Privacy Policy

1. Introduction
At Delight Calling, we take seriously our responsibilities to look after your Data and we are committed to protecting your privacy. We, Delight Calling, use your Data to provide Services to you.

This Privacy Policy applies to all Services provided by Delight Calling and Users to you. This Privacy Policy describes how we collect, store and use your Data. There are steps you can take to control what we do with your Data and these steps are explained in this Privacy Policy.

It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to websites.

2. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
Account means collectively the airtime account and that Delight Calling use to record any Services that you have used. This includes My Delight service and other System.

Data means collectively all information that you submit to Delight Calling, depending on how you use our Services and our Website. This definition shall mean any information relating to an identified or identifiable natural person, in accordance to the definition in the General Data Protection Regulation (EU) 2016/679;

Charges means the cost applicable for providing the Service including, but not limited to usage and service charges and the charges applicable for any additional services that you order from Delight Calling or use;

Delight Calling means Delight Calling Limited a company registered in England and Wales under company number 04553934 registered office of 54 Marsh Wall, London E14 9TP;

My Delight means the online facility available on Delight Calling website where you can check your Account including call history, cost of calls, duration of calls, payments and other personal Data;

Services means the basic and any additional services that Delight Calling provide to you which you access by using any SIMS, Apps, Goods, Account, System, My Delight and collectively any online facilities, tools, services or information that Delight Calling makes available through the website either now or in the future;

System means any online communications infrastructure that Delight Calling makes available through the website either now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities and email links;

UK and EU Cookie Law means the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;

User means any third party that accesses the Website and is not employed by Delight Calling and acting in the course of their employment; and

Website means the website that you are currently using (www.delightcalling.com) and any sub-domains of this site (e.g. subdomain.delightcalling.com) unless expressly excluded by their own terms and conditions.

3. Data Collected
Depending on how you use our Services and our Websites, the following Data about you may be collected:
3.1Your name and contact details such as email addresses, telephone numbers, and address;
3.2 Personal details such as date of birth, gender, occupation, profession;
3.3 Communication we have with you such as emails, letters, telephone calls, messages to our online chat service, messages sent to us through our social media platforms, feedback;
3.4 Payment and billing information such as payment card details and billing address;
3.5 Technical information such as call data records, voice mail recordings top up records, traffic data, location data;
3.6 Information that is automatically collected such as IP address, web browser type and version, operation system, your activity on this Website;
3.7 Demographic information such as post code, preferences and interests;
3.8 We may supplement the information that you provide to us with information that we received from third parties, for example, collected from other members of your household.

4. Our Use of Data
4.1 Delight mobile will only process and use your Data if we have a proper reason for doing so. According to the law, we may only use your Data for one or more of the following reasons:
4.1.1 If necessary for the performance of a contract with you;
4.1.2 If you consent to the use; or
4.1.3 When it is in our legitimate interests.
4.2 Legitimate interests will be based on our business and commercial reasons for using your data, however, we will not unfairly put our legitimate interests above what is best for you.
4.3 We may use the above Data you provide to us in order to provide the best possible customer experience when you use our Services, in particular:
4.3.1 To provide our Services to you;
4.3.2 To manage your Account and My Delight, this includes but is not limited to administration,  
creating and maintaining internal records, accounts and statistical data;
4.3.3 To personalise and improve your customer experience and our products/ services;
4.3.4 To carry out necessary duties for the running of our business;
4.3.4 To detect, investigate and seek to prevent fraud / financial crimes and comply with any legal
and regulatory obligation;
4.3.5 To provide customer services facilities in respect of any query or complaint raised;
4.3.6 To communicate and send you information about your Service subscription;
4.3.7 To inform you of news and our offers that we think you may be interested in.      

5. Sharing your data
5.1 We share some of your personal data with, or obtain personal data from, the following categories:
5.1.1 Government authorities and law enforcement authorities when necessary to comply with our
legal obligations;
5.1.2 Other mobile operators when you request to port out of/ port into our network;
5.1.3 Suppliers who provide services to us?
5.1.4 Companies within the Delight group, including Delight Calling’s affiliates, to provide the
best Services to you;
5.1.5 Payment card and fraud management services provider to process payments and prevent and
         detect fraud.
5.2 We may send data outside of the EEA to work with our affiliates and companies of the Delight group, and we will ensure that it is protected in the same was as if it were being used in the EEA. Such recipients are subject to a contract requiring protection of Data to the same standards as required within the EEA.
5.3 Unless we are obliged or permitted by law to do so, and subject to Clause 7 and notwithstanding the above Clauses 5.1 and 5.2, your Data will not be disclosed to any other third parties.

6. Storage and protection of your Data
6.1 Any personal Data you submit will only be retained by Delight Calling for as long as is necessary for its use. How long we need Data depends on what we are using it for, whether that is to provide Services to you, for our own legitimate interests, or so that we can comply with the law.
6.2 We will actively review the information we hold and when there is no longer a customer, legal or business need for us to hold it, we will either delete it securely or in some cases make it anonymous.
6.3 Data security is of great importance to Delight Calling. We have put in place appropriate physical, electronic and managerial procedures to safeguard and secure Data collected, including:
6.3.1 Encryption and password protection for systems holding Data;
6.3.2 Limiting the number of people who have access to the systems;
6.3.3 Reviewing industry security standards to keep up to date with current best practice.

7. Changes of Business Ownership and Control
7.1 Delight Calling may at any time expand or reduce its business and this may involve the sale and/or the transfer of control of all or part of Delight Calling. Data provided by you may also transfer with this sale and/or transfer of control to the new owner or new controlling party. Any new owner or new controlling party will be subject to the use of your Data, in accordance with the terms of this Privacy Policy.
7.2 In the event that any Data submitted by you is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

8. Your rights
8.1 You are entitled to:
8.1.1 Request copies of all your personal Data held by Delight Calling;
8.1.2 You are entitled to amend, correct or delete such Data held by Delight Calling;
8.1.3 You are entitled to limit, restrict or object our processing of your Data;
8.1.4 You are entitled to request the transfer of your personal Data to another operator;
8.1.5 You are entitled to withdraw any consent you have previously given to use your Data.
8.2 Delight Calling reserves the right to charge a reasonable fee or inform you of our refusal to respond when requests of access to personal Data in accordance to Clause 8.1.1, is manifestly unfounded or excessive.
8.3 If and when you exercise your rights, we will aim to respond as soon as possible and where possible within one month. If your request is more complicated, it may take a little longer to process, and we will respond within two months of your request.
8.4 So as to safeguard against fraud we may ask you for documentary confirmation of your identity before we provide any information to you. 
8.5 To raise any objections or to exercise any of your rights, you can put your request in writing, to Delight Calling Customer Services, 54 Marsh Wall, London E14 9TP.

9. Marketing: How to manage the marketing communication you receive
9.1 We may send you marketing communications if you have indicated that you are happy to receive such communication (or if you have signed up for our Services and you have not told us that you no longer wish to receive marketing communication).
9.2 Our marketing communications include information about our new and existing Services, which we think you might like and other products we think might be useful to you.
9.3 If you have previously opted-in to receive marketing communication from us, you may opt out of receiving marketing communication for us at all. You can update your preferences at any time. You can also opt out of receiving marketing communication by clicking on the unsubscribe link which we include in all our marketing emails or by texting ‘STOP’ to our marketing texts.
9.4 Please note that if you ask us to stop sending marketing communication, we will keep a note of your personal information and your request so that we can make sure you are excluded from the emails when they are sent out.

10. Cookies
10.1 You may access certain areas of the Website without providing any Data at all. However, to use all features and functions available on the Website you may be required to submit certain Data.
10.2 This Website places certain first party cookies on your computer. Cookies are text files containing small amounts of information which are downloaded onto your device when you visit a website. Certain features of the Website depend upon cookies to function. Certain cookies may be placed immediately when you visit the Website and it may not be possible to obtain your prior consent, however, you may block these cooking in accordance with Clause 10.5 to 10.7 below. 
10.3 Delight Calling uses cookies, in accordance to UK and EU cookie law, for the following reasons:
10.3.1 To improve your experience and allow efficient navigation;
10.3.2 To identify and understand your preferences to personalise Services we offer to you;
10.3.3 To improve our range of products and Services;
10.3.4 To analyse and understand Website usage patterns and statistics to then provide improved
Services via the Website; 
10.4 This Website contains third party cookies, placed by websites and/or third parties other than Delight Calling for advertising services, and these are not integral to the services provided by this Website;
10.5 Upon entering the Website, you will be presented with a pop-up requesting your consent to enable the Website’s cookies. You may, if you wish, deny your consent at this point. However, certain features of the Website may not function fully or as intended.
10.6 By default, most internet browsers accept cookies but you can choose to either enable or disable cookies in the settings of your internet browser. For further details, please consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
10.7 You can choose to disable the cookies at any time howev4er you may lose any information that enables you to access the Website more quickly and efficiently.

11. Complaints
We would hope that you will always raise any issues with us first, and that we will be able to resolve them to your satisfaction. For this you may contact our data protection officer at:

Data Protection Officer
54 Marsh Wall
Canary Wharf
London
E14 9TP

However, if this isn’t possible then you always have a right to complain directly to the Information Commissioner’s Office (ICO) if you believe that any use of your personal information by us is in breach of applicable data protection laws and regulations. Please see below for contact details of the ICO:

Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)
Email: casework@ico.org.uk

11. Changes to this Policy
Delight Calling reserves the right to change this Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Policy on your first use of the Website following the alterations. This Privacy Policy was last updated on 24 May 2018.