1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and service users.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

  1. Credit

2.1    This document was created using a template from SEQ LEGAL (https://seqlegal.com).

  1. The personal data that we collect

3.1    In this Section 3 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

3.2    We may process data enabling us to get in touch with you (“contact data“). The contact data may include your name, email address, telephone number, postal address. The source of the contact data is you when you complete the enquiry section within our website.

3.3    We may process your website user account data (“account data“). The account data may include your account identifier, name, email address, business name, account creation and modification dates. The primary source of the account data is you, although some elements of the account data may be generated by our website. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.

3.4    We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.

3.5    We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.

3.6    We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.

  1. Purposes of processing and legal bases

4.1    In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.

4.2    Operations – We may process your personal data for the purposes of providing our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of services and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

4.3    Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

4.4    Legal compliance and vital interests – We may process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

  1. Providing your personal data to others

5.1    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

5.2    We may disclose your personal data to the Scottish Government for use under the R100 Programme and the Scottish Broadband Voucher Scheme (SBVS). This will be used by the Scottish Government in its administration, management and operation of the SBVS in compliance with their obligations under the Data Protection Laws.

5.3    Financial transactions relating to our services are handled by our payment services providers, Stripe and GoCardless. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://stripe.com/at/privacy and https://gocardless.com/legal/.

5.4    In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

  1. Retaining and deleting personal data

6.1    This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3    We will retain your personal data as follows:

(a)    contact data will be retained for a period of six years following the date of the most recent contact between you and us;

(b)    account data will be retained for a minimum period of 30 days following the date of closure of the relevant account, and for a maximum period of one year following that date;

(c)    transaction data will be retained for a minimum period of 30 days following the date of the transaction, and for a maximum period of one year following that date;

(d)    communication data will be retained for a period of six years following the date of the communications in question;

(e)    usage data will be retained for a minimum period of 30 days and a maximum period of one year following the termination of the use of our service.

6.4    Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Your rights

7.1    In this Section 7, we have listed the rights that you have under data protection law.

7.2    Your principal rights under data protection law are:

(a)    the right to access – you can ask for copies of your personal data;

(b)    the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c)    the right to erasure – you can ask us to erase your personal data;

(d)    the right to restrict processing – you can ask us to restrict the processing of your personal data;

(e)    the right to object to processing – you can object to the processing of your personal data;

(f)    the right to data portability – you can ask that we transfer your personal data to another organisation or to you;

(g)    the right to complain to a supervisory authority – you can complain about our processing of your personal data; and

(h)    the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

7.3    These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

7.4    You may exercise any of your rights in relation to your personal data by written notice to us at info@wifiscotland.co.uk.

  1. Amendments

8.1    We may update this policy from time to time by publishing a new version on our website.

8.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

8.3    We may notify you of significant changes to this policy by email.

  1. Our details

9.1    This website is owned and operated by WiFi Scotland LLP.

9.2    We are registered in Scotland under registration number SO306648, and our registered office is at Taigh Na Siach, Boharm, Craigellachie, AB38 9RN.

9.3    You can contact us:

(a)    by post, to the postal address given above;

(b)    using our website contact form;

(c)    by telephone, on the contact number published on our website; or

(d)    by email, using the email address published on our website.