PRIVACY POLICY - REVERSE CORP LIMITED
WE RESPECT YOUR PRIVACY
0800 Reverse Pty Ltd, together with its affiliated group members ("Reverse") understands and respects that privacy is important to all of our Users, Customers and other people we do business with. This document sets out our Data Protection and Privacy Policy and describes how we will handle any personal data that you may provide to Reverse. Please read this Data Protection and Privacy Policy carefully as use of our website is conditional upon you agreeing to be bound by it.
This Policy is organised as follows:
Data Protection Principles
What Personal Data Is Collected and How Is It Used?
Will Personal Data be Given to Anyone Else?
Security of Personal Data
Access and Correction
Online Privacy
How to Contact Reverse
1. Data Protection Principles
Among other things, the Data Protection Act 1988 (as amended) (the "Act") sets out principles as to how a "data controller" is to "process" "personal data".
"Personal data" is defined as "data relating to a living person who is or can be identified either from the data or from the data in conjunction with other data that is in, or is likely to come into, the possession of the data controller." Reverse does not collect or process "sensitive personal data" (i.e., data relating to race, ethnicity, politics, religion, philosophy, health, sexual preferences, trade union affiliations or offences).p>
"Processing" of data is widely defined and includes obtaining, recording, keeping, organizing, storing, altering, retrieving, disclosing, combining and erasing data.
In processing any personal data, Reverse does so in accordance with the following requirements:
- Data must be obtained and processed fairly.
- Data must be accurate and complete and where necessary, kept up to date. This does not apply however to back up data.
- Data must be kept only for specified and lawful purposes, not disclosed in any manner incompatible with such purposes, must be adequate, relevant and not excessive for such purposes and must not be kept longer than is necessary (except if kept for certain statistical or research or other scientific purposes).
- Appropriate security measures must be taken against unauthorised access, disclosure, alteration or destruction.
2. What Personal Data Does Reverse Collect and How Is It Used?
Reverse provides Customers with services such as the ability to make and receive reverse charge telephone calls and messages in accordance with our Terms and Conditions ("our Services").
People who receive telephone calls from a person using our Services are described herein as "our Customers". This is because the person receiving the call pays for the call. Persons who make calls using our Services, or who use our websites, are described as "our Users".
Reverse may from time to time collect personal data in order to provide our Services to our Customers and our Users. The types of personal data that Reverse collects will depend on the nature of your dealings with us.
(a) Customers
As part of our pro-active Customer Service we may contact Customers for various reasons. For example, we may contact Customers who receive an unusually high number of reverse charge calls in a short period in order to ensure the Customer is personally aware of the call level and cost. In doing so we will ask you to verify your name, telephone number, billing address and details. If you choose to voluntarily provide us with the requested information, then we will be able to verify you as the actual Customer and hence provide you with call information. Other examples of when we may collect personal details such as your name, address, email address and telephone numbers include if you send us a customer service email/web enquiry or if you elect to "opt-in" to one of our text request messages or related services / offers.
(b) Users
Sometimes Reverse collects personal data from "Users". For example, if you register to become a 1800 Reverse Club Member, enter one of our competitions, submit an enquiry or complaint, or "opt-in" to one of our text request messages or related services, then we will collect personal data from you which may include your name, address, email address, date of birth, gender, telephone numbers and whether you are a residential or a business customer.
If we collect personal data through competitions, details about how we will use that personal data will be set out in the terms and conditions of entry for the relevant competition. We may use personal data collected in this way for marketing or publicity purposes, or to conduct market analysis. If you do not wish personal data about you to be used in this way, you may not be eligible to enter the relevant competition (depending on what the terms and conditions of entry are).
(c) Other business contacts
We may collect the business contact details of other people we do business with, such as the contact people in our external service providers or government regulators. This data is only used for the business purpose for which it was collected, such as managing a particular contract, or making enquiries about the application of laws to our business.
Reverse does not collect data that it does not need for the proper operation of its services.
3. Will Your Personal Data be Given to Anyone Else?
Reverse will not sell, rent or trade personal data about you to or with third parties.
Personal data may be disclosed outside of Reverse in the circumstances described below.
Personal data collected by Reverse may be disclosed to third parties to whom Reverse contracts out specialised functions (e.g. billing or marketing functions). In such cases Reverse takes reasonable steps to ensure that those third parties:
(a) comply with the principles in the Data Protection Act (as amended) when they handle your personal data; and
(b) are authorised only to use personal data in order to provide the services or to perform the functions required by Reverse.
Reverse may disclose personal data if this is permitted under the Data Protection Act (as amended) or required by another law. This may include disclosures to law enforcement bodies or regulatory bodies (such as the ComReg) where Reverse has a legal obligation to make such disclosures.
In some circumstances, Reverse may need to disclose your personal data to someone overseas. For example, if you win a promotion or competition, then we may need to disclose your name and other details to book your award or prize.
4. Security of Personal Data
Reverse takes steps to ensure the security of personal data we hold. Our IT systems are password restricted and comply with relevant security standards. We take steps to ensure that all data transmitted to the Reverse website is secure (to the extent possible using existing technology), but you should be aware that no Internet transmission can be completely secure. If personal data is held as paper files, it is stored in locked compactuses or filing cabinets. In all cases, access to the personal data we hold about you is restricted to authorised personnel. We educate our staff about their duty to protect your privacy.
5. Access and Correction
You have the right to request access to the personal data which Reverse holds about you (although there are some exceptions to this). You also have the right to ask us to update or correct your personal data if it is inaccurate, incomplete or out of date. If you wish to exercise this right please contact our Privacy Officer.
If you make a request for access to personal data, Reverse will assume (unless you tell us otherwise) that your request relates to our current records about you. These current records will include personal data about you which is included in our databases and in paper files, and which we may use on a day-to-day basis.
To provide you with access to personal data about you, Reverse will ordinarily provide you with a copy of the relevant personal data (ordinarily, a print-out from a database or a photocopy of files recorded only in paper form). If personal data about you (for example, your name and address) is duplicated across different databases or paper files, we will generally only provide you with one print-out of this data, rather than multiple print-outs. Reverse will not charge you for the cost of providing this type of access to these current records. If the personal data we collected about you has been de-identified such that we can no longer identify this data as being about you, you will not be given access to the de-identified data (as it will no longer be "personal data").
For legal and administrative reasons, Reverse may store records containing personal data in its archives. You may seek access to these non-current records held by Reverse, but if you do, please be aware that it may take time to locate these records, and we may charge you for the cost of providing access. If you require access to non-current records, contact our Privacy Officer.
After we have provided you with access, if you are of the view that your personal data is not accurate, complete or up-to-date, please let our Privacy Officer know immediately.
6. Online Privacy
(a) Personal Data
As noted above, at our websites Reverse may collect personal data if it is volunteered by you. Otherwise, Reverse does not collect personal data about you through our websites.
(b) Non-Personal Data
Reverse may collect non–personal data from you when you use our websites. For example, we might track data about the date and time you access one of our websites, the type of web browser you use, and the website from which you connected to our site. Our websites collect this data by depositing "cookies" in your computer. This technology does not collect data which personally identifies you. Rather, this data is collected in an aggregate form. The cookies can tell us how and when pages in a website were visited and by how many people. This aggregate data enables us to improve our websites to serve and inform you better. It also may allow you to shortcut access to points of interest on our website when you re-enter our system. Reverse does not match any personal data we have collected about you with the anonymous data described above. In general, Reverse only uses cookies for security purposes and to assess the usage and to improve the functionality of our website. You may set your computer so that cookies are not placed on your system, however, disabling cookies may result in some reduction in the functionality and ease of use of this site.
7. How to Contact Reverse
If you have questions, comments or complaints about our Data Protection and Privacy Policy, would like a copy (including in large print or in a language other than English) or have an enquiry concerning your personal data, please contact Reverse's Privacy Officer:
telephone on 1890 787778; or
facsimile on 1890 252830; or
by email at customerservice@1800reverse.ie
by letter at
Attention: Privacy Officer
1800 Reverse
20 Canning Place
London W8 5AD England
For independent information about data protection and privacy issues see www.dataprotection.ie.
DISCLAIMER
Nothing in this document is, or is intended to be, legal advice or a complete, accurate summary or advice in relation to the Data Protection Act (as amended) or other law or regulation. The reader must not rely on the data contained herein and must make his/her own investigations and seek independent advice. As far as permitted by law, Reverse makes no warranty, express or implied, statutory or otherwise relating to this policy or to any data and material contained on its websites. Reverse accepts no liability for direct, indirect or consequential loss or damage of any kind arising from any data or material on its websites. However, nothing in the websites shall exclude or limit Reverse's liability for death or personal injury resulting from Reverse's negligence.