Privacy and Cookies

1.1 VirtualLandline.com by Freedom Telephony is a trading name of Freedom Telephony Limited, a company registered in England and Wales under company number 14686171. In this notice, Freedom Telephony Limited is referred to as "Freedom Telephony", "we", "us" or "our".

1.2 Freedom Telephony is the controller responsible for the personal information described in this notice. Our registered office is 197-201 Manchester Road, West Timperley, Altrincham, Cheshire, England, WA14 5NU.

1.3 We handle personal information in accordance with the UK General Data Protection Regulation, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003.

1.4 This is the Privacy Notice referred to in our Terms and Conditions. Capitalised words such as Account, Number, Order, Service and Website have the meanings given in those Terms.

1.5 Questions about this notice or your information can be sent to support@virtuallandline.com or raised on 0161 706 3232.

2.1 This notice applies to:

• customers and people who start or place an Order;
• people who manage an Account for a business or other organisation;
• visitors to the Website;
• people who contact our support team by email, telephone or live chat; and
• people who call a Number supplied through our Service ("callers").

2.2 Where a customer uses a Number for business, that customer is responsible for any information it separately collects from callers, such as names, messages or notes taken during a call. This notice covers only the information that we handle.

2.3 If you give us information about another person, such as a colleague who manages the Account, you should make sure they are aware of this notice.

3.1 When you order or use the Service, we collect:

• your name, email address and the UK mobile number that calls are forwarded to;
• business or organisation details where you order on behalf of an organisation;
• billing details, such as billing name and address;
• your Order choices, including Number type, plan, top-ups, Extra Minutes, destination changes, cancellations and porting requests;
• login details and one-time login codes used to access your Account; and
• identity, address, business or authority evidence where we ask for it to complete checks.

3.2 When you contact us, we collect the content of your emails, live chat messages and complaints, and notes of telephone conversations with our support team.

3.3 Please do not send us health information or other sensitive details unless we ask for them. We do not need them to provide the Service.

4.1 When you use the Website or your Account, we and our suppliers collect:

• your IP address and the approximate location that can be derived from it;
• device, browser and operating system information;
• login activity, including the date, time and IP address of sign-ins and Account changes;
• pages viewed, how you arrived at the Website and actions taken during checkout; and
• information collected through cookies and similar technologies, as described in section 17.

4.2 Our payment providers collect device and transaction information during checkout to authorise payments and assess fraud risk.

5.1 To route, bill, secure and support the Service, we and our telecommunications suppliers process traffic data about each call to a Number, including:

• the calling number, where it is available;
• the Number called and the mobile number the call is forwarded to;
• the date, time and duration of the call;
• whether the call connected and how it was routed; and
• the effect of the call on credit, Base Minutes or Extra Minutes.

5.2 We use traffic data only as the law allows, including to connect calls, calculate charges, manage traffic, deal with enquiries and complaints, detect and prevent fraud and misuse, and meet legal requirements.

5.3 If a caller withholds their number, we do not override that choice. The network may still pass the number to us and our suppliers for routing, billing and fraud prevention, but we do not make a withheld number available to our customer.

5.4 We do not collect the physical location of your mobile phone.

6.1 We receive information from:

• payment providers, including payment results, risk assessments, refunds, disputes and chargeback notices;
• telecommunications suppliers and carriers, including call records, fault reports, fraud alerts and porting information;
• banks and card schemes, in connection with disputed or unauthorised payments;
• other brands operated by Freedom Telephony, where information is relevant to fraud or misuse;
• the police, regulators and other public bodies, where they contact us; and
• public sources, such as Companies House, when we check a business customer.

6.2 If someone else manages an Account on your behalf or places an Order that names you, we receive your information from them.

7.1 We use personal information only where we have a lawful basis. The main purposes and lawful bases are:

• Providing the Service: setting up and running your Account and Number, forwarding calls, applying credit and minutes, taking payments and processing renewals, cancellations and ports. Lawful basis: performance of our contract with you, or our legitimate interests where the customer is an organisation.
• Service messages: sending confirmations, login codes, receipts, payment and renewal notices, suspension notices and security alerts. Lawful basis: performance of our contract and legal obligation.
• Support and complaints: answering questions, investigating faults and handling complaints. Lawful basis: performance of our contract and legitimate interests.
• Fraud prevention and security: checking Orders, payments and calling patterns, protecting our suppliers and networks, and investigating misuse. Lawful basis: legitimate interests and, where applicable, legal obligation.
• Calls to a Number: connecting, billing and protecting calls made to a Number. Lawful basis: legitimate interests.
• Payment disputes and debts: responding to chargebacks, recovering money owed and establishing, exercising or defending legal claims. Lawful basis: legitimate interests.
• Legal and regulatory requirements: keeping accounting and tax records, meeting telecommunications rules and responding to lawful requests. Lawful basis: legal obligation.
• Improving the Website and Service: understanding how the Website is used and fixing problems. Lawful basis: consent for analytics cookies, otherwise legitimate interests.
• Measuring advertising: finding out whether our adverts lead to visits and Orders. Lawful basis: consent.
• Business changes: sharing information with a prospective buyer, investor or their advisers if all or part of our business is sold, transferred or restructured. Lawful basis: legitimate interests.

7.2 Where we rely on legitimate interests, we have considered whether those interests are overridden by your rights. Our interests include running a secure and reliable telecommunications service, preventing fraud, recovering money owed and developing our business. You can object, as explained in section 19.

7.3 If you do not provide information we need to supply the Service, such as a valid destination mobile number or payment details, we may be unable to accept your Order or keep the Service active.

10.1 We send service messages by email, SMS or Account message, including confirmations, one-time login codes, receipts, payment and renewal notices, suspension notices and security alerts. These are part of the Service and cannot be switched off while your Account is active.

10.2 We do not currently send marketing messages. If we start, we will send them only where the law allows, for example to existing customers about our own similar services where they have not opted out, or with consent.

10.3 Every marketing message will include a simple way to opt out, and you can also opt out at any time by emailing support@virtuallandline.com. Opting out does not affect service messages.

11.1 If you contact us, we use the information you provide to answer your query, investigate faults and complaints, and keep a record of what was agreed.

11.2 Live chat on the Website is provided by a third-party live chat provider. Your messages, any name and email address you give, and technical information such as your IP address and the page you are viewing are processed by that provider on our behalf.

11.3 Before discussing an Account, we may ask questions to confirm your identity or authority.

12.1 We share personal information only where necessary, with:

• telecommunications suppliers, VoIP providers and carriers that supply Numbers, route calls and support porting;
• payment providers that process payments, refunds and disputes;
• hosting, IT, email and SMS delivery providers that run the Website, Account and our messages;
• our live chat provider;
• analytics and advertising providers, where you have accepted the relevant cookies;
• banks and card schemes, in connection with payments, disputes and chargebacks;
• professional advisers, including accountants, lawyers and insurers;
• debt recovery agents and courts, where we need to recover money owed; and
• a prospective buyer, investor or successor and their advisers, if all or part of our business is sold, transferred or restructured.

12.2 Suppliers that handle information on our behalf may use it only to provide their services to us and must keep it secure.

12.3 Some organisations, including payment providers and telecommunications carriers, also use information as independent controllers for their own purposes, such as meeting financial or telecommunications regulation and preventing fraud. Their own privacy notices apply to that use.

12.4 We do not sell personal information.

13.1 We may disclose information to the police, other law-enforcement agencies, regulators such as Ofcom and the Information Commissioner's Office, courts and other public bodies where the law requires or allows it. This includes lawful requests for communications data and disclosures needed to prevent or detect crime.

13.2 We may report suspected fraud or other crime to the police or another appropriate organisation.

13.3 We may not tell you about a request or disclosure where the law prevents us from doing so or where telling you would prejudice an investigation.

14.1 Some of our suppliers are based outside the UK or can access information from outside the UK, including in the European Economic Area and the United States.

14.2 Where information is transferred outside the UK, it is protected by UK adequacy regulations, such as the UK Extension to the EU-US Data Privacy Framework where a supplier is certified, or by safeguards approved under UK law, such as the International Data Transfer Agreement or the UK Addendum to the EU standard contractual clauses.

14.3 You can ask us for more information about these safeguards.

15.1 We keep information only for as long as we need it. Our standard periods are:

• Account, Order and billing records: 6 years after the Account closes, for tax, accounting and legal claims.
• Call and traffic records: 24 months from the date of the call.
• Support emails, live chat and other correspondence: 2 years from our last contact with you.
• Fraud, chargeback and ban records: up to 6 years after the last relevant event.
• Website analytics: up to 14 months.
• Cookie choices: stored in your browser until they expire or you clear them.

15.2 We may keep information for longer where it is needed for an unresolved dispute, investigation, legal claim or legal requirement.

15.3 When information is no longer needed, we delete it or anonymise it so that it can no longer identify you.

16.1 We use technical and organisational measures to protect personal information, including encrypted connections to the Website, restricted access to our systems and one-time login codes for Account access.

16.2 Our suppliers must protect information to a standard appropriate to the risk.

16.3 No online system is completely secure. If you think your Account has been accessed without permission, please contact us straight away.

16.4 If a personal data breach is likely to result in a risk to your rights, we will notify the Information Commissioner's Office and, where the law requires, you.

18.1 When you first visit the Website, our cookie banner asks which optional cookies you accept. Optional cookies are not set until you make a choice.

18.2 You can change your choices at any time using the cookie settings option on the Website.

18.3 You can also block or delete cookies in your browser settings. Blocking strictly necessary cookies may stop the Website or your Account from working properly.

18.4 To opt out of Google Analytics on all websites, you can install Google's browser add-on at tools.google.com/dlpage/gaoptout.

20.1 If you are unhappy with how we have handled your information, please contact us first at support@virtuallandline.com so that we can try to put it right. We will acknowledge your complaint within 30 days and respond without undue delay.

20.2 You also have the right to complain to the Information Commissioner's Office, the UK regulator for data protection, at ico.org.uk or on 0303 123 1113.

21.1 The Service is for people aged 18 or over and the Website is not aimed at children. We do not knowingly collect children's information through the Website or an Account.

21.2 Call records may relate to anyone who calls a Number, including children. We handle those records in the same way as all other call records.

21.3 If you believe a child has given us information, please contact us and we will delete it where appropriate.

22.1 We may update this notice to reflect changes to the Service, our suppliers, the law or how we use information. The date at the top of this page shows when it was last updated.

22.2 If we make a significant change that affects customers, we will tell you by email or Account message before it takes effect where reasonably possible.

Freedom Telephony Limited trading as VirtualLandline.com by Freedom Telephony

Company number 14686171

Registered office 197-201 Manchester Road, West Timperley, Altrincham, Cheshire, England, WA14 5NU

Email support@virtuallandline.com (please include "Privacy request" in the subject line)

Telephone 0161 706 3232

Website VirtualLandline.com by Freedom Telephony