Your privacy is extremely important to us. This policy explains what personal information we have, how we use it and how you can check and update any of your personal information.

For the purposes of this Privacy Policy, when we refer to:

·      “you”, we mean the person/s who use, contract for, or show interest in The SIM Works products and services, their representatives and any third parties connected to you that you’ve told us about;

·      “we” or “us”, we mean The SIM Works Ltd “The SIM Works”

Why do we collect your personal information?

We collect information because:

You've contracted with us. For example, we need your information to help manage your account and deliver products and services relevant to you (whether we provide them or not), or you work for The SIM Works and we need your information to look after you and your employment with us;

You've given us your consent. For example, if you've entered a competition, or agreed for us, or specified third parties, to send you direct marketing, offers and that are relevant to you;

We've got a legitimate interest to help us run and grow our business. For example, improving our products and services, developing new ones, telling you or prospective customers about our products and services (unless it’s in a way that requires consent), finding new customers, understanding more about who our customers are and what they like, tailoring our advertising to the right audience/s managing credit and fraud risks, managing our network and complying with our legal and regulatory obligations. The law also requires us to process some information. For example, we need to monitor usage to make sure we implement spend caps correctly. Occasionally this information is anonymised so you can't be identified.

To find out more, click on any of the sections below:

The type of Information we have

Where do we get your information?

How we use your information

How we share your information

Why we keep hold of your information?

How to check and update your information

Product specific terms

Other important things to know and your rights

The type of information we have

The information we have about you includes things like who you are, how you use your The SIM Works products and services, where you use our network, and how you pay for your services.

Who you are includes:

·      Your name, phone number, address, gender, age, interests, etc.

·      Your debit or credit card details, bank details and other payment information.

·      Your interests and preferences.

·      Your driving license or other documents that help us verify your identity or contact details or your authority to represent a The SIM Works customer.

·      How you use your The SIM Works products and services includes:

·      Your call, text, surfing and billing records.

·      Details about your usage of any other products we supply to you, such as our apps. This includes the date and time you use them, how long for, where you use them and how much it costs.

·      We don't look at the content of your messages or listen to your calls (unless you are talking to one of our customer service advisors).

Where you use our network:

So we can connect you to our network, and for some of the purposes mentioned in this Privacy Policy, we need to know your location when you make or receive phone calls, messages or use the internet. We call this network location. It works by finding you through nearby phone masts, providing us with a rough location so we can put calls through or connect you to the internet.

If you don't want us to share your network location or some or all of your services, please contact The SIM Works Customer Services team.

If you use a smartphone it might also have a Global Positioning System (GPS) location, that's used by your phone and certain apps. It is more accurate than network location alone because it uses satellites. If you are using some of our apps, like The SIM Works Community we, or our partners, might collect some of your GPS location information.

GPS location is different from network location. We do not control it, so there is no need to contact The SIM Works Customer Services team. GPS is based on satellites and is set up on the phone itself. Look at your phone's settings to configure it. Remember, if you choose not to share your location, you might not be able to use certain services that need to know where you are for those services to work.

Where do we get your information?

We collect information mainly when you sign up with us, contact us and when you use our products and services. We also record calls for training and monitoring purposes.

For example, we will collect information when:

·      You register as or enquire about The SIM Works products and services or take part in market research.

·      You get in touch with us to ask something.

·      You buy from us – whether it's online, over the phone or somewhere else.

·      You enter any surveys, promotions, competitions or prize draws.

·      You make changes to or close your The SIM Works account.

·      You go to our website, apps, or the websites or apps of any other third parties working with us, or websites used for market research purposes.

·      You submit content, including photographs, or comments to participate in discussion threads.

·      You use any of our networks – mobile, WIFI or other The SIM Works products and services.

·      You sign up for a service with us that means we need to check with credit reference and fraud prevention agencies, or you sign up for a service with someone else and they need to verify details with us.

·      You sign up for an insurance product that means we need you to provide sensitive personal data, including any medical or criminal record information, about you or a third party.

·      You apply for a job with us.

·      You join one of our community groups

We also collect information from other sources, including business directories and other commercially or publicly available sources, for example if you’ve agreed to share data or accept the use of cookies with other sites, such as Google or social media.

If we need to conduct a credit check, we will receive information from credit reference agencies.

If you use third party services which need to verify your mobile number or identity, or if you have purchased products or services through a third party but have specifically consented to receive communications from us, we will receive your information from that third party.

How we use your information

We use and analyse your information to keep in touch with you and to supply and improve our products and services. We will also use your information to tell you about products and services that we think may interest you. Sometimes we'll combine and anonymise this information, so you won't be identified.

In particular, this means using your information to:

·      Help you and us manage your account, including:

·      Sorting out a payment, put your order through our system or send you an order.

·      Getting in touch with you (e.g. if we need to tell you about any problems with a service).

·      Looking into any complaints or questions you may raise;

·      Telling you if we've changed the way a service works or other important information about the products and services you use;

·      Checking whether you qualify for credit or other products, services and offers. We use automated systems to analyse your information to help us make fair and objective decisions about whether we can give you (and members of your household) credit, credit-related services, other similar facilities or insurance. As part of this we may also need to check the financial status of people connected to you (e.g. your spouse or other family members).

·      Tracing and recovering debts, managing credit, detecting and preventing fraud and money laundering.

·      Recovering any money you might owe us.

·      Assigning your debt to permitted third parties and look after any credit you might have.

·      To run our business, supply and improve our products and services and develop new ones, including:

·      Looking at markets, writing reports or carrying out research and number crunching. And, if the law allows it, looking at information about you (including the calls you make, your spending, what you use the internet for and where you are when you do it).

·      Managing our network and your use of our network.

·      Improving our (and third party partner) products and services and develop new ones.

·      Complying with legal and regulatory obligations (such as legal obligations to keep details of calls made by customers for a certain period of time, to protect vital interests, national security or comply with requests from legal or enforcement authorities);

·      Prevent fraud, illegal activity and money laundering to minimise our credit and fraud risks and protect you and our business.

·      To market products and services, including:

·      Telling you about a new service that we think may interest you, checking what you're interested in or eligible for, so we can offer (and develop) relevant products and services, and surveys.

·      Understanding more about you and The SIM Works customers so you only receive marketing which is of interest to you and so we can find and attract new customers who have similar tastes.

·      Helping build effective and targeted marketing campaigns to you and similar audiences.

·      Sending you information about our products and services (or those from selected third parties we think you'd be interested in) by phone, post, email, text, picture message, online banner advertising, or other ways. For some of this marketing activity we need your consent and, in those circumstances, we will only send you messages if you have asked to receive them. You can update marketing preferences at any time using the link in any marketing communication received or by contacting The SIM Works Customer Services team.

·      Where you have provided your consent, telling you about products and services from other companies we think you'd be interested in, or let selected third parties tell you directly about their products and services.

How we share your information

We may share your information in order to do all the things we’ve described above. We only provide the information they need to perform their services, and they’re only allowed to use it for the purpose that we’ve agreed with them.

This might mean sharing that information with:

·      Our partner companies or agencies and their sub-contractors or prospective partners who help us run and develop our current and future products and services, for example our delivery couriers billing or customer service centres and our initiatives.

·      Insurance providers when you take out a policy through us.

·      Third parties whose products and services we market to you (where you have given permission to receive such messages).

·      Third parties whose services or offers you sign up to, and in order for those third parties to mitigate fraud, identity theft, or facilitate a quicker and more secure access to their services or who may market to you. Third parties like Google or Facebook, to ensure that you are not included in marketing campaigns which are not of interest to you or to understand our customers better and find new audiences who have similar tastes to you. This is based on either your acceptance of cookies or your agreement with Google or Meta (Facebook);

·      With our partners and contractors for market research and other construction.

·      Third parties with whom we annonymise cookie data (see our Cookies Policy for more detail).

·      Third parties in connection with a corporate reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock, including in connection with any bankruptcy or similar proceedings.

·      Other communications companies.

·      New or prospective owners of The SIM Works Ltd.

·      Credit reference and fraud prevention agencies. When we check your credit score with a credit reference agency, the information that we give them (including details of your credit application and financial details) as well as the fact that we have requested that search will also be recorded by the credit reference agency. We exchange information with credit reference agencies on payment performance and your financial situation on an ongoing basis and this information could be used by us and third parties to make future credit assessment decisions. Your data will also be linked to the data of your spouse, any joint applicants or other financial associate. If fraud is detected, you could be refused certain services, finance, or employment.

We might also share your information:

• With any public authority or law enforcement agency (if they ask for it).
• To comply with law or regulations, or for possible legal proceedings.
• If you give us personal information that's wrong or we find out (or think) you're responsible for fraud. In these circumstances we might share your information with third parties such as law enforcement agencies, credit reference agencies and other affected third parties.
• If one of our partners who are processing information for us are compelled to do so by law.
• If there's an emergency and we think you or other people are at risk.

Why we keep hold of your information:

• We keep information for as long as we need it for the purposes described above. There are certain reasons we have to keep hold of your information.
• We keep information while you're our customer. After you've left us, we will generally keep it for at least one year and up to seven years, depending on the type of information and the reason we need it. Sometimes we may need to keep it for longer. The retention period will be determined by various criteria including:
• We might need to sort out disagreements, stop fraud and abuse, prove that you had an account with us or follow our legal obligations. Or the police may need it as evidence. We may also keep information about how you use our products or services. But in each case, we will only keep the information for as long as we need it. Credit reference of fraud prevention agencies with whom your information may be shared may need to keep the information for up to six years
• If we need it for audits, checks or corporate responsibilities.
• Laws or regulation may set a minimum period for which we have to keep your information.
• If the data is aggregated or anonymised so you can no longer be identified by it.

Your rights

You have a number of legal rights in relation to the information that we hold about you, including:

• The right to request details of the information we have about you.
• The right to withdraw your consent to the use of your information where we are relying on that consent (for example, you can opt out of receiving marketing messages from us). Please note that we may still be entitled to process your information if we have another legitimate reason (other than consent) for doing so.
• In some circumstances, you have the right to receive some of your information in a usable format and/or request we transmit that data to a third party where this is technically feasible. Please note that this right only applies to information which you have provided to us.
• The right to ask that we update your information if it is inaccurate or incomplete.
• The right to ask that we erase your information in certain circumstances. Please note that there may be circumstances where you ask us to erase your information, but we are legally entitled to retain it.
• The right to request that we restrict the processing of your information in certain circumstances. Again, there may be circumstances where you ask us to restrict the processing of your information, but we are legally entitled to refuse that request.
• The right to make a complaint with the Information Commissioner www.ico.org.uk if you think that any of your rights have been infringed by us.

You can exercise your right by emailing us or you can speed up the process by completing our “Personal Information Request Form”. Along with the details required to complete the form, you'll need to include some proof of identification. We provide you with guidance notes to help you make your Subject Access Request.

Other Important things to know

About cookies:

Like other sites, we use cookies. A cookie is like a tag that some sites put on your computer or phone when you visit them so they can recognise you next time. Find out more here: https://www.thesimworks.net/aboutcookies

Communicating over the internet:

Please remember, any emails or other communications you send over the internet aren't safe unless they've been encrypted. They might go through a few countries before they get to your friend who lives around the corner. Unfortunately, that's the nature of the internet. If someone gets into your emails without your permission, or your personal information is shared publicly, we can't accept responsibility. It is out of our control.

Other important information

Please note that if you're signing up for our products and services there might be extra terms and conditions to look at.

If you would like to know more about how credit reference and fraud prevention agencies use and share your personal information you can find that information at:

www.callcredit.co.uk/crain

www.equifax.co.uk/crain

www.experian.co.uk/crain

www.cifas.org.uk/fpn

Contact Us

If you want to know more about how we use your information or to raise any queries with us in relation to your information, you can contact us or email: hello@thesimworks.net

Version:TSWPPV.01

Publication Date: May 2022