At Gamma we are mindful of the importance of supporting our customers and those partners we do business within their endeavours. In that line, we recognise the need to ensure that any personal data that we may collect is properly protected and that we are transparent and responsible in the way we handle it.
In these pages you can find information about what personal data we collect as a controller, what we do with it and how you can contact us if you have any question or need any further information.
If you are an existing Gamma customer, Gamma may process your or your customers’ or end users’ personal data on your behalf as part of the services Gamma provides to you. Details of such processing are provided in our contracts/terms and conditions and are available at any time upon request. Note that this Privacy Policy does not deal with such processing.
From whom does Gamma collect personal data?
Gamma (as defined below) collects personal data from shareholders, customers, suppliers and professional advisers, and their employees with whom Gamma has an existing or prospective business relationship (“Business Partners”) in order to manage such relationship and interact with the Business Partners.
Who is the controller?
In relation to such personal data Gamma acts as the controller and collects and process such data on the grounds of its legitimate interest of managing the relationship with Business Partners and compliance with its legal obligations.
What personal data does Gamma collect?
The personal data consists of any or all of the following: name, address, email, telephone numbers and communications records (emails, letters & call recordings).
In addition, for shareholders Gamma collects full date of birth, nationality, bank account details, national insurance number, passport number and overseas identification card numbers, shareholdings, communication method preference, and any data that is mirrored from the CREST system.
How does Gamma collect personal data?
The personal data is collected during our engagement with Business Partners by email, phone, meetings, Gamma’s website (gammagroup.co) and events organised by Gamma.
How does Gamma use the personal data?
The personal data is exclusively used for the management of the relationship with the Business Partner and, in the case of existing or prospective customers, for the promotion of services provided by Gamma relevant to them. Note that the personal data is not used for automated decision taking (including profiling).
In addition, for existing customers, Gamma will process personal data to provision and support the service; to comply with statutory obligations, and to maintain accounts and records for billing and customer account support. This will involve collection, storage, analysis, disclosure and deletion of personal data that Gamma receives from (or on behalf of) the customer in accordance with the relevant contract with Gamma.
With whom does Gamma share the personal data?
The personal data is shared among the Gamma Entities (as defined below) for the same purposes stated above.
In addition, personal data is shared with:
Existing customers:
– our service suppliers in order to be able to provide their services to our customers, which include communication providers, hardware distributors & cloud services providers.
– legal and industry regulators (when requested) & emergency services (when requested).
– salesforce.com EMEA Limited, our customer relationship management provider.
Prospective customers:
– salesforce.com EMEA Limited, our customer relationship management provider.
– Third Party Processors
Our carefully selected partners and service providers may process personal information about you on our behalf as described below:
Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:
(i) Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: https://sopro.io/legal/#privacy-policy. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.
Shareholders:
– Link Market Services Limited, Gamma shares registrar;
Does Gamma transfer personal data outside the European Economic Area?
No personal data is transferred outside the UK other than in the case of salesforce.com EMEA Limited in relation to prospective and existing customers. Such transfer is subject to a data processing addendum pursuant to the UK standard data protection clauses for the transfer of personal data to processors established in third countries and international organisations (specified in regulations made by the Secretary of State under section 17C of the 2018 Act).
How long does Gamma retain the personal data?
Personal data is retained for the duration of the relationship with the Business Partner and for a period of up to 7 years from the end of such relationship, with the following exceptions.
In the case of shareholders, for up to 13 years from the from the date that the shareholding of such shareholder becomes a nil share balance and no outstanding cash balance is held by the registrar in relation to such shareholder.
What rights do Business Partners have in relation to their personal data?
Business Partners have, in relation to their personal data, the following rights: right of access, right to rectification, restriction of processing, erasure (“right to be forgotten”), data portability, object to the processing, and their right not to be subject to an automated individual decision making.
These rights can be exercised by contacting Gamma using the contact details provided below.
Complaints can be raised with Gamma or with the Information Commissioners Office (ICO): www.ico.org.uk / 0303 123 1113.
Does Gamma use cookies in its website?
Gamma use cookies subject to the Gamma Cookie Policy available at gammagroup.co/cookie-policy/
How to contact Gamma?
Gamma’s Data Protection Officer can be reached using the following contact details:
Data Protection Officer, Gamma Telecom, Kings House, Kings Road West, Newbury RG14 5BY. DPO@gamma.co.uk.
“Gamma” means the Gamma Entity with whom the Business Partner has the relationship with.
“Gamma Entity” means Gamma Communications Plc, Gamma Telecom Holdings Limited, Gamma Telecom Limited, Gamma Network Solutions Limited or Gamma Business Communications Limited.
