us with the provision of services to you. Therefore, we may engage Third Party Service Providers to provide marketing, advertising, communications, security, infrastructure and IT services, to customize, personalize and optimize our service, to provide bank account or balance information, to process credit card transactions or other payment methods, to provide customer service, to analyze and enhance data (including data about users' interactions with our service), and to process and administer consumer surveys. In the course of providing such services, these Third Party Service Providers may have access to your personal or other information. We do not authorize them to use or disclose your personal information except in connection with providing their services to us. Third Party Service Providers have a Data Processing Agreement enforced by 1GLOBAL, thus cascading to them the security and privacy requirements we uphold with the customers.
Business transfers: In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Policy.
Whenever in the course of sharing information we transfer personal information to countries outside of the European Economic Area and other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by the applicable laws on data protection.
IN ORDER TO PROVIDE YOU WITH THE SERVICES 1GLOBAL MAY TRANSFER YOUR PERSONAL DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA TO THE COUNTRIES THAT PROVIDE AN ADEQUATE LEVEL OF PERSONAL DATA PROTECTION, OR IN COUNTRIES THAT DO NOT PROVIDE SUCH A LEVEL LIKE UNITED STATES, HONG KONG OR PHILIPPINES. IN THE LATTER CASE 1GLOBAL SECURES YOUR DATA BY CONCLUDING AGREEMENTS WITH RESPECTIVE COMPANIES CONTAINING THE SO-CALLED STANDARD CONTRACTUAL CLAUSES APPROVED BY THE EUROPEAN COMMISSION. BY ACCEPTING THIS PRIVACY STATEMENT AND INFORMATION CLAUSE YOU HEREBY ACKNOWLEDGE THIS FACT AND CONSENT TO THAT.
SECURITY OF PROCESSING
Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, 1GLOBAL has implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk.
TP Global Operations Ltd is an ISO 27001 – Information Security Management System and ISO 22301 – Business Continuity Management System Certified Organisation and upholds best practices certifications from GSMA Security Accreditation Scheme and the UK Cyber Essentials Plus.
We also take, on a continuous basis, independent audits regarding security best practices and compliance against the General Data Protection Regulation (GDPR).
If you suspect that we have shared your data inappropriately, or wish to report a security issues or non-compliance with your data, then please email: ciso@1global.com or call our helpdesk providing us details of the issue and we will investigate immediately.
INFORMATION STORAGE
There are strict obligations which define for how long we may hold personal data about you. These obligations are included in data protection and data retention legislation. We will hold your personal data as outlined in the table below:
DATA RETAINED
RETENTION PERIOD
Provision of the Service(s): 3 years
Call & SMS Usage: 12 months or As Required by Legislation
Data usage: 30 Days or As Required by Legislation
Payment Records: 7 Years
Customer Support Records: 3 Years
1GLOBAL also stores your personal data for the duration of the agreement concluded with you, and - after its termination - for the period in which it is possible to pursue claims in connection with the performance of the agreement.
1GLOBAL may as well stores your personal data for marketing purposes for the duration of the legal basis and the purpose of data processing.
SUPERVISORY BODY
If you want to contact us about any of your rights or complain about how we use your information, please contact us at dpo@1global.com – we’ll do our best to help but if you’re still unhappy, you can contact the Information Commissioner’s Office (ICO). Their website www.ico.org.uk has details on how to contact them.