Privacy Statement #

This privacy statement sets out how CityFibre Holdings Ltd, CityFibre Limited and Entanet International Limited (referred to in this statement as CityFibre / we / us) use and protect any personal data that you give us when you use this website or that we hold in connection with any of our products, services or offerings.

This privacy statement applies to users of our websites, customer contacts, supplier contacts and residential householders whose personal data is collected or used when you are accessing or using our websites or interacting with us.

We are part of the CityFibre Group of companies. CityFibre Holdings Ltd is our corporate function and CityFibre Limited and Entanet International Limited are our operational companies. To the extent that they are joint controllers, their respective responsibilities for data protection compliance are set out in this privacy statement.

We are committed to ensuring that your privacy is protected. We also want to ensure you are properly informed about how your information is used and that you receive certain information that we are required to give you by law, which is why provide this privacy statement.

We may change this statement from time to time by updating this page. You should check this page from time to time to ensure that you are aware of and understand any changes.

The personal information we collect

We may collect, store and use personal data including:

Information about your device and about your visits to and use of the website including IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, website navigation;
Information provided when you register with us, subscribe to our website services and email notifications, or that you may send us via our website, email address or our business premises, for example when you make an enquiry;
For business contacts at our existing and prospective customers, partners and suppliers / third party service providers, basic contact details such as name, address, telephone number, email address, Skype / messenger service details, LinkedIn profile details, job title, function and other information, such as details contained in commercial bid documentation, Program name or code identifier and other Program-related details;
For residential householders, basic contact details such as name, address, telephone number, email address and details contained in wayleave access documentation (see below for an explanation of wayleaves);
Information about residential householders shared with us by councils and local authorities so that we can carry out build work for our network.

Information that you may provide to our sales representatives, customer service team, trusted partners (as see further below) and third party service providers, for example, when they attend premises to carry out installations, when you contact us for pre or post-sales support, or at corporate events.

We may also obtain some information relating to you from trusted third parties such as our wholesale channel partners, our installation partners, our service provider partners and also providers of lead generation services. We carry out due diligence and have contracts in place with such third parties to ensure they have obtained your information lawfully and can pass it on to us to use.

Note: A wayleave is a contractual agreement between a landowner and a telecommunications provider, where the landowner grants the network provider a licence with the right to access property, to install and/or maintain electronic communications equipment. For further information about wayleaves, see here.

Using your personal information

We collect information about individuals for the purposes stated below in this Statement or such other purposes as we may notify you of from time to time, for example, on other parts of the website or in other relevant documentation.

We use your personal data for these purposes where either: (1) you have consented to this; or (2) this is necessary to provide services or take actions that you have requested; or (3) this is necessary to perform our legal and regulatory obligations; or (4) this is necessary for the purposes of our legitimate interests.

Where processing is necessary for the purposes of our legitimate interests, you can object to this processing at any time by contacting us using the contact details below. This processing is indicated with a “*” below. See also “Your rights” regarding your right to object below.

Your personal data may be required by us from time to time in order to provide you with the best possible service and experience when using our website or our products or services, or to assess which products or services may best suit your needs or those of your business.

Specifically, information held about you may be used by us for the following reasons:

To ensure that content from our website is presented in the most effective manner for you and for your device and to gain insights into how website users are using our website and to improve user experience;*
To ensure the efficient and effective running of our services;
To monitor and analyse network build performance and to benchmark our business processes and performance data;*
To provide you with information, [ 1] products or services or take actions that you request;
To provide you with information about network updates, such as service outages, connection failures and maintenance work;*
To provide you with promotional material which we feel may interest you (subject to the appropriate marketing permissions) – see ‘Marketing to business contacts’ below;*
To provide you with promotional material which we feel may interest you by email, phone, text or mail about new products, special offers, network updates, local events or other information (subject to the appropriate marketing permissions) – see ‘Marketing to business and consumer contacts’ below;*
To provide third parties with statistical information about our web users (for example Google Analytics);*
To allow you to participate in interactive features of our products and services (such as the availability checker), when you choose to do so;
To notify you about changes to our products and services;
For sales and lead generation, including for organising and attending corporate events and for marketing planning;*
To undertake segmentation and demographical analysis to predict areas of demand;*
To perform our obligations arising from or related to any contracts entered into between your business and us, and for effective customer account management, partner management and supply chain management, including performance monitoring and management;*
To perform our obligations arising from any contracts between us and your service provider to deliver the connectivity requirements you have signed up to;
To maintain risk and compliance records, and carry out compliance monitoring, incident management and investigations of relevant suppliers and third party service providers;
For internal administration, governance and recordkeeping and for business analytics, financial and accounts management and reporting purposes;*
To help us prevent, detect and investigate fraud;*
To meet our legal obligations or to bring or defend legal claims;
To maintain the security of our websites, services, systems and assets, as well as to detect and investigate activities that may be illegal or prohibited;*
To facilitate multi dwelling unit and single dwelling unit wayleaves, including to keep you informed about build issues that may affect your property;
To maintain risk and compliance records, and carry out compliance monitoring, incident management and investigations of relevant suppliers and third party service providers;
For internal administration, governance and recordkeeping and for business analytics, financial and accounts management and reporting purposes, and network fault management process purposes.*
[ 2]

Visiting our premises in person

When you sign in we will process your personal data for the purpose of site security and fire safety. This is necessary for compliance with our legal obligations.

We will store personal data relating to your visit for 12 months, or longer if required in relation to a legal claim. We will share your personal data with other third parties only to the extent that the disclosure is reasonably necessary for the purposes of investigating incidents occurring on our premises, or as required by law.

Queries and complaints

We collect information when:

You contact us to ask for information
You bring a complaint to us, including about our build projects
We are looking at a complaint and need more information to resolve a query
You ask us to review any decision we’ve made

We will normally let you know what types of information we are asking for and why. For example this may include:

Your name
Your contact details
Information you tell us about your complaint or query

We use this information to:

Provide you with information
Refer back to the information if you contact us again
Investigate and make decisions on complaints
Respond to complaints about our work
Bring and defend legal claims or investigations by regulators or enforcement agencies
Monitor and assess the quality of complaint handling and service provision by our teams
Report on trends and statistics
Learn more about our users and what their needs are
Ask you about our service in the form of a customer satisfaction survey

Responding to surveys

We may use third party services to conduct surveys. We may need to pass your contact details on to them so that they can share information about the survey with you but they are required to keep personal information secure and handle it in accordance their own privacy policies and as is necessary to provide the service to us.

Residential householders

We may from time to time ask residents to complete an optional survey if you make a complaint or in relation to other aspects of our operations, such as our door knocking activities. When you respond to any surveys we will collect and analyse the responses you give us to help us improve our service or for compatible purposes.

Resident surveys will generally be anonymous unless you include any additional information from which you can be identified in the optional comments sections, in which case your information will be used in accordance with this Privacy Statement, including to respond to any specific issues that you have raised. Otherwise, personal data contained in surveys will be erased or deidentified at the earliest opportunity.

Business contacts

We may also from time to time ask our partners and suppliers to complete surveys. When you respond to any surveys we will collect and analyse the responses you give us to help us improve our service or for compatible purposes, such as analysing and monitoring network build performance and benchmarking our business processes and performance data.

Marketing to business and consumer contacts

As a wholesale fibre network infrastructure provider, we may periodically send promotional information to business and consumer contacts by email, phone or mail about new products, special offers, network updates, build updates local events or other information from us, our affiliate companies (including our sister company CityFibre Metro Networks Limited) or our approved third party internet service provider partners which we think you may find interesting and relevant, using the contact details which you have provided.

Please follow the “unsubscribe” or opt-out process in any of our communications or email info@cityfibre.com at any time with “Unsubscribe” in the subject line if you do not wish to receive such information.

We retain your personal data for as long as is necessary for our lawful purposes, subject to our legal, regulatory and reporting obligations, or where we have your consent to retain it for longer. Wayleave access information is retained for the duration of the build being carried out by our wayleave and multi-dwelling unit teams and relevant contractors, which is typically five to 10 years.

Disclosing personal information

Website users and business and consumer contacts

To other companies in our corporate group for the purposes of internal administration, governance and recordkeeping, business analytics, financial and account management and reporting purposes;
To trusted partners that provide essential support to our network, such as (where relevant) our network integrators and resellers, our approved third party internet service provider, data centres and mobile operators / “fibre to the home” providers, such as Vodafone and other internet service providers, and our broadcasting partners, including Entanet, our wholesale channel partner;
To authorised third parties providing a service on our behalf or in connection with our business, including our insurers and professional advisors, marketing services partners, survey partners, technology and hosting providers; payment processors; hosting and IT services providers; delivery partners; and network activity partners (such as installation, testing, repair and removal);
To the extent that we are required to do so by law, including by regulators, courts or law enforcement agencies;
In connection with any legal proceedings or prospective legal proceedings;
In order to establish, exercise or defend our legal rights;
For the purposes of fraud prevention and reducing credit risk;
To the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information, or as otherwise set out in this privacy statement.

We only share personal information with third party service providers that is strictly necessary for them to perform the services that we request. These service providers are required to keep personal information secure and handle it in accordance with their own privacy policies and as is necessary to provide the services to us.

Where our website contains links to other websites, we are not responsible for the privacy policies or practices of such third party websites.

Residential householders

We may disclose information about you to any of our employees, officers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes as set out in this privacy statement. We may also disclose your personal data:
• To other companies in our corporate group for the purposes of internal administration, governance and recordkeeping, business analytics, financial and account management and reporting purposes;
• To trusted partners that provide essential support to our network (such as installation, testing, repair, upgrade or removal), and companies that provide hosting, IT and CRM services and systems to us;
• To authorised third parties providing a service on our behalf or in connection with our business, including our insurers and professional advisors, marketing services partners, survey partners, technology and hosting providers; payment processors; hosting and IT services providers; delivery partners; and network activity partners (such as installation, testing, repair and removal);

We only share personal information with third party service providers to the extent that is strictly necessary for them to perform the services that we request. These service providers are required to keep personal information secure and handle it in accordance with their own privacy policies and as is necessary to provide the services to us. Where our website contains links to other websites, we are not responsible for the privacy policies or practices of such third party websites.

Retaining personal data

Except for where stated otherwise in this Statement, we retain personal data for as long as is necessary for our lawful purposes, subject to our legal, reporting and regulatory obligations.

International data transfers

Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information as set out in this privacy statement, in particular to provide you with our products or services. Currently this is only within the UK.

Some of our trusted partners and third party service providers run their operations outside the UK. In these circumstances, there are measures in place to ensure that personal information is protected adequately in accordance with UK data protection law.

Your rights

You have the following rights regarding your information (each of which is subject to various exceptions and limitations):

Rights	What does this mean?
1. The right to be informed	You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this privacy statement.
2. The right of access	You have the right to obtain access to your information (if we are processing it), and other certain other information (similar to that provided in this privacy statement). This is so you are aware and can check that we are using your information in accordance with data protection law.
3. The right to rectification	You are entitled to have your information corrected if it is inaccurate or incomplete.
4. The right to erasure	This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5. The right to restrict processing	You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability	You have rights to obtain and reuse your personal data for your own purposes across different services. Eg, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between one provider’s IT systems and another’s safely and securely, without affecting its usability. However, we consider this right would only have very limited application in respect of the type of data that we would typically hold.
7. The right to object	You have the right to object to certain types of processing that is based on legitimate interests. Where you object, we may continue to process your information where we can show compelling legitimate grounds for the processing which override your rights and interests or where we need to use your information to bring or defend legal claims. However, if you object to direct marketing, we will stop this as soon as possible (although there may sometimes be a short delay while your request is processed).

To make a request to exercise any of your rights in relation to your information, please contact us using the details in the “Contact” section below. You may also make a complaint to the Information Commissioner’s Office.

Contact

If you have any questions about this privacy statement or our treatment of your personal data, please contact us:

Attention: Company Secretary

CityFibre Holdings Limited / CityFibre Limited

15 Bedford Street, London, WC2E 9HE

dataprocessing@cityfibre.com

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