Trunk Networks Limited 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 Trunk Networks treats your information, not how other organisations treat your information. If you are using Trunk Networks in a workplace or on a device or account issued to you by your employer or another organisation, that company or organisation is likely to have its own policies regarding storage, access, modification, deletion, and retention of communications and content which may apply to your use of any Trunk Networks service. 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.

For the purposes of data protection laws, Trunk Networks Limited (info@trunknetworks.com| 03333443322) is the data controller when collecting and processing data from its own customers but is a data processor when dealing with data on behalf of a third party.

Fair and Lawful Processing

Many of the current regulations and processes Trunk Networks 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 Trunk Networks to continue being able to continue providing existing services.

Information we collect

Trunk Networks collects different kinds of information. Some of it is personally identifiable and some are non-identifying or aggregated, such as statistical data. 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 Trunk Networks 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.
• Payment Records – Trunk Networks retains a transaction history of purchases made for products and services. This is fundamental to our accounting processes
• Radius Logs – Trunk Networks retains data on Broadband sessions such as the time the connection commenced and duration. Trunk Networks may also log metrics such as sync data and bandwidth used.
• Email Logs – We retain data of email processed by our email gateways (Mail Launder) such as the sender, the recipient and the subject for the purposes of Spam and Malware tracking. We also collect other metrics such as speed of processing and if an email has been scanned as clean, Spam or infected.
• Websites and portals – Our websites use cookies in order to offer users functionality. We also use cookies for analytical and service improvements. Trunk Networks monitors login data for fraud and security protection.
• Communicating with Trunk Networks – 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 personalise 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. Trunk Networks websites use cookies.

How we use your information (Processing your data)

Trunk Networks uses your information for the following:

• Providing the Trunk Networks 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 Trunk Networks 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 & Email Log Data – Stored for 6 calendar months and then deleted.
• Quarantined Email – If an email is considered to be possible spam then it will be quarantined until released by the Customer. Quarantined emails are stored for 30 days 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 – Trunk Networks 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 Swipe or PayPal. Trunk Networks does store Active Direct Debit details, these are held by our payment processor, GoCardless

Sharing and Disclosure

There are times when communications and related content and other user information may be shared by Trunk Networks. With consent, to comply with legal process, or to protect Trunk Networks 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 Trunk Networks; or to detect, prevent, or otherwise address fraud, security or technical issues. If we receive a 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 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: Some international telephone number rentals require the subscriber to provide official identity documents as a regulatory requirement in that country.

Security

Trunk Networks takes reasonable steps to protect the information you provide to us as part of your use of the Trunk Networks 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 Trunk Networks staff are trained and partake in refresher training in data protection.

Data Storage and Transfers

Trunk Networks 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:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. note that this right only applies to automated information which you initially provided consent for us to use or where we used information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Customers should contact the Data Protection Officer in relation to these queries. Please contact us via the website and a member of the team will respond to you.

Changes to this Privacy Policy

Trunk Networks 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 Trunk Networks’ services 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 Trunk Networks use of your personal information, you can contact Trunk Networks via the website and a member of the team will respond to you.