Privacy notice and cookies policy

1. About us

This Privacy Notice applies to the Giacom Group (consisting of companies listed here)

When we refer to “we”, “our” or “us” we are referring to the relevant company in the Giacom Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. We take data protection seriously and safeguarding the privacy of our website visitors, customers and partners is important to us. This policy sets out the basis on which any personal information we may hold about you will be processed by us.  It applies whenever you visit our website, during any time when we are processing any application or order you submit to us or while you are our partner or customer, and afterwards. This policy also describes how we use cookies on our websites and how you can manage them.

We regularly review our policies and any changes will be posted on our website. We therefore encourage you to review our Privacy Notice periodically for the most up-to-date information. This policy was last reviewed and updated in March 2022.

Any links from our website to other websites are provided merely for your convenience and do not imply our endorsement of the content or the provider. If you follow a link to any of these websites, you do so at your own risk and we do not accept any responsibility or liability for the content of such websites.

By using our websites or by registering for any of the products and services we offer through it, you are confirming to us that you understand and accept that your personal information may be used by us in the manner described below.

If you have any questions or complaints regarding how we use your information or you wish to exercise any of your rights set out in the ‘Your rights and how to contact us’  section of this Privacy Notice, please contact our Data Protection Officer at [email protected] or at Giacom Group, Milton Gate, 60 Chiswell Street, London, EC1Y 4AG.

Giacom Group pays data protection fees under the Data Protection (Charges and Information) Regulations 2018 and our key registration numbers are:

Giacom (Distribution) Limited	ZB290502
Giacom (Communications) Limited	Z560363X
Giacom (Worldwide) Limited	Z8556712
Giacom (Billing) Limited	Z7474338
Giacom (Cloud) Limited	Z8614039
Giacom (Communications) Group Limited	ZB293861

2. How do we collect information about you?

We collect your personal information directly from you when:

• you use our website;
• you contact us by email, telephone and through other written and verbal communications; and
• you request information about our services.

As well as obtaining personal information directly from you, we can also collect your personal information from:

• publicly available sources such as internet search engines like Google, Companies House and social media sites, including Facebook, Twitter and LinkedIn;
• fraud prevention and detection agencies;
• credit reference agencies; 
• your employer. 

We may also share your personal information between companies within the Giacom Group.

3. What information do we collect and how do we use it?

We process your personal information for a number of different purposes. For each purpose we must have a legal basis for such processing.

When relying on legitimate interests for processing your personal information we will balance the legitimate interest pursued by us and any relevant third party with your interests and rights in relation to the protection of your personal information to ensure it is appropriate for us to rely on such legitimate interest and to identify any additional steps we need to take to achieve the right balance.

In some situations, we may share your personal information with other parties. We have listed below the parties with whom we may share your personal information.

We will not process more information about you than is necessary. We may process the following data about you:

The information we collect	How we use the information	Legal basis for this use of the information	Who we may share the information with and for what purpose
Your name and contact details including your email address, telephone number(s) and delivery address, together with employment details such as the name of the company you work for, your work contact details (address, email, phone number) and job title	To register you as a new customer or partner, to enable us to process your application, and to provide products and services to you.	This is necessary to perform a contract between us.	Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them for the supply of products and/or services to you. For example, we need to share your name and delivery address with postal and courier services to arrange for the products you order to be delivered to you.
Your name and contact details including your email address, telephone number(s) and delivery address, together with employment details such as the name of the company you work for, your work contact details (address, email, phone number) and job title	To prevent fraud.	This is necessary for the purposes of our legitimate interests and those of the networks we represent in respect of fraud prevention, and your interests and fundamental rights do not override those interests.	Credit reference agencies who provide anti-fraud and credit score information to us as necessary in order to carry out fraud and credit checks, and the network providers and suppliers through which we fulfil your orders, or with which you have a direct relationship that we administer on your behalf.
Your name and contact details including your email address, telephone number(s) and delivery address, together with employment details such as the name of the company you work for, your work contact details (address, email, phone number) and job title	To contact you from time to time about our products, news, offers, new competitions and sponsored events.	This is necessary for the purposes of our legitimate interests: marketing and your interests and fundamental rights do not override those interests.	Our group companies, brands and business units that have relationships with our customers and users. We do so because we hope to have a relationship with you across all these different brands and businesses, if not now, then in the future, and we want to be able to provide you with the same value and high quality of experience wherever you choose to interact with us.
Your name and contact details including your email address, telephone number(s) and delivery address, together with employment details such as the name of the company you work for, your work contact details (address, email, phone number) and job title	To communicate with you about operational changes to our website, our products, services and mobile apps, for example if we were to withdraw a feature of our website or one of our apps or change this Privacy Notice.	This is necessary for the performance of a contract with you and for the purposes of our legitimate interests: marketing and your interests and fundamental rights do not override those interests.
Full details of the orders you place on behalf of your customers and the purchases you make, including the time and date of purchase and details of any relevant payment card (including its billing address)	To enable you to process your customer’s orders through us and to allow you to order products from us on our website. We use your payment card details (including its billing address) so we can take payment and details of the products you buy so we can provide you with a receipt.	This is necessary to perform a contract between us.	The network providers and suppliers through which we fulfil your orders, or with which you have a direct relationship that we administer on your behalf. Banks and finance companies where we have allowed them to offer you the possibility of purchasing our products on credit or through a loan arranged through our stores or online. They may retain this information, for example if you take any service they offer, for the purpose of providing you with that service. Payment services companies who enable you to use payment cards with us.
Full details of the orders you place on behalf of your customers and the purchases you make, including the time and date of purchase and details of any relevant payment card (including its billing address)	To enable you to process your customer’s orders through us and to allow you to order products from us on our website. We use your payment card details (including its billing address) so we can take payment and details of the products you buy so we can provide you with a receipt.	This is necessary for the purposes of our legitimate interests: fraud prevention and debt recovery and your interests and fundamental rights do not override those interests.	Our lawyers and debt recovery companies who recover debts on our behalf.
Full details of the orders you place on behalf of your customers and the purchases you make, including the time and date of purchase and details of any relevant payment card (including its billing address)	To enable you to process your customer’s orders through us and to allow you to order products from us on our website. We use your payment card details (including its billing address) so we can take payment and details of the products you buy so we can provide you with a receipt.	This is necessary for preventing crime.	The police, where necessary for preventing crime
Full details of the orders you place on behalf of your customers and the purchases you make, including the time and date of purchase and details of any relevant payment card (including its billing address)	To perform any contract we have entered into with you but also to enforce a contract against you if you do not honour it, including seeking to collect any debts that you may owe us.	This is necessary to perform a contract between us.	Our professional advisers, including our solicitors and debt recover service providers
Full details of the orders you place on behalf of your customers and the purchases you make, including the time and date of purchase and details of any relevant payment card (including its billing address)	To maintain administrative and legal records about our business to enable us to understand what we have sold, how, when, where and at what price and account to HM Revenue & Customs for the related taxes that we have to pay.	This is necessary for compliance with legal obligations to which the Giacom Group is subject.	Our professional advisers, including our accountants, auditors and solicitors
Full details of the orders you place on behalf of your customers and the purchases you make, including the time and date of purchase and details of any relevant payment card (including its billing address)	To enable us to run competitions and offers for which you have signed up, about which we need to be able to communicate with you.	This is necessary for the purposes of our legitimate interests in respect of marketing, and your interests and fundamental rights do not override those interests.	Third party marketing companies who run competitions and offers on our behalf.
Full details of the orders you place on behalf of your customers and the purchases you make, including the time and date of purchase and details of any relevant payment card (including its billing address)	To gather feedback from you about our website, our products, mobile apps, other services and activities from time to time. We may invite you to provide this feedback on occasion, for example by emailing you to ask if you would like to review a product you have bought. We may use independent research and feedback providers to do so on our behalf.	This is necessary for the purposes of our legitimate interests in respect of marketing, and your interests and fundamental rights do not override those interests.	Other people and businesses who help us provide our website, mobile apps, and related services to you, for example, information technology companies who design and host our website. We may need to share your contact details with the independent research and feedback providers we use to gather this feedback.
Full details of the orders you place on behalf of your customers and the purchases you make, including the time and date of purchase and details of any relevant payment card (including its billing address)	To respond to any questions, suggestions, issues or complaints you have raised with us.	This is necessary for the performance of a contract with you.	We may need to share details about any complaint you make with our professional advisers, including our solicitors, thenetwork providers and suppliers through which we fulfil your orders, or with which you have a direct relationship that we administer on your behalf, the Information Commissioner’s Office and/or relevant regulatory authorities.
Information on what you search for, view, click on and access in and through our website, our marketing emails and text messages (SMS or MMS) and mobile apps. We may collect the time and geographic location of your device when you do so. This information may also include where you came to our website from, and where you went when you left it. We also track how often you visit and use our website and our mobile apps. We do this through the use of email and website cookies and similar tracking technology built into our mobile apps. See IP addresses and cookies for further information on the cookies we use.	To ensure that we serve relevant adverts to you and others.	This is necessary for the performance of a contract with you, and for the purposes of our legitimate interests in respect of marketing and your interests and fundamental rights do not override those interests.	Advertisers and advertising networks which 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 may provide them with aggregate information about our users. Analytics and search engine providers who assist us in the improvement and optimisation of our website.
Information on what you search for, view, click on and access in and through our website, our marketing emails and text messages (SMS or MMS) and mobile apps. We may collect the time and geographic location of your device when you do so. This information may also include where you came to our website from, and where you went when you left it. We also track how often you visit and use our website and our mobile apps. We do this through the use of email and website cookies and similar tracking technology built into our mobile apps. See IP addresses and cookies for further information on the cookies we use.	To ensure that we serve relevant adverts to you and others.	This is necessary for the purposes of performance of a contract with you and our legitimate interests in respect of marketing, and your interests and fundamental rights do not override those interests.	Our third party service providers
Your social media content (where you have made this public) and any messages you send us via social media. This information can include posts, comments, pictures and video.	To promote our products and services.	This is necessary for the purposes of our legitimate interests in respect of marketing, and your interests and fundamental rights do not override those interests.	We may share your posts and comments on social media, for example by liking your Facebook posts or retweeting your tweets on Twitter.
Technical information about the devices you use to access our website and on which you use our mobile apps. We collect each device’s unique identifying code (MAC address), relevant IP address, operating system and version, web browser and version, and geographic location.	–	This is necessary for the purposes of ensuring network and information security and our legitimate interests in respect of marketing, and your interests and fundamental rights do not override those interests.	Other people and businesses who help us provide our website, mobile apps and related services to you, for example, information technology companies who design and host our website.
Technical information about the devices you use to access our website and on which you use our mobile apps. We collect each device’s unique identifying code (MAC address), relevant IP address, operating system and version, web browser and version, and geographic location.	–	The legal basis is that this is necessary for the purposes of our legitimate interests in respect of ensuring network and information security, and your interests and fundamental rights do not override those interests.	Other people and businesses who help us provide our website, mobile apps and related services to you, for example, information technology companies who design and host our website.
Basic background information on you available from government sources	To protect you and our business against any other criminal behaviour, including identity theft and fraud	This is necessary for the purposes of our legitimate interests: the prevention of fraud and other crime and your interests and fundamental rights do not override those interests.	Central and local government departments, for example local authorities who run the UK electoral rolls, banks and finance companies who also provide anti-fraud services as necessary in order to benefit from their services. Where we do so for anti-fraud purposes, the recipient organisation may hold your information on file for the purpose of their fraud prevention services in future.
Information from banking, credit card and credit reference agencies about your financial status and the status of any payment card presented to us (for example, if it has been reported stolen) to check we are likely to be paid for any transaction and to reduce the risk of fraud	–	This is necessary for the purposes of our legitimate interests in respect of fraud prevention, and your interests and fundamental rights do not override those interests. The legal basis is that this is necessary for entering into a contract with you. You have the right to require that the decision be reviewed by a human, express your point of view and contest the decision. Please note that these decisions can be made on the basis of a policy of the relevant bank, credit card provider, payment processing company or credit reference agency. These organisations hold information about you independently, so you may need to contact them directly to exercise these rights.	Credit reference agencies who provide anti-fraud and credit score information to us as necessary in order to benefit from their services.
Information collected independently by online advertising networks (for example Google) through which we place advertisements. The information we obtain varies from network to network. It often summarises the actions of lots of people, in which case it does not enable us to identify you individually. It relates to what you view, click on, and access through websites in their network, including the subject matter of the website you started at and where you subsequently go. It may also include their analysis of your behaviour across the wider internet and a profile of you. If you are unhappy about this happening you should look out for “settings” and “Do Not Track” options in online advertisements and in the privacy and cookies functionality on your devices and consider changing your settings to block third party cookies in particular. We do not control the information on you that such networks obtain, or the technology they use to do so.	We use this information to evaluate the success of our advertising.	This is necessary for the purposes of our legitimate interests in respect of marketing and your interests and fundamental rights do not override those interests.	–
Any of the information referred to above in this table	In the process of anonymising your information so that you are no longer identifiable to us To assist us in the development of new products and services over time, for example to gauge whether a new product is likely to appeal to a large proportion of our customer base We do so in part by matching information common to the various different sources of information we have about you, to build a bigger, richer picture. So for example, if you sign up to a competition and provide your email address, and then register for an online account with us using the same email address, we link those two pieces of information together. We can achieve the same effect through matching transaction details and technical information about the electronic devices you use. By doing so, we can understand you better and provide a better experience to you, as we set out above.	This is necessary for compliance with legal obligations to which the Giacom Group is subject.	The prospective buyer of any part of our business or assets that we may sell Our professional advisers for example our lawyers, accountants and technology consultants when they need it to provide advice to us The police, local authorities, HM Revenue & Customs (HMRC), the courts and any other central or local government bodies where they request it and we may lawfully disclose it, for example for the prevention and detection of crime Other people who make a subject access request to us, where we are allowed to do so by law. We may also share the information we collect where we are legally obliged to do so, for example, to comply with a court order. Our insurers and insurance brokers where required in order for us to be able to obtain insurance against risks we face in running our business. They may retain this information for the purpose of ongoing risk assessment and insurance broking and underwriting services.
Special category personal information	When required in connection with the provision of support, for example where you or your customer provide personal information about an individual relating to their health or disability because this is relevant to how we or our representatives provide services for the benefit of that individual.	This is necessary for the performance of a contract with you.	The network providers and suppliers through which we fulfil your orders, or with which you have a direct relationship that we administer on your behalf. Our third party service providers and suppliers.

Special category data, such as data about your racial or ethnic origin, your physical or mental health or your religious beliefs, and data relating to criminal convictions and offences require additional protection. We try to limit the circumstances in which we collect sensitive personal data of this kind and will only process this type of data with your explicit consent.

The provision of some data is a contractual requirement or a requirement necessary to enter into a contract. You are not obliged to provide this data, but if you do not, then we may be unable to enter into a contract with you or fully perform the contract we have entered into with you. In some cases, it may lead to the termination of your contract with us.

Legitimate interests are our business or commercial reasons for using your data, but even so, we will not unfairly put our legitimate interests above what is best for you. Where we use your data for market research, training, credit reference and fraud prevention checks, defending or bringing claims and sending some types marketing, we do so because it is in our legitimate interests of developing and running an efficient and effective business.

We will only retain your personal data for as long as is necessary. The retention period will vary depending on the type of personal data concerned. In order to determine the retention period we take into account the nature of the personal data, the purpose(s) for processing it, your relationship with us, any legal and regulatory requirements and any industry standards and guidelines. If you have previously held an account with us and return we may link your data to your previous account, which will also affect the retention period. Once we no longer need your personal data, it will be securely destroyed.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

4 – Transfers of data outside of the United Kingdom and the EEA

In order to provide you with requested products and services we may need to transfer your personal information to service partners based in countries outside the UK and the European Economic Area (EEA), noting that transfers to the EEA are permitted under UK data protection law. This does not diminish your rights. Where such international transfers outside the UK and the EEA do occur, we will ensure your personal data is protected in a manner that is equivalent to the way it would be protected within the UK and in accordance with this Privacy Notice. We will only make such a transfer where:

• a decision has been made by the European Commission that a place provides adequate protection for your personal data; or
• we have put appropriate safeguards in place to protect your personal data such as standard contractual clauses; or
• we rely on a specific ground for the transfer (called a derogation), such as your consent.

If you would like details of the specific safeguards in place, please contact us using the contact details at the section of this Privacy Notice titled ‘Your rights and how to contact us’.

5 – IP addresses and cookies

5.1 IP addresses

We may collect information about your computer, including where available your IP address, operating system and browser type for system administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

5.2 Cookies

Cookies and other similar technologies, such as pixels and web beacons, (we will refer to all similar technologies as cookies) store information on your device or access data from your device.

We use cookies on our website to recognise your device and store information about your preferences or past actions, which help make your future website visits to us more efficient. They do not store any personal information as they are designed only to collect information of an anonymous nature. We will not combine such anonymous information with your personal details.

We also use cookies in some of our emails to gather statistics arounds email openings and clicks to monitor and improve our content.

Save for the use of cookies, we do not automatically log data or collect data. You can set your computer browser to reject cookies but this may preclude your use of certain parts of our website or emails.

Some cookies are essential to using the website and others improve user experience of the website. Below are some examples of how we use cookies to do this:

• To gather information which allows us to identify your platform and record enquiries so we may improve customer experience and identify issues on the website
• To help ensure you are provided with correct and useful information during your visit to our website
• To collect data which allows us to improve our content and services based on your purchases, website usage and email interaction

Cookies in use

The cookies we use can be split into different functions as explained in the table below:

The cookies we use, the reason for using them and the duration for which they are stored, are as follows:

First-party cookies are cookies that belong to the same domain that is shown in the browser’s address bar (or that belong to the sub domain of the domain in the address bar).

Cookie name	More information
_ga	Google Analytics cookie. Used to distinguish users.
_gat_	Google Analytics cookie. Used to throttle requests.
_gid	Google Analytics cookie used to distinguish users.

Third party cookies

Third party cookies are cookies that belong to domains different from the one shown in the address bar. Web pages can feature content from third party domains (such as banner ads), which opens up the potential for tracking the user’s browsing history. Privacy setting options in most modern browsers allow the blocking of third party tracking cookies.

For more information about cookies please visit All About Cookies | Online Privacy and Digital Security

We may from time to time, via secure means, upload data into Google or LinkedIn. The data is ‘hashed’ so that it is an anonymous data sequence.

We may from time to time add different cookies to test systems to make your user experience better. We will not use or keep any of the data captured during these trials.

What cookies do we use?

This website uses the following cookies:

Our Cloud Market website uses the following cookies:

Your consent to our use of cookies

On our website there is a notice that tells you that we use cookies and provides a link to this Privacy and Cookies Policy to demonstrate how we use cookies and how you can change which cookies you choose to accept.

If you click ‘agree and continue’ you are providing your consent to those cookie settings and unless and until you change your settings, you’ve agreed to them. Additionally, if you change the settings using your browser settings, you are giving your consent to our use of those cookies which you have not disabled.

How to reject and manage cookies

You can choose not to allow cookies in your browser settings. How you do this will depend upon the browser you are using. More information on cookies, their use and how to accept or reject them can be found at www.allaboutcookies.org.

If you do not wish to accept the cookies in our emails, you can choose not to download any images or click on any links or opt out of marketing. For more information, please refer to your email or device instructions.

To opt out of being tracked by Google Analytics across all websites visit Google Analytics Opt-out Browser Add-on Download Page

As our cookies are largely aimed at improving the user experience on the website, you may find that if you block certain cookies you may experience deterioration in the service you receive.

6 – Your rights and how to contact us

Data protection legislation provides you with the following rights regarding your personal data:

the right to access a copy of the personal data we hold about you (commonly known as a subject access request (SAR))

• the right to rectify the personal data we hold about you where it is inaccurate or incomplete
• the right to have the personal data we hold about you deleted (commonly known as the right to be forgotten)
• the right to restrict the way we use your personal data
• the right to data portability e.g. get your personal from us in a commonly used and machine readable format or ask transfer it another organisation
• the right to object to the way we process your personal data

You can access and amend some data and opt out of marketing by using our privacy centre or logging into your account.

In addition to these rights, if you gave us consent to use your data e.g. so that we can send you marketing emails, you can withdraw your consent at any time and free of charge. Information on how to do this is on each marketing email you receive as well as the preference centre.

Often, how we deal with data subject rights will be through our business as usual processes. There are some rights that we will always comply with, such as an objection to receiving direct marketing. However, we are not obliged to comply with all requests we receive. If there is a legitimate reason why we cannot comply with a request you make, for example a legal requirement may mean we have to keep your data even if you have requested that we delete it, we will let you know. We aim to respond to you within one month of receiving your request. However, we are permitted to extend this timeframe by an extra two months, where necessary. If this is the case, we will let you know within a month of receiving your request.

We will not charge you for exercising your rights, unless the request is manifestly unfounded or excessive, in which case we may charge a reasonable fee for our administrative costs or refuse to act on your request. We may also charge a reasonable fee for additional copies of data. We may require identification from you before we can consider your request. If identification or a fee is required or we are refusing to act on your request, we will let you know without undue delay.

If you have any queries about this policy or would like to exercise any of your rights you can contact our Data Protection Officer at [email protected] or at Giacom Group, Milton Gate, 60 Chiswell Street, London, EC1Y 4AG.

Whilst we always endeavour to resolve your concerns, you also have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner. Please visit the Information Commissioner’s Office’s website for more information on how to do this – www.ico.org.uk

7 – Security

Information provided through our website is stored on our secure servers or those of any third party we engage to provide our IT platform, and is encrypted using standard technology, adhering to UK legislation.

We limit access to your personal information to employees and contractors who need access to enable us to process your information for the purposes set out in the What information do we collect and how do we use it?  section.  They are only permitted to process your information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach, which means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.  We will notify you and any applicable regulator (for example the Information Commissioner’s Office) where we are legally required to do so.

Where we have given you, or you have chosen, a password which enables you to access your account or certain parts of our website, you are responsible for keeping the password confidential and must not share it with anyone. You are responsible for any actions carried out using your password except where there has been fraud.

8 – Recruitment Privacy Notice

The Recruitment Privacy Notice can be downloaded here