Last Updated: 20/07/2020
39D Is a trading Name of Thirty Nine Degrees Ltd (11715128)
Run Way House, North Weald Air Field, Northweald, Essex, England, CM16 6HR
39D Privacy and Customer Data Retention Policy
This privacy policy is here to help you understand what information we collect and how we use it. This policy only describes how 39D treats your information, not how other organisations treat your information. If you are using 39D in a workplace or on a device or account issued to you by your employer or another organisation, that company or organisation likely has its own policies regarding storage, access, modification, deletion, and retention of communications and content which may apply to your use of any 39D. Content that would otherwise be considered private to you or to a limited group of people may, in some cases, be accessible by your account owner or administrator. Please check with your employer or account administrator about the policies it has in place regarding your communications.
Fair and Lawful Processing
Many of the current regulations and processes 39D adhere to require a person to be named as the subscriber for the service. An example of this may be a telephone number or broadband service that cannot be anonymous or unnamed or without an address for installation or emergency services purposes. Person(s) wishing to continue with services should, therefore, offer an alternative to allow 39D Limited to continue being able to continue providing existing services.
Information we collect
39D collects different kinds of information. Some of it is personally identifiable and some are non-identifying or aggregated. Here are the types of information we collect or receive:
- Account Information – This includes all the information under your account details within our web portal. It includes names and full contact details for the individual or business that created the account. This is vital for accounting purposes and conforming to our regulatory provisions for providing accurate access to the emergency services.
- Call detail records (CDRs) – This is a record of the communication that has traversed the 39D network. It typically includes a source, destination and duration although it can also include quality metrics and fraud prevention data too. CDRs allow us to create an itemised bill for you which forms part of our accounting procedures.
- IP Address This is a record of the Internet Data that has traversed the 39D network.
- Payment Records – 39D retains a transaction history of purchases made for products and services. This is fundamental to our accounting processes.
- Radius Logs – 39D retains data on Broadband sessions such as the time the connection commenced and duration. 39D Limited may also log metrics such as sync data and bandwidth used.
- Websites and portals – Our websites use cookies in order to offer users functionality. We also use cookies for analytical and service improvements. 39D monitors login data for fraud and security protection.
- Communicating with 39D – We operate systems which log details of calls, emails and web chat correspondence. This allows us to deal with our customers effectively.
- Call Recordings – Call recordings are disabled by default and are opt-in only.
- Cookies – Cookies enable you to use shopping carts and to personalize your experience on our sites, tell us which parts of our websites people have visited, help us measure the effectiveness of ads and web searches, and give us insights into user behaviour so we can improve our communications and products. 39D websites use cookies.
How we use your information (Processing your data)
39D uses your information for the following:
- Providing the 39D service and improving our products – To make the product better we have to understand how users are using it.
- Investigating and preventing bad stuff from happening – We work hard to keep 39D Limited secure and to prevent abuse and fraud. This may also include requests from the authorities or courts.
- Communicating with you – Solving your problems and responding to your requests. If you contact us with a problem or question, we will use your information to respond to that request and address your problems or concerns.
- Email messages – We may send you service and administrative emails, such as when we notice that you are nearing credit limits. We may also contact you to inform you about changes in our services, our service offerings and important service-related notices, such as changes to this policy or security and fraud notices. These messages are considered part of the service and you may not opt-out of them.
Data Retention
- Call Recordings – If activated are stored for 30 calendar days unless specified to be longer by you.
- Call Detail Records (CDRs) – Are stored for 12 calendar months and then deleted.
- Radius Data – Stored for 6 calendar months and then deleted.
- Account Data – If the authorised account holder chooses to deactivate the account. The data will be archived for no more than 15 years.
- Correspondence – This includes but is not limited to: emails, call-recordings, CDRs, webchats, Fax transmissions and post. The data may be kept for no more than 15 years.
- Payment Data – 39D Limited does not process nor retain card payment data. All sensitive transactional payment data is processed and stored in accordance with PCI-DSS regulations by payment providers such as GoCardless or PayPal. 39D Limited does store Active Direct Debit details.
- LDAP Data – Customers are in control of LDAP (Hosted Address Directory) data which can be removed permanently via the web-portal.
Sharing and Disclosure
There are times when communications and related content and other user information may be shared by 39D. With consent, to comply with legal process, or to protect 39D and our users. When we have your consent or if we believe that disclosure is reasonably necessary to comply with a law, regulation or legal request; to protect the safety, rights, or property of the public, any person, or 39D; or to detect, prevent, or otherwise address fraud, security or technical issues. If we receive law enforcement or other third party request for information we will provide prior notice to the subject of the request where we are legally permitted to do so.
Examples of sharing and disclosure are below and but not strictly limited to the following:
- Example: Telephone number subscriber information is shared with authorities for emergency services purposes (999/911)
- Example: Telephone number subscriber information is shared between the companies involved in a telephone number port as validation. (Openreach/BT along with the RH, LCP and GCP)
- Example: Fixed line services (Broadband and WLR) require installation addresses, therefore, disclose of this information is given to those involved in the provision and installation of these services.
- Example: Fault finding such as UK PTSN based services sometimes require engineer visits in which case we would ask your permission to provide a contact telephone number and name. These can be from BT Group companies or subcontractors or LLU providers and their subcontractors.
- Example: Direct Debit data is stored and processed with the GoCardless payment network.
- Example: Some international telephone number rentals require the subscriber to provide official identity documents as a regulatory requirement in that country.
Security
39D takes reasonable steps to protect the information you provide to us as part of your use of the 39D service from loss, misuse, and unauthorised access or disclosure. These steps take into account the sensitivity of the information we collect, process and store and the current state of technology. When you enter sensitive information (such as sign-in credentials) we encrypt the transmission of that information using secure socket layer technology (SSL) and encrypt all data at rest. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once we receive it. All 39D staff are trained and partake in refresher training in data protection.
Data Storage and Transfers
39D does not store or process data outside of the United Kingdom.
Data Subjects Rights & Data Protection Officer
Data Subjects have the rights in relation to their personal data under the Privacy Legislation. Those rights include;
The right to be informed
The right of access
The right to rectification
The right to erasure
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision making and profiling
Customers should contact the Data Protection Officer in relation to these queries with the subject DPO via the following page: https://39support.com/contact-us/
Thirty Nine Degrees Ltd is registered in the United Kingdom with the Information Commissioners Office under registration number ZA764888.
https://ico.org.uk/ESDWebPages/Entry/ZA764888
Changes to this Privacy Policy
39D may change this policy from time to time, and if we do we’ll post any changes on this page. If you continue to use 39D after those changes are in effect, you agree to the revised policy. If the changes are material, we may provide more prominent notice or seek your consent to the new policy.
This privacy policy does not cover third party websites that you can link to through the Website. We accept no liability for these sites. If you have any complaints, questions or comments about this privacy policy or 39D use of your personal information, you can contact 39D here https://39support.com/contact-us/
