Privacy Policy
Netgem UK
Privacy and Data Policy
This is the Privacy and Cookies Policy for www.netgem.co.uk (“we“, “us” and “our site“), and the Netgem app (our “App“) Netgem device (including the NetBox and SoundBox) (together, the “Platform“). The Platform is operated by or on behalf of Netgem UK Ltd, trading as Netgem. We are committed to protecting and respecting your privacy.
This policy (together with our Terms & Conditions and any other documents referred to) sets out:
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- Information we collect about you
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- Cookies and other technologies
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- How we use your information
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- Our promotional updates and communications.
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- Who we give your information to
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- Where we store your information
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- Public forums
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- Child safety
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- Payment processing
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- How we protect your information
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- How long we keep your information
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- Your rights
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- Changes to this policy
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- Contact us
| Please read this policy carefully to understand how we collect and use your personal data.By accepting our products or services you acknowledge you have read and understood this privacy policy. |
For the purposes of European Economic Area data protection law, (“Data Protection Law“), the data controller is Netgem UK Ltd.
Information we collect about you
We will collect and process the following personal data from you:
| YOU PROVIDE US WITH |
This is information about you that you give us directly. It includes information you provide when you register to use the Platform, enter a competition, promotion or survey, submit a query, and when you report a problem with the Platform. It may also include aggregated information you provide when interacting with Netgem via smart speakers, namely set-top box (STB) ID / device MAC ID and the command requested. Identity: including first and last name. |
| OTHER PARTIES MAY PROVIDE US WITH | We work closely with third parties (including, for example, media & content providers, mobile and broadband providers, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information. We also work with third parties that help us verify your subscription details – we don’t see all the information you provide to them, just the final verification outcome. This may involve processing your identity and contact information, and your financial information.We will tell you, in this policy, when we collect data which we share within Netgem (including our group companies), or if we combine data from other sources with data you’ve given to us – for example, by using our service with a smart speaker. |
| WE AUTOMATICALLY COLLECT | We will automatically collect information from you each time you use our Platform. This includes: Technical Information about your visit. Technical information may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team. Location data – we collect information through the Platform as to your real time location to provide location services where requested or agreed to by you in order to allow tagging, allow check-in and deliver content, advertising or other services that are dependent on knowing where you are. This information may also be collected in combination with an identifier associated with your device to enable us to recognise your mobile browser or device when you return to the site/App. Delivery of location services will involve reference to one or more of the following: (a) the coordinates (latitude/longitude) of your location; (b) look-up of your country of location by reference to your IP address against public sources; and/or (c) your Identifier for Advertisers (IFA) code for your Apple device, or the Android ID for your Android device, or a similar device identifier. See Cookies and other technologies for more information on the use of cookies and device identifiers on the Platform. |
How we use your information
We’ve set out how we use each category of personal information, and what legal basis (or bases) allow us to undertake the processing. We explain more about what each legal basis means below.
We may process your personal data based one or more than one legal basis, depending on the specific purpose(s) for which we are using your personal information. Please contact us if you would like further details about the specific legal basis we are relying on to process your personal data.
| TYPE OF PERSONAL INFORMATION | HOW WE USE THIS PERSONAL INFORMATION | OUR LEGAL BASES FOR PROCESSING |
| Identity Contact Account Financial |
To register you as a new customer who wants to use our Platform | Contract |
| Identity Financial |
Your mobile or broadband provider may share your please specify, e.g. identity, contact and account data information with us (or companies who work for us) which allows us to offer you exclusive deals and offers,To perform our contract with you (as explained below), andTo share aggregated and anonymised statistics (based on identity and financial data). You cannot be identified from this information. Where we receive your personal information from a third party, they will be a separate data controller of your personal information, and will have their own legal bases for processing. |
Contract Consent |
| Identity Contact Account Financial |
To perform our contract with you, including administering your account with us, managing your warranty with us,storing your personal information, providing our Platform to you, customise our Platform for you, notifying you of any changes to our Platform, and providing information to you which you have requested. | Contract Legal Obligation Our legitimate interests |
| Identity Contact Account |
To manage our relationship with you which will include:sending you service updates (including security alerts),notifying you about changes to our terms or privacy policy, andasking you to leave a review, provide feedback or take a survey. | Contract Legal Obligation Our legitimate interests |
| Identity Contact Account Financial |
Verifying and managing payments, fees and charges in relation to our Platform Conducting credit checks Collect and recover money owed to us. |
Contract Our legitimate interests |
| Identity Contact Account Automatically collected information |
To customise your experience and offer you relevant content and recommendations To display marketing and advertising tailored to your preferences To promote our service to you and keep you updated with information about our services, including:delivering relevant content on topics we think may be of interest to you, andletting you know about new functionalities or services. See Our promotional updates and communications to learn more |
Consent Our legitimate interests |
| Contact Automatically collected information |
To administer our Platform and for internal operations, including bug fixes, troubleshooting, data analysis, testing, and survey purposes. To improve our Platform to ensure that content is presented in the most effective manner for you and for your computer. We may also use aggregated information to help us plan and introduce new features. To keep our Platform safe and secure. |
Our legitimate interests |
| Identity Contact Account Automatically collected information |
For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you. For analysing our user base, product and service usage, feature and content popularity, software and hardware quality, and market trends. We may also use this information to inform, refine and deliver our wider online marketing campaigns, including delivering our advertisements to you when you are not on our Platform. (See also Cookies and other technologies) |
Our legitimate interests Consent |
Our promotional updates and communications
Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information to provide you with promotional update communications by email or via push notification about our products and services.
We will also use this information for marketing analysis. This is based on technical information and information about your visit.
You can object to further marketing at any time by checking and updating your contact details within your account, or selecting the unsubscribe link at the end of all our marketing and promotional update communications to you, or by sending us an email to enquiries@netgem.co.uk. You can opt out of push notifications by changing your device settings.
We may also send you notifications within our Platform while you are using your Netgem device. You will not receive these notifications when you are not using your Netgem device.
Legal bases explained
Who we give your information to
We may give your information to:
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- Any member of the Netgem group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your prior consent.
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- Selected third parties:
| Our selected third parties may include: |
| Organisations who process your personal data on our behalf and in accordance with our instructions and Data Protection Law. This includes in supporting the services we offer through the Platform, including:providing website and data hosting services, providing fulfilment services, distributing any communications (e.g. emails) we send, supporting or updating marketing lists, facilitating feedback on our services, and providing IT support services. These organisations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) will only use your information to the extent necessary to perform their support functions. |
| Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 women aged over 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience and subject to the cookie section of this policy. |
| Analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy (this will not identify you as an individual). |
| Business partners who provide services to you and with whom we have entered into agreements in relation to the processing of your personal data. |
| Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you. |
| Payment processing providers who provide secure payment processing services.We will disclose your personal information to third parties:∙ In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.∙ If Netgem or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.∙ If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of Netgem, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime. |
Where we store your information
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA) that may not be subject to equivalent Data Protection Law.
Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy.
Find out more
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We may transfer your personal information outside the EEA: We may transfer your personal information to the following countries and using the following safeguards outside the EEA: |
Child safety
Protecting the safety of children when they use the Internet is important to us.
The Platform is intended for use only by persons who are at least 13 years of age.
By using the Platform, you confirm to us that you meet this requirement. If you are under the age of 18, you confirm you have received permission from your parent or guardian before using this Platform or sending us personal information.
If you are under the age of 18 your parent or guardian must consent on your behalf where we ask for consent in relation to the use of your information.
PSTI Compliance
Netgem declares being fully compliant with Schedule 1 of the UK PSTI (Product Security and Telecommunications Infrastructure) legislation. To read our statement please click here
How we protect your information
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using RSA 2048 bits (SHA256 with RSA). Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Our site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
How long we keep your information
We retain personal data for as long as you have an account with us in order to meet our contractual obligations to you and for six years after that to identify any issues and resolve any legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
Your rights
You have the right under certain circumstances:
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- to be provided with a copy of your personal information held by us;
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- to request the correction or deletion of your personal information held by us;
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- to request that we restrict the processing of your personal information (while we verify or investigate your concerns with this information, for example);
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- to object to the further processing of your personal information, including the right to object to marketing; and
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- to request that your provided personal information be moved to a third party.
You can also stop all information collection by un-installing the App. You may use the standard un-install processes as may be available for your mobile device.
Data Deletion Instructions:
To request your data to be deleted from our platform or for any of the queries listed above (under “Your Rights”), please contact us at enquiries@netgem.co.uk. We will ensure the data is promptly & permanently deleted from our database.
Your right to withdraw consent
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us. You can also change your marketing preferences at any time as described in Our promotional updates and communications section;
You can also exercise the rights listed above at any time by contacting us at enquiries@netgem.co.uk.
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see European Commission: Data Protection ). The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
Changes to this policy
Any changes we make to our privacy policy in future will be posted on this page and, in relation to substantive changes, will be notified to you by e-mail. This policy was last updated on 26th June 2019.
Contact Us
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to:
Netgem Privacy
Netgem UK, Trinity House Station Road, Borehamwood, WD6 1DA
Cookies and other technologies
The Platform uses cookies and/or other similar technologies such as device-IDs, in-App codes, pixel tags and web beacons to collect and store certain information. These typically involve pieces of information or code that a website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you. Cookies and similar technologies enable us to remember you when using the same computer or device to interact with us. Cookies can be used to manage a range of features and content as well as storing searches and presenting personalised content.
The Platform uses cookies and similar technologies to distinguish you from other users of the Platform. This helps us to provide you with a good experience when you browse our site/use our App and also allows us to improve the Platform.
Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that and your help screen or manual will tell you how to do this. You may not be able to take full advantage of our website if you do so.
A number of cookies and similar technologies we use last only for the duration of your web or app session and expire when you close your browser or exit the App. Others are used to remember you when you return to the Platform and will last for longer.
We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, or where you have consented to their use.
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We use cookies and/or other similar technologies, such as device-IDs, in-App codes, pixel tags and web beacons, either alone or in combination with each other to create a unique device ID.We use the following types of cookies: ∙ Strictly necessary cookies. These are cookies that are required for the operation of our website and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. We may also work with advertising networks that gather information about the content on the Platform you visit and on information on other websites and services you visit. This may result in you seeing advertisements on the Platform or our advertisements when you visit other websites and services of third parties. For more information about how to turn this feature off see below or visit http://www.youronlinechoices.com/uk. |