Smartphoneoffer.co.uk is a trading name of TFLI Limited and is licenced by the Information Commissioners Office, (Registration Number Z3585914), Registered in the UK, number 08424810. Registered Office Address: The Old Boiler Room, Adelphi Mill, Grimshaw Lane, Bollington, Cheshire, SK10 5JB.
Smartphoneoffer.co.uk are aware how important your privacy is, based on this we have implemented measures which will ensure any personal information that is obtained from you by visiting our website will be processed and maintained in line with accepted principles of good information handling and in accordance with the General Data Protection Regulation (GDPR). Contained within this statement and set out below are details of the type of information that we at Smartphoneoffer.co.uk may hold about you our customer, also how we obtain and process any information we may have and importantly how we protect your privacy.
We and our panel of mobile phone providers, will keep you informed with the progress of your enquiry. Unless you state otherwise you may be contacted via telephone, email and SMS. (see further section on 'How we keep you informed')
Lawful basis for collecting your personal data
Our use of your personal data will always have a lawful basis.
We rely upon a different lawful basis to process your personal data according to the reason for which you have provided your data to us.
When you submit your smart phone offer application with TFLI Limited, we process your personal data on the basis that you have provided your consent to be contacted by TFLI Limited and our panel of Mobile Phone providers.
You can withdraw your consent to us processing your personal data at any time by clicking the "unsubscribe" option in any SMS, email we, or any associated third party, send to you.
Alternatively, you can withdraw your consent by contacting our Data Protection Officer at email@example.com or using the contact details stated in section 15 / 16. If you change your mind about agreeing to us processing your personal data, this will not have any effect on the lawfulness of any processing we have carried out before you changed your mind.
Your personal data will also be processed on the basis that we need this information to fulfil our obligations under the contract we have entered into with you by introducing you to a Mobile Phone provider. TFLI Limited and our panel of Mobile Phone providers will contact you regarding your smart phone application.
We have a legitimate interest in processing your data (i.e. to share your smart phone application with our panel of Mobile Phone providers) to obtain your smart phone offer you have applied for.
It also includes processing your data for ID protection and tracing purposes such as Credit Reference and Fraud Prevention. This is in relation to appropriate agencies which are listed within section 9.
You can object to us processing your data in this way by contacting our Data Protection Officer at firstname.lastname@example.org or using the contact details stated in section 15 / 16.
If you are required to telephone us using the specified telephone numbers on our website under the Contact or advertising/marketing correspondence then your call may be recorded for training, quality and regulatory purposes. We pride ourselves in complete customer care and this gives us the opportunity to continuously improve and monitor our customer experience.
We may want to make contact with you at some point in order to keep you informed regarding offers on products or services which we think you may find of interest, this contact will be made via email and SMS.
If you apply with us and have a question about our services, or alternatively choose to send an email to email@example.com may also collect the above personal information/data in this instance in order for us to respond to your enquiry.
Unless the customer states otherwise we will contact the customer via means of telephone, SMS and email to provide information and alerts relating to our services and our associate companies. We may also receive personal information/data from third parties, which enables us to offer Identified potential customers products, and services who have expressed interest in our products and services. Any information/data obtained from third parties is checked in regards to accuracy and we will endeavour to check your information with you on occasion.
Ensuring your personal details & or preferences are kept up to date.
It is your responsibility to ensure that any information we have on record for you is kept up to date and correct. If you do require any of your information to be updated then please contact us as soon as possible so we can ensure it is corrected.
If you require your preferences to be updated then please contact our Compliance Manager as soon as possible (details set out below).
We collect personal information about you when you give this to us when applying for a mobile phone product online. This might be, for example, to obtain comparative quotes for mobile phone products offer by mobile phone providers. In the course of providing the Services to you, we may also store information about how you use our Sites, for example, the pages viewed, the website from which you came to visit our Sites, changes you make to information you supply to us, details of the quotes you request and your applications, together with details of your financial information, for example, bank account or payment details.
We will store the information you provide and may use it to pre-populate fields on the Sites and to make it easier for you to use the Sites when making return visits
We may monitor or record your calls, emails, SMS or other communications but we will do so in accordance with data protection legislation and other applicable law. Monitoring or recording will always be for business purposes, such as for quality control and training (e.g. where you call our compliance or customer service department), to prevent unauthorised use of our telecommunication systems and Sites, to ensure effective systems operation, to meet any legal obligation and/or to prevent or detect crime.
We will periodically review your personal information to ensure that we do not keep it for longer than is permitted by law.
When you complete an enquiry, you consent to us disclosing your personal information to the following parties:
Mobile Phone Providers offering mobile phone products such as smart phone contracts. Our preferred partners in this sector are:
Our Channel Operators: whilst the majority of the channels on our Sites are run by us, some of our channels are designed and maintained for us by our third party service providers. We may receive your personal information from these service providers and use it in accordance with section 4 above. We will only use the personal information we receive from third parties where the relevant third party can show that it was collected and processed with your consent;
Regulatory/governing bodies, for the purposes of compliance monitoring;
Where permitted by data protection and privacy law, we may also disclose information about you (including electronic identifiers such as IP addresses) and/or access your account:
1. if required or permitted to do so by law;
2. if required to do so by any court, the Competition and Markets Authority or any other applicable regulatory, compliance, Governmental or law enforcement agency;
3. if necessary in connection with legal proceedings or potential legal proceedings; and/or
4. in connection with the sale or potential sale of all or part of our business.
If we reasonably believe false or inaccurate information has been provided and fraud is suspected, details may be passed to fraud prevention agencies to prevent fraud and money laundering.
FRAUD PREVENTION AGENCIES (FPA'S)
If we reasonably believe false or inaccurate information has been provided, including in relation to a person's identity, and fraud is suspected, details, including personal data may be passed to fraud prevention agencies to prevent fraud and money laundering. Your details may be passed to statutory bodies, regulators, legal bodies, credit reference agencies, fraud prevention entities and identity and address verification agencies who may record and use your details. They may also disclose your information to other organisations for credit reference, debt tracing, and fraud and money laundering prevention purposes. If you have any queries regarding these uses, please contact the relevant organisation.
By submitting an enquiry form on our site, you confirm that all of the information provided is true and accurate. You also, when applying, authorise the Alternative Solutions Provider to use both fraud prevention and credit referencing agencies to help make relevant decisions. Credit checks and credit reference agencies can also help prevent fraudulent applications.
What is a Fraud Prevention Agency?
Fraud Prevention agencies collect, maintain and share information on any known or suspected fraudulent activity.
They work in the following ways with various organisations:
We may use your personal information:
We use a single first party cookie, named 'PHPSESSID'. This cookie is vital for the operation of the website, as it allows us to track different page loads to yourself, which allows the form and application process to work.
To find out more about accepting or refusing cookies please visit www.allaboutcookies.org.
We also use Google Analytics to collect non-personally identifiable information, in aggregate form, to understand website/page visit volumes in terms of source, geography, browser, etc.
Google Analytics employs a software technology called web beacons, that help us better manage content on our site by informing us what content is effective. Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users or responses to emails. In contrast to cookies, which are stored on a user's computer hard drive, web beacons are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. Web beacons cannot be disabled in same manner as cookies may. We do not tie the information gathered by web beacons to our customers' personally identifiable information.
Important: Read the Google Analytics privacy document for more details about the data collected by Google Analytics.
We use the "visitor action pixels" from Facebook Inc (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook")) on our website.
This allows user behaviour to be tracked after they have been redirected to the provider's website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook's Data Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes.
The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads.
Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
On our websites functions of the service Instagram are embedded. These functions are offered by the Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA. If you are logged in to your Instagram account, you can link contents of our websites to your Instagram profile by clicking the Instagram button. By this ,Instagram will associate the visit of our websites with your user account. We would like to point out that we, as providers of these websites, do not obtain knowledge about the contents of transmitted data as well as their use by Instagram.
On our website, we use the Conversion Tracking Service of Twitter Inc. (1355 Market Street #900, San Francisco, California 94103, "Twitter"). Twitter stores a cookie on the user's computer to enable an analysis of the use of our online products and services. Twitter Conversion Tracking tracks the actions of users after they have viewed ads or interacted with ads on Twitter. Twitter's Conversion Tracking allows you to assign conversions such as link clicks, retweets or "like" data.
The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. If you wish to object to tracking, you can do so using the Digital Advertising Alliance tool at optout.aboutads.info.
Twitter is certified under the Privacy Shield Agreement and thus guarantees its compliance with European data protection legislation: (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active)
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please note that by disallowing cookies some functionality on the site may be restricted.
Our Sites are "Let's Encrypt Secure Websites" and keeping information about you secure is very important to us. However, no data transmission over the internet can be guaranteed to be totally secure. Sensitive information, for example, your card details, is encrypted to minimise the risk of interception during transit.
We do our best to keep the information you disclose to us secure. However, we can't guarantee or warrant the security of any information which you send to us, and you do so at your own risk. By using our Sites you accept the inherent risks of providing information online and will not hold us responsible for any breach of security.
You have certain rights under the General Data Protection Regulations . For example, we will always let you have a copy of the personal information we hold about you, if you request it from us in writing.
The amount of time we retain your information for will depend on the reason it was provided:
You can opt out of future contact from Smartphoneoffer.co.uk at any time. All of our marketing messages provide an opt out link - please allow up to 48 hours for us to process your opt out request. Alternatively you can email firstname.lastname@example.org where your details will be removed from any future marketing campaigns.
Under the General Data Protection Regulation (GDPR), all individuals have the right to request the deletion or removal of personal data (the right to be forgotten) under the following circumstances:
There are some circumstances where the right "to be forgotten" does not apply i.e. where we need to comply with a legal obligation.
If you wish to request your "right to be forgotten" please email: email@example.com
Smartphoneoffer.co.uk always aim to be fair and honest in everything we do, so if you have a complaint about any aspect of our service we're keen to resolve it as quickly as possible. You can contact us in any of the following ways:
Complaints Department, TFLI Ltd trading as Smart Phone Offer, The Old Boiler Room. Adelphi Mill, Grimshaw Lane, Bollington, Cheshire, SK10 5JB
01625 32 22 74 (calls are charged at local rates and are inclusive of mobile phone users' free minutes)
By Email: firstname.lastname@example.org
We will acknowledge receipt of the complaint within 3 working days and we hope to provide a final response within 4 weeks. We will write to you again within 4 weeks if we are unable to provide a final response within that time period. In any event we will respond to your complaint in full within 8 weeks.
If you are not satisfied with our response, or if a complaint is not resolved after eight weeks, you may refer the complaint to -
Financial Ombudsman Service
Telephone: 0800 023 4567
Web site: www.financial-ombudsman.org.uk
You can report any of your concerns to the Information Commissioner's Office (ICO)
Information Commissioner's Office
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number
Fax: 01625 524 510
Last updated: August 2020