Y-ROAM (GUERNSEY) LIMITED (We) are committed to protecting and respecting your privacy.

This document applies to our Y-Roam app (App) and our website y-roam.com (our site).

This policy (together with our terms of use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting y-roam.com you are accepting and consenting to the practices described in this policy.

For the purpose of the Data Protection (Bailiwick Of Guernsey) Law, 2017 (the Act), the data controller is Y-Roam (Guernsey) Limited of YROAM HOUSE, Sunnycroft, The Grange, St Peter Port, Guernsey, GY1 2QG.

Y-Roam (Guernsey) Limited is registered with the Office of The Data Protection Commissioner as a data controller under registration number 58683.

INFORMATION WE DO NOT COLLECT

We do not store customer credit card details.

INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following data about you:

Information you give to us (‘Submitted Information’). You may give us information about you by filling in forms on our site or within the App, or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, or register or download our App, subscribe to our service, search for a product, place an order on our site, participate in an interactive panel where you can input information regarding how often you access your emails or watch videos, for instance, which means we can assess what type of data package would suit your needs best. (When you make an input into an interactive panel, the information is not stored and no personal details from you are required to be entered). It also includes information you provide when you report a problem with our App or our site. The information you give us may include your name, address, e-mail address and phone number, the device’s telephone number, your username, password and other registration information, images taken or stored within the App, financial and credit or debit card information, personal description and photograph.

Information we collect about you. With regard to each of your visits to our site or our App, or we may automatically collect the following information:

• technical information, including the type of device you use, a unique identifier (for example your device’s IMEI number, the MAC address of the device’s wireless network interface, or the mobile number used by the device), the Internet protocol (IP) address used to connect your computer to the Internet, mobile network information, your login information, browser type and version, time zone setting, browser plug-in types and versions, the type of mobile browser you use, operating system and platform, time zone setting (‘Device Information’);

 

In addition to this, we may also collect any other data that you provide or make available such as:

• information stored on your device, including contact information, login information, photos and videos held in the App or other digital content (‘Content Information’);
• details of your use of any of our apps or websites, including but not limited to, traffic data, location data, weblogs and other communication data, including the Internet Protocol (IP) address used to connect your device to the Internet and the resources that you access (‘Log Information’);
• if you contact us, we may keep a record of that correspondence;
• where activated on your device, we may also use GPS technology to determine your current location (Location Information). Some of our location-enabled services may require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can control this function by disabling the location function on your device;
• information about your visit, including 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), and methods used to browse away from the page and any phone number used to call our customer service number;
• when you install or uninstall a service containing a unique application number or when such a service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us (‘Unique Application Numbers’).

 

Information we receive from other sources. We may receive information about you if you use any other websites we operate or other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers) and may receive information about you from them.

 

COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and any advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

 

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie	Name	Purpose
Google Analytics	Google Analytics	This cookie is used to measure our visitors anonymously on our site. Examples of purposes for which a cookie may be used: – We measure visitors to our website using Google Analytics, which use cookies to record what pages you view within our site, how you arrived at our site and some basic information about your computer. All of that information is anonymous – so we do not know who you are. We just know that somebody visited our site. The information we collect from analytics helps us understand what parts of our sites are doing well, and how people arrive at our site. Like most websites, we use this information to make our website better.

 

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

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 if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

 

USES MADE OF THE INFORMATION

We use information held about you in the following ways:

Submitted Information and unique application numbers:

• to administer the App or our site, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve the App or our site to ensure that content is presented in the most effective manner for you and for your device;
• to allow you to participate in interactive features of our services, when you choose to do so;
• as part of our efforts to keep access to the App and our site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
• to make suggestions and recommendations to you and other users of the App or our site about goods or services that may interest you or them.

 

Device, Content, Log and Third Party Information:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
• to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. Where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please do not tick the relevant box to consent to such marketing that will, where relevant, appear before you enter such data.
• to notify you about changes to our service;
• to ensure that content from our site and App is presented in the most effective manner for you and for your computer or device.

 

Information we receive from other sources:

We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).

We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.

 

DISCLOSURE OF YOUR INFORMATION

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may share your information with selected third parties including:

• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
• We may disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If Y-Roam (Guernsey) Limited or substantially all of its assets is 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 use or terms and conditions of supply or any other agreements with you; or to protect the rights, property or safety of our employees, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

 

WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site or App, 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 our site or App; 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.

We may collect and store personal data on your device using application data caches and browser web storage (including using HTML 5) or other technology.

 

RETENTION OF DATA

We will not keep your personal data for longer than is necessary for the purpose for which it is held or otherwise processed by us. This means that data will be securely destroyed or erased from our systems when it is no longer required.

 

YOUR RIGHTS

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by not checking certain boxes relating to marketing on the forms we use to collect your data. You can also exercise the right at any time by contacting us at YROAM House Sunnycroft, The Grange, St Peter Port, Guernsey GY1 2QG or customerservices@y-roam.com.

Our site and the App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

 

ACCESS TO INFORMATION

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

 

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or, in relation to the App, when you next start the App. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or services.

 

CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Y-Roam (Guernsey) Limited, YRoam House, Sunnycroft, The Grange, St Peter Port, GY1 2QG or customerservices@y-roam.com.