Freewire Privacy Policy

1. Introduction.

Welcome to the Freewire Privacy Policy. Freewire is wholly owned and operated by Inuk Networks Limited.

Please note that in this Privacy Policy, reference to "we","us","our", Freewire and Inuk Networks, denotes Inuk Networks Limited, registered in England and Wales at:
Enterprise House, Navigation Park, Abercynon, Mid Glamorgan South Wales, CF45 4SN, registered company number 5267418 and "you","your" denotes you the customer.

Inuk Networks will be responsible for all uses of your personal data.

We respect your right as our customer to privacy and take our responsibilities regarding the security of your customer information very seriously. We have developed this policy because we want you to feel confident about the privacy and security of your personal information.

Inuk Networks has notified the Information Commissioner's Office of its activities in accordance with the Data Protection Act 1998 (registration number BPR380). This notification can be viewed at www.ico.gov.uk. Inuk Networks takes all reasonable care to prevent any unauthorised access to your personal information.

2. About Inuk Networks.

Inuk Networks is leading-edge broadband, telephony and television service provider in the UK. Our mission is to bring these advanced services to universities and students alike. Please contact our sales office (Please call the number given in section 8, Finding out what Personal Data we hold about you) to find out if you are able to receive our services in your area, or alternatively check on our Freewire website at www.freewiretv.com.

3. Definition of Personal Data.

3.1 This privacy policy has been created to explain to you the way in which Inuk Networks uses your "personal data". When we refer to "personal data" in this privacy policy, we mean personal information which identifies you as an individual, or is capable of doing so. This may include information which tells us something about you as an individual, for example your name, address or telephone number. We are committed to providing you with a professional and personalised service whilst at the same time safeguarding your privacy and protecting your personal data from unauthorised uses or disclosures.

3.2 "Sensitive personal data" is a particular category of information and is any "personal data" which concerns racial or ethnic origin, political opinion, religious beliefs or other beliefs of a similar nature, membership of a trade union, physical or mental health or conditions, sexual life, commission or alleged commission of any offence or any proceedings for any offence committed or alleged to have been committed by you, the disposal of such proceedings or the sentence of any court in such proceedings. Any sensitive personal data which you provide to us will be processed in accordance with this policy and the Data Protection Act 1998. By providing us with your sensitive personal data you are consenting to such use.

4. Collection of Personal Data.

4.1 We may hold and use data about you in your capacity as a customer or in any other capacity, for example, when you visit our website. The types of personal data we will collect may include details of your name, address, telephone number, email address, fax number and date of birth.

4.2 In some instances, we may need your credit/debit card details to charge for services. All financial transactions are secured by SSL encryption to offer secure communications of sensitive data to and from our website. However, no data transmission over the Internet can be guaranteed to be totally secure and any information which you send to us is sent at your own risk.

4.3 When you (or someone using your telephone line) make a telephone call or send a fax that uses our telephone network or connect to the Internet, we keep a record of that call (including the number called) to enable Inuk Networks to charge for it. We also receive information from other operators about calls made over our network, where we need that information for connecting and billing purposes.

4.4 If a customer abuses the Freewire Telephone Service, for example by making offensive or nuisance calls, we may keep information relating to that abuse.

4.5 If a customer abuses the Freewire Internet Service or any value-add services connected with it, for example by breaching any of part of our Internet Acceptable Use Policy available on our Freewire website, we may keep information relating to that abuse.

4.6 We have information about your use of our services (such as the amount of time you spend on-line), which we use to manage our network, and for billing. We may also use this information for marketing products and services but we will give you the option to opt in to receiving this material if you so wish. You can do this when signing up for an account with us at the "where are you?" stage. Thereafter you can opt in or out at will in the self-care area of your account.

4.7 We may from time to time hold competitions or promotions. If you enter into any of our competitions or promotions, we may ask for information about you, which will be made clear at the time you enter. We will also inform you of the purposes for which the information you provide may be used.

4.8 We may ask you from time to time about what use you make of the services we provide, what other services you would like us to provide in the future, and for other information, such as lifestyle data. This information is only used internally to enable us to improve the quality of our service and will not be published on the site. We may also use your data to perform statistical analysis to help understand how people are using our services so that we can improve them.

4.9 We may receive personal information about you from other companies and organisations (for example, for marketing purposes) and we rely on these third parties to obtain your consent for us to use this information.

4.10 When you order services from Inuk Networks we may make enquiries about you for credit reference purposes. These enquires include searching your records held by Experian / Equifax or any other credit reference agency and checking any details held on you by the Interactive Media in Retail Group (IMRG) Security Alert or any other fraud prevention scheme. At all times where your information is disclosed to us we will protect it in accordance with this policy and keep it secure.

4.11 We will use your personal data in accordance with the Data Protection Act 1998 and in accordance with this Privacy Policy. Inuk Networks will not disclose your personal information to third parties other than is required to provide services to you.

4.12 Our Freewire website is not intended for persons under 13 years of age. Inuk Networks does not knowingly solicit or collect personal information from or about children on the website except as permitted under applicable law. If your child has submitted personal information and you would like to request that such information be deleted from our records, you may do so by contacting Inuk Networks using the address shown in Section 8 (Finding out What Personal Data we hold about you), paragraph 8.2.

5. Direct Marketing.

5.1 If you have consented at the point of data collection to Inuk Networks (and/or any third party) providing you with direct marketing material, you may be sent this by email or by post. We will only provide you with such material by these means. If, at any stage, you object to our use of your personal data for direct marketing, you may choose to unsubscribe to its receipt. If you have consented to receive third party direct marketing you will need to unsubscribe directly with that third party.

5.2 If you would like to stop unsolicited telemarketing calls from companies (including Inuk Networks), please contact the Telephone Preference Service on 0845 070 0707 or do this online at www.tpsonline.org.uk and register your telephone number(s). Direct marketing calls should stop after 28 days.

5.3 If you would like to stop unsolicited direct marketing mailings companies (including Inuk Networks), please contact the Mail Preference Service on 0345 034599 or do this online at www.mpsonline.org.uk. Direct marketing mailers should stop or significantly reduce after 3 months.

5.4 If you would like to stop unsolicited fax calls from companies, please contact the Facsimile Preference Service (FPS) on 0845 070 0702 or do this online at www.fpsonline.org.uk and register your telephone number(s). Direct marketing calls should stop after 28 days.

Please remember to re-register if you change your address.

6. Sharing of your Personal Data.

6.1 As a normal part of our business we share with other communications companies, information for connecting and charging for calls over each others networks. We sometimes use other companies to provide services to you or to provide services to us. To enable them to do this, we may need to share your personal information with them. When we do so, these companies are required to act in accordance with the instructions we give them and they must meet the requirements of the Data Protection Act (1998) to keep the information secure.

6.2 We make our customers’ telephone numbers available to directory enquiry services unless customers have chosen to be registered ex-directory.

6.3 We may provide information, in response to properly made requests, for the purposes of the prevention and detection of crime, and the apprehension or prosecution of offenders. We may also provide information for the purpose of safeguarding national security. In either case we do so in accordance with the provisions of the Data Protection Act (1998). We also provide information when required to do so by law, for example under a court order, or in response to properly made demands, under powers contained in legislation.

6.4 If there is a change (or prospective change) in the ownership of Inuk Networks or any of its assets, we may disclose personal information to the new (or prospective) owner. If we do so, we will require them to keep it confidential.

6.5 We may disclose your personal data to carefully selected business partners and third party suppliers to whom we engage to provide services and as is necessary to provide services to you. Disclosures to third parties, other than as described in this privacy policy, will occur only with your express consent or as is required by law.

6.6 If you believe the personal information we hold on you is incorrect you may amend it by following the procedure set out below in "Making Changes to Your Retained Personal Data."

7. Retention of your Personal Data.

The time period for which we keep information varies according to what the information is used for. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we will retain it for no longer than is necessary for the purposes for which the data was collected or for which it is to be further processed.

8. Finding out what Personal Data we hold about you.

8.1 You have certain rights under the Data Protection Act 1998 and you can contact us to ask whether we are keeping personal data about you. If you want specific information please tell us and give us any relevant information to enable us to locate the information about you because this will speed up our reply. We may be able to provide the specific information you want without you having to make a formal request.

8.2 You can make a formal request if you want to know what personal information Inuk Networks holds about you. We may make a small charge for providing this information. Please put your request in writing to the following address:

Data Protection Officer
Inuk Networks
Enterprise House
Navigation Park
Abercynon
Mid Glamorgan
CF45 4SN.

9. Making Changes to your retained Personal Data.

If you believe that the personal data Inuk Networks holds about you is in any way incorrect, you can contact our Data Protection Officer to notify the required changes. Please contact Inuk Networks using the address shown in Section 8 (Finding out What Personal Data we hold about you), paragraph 8.2.

10. Use of "Cookies".

As well as the personal information that you provide us with, we will also use information obtained about you automatically from cookies (files which are sent by us to your computer). The main reason we use cookies is to help improve your experience of using our services. They also help to tell us what you and other users do on our website, feedback service information to us (although you personally are not identified) so that we can make the whole experience better for everyone.

We use two types of cookie; session and persistent.

Session cookies.
In the instance of a session cookie, we use them to collect statistical information about the ways visitors use our Freewire website; which pages they visit, which links they use, and how long they stay on each page. We analyse this information in statistical form to better understand our visitors' interests and needs to improve the content and functionality of the Freewire website.

Persistent cookies.
In the instance of persistent cookies, these cookies do not expire when you close your browser; they stay on your computer until you delete them. By assigning your computer a unique identifier, we are able to create a database of your previous choices and preferences and in situations where these choices or preferences need to be collected again, they can be provided by us automatically, saving you time and effort.

If you want to stop cookies being stored on your computer in future, please refer to your browser manufacturer’s instructions by clicking "Help" in your browser menu. Please note however that by deleting our cookies or disabling future cookies you may not be able to access certain services we provide or features of our Freewire website. For more information about deleting and controlling cookies visit www.aboutcookies.org.

Please note: we will at all times automatically receive your IP address, a unique identifier for your computer or other access device; but we will not identify you as an individual.

11. Security of your Personal Data.

We take very seriously the guarding and security of your personal information and the details of any transactions made. We take appropriate organisational and technical security measures to protect your data against unauthorised disclosure or processing. We use secure servers to store the information you give us when you register or place an order (including your credit card details and your password). Any personal data you send us online is securely encrypted. These measures ensure an appropriate level of security in relation to the risks inherent in the processing and the nature of the personal data to be protected. Your securely held personal data will only be accessible by selected authorised personnel who are employed by Inuk Networks or are partners of Inuk Networks whom we engage to provide services and as is necessary to provide services to you.

Please note that your billing account number is a sensitive piece of information, which can be used together with other information such as your telephone number to find out information about your use of our services. Please be sure to keep this information safe, and do not share it with others. For access to information such as itemised billing and some business account and ordering services, extra proof of identity and authorisation may be needed.

12. Your Privacy and Third Party Websites

In the event that you will be able to link to third party websites from the Freewire website (for information, products or services), they are not covered by our privacy policy, so we urge you to be careful when you enter any personal information online. Inuk Networks does not accept responsibility or liability for these sites. You are strongly advised to read any privacy policy which is displayed on a third party's website.

In the event we allow other companies to advertise or offer their products or services on our Freewire website, they may also allocate cookies to your computer. The use of the information generated by such cookies will be governed by their own privacy policies and not ours. However, you may refuse such cookies by following the procedure described in paragraph 10 above.

13. Children and Parents.

The Website is not intended for persons under 13 years of age. Inuk Networks does not knowingly solicit or collect personal information from or about children on our Freewire website except as permitted under applicable law. If your child has submitted personal information and you would like to request that such information be deleted from our records, you may do so by writing to us at the address given in 8.2.

14. Changes to This Privacy Policy.

We may change our privacy policy from time to time. New versions of the policy will be published on our Freewire website.