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Privacy Policy


The website, mobile phone application and the Service (“Service”) are provided by ORANGE PERSONAL COMMUNICATION SERVICES LIMITED (“ORANGE”, “we”, “us” “our”). The collection of data, Personal and Aggregated, is carried out on behalf of ORANGE by Icom Limited a Company registered in England and Wales registered number 05185819 (“SUPPLIER”). Icom is the provider of the patented technology that underpins the Service. For the purposes of the Data Protection Act 1998 Icom is the designated Data Controller for the Service.

What is the purpose of our Privacy Policy?
In conjunction with our trusted service provider Icom, We provide a unique and innovative mobile phone application Service. In order to provide and power the Service, we require certain information to be disclosed. The Service also records and processes the user’s interaction and further disclosed data, to provide the user with a personalised service.

When you enter your details request the Service, whether from the internet or SMS Shortcode (64446), you enable ORANGE and its service providers to deliver the services you have requested. In order to deliver the Service we need to store and use your MSISDN which is your mobile phone number. When you connect with our server to download the Service or for further updates we will identify your mobile phone make, model, network provider and whether you are on a pre or post pay contract (“Phone Information”). The Phone Information will be stored for as long as is necessary to provide an optimised mobile experience. When using your Phone Information ORANGE will act in accordance with current legislation and aim to meet current industry best practice

This Privacy Policy explains how we use and protect your Personal Information.

Usage Information
Our definition of Phone Information does not include “Usage Information”, this is data which we collect about your use of the service, this includes which aspects of the Service you used and when you used them. We collect this Usage information to help us identify areas of improvement or to fix any bugs with the Service. Usage Information related to an individual MSISDN is only held by us for as long as we need it to provide the Service. After such time the Usage Information is aggregated for general research analytics but at this stage is not associated to any specific MSISDN (“Aggregate Information”).

By accepting the Terms and Conditions and this Privacy Policy you agree and understand that ORANGE may use and share Aggregate Information with a 3rd party for any reason whatsoever.

Disclosure of Personal Information
ORANGE does NOT sell Personal Information to third parties.

ORANGE will only use your Information:
  • With your consent
    We will only disclose information where you have shown an express intent to disclose an item of your Information, expressed either through email, clicking in/on a request button or some other verifiable means of interaction with the Service.

  • Transactional Processing
    We will only use or disclose your Information in transactions to verify, validate and execute such transaction, with either an ORANGE company or a partner organisation.

    When and if we disclose Information to third parties for transactional processing purposes, we strictly limit the third party to using your Information for the execution of that specific transaction only. The transactional processing may take place in the UK, another EU country or in a country outside the EU.

  • Business Transfers
    Although it is not foreseen, a business can often go through a merger and/or acquisition at some point in its trading life. Similarly, a business may also go through Insolvency, Bankruptcy or Receivership. ORANGE reserves the right to transfer Information as one of the business assets in any such situation or transfer.

  • Legally Justified Reasons
    ORANGE may release Information and any other information when release is required to comply with the law or bona fide judgment. This may include, but is not limited to, a lawful order of disclosure, protection of our or our partner organisations’ Intellectual Property Rights, to protect from fraud, abuse, misleading information, slander, inflammatory remarks or incitement of illegal acts, racism and/or obscenity.

  • By Way of Protection
    ORANGE will also use your Information to protect other users and our partner organisations when enforcing customer agreements.

  • Risk of Harm
    At ORANGE we strive to protect both our user’s Information and our user’s general well being. If we detect anything which may cause harm or death to any of our users, we may disclose your Information to the appropriate professional body or authority in an attempt to prevent the foreseen harm or death.
  • How is my Personal Information Secure?
    From the start of your relationship with our Service, the security of your Information is our utmost concern. Our business is built around integrity and quality of service.

    All Information taken from your interaction with our Service is subject to rigorous, electronic and procedural safeguards to meet and exceed industry standards. For example, we use HTTP and SSL (Secure Socket Layer) transport mechanism which encrypts all Personal Information you input into our Service or communicate out from our Service.

    We must point out that we cannot, and do not, guarantee the security of information on other sites on the mobile internet or world wide web.

    When using your Information internally, We strictly limit the amount and type of information to those employees who need to know those items of Information in order to provide only the relevant products or services to you. We will ensure that all personal information supplied is held securely, in accordance with the Data Protection Act 1998.

    How can you help us to help you?
    As we have explained, ORANGE takes the security of your Information extremely seriously. However, in order for the protection to be maintained, we insist that you use your best efforts to protect your wireless access and your mobile phone access.

    Always keep your mobile phone handset with you and we recommend using a security feature such as PIN locking your handset when not in use.

    Access to your Personal Information
    You have the right to request a copy of the Personal Information that We hold about you and to have any inaccuracies corrected (we charge £5 for information requests.) Please address requests to the Data Protection Officer at info@icomgroup.net

    PLEASE NOTE: SUPPLIER is a Company registered in England and Wales and, as such, any information or data (including Personal Information) stored by the Service will be stored in England.

    Dispute Policy
    Any dispute relating to this Privacy Policy or its application is subject to the provisions contained in the Terms and Conditions, including limitations on damages and arbitration of disputes.

    Updating our Policies
    Due to the ever changing nature of the computer industry and the World Wide Web, it is likely that this Privacy Policy will be updated from time to time, to keep up with technology, product and service improvements. As such, you should refer to this page, by using the link provided at the foot of each page throughout this site, to check for such updates.

    Termination
    You can terminate your registration and access to the Service at any time by emailing info@icomgroup.net

    It is a legal requirement that we keep some information after you have terminated your registration so that we are able to identify you as an ex-user. This information is kept to the absolute minimum required by Law.


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