PRIVACY POLICY

This Privacy Policy applies to your use of JustSims products and services.

1.Definitions:
“We”, “Us” or “Just Sims”, a company registered in Waltham Cross with registered number 10002684 and with its registered office situated at JustSim House, 122 High Street, Waltham Cross, EN8 7BX England

1 How We Collect Information about You:
1.1 We collect information directly from you when you are asked to provide personal details about yourself, including but not limited to when you:
i) Purchase products or services from us whether in store, online, by phone or elsewhere;
ii) Register to become a JustSims customer;
iii) Submit enquiries to us or contact us;
iv) Enter any promotions, competitions or prize draws;
v) Use JustSims products and services;
vi) Take part in market research; and/or
vii) When you terminate your account with us

Viii) We do not store credit card details nor do we share financial details with any 3rd parties

1.2 We collect information indirectly from you when:
i) You choose to register with us and use our service, visit or browse this site or use our networks
ii) Visit or browse this site or other JustSims websites;
iii) Browse or otherwise access the Internet, WAP sites and/or the JustSims internet via the services; or
iv) Use our networks

1.3 We collect information about you from other sources, including but not limited to credit reference agencies, fraud prevention agencies; and business directories and other commercially or publicly available sources.

2 The Type of Information We Would Collect:
2.1 We collect such information as:
i) Your name;
ii) Billing address;
iii) Delivery address;
iv) Telephone number; Email
v) Your use of products and services including but not limited to phone numbers and/or email addresses of calls, texts, MMS, emails and other communications made and received by you and the date, duration, time and cost of such communications, your searching, browsing history (including web sites you visit) and location data, address location for billing, delivery, installation or as provided by individual, phone location;
vi) How you conduct and manage your account(s) with us;
vii) Debit or credit card details, banking details and other payment information;
3 How We use your information
3.1 We may use and analyse information about you in order to:
i) Provide you with access to parts of this site;
ii) Process your order;
iii) Supply services and products that you have ordered;
iv) Contact you if necessary;
v) Verify that you are an authorised user for security purposes;
vi) Arrange for payment of goods or services purchased;
vii) Inform you of any service related message or of any new services or functionality (e.g. the introduction of a new messaging service);
viii) Assist us with crime and fraud prevention such as to check your identity;
ix) Assist you with any product or services enquiries, including the investigation and resolution of service affecting issues and dealing with any billing queries you may have;
x) Investigate any complaints or other enquiries that you submit to us;
xi) Enhance and personalise the products and services that we offer you and to develop new products and services;
xii) Analyse markets and produce reports, perform research and statistical analysis and to monitor usage behaviour (including when you are no longer a JustSims customer);
xiii) Market our products and services generally
xiv) Send information to you about our products and services from time to time by phone, post, email, text, MMS, automated dialling equipment or other means (subject to any objection or preference you may indicate when submitting your details to us);
xv) Inform you of any products and services offered by other companies that we think may be of interest to you, provided that you choose to receive this information;
xvi) Disclose your personal information or usage of our services to certain third parties. Please see Section 4 below;
xvii) Assess applications for and make decisions about credit, credit-related services from you and members of your household;
xviii) Debt tracing, debt recovery, credit management and crime, fraud and money laundering detection and prevention; and
xix) Aggregate information about you, your spending and your use of the services with information about other users of the services in order to identify trends (“Aggregated Data”). We may pass Aggregated Data to third parties, such as advertisers, content providers and business partners or prospective business partners, to give them a better understanding of our business and to bring you a better service. Aggregated Data will not contain information from which you may be personally identified.
xx) Analyse information about you including your calling, searching, browsing and location data on a personalised or aggregated basis. We may pass this data to the third parties and we may use this information to provide you with targeted JustSims or third party offers, promotions, adverts or commercial communications.
4 Disclosure of your Information
4.1 We may disclose your information:
i) To our partners, agents and subcontractors (including prospective partners, agents and subcontractors) who are involved in the delivery of providing products or services used or ordered by you;
ii) To credit reference agencies and fraud prevention agencies;
iii) To other communications companies;
iv) To any relevant public authority or law enforcement agency;
v) To third parties for checking details of job applicants and employees;
vi) To third parties from whom you have chosen to receive marketing information.
vii) Where there is a change (or prospective change) in the ownership of JustSims, to new or prospective owners of JustSims. In these circumstances we would require them to keep it confidential.
viii) Where required by law, regulation or legal proceedings;
ix) Where we believe it is necessary to protect JustSims or third party rights and property; or
x) Where you give us false or inaccurate information and we identify or suspect fraud.
xi) Where we, or an affiliate processing your data on our behalf, are compelled to do so by law;
xii) In response to a valid, legally compliant request by a competent authority;
xii) During emergencies when we believe physical safety is at risk;
xiv) Where the service is moderated; or
xv) In response to a complaint that that there has been a breach of the services terms & conditions or any other product or service terms of which you have been notified.
4.2 Additional terms and conditions may be presented when signing up for specific products and services.
5 Security Matters
5.1 We recognise that you may be concerned about how we would protect your personal information from misuse and abuse. JustSims is constantly reviewing and enhancing our technical, physical and managerial procedures and rules to protect your personal data from unauthorised access, accidental loss and/or destruction.
5.2 Where we have contracted with a third party to provide some part of a service that you have requested, we will ensure that those agents, by written agreement, are required to implement similar security measures and will process your information only as authorised by JustSims to fulfil the service that they have been contracted to provide on our behalf. Those third parties will not be entitled to use your personal data for their own purposes.
5.3 Please be aware that communications over the Internet, such as emails/web mails, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered – this is the nature of the World Wide Web/Internet. JustSims cannot accept responsibility for any unauthorised access or loss of personal information.
6 Retention of Information
6.1 We retain information only for as long as we need it. In relation to the following information we are required to retain it for not less than six months and not more than two years in order to ensure that this information is available for the purpose of the investigation, detection and prosecution of serious crime:
i) User ID and telephone number allocated to any communication entering the public telephone network;
ii) Name and address of subscriber to whom an Internet Protocol (IP) address, user ID or telephone number was allocated at the time of a communication;
iii) User ID or telephone number of the recipient of an Internet telephony call;
iv) Name and address of subscriber and user ID of the intended recipient of a communication;
v) Date and time of log-in and log-off of our Internet access service, IP address and user ID of the subscriber;
vi) Internet service used;
vii) Calling telephone number for dial-up Internet access of the originator of a communication; and
viii) Digital Subscriber Line (DSL) or other end point of the originator of a communication.
7 Accessing your Information
7.1 If you are a JustSims Registered Customer, you may verify, update or amend the personal information you have provided to JustSims online at any time through your account on our web site. The ‘opt-in’ on the website allows you to select whether you receive marketing information from JustSims only, or from our business partners. You can opt-out of either or both at any time.
7.2 We can supply certain types of personal information on request: including but not limited to billing, name and address, aggregated phone usage. Requests should be made in writing and include your name, JustSims telephone number and proof of your identity (such as a photocopy of your passport, birth certificate or driving licence) and address (for example, a copy of a utility bill or bank statement), and the information you require. We’ll charge you £10 to cover the administrative cost of supplying the requested information. If we hold any inaccurate information about you, please tell us and we will correct it.
Our address is:
Data Controller
JustSims
JustSim House, 122 High Street, Waltham Cross, EN8 7BX England
8 Changes to this Policy
We will keep this policy under review and any changes made from time to time will be posted on this page.
9 Security and Protection of Customer Information
9.1 Security
i) Passwords
You must not share your password for any message services or portal access. Your passwords and the answers to secret questions are your responsibility, and must not be disclosed to any third party. This is also important for your own protection.
ii) Data Security Procedures
We are constantly reviewing our procedures to protect your personal data from unauthorised access, accidental loss and/or destruction.
We may employ third parties to provide services on our behalf. In such cases, if they collect any data on their own behalf it will be covered by this policy unless they inform you that they provide their own privacy policy. We do endeavour to ensure that any partners we use apply the same high standards of privacy and security over your information. However, we advise you to read their policy carefully.

We do not store credit card details nor do we share financial details with any 3rd parties
iii) Security of Communications
Please be aware that communications over the Internet, such as e-mails and Webmail’s, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered – this is the nature of the World Wide Web/Internet. JustSims cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
iv) Media Messaging
Any Media Messages you send to an email address, including Media Messages from your phone and messages may include personal details such as your registered first name and last name, your phone number or email address which will be displayed in the ‘from’ field of the message.
9.2 Non-EEA Use of Information
The information you provide to us may be passed to third parties located outside the European Economic Area. Countries outside the European Economic Area do not always have strong data protection laws. However we will always take steps to ensure that your information is used by third parties in accordance with this policy.
Additional terms and conditions may be presented when signing up for specific products and services.
9.3 Marketing Information from Third Parties
If you choose to receive marketing information from other companies, we will only disclose your personal information to these companies where they have undertaken not to use your personal information for any purpose other than to provide information to you or other uses to which you have agreed. If you decide that you no longer want to receive information from a particular company, you should contact that company directly. You should be aware that if you subsequently give any personal information to another company, the uses to which that information may be put will be determined by that company’s privacy policy.