Privacy Notice

1. Who we are and scope

1.1 Talk4 Communications Ltd trading as Talk4 Telecoms is the controller for personal information described in this Notice unless we state otherwise. Company number 06827172; registered office 38 Rothesay Road, Luton, England, LU1 1QZ.

1.2 This Notice covers customers, authorised users, account contacts, prospective customers, website/app users and people who contact us. It should be read with any service-specific privacy information presented at collection.

1.3 We comply with applicable UK data protection law, including the UK GDPR and Data Protection Act 2018, and with PECR where relevant, each as amended from time to time.

2. Personal information we collect

• Identity and contact data: name, title, date of birth where necessary, address, email, telephone number and business details.
• Account and contract data: account/service identifiers, selected products, contract dates, network, SIM/eSIM identifiers, numbers, service addresses, orders and support history.
• Billing and payment data: invoices, payment status, bank/direct debit details or payment-token/provider references; Talk4 should not store full card data unless operationally necessary and appropriately secured.
• Technical/service data: IP addresses, device/router identifiers, network events, usage metadata, fault diagnostics, speed/performance data, logs and security telemetry.
• Communications data: calls/messages/traffic data and related metadata only to the extent processed lawfully for service, billing, security, fraud, regulatory or other permitted purposes.
• Customer service data: call recordings where used and notified, chat/email correspondence, complaints and engineer notes.
• Marketing/preferences data: consent, opt-outs, channel preferences, campaign interactions.
• Accessibility/vulnerability data: information you choose to give us so we can provide support; this may sometimes reveal health/disability or other sensitive circumstances and is handled with additional care.

3. Where information comes from

• directly from you or an authorised representative;
• from other users/account holders where they are authorised to provide it;
• from wholesale/network providers and installers involved in your service;
• from credit-reference, identity-verification and fraud-prevention providers where used;
• from payment providers;
• from website/app technologies and service/network systems;
• from public or official sources where lawful.

4. How and why we use information

5. Lawful bases

5.1 Depending on the purpose, we rely on one or more lawful bases: performance of a contract or steps requested before contract; compliance with legal obligations; legitimate interests where those interests are not overridden by your rights; consent where required; and, in rare cases, protection of vital interests.

5.2 Where special-category data is processed (for example disability information supplied for accessibility support), we identify an additional lawful condition and minimise access/use. [TALK4 TO DOCUMENT THE ACTUAL ARTICLE 9 CONDITION(S) USED IN ITS RECORD OF PROCESSING.]

6. Communications and traffic data

6.1 Telecoms traffic/location/communications data is subject to additional communications-privacy rules. We use it only for purposes permitted by law, such as transmitting communications, billing, managing networks, preventing fraud/security incidents, providing requested value-added services with any required consent, or complying with lawful requirements.

6.2 We do not sell the content of customer communications to advertisers.

7. Credit, fraud and identity checks

7.1 Where appropriate for a product, we may use credit-reference, identity-verification or fraud-prevention services. Before publication, Talk4 should list the actual providers or provide sufficiently specific categories and any required credit-reference/fraud notices.

7.2 Information may be used to verify identity, assess payment risk, prevent fraud and protect customers/networks. An adverse automated outcome will be handled in accordance with applicable rights and our actual decision process.

8. Marketing

8.1 We send electronic direct marketing only where permitted by PECR/data-protection law, for example with valid consent or where a lawful existing-customer “soft opt-in” applies and all conditions are met.

8.2 You can opt out at any time using the unsubscribe mechanism or by contacting us. Service/contract messages are not marketing and may still be sent where necessary.

9. Cookies and online tracking

9.1 Our Cookies & Online Tracking Notice explains cookies, pixels, local storage, scripts/tags, device identifiers and similar storage/access technologies. Non-exempt technologies are not pre-enabled before the required consent.

10. Who we share information with

• mobile/fixed wholesale network providers and porting/switching partners;
• Openreach/alternative access networks and engineers/installers;
• cloud hosting, CRM, billing, communications and support providers;
• payment processors, banks and direct-debit/payment providers;
• identity, credit and fraud-prevention providers where used;
• professional advisers, auditors and insurers;
• regulators, courts, law-enforcement and public authorities where legally required/permitted;
• a buyer/seller/adviser in a genuine corporate transaction, subject to confidentiality and data-protection controls.

10.2 Before publication, Talk4 should maintain an internal processor/recipient register and make the public description as specific as reasonably possible.

11. International transfers

11.1 Some suppliers may process information outside the UK. Where personal data is transferred internationally, we use a lawful transfer mechanism such as UK adequacy regulations or appropriate safeguards (for example the UK International Data Transfer Agreement/Addendum), and supplementary measures where needed.

11.2 [TALK4 TO CONFIRM ACTUAL INTERNATIONAL TRANSFERS, COUNTRIES/SUPPLIERS, MECHANISMS AND HOW CUSTOMERS CAN OBTAIN A COPY OF RELEVANT SAFEGUARDS.]

12. Retention

12.1 We keep personal information only as long as necessary for the purpose collected, including contract performance, billing, tax/accounting, dispute/complaint, fraud/security and regulatory/legal requirements.

13. Security

13.1 We use appropriate technical and organisational measures proportionate to risk, including access controls, authentication, encryption in transit where appropriate, monitoring, supplier controls, staff training, incident response and backups/business continuity as relevant.

13.2 No system is completely secure. Customers should keep credentials confidential and report suspected compromise promptly.

14. Automated decisions and profiling

14.1 We may use automated tools to detect fraud/security risks, segment service/marketing activity or support credit/identity checks. If Talk4 makes a decision based solely on automated processing that produces legal or similarly significant effects, we will provide the information and rights required by applicable law.

14.2 [TALK4 TO CONFIRM WHETHER ANY SOLELY AUTOMATED SIGNIFICANT DECISION-MAKING IS ACTUALLY USED.]

15. Your rights

15.1 Depending on the processing and lawful basis, you may have rights of access, rectification, erasure, restriction, portability, objection and rights concerning automated decisions/profiling. Where we rely on consent, you may withdraw it at any time without affecting earlier lawful processing.

15.2 To exercise rights, contact Talk4 Data Protection at support@talk-4.co.uk or by post to 38 Rothesay Road, Luton, England, LU1 1QZ. We may need to verify identity before acting.

16. Children

16.1 Talk4 contracts are normally entered into by adults. If a service is used by a child under an adult account, the account holder should supervise use. Where Talk4 intentionally offers an online service directly to children, it will apply age-appropriate data-protection requirements.

17. Complaints to the ICO

17.1 If you have a data-protection concern, contact us first so we can investigate. You also have the right to complain to the UK Information Commissioner’s Office (ICO). Current ICO contact details are available at ico.org.uk.

18. Changes and contact

18.1 We may update this Notice to reflect changes in law, services or processing. Material changes will be highlighted where appropriate, and historic versions will be retained where needed for transparency.

18.2 Data Protection contact: support@talk-4.co.uk (mark “Data Protection”) or 38 Rothesay Road, Luton, England, LU1 1QZ. [INSERT DPO NAME/DETAILS IF TALK4 IS REQUIRED OR CHOOSES TO APPOINT A DPO.]