Ymobile – App Privacy Notice
Notice version: 24th September 2024
Introduction:
Ymobile (the app) is provided by Y Corporation Limited (Ycorp), a company registered in England and Wales with company registration number 14232896 and registered address at 1st Floor, Unit 27 Tileyard Road, London, N7 9AH (‘we’, ‘our’ or ‘us’), to enable you to use our eSIM and associated mobile service plans. For more information on who we are and what we do, go to www.ymobile.co.uk
Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your information).
It also explains your rights in relation to your information and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your information is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
We are the controller of your information obtained via the app, or our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
The app is designed for and intended for those aged 18 and over only. If you are under the age of 18 you must not use the app. If you are aware that any information of anyone under the age of 18 has been shared with the app, please let us know so that we decide whether delete it.
The app is distributed only on UK app stores and is solely intended for use by people in the UK, unless you chose to activate our roaming services.
This privacy notice is divided into the following sections:
- What this policy applies to
- Information we collect about you
- Location services/data
- How your information is collected
- How and why we use your information
- Marketing
- Who we share your information with
- How long your information will be kept
- Transferring your information out of the UK
- Your rights
- Keeping your information secure
- How to complain
- Changes to this privacy notice
- How to contact us
1. What this policy applies to
This privacy notice relates to your use of the Ymobile app only.
The app links to services owned and operated by certain third parties to make additional products, information and services available to you. These other services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other services, please consult their privacy policies as appropriate.
2. Information we collect about you
The information we collect about you depends on the particular activities carried out through the app. We will collect and use the following information about you:
General category of data
In more detail
Retention Period
Identity information
This is information relating to your identity such as your name and date of birth.
7 years from the end of the accounting period to which the information relates.
Contact information
This is information relating to your contact details such as your address, email address and telephone number.
7 years from the end of the accounting period to which the information relates.
Payment information
This is information relating to the methods by which you provide payment to us such as bank account details, credit or debit card details and details of any payments (including the amounts and dates) that are made between us.
7 years from the end of the accounting period to which the information relates.
Transaction information
This is information relating to transactions between us such as details of the goods, services and/or digital content provided to you and any returns details, as well as billing and payments data.
7 years from the end of the accounting period to which the information relates.
Consumption data
This is information relating to your consumption of data,
7 years from the end of the accounting period to which the information relates
Website, Device and Technical information
This is information about your use of our app and technical data which we collect which may include eSIM data, app data, mobile network information, behavioural data and other information we receive about your device.
Up to one year from your last interaction, after which your personal information will be removed.
Special category information
Whilst we do not purposefully collect special category information, in our capacity as data controller we may encounter data associated with children or other vulnerable groups. Any special category data collected will be minimal and/or a byproduct of fulfilling our obligations. Where this happens, we do not possess the ability to identify individuals as belonging to any of these groups.
Depends on the category the data belongs to
Customer contact history
This is information relating to your contact with us, for example to provide feedback or make a complaint
1 year from the end of the accounting period to which the information relates
Location data
This is information relating to your use of a roaming pass to ensure you are not exceeding the terms of the pass, are maintaining a prevailing presence within the UK and to ensure that you are on the correct price tariff
1 years from the end of the accounting period to which the information relates
You must provide this information to use the app and its services.
We collect and use your information for the purposes described in the section ‘How and why we use your information’ below.
3. Location services/data
The app requires your device location to ensure you are in accordance with our Fair Usage terms when using a roaming pass and to ensure you are on the correct price tariff. We will not process your location data other than as strictly required to ensure you are on the correct tariff and roaming in accordance with the requirement to maintain a prevailing presence in the UK and within the confines of the pass.
The location services in the app will not operate unless location services/data are generally enabled on your device. You may disable such functionality at any time by going to your device settings but this may affect your ability to use your roaming pass.
4. How your information is collected
We collect information from you directly when you engage with our website, for example to browse available dataplans, or access our FAQs, or when you access and interact with the applicable app store (iOS or Android) to download the Ymobile app, and when engaging with the app to register for and activate an account with us or indirectly, such as your activity while using the app.
We may also collect information about you from third parties, such as those who are required to support our systems, provide you with accurate invoices and process payments and manage customer relationships. Further information on this can be found in the table below in ‘How we use your information and why’.
5. How your information is collected
Under data protection law, we can only use your information if we have a proper reason, e.g.;
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;
- for the performance of a contract with you or to take steps at your request before entering into a contract, or;
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use your information for and why.
What we use your personal data for
Our reasons
Providing products and/or services to you
To perform our contract with you or to take steps at your request before entering into a contract
Website and operational improvements
For our legitimate interests, for example to monitor website performance to improve Ymobile’s ability to provide a better customer experience
Website and operational improvements
For our legitimate interests, for example to monitor website performance to improve Ymobile’s ability to provide a better customer experience
To provide you with information regarding the services we provide to you
For our legitimate interests or to perform our contract with you, for example to provide you with updates that may impact how you engage with Ymobile
To provide you recommendations and communications to you about things we think you may be interested in
Your consent, which you can update at any time
Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us
To comply with our legal and regulatory obligations;
To enforce Ymobile’s legal rights and comply with legal and regulatory obligations
Depending on the circumstances:
—to comply with our legal and regulatory obligations;
Or
—in other cases, for our legitimate interests, i.e. to protect our business, interests and rights.
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency
In such cases information will be anonymised where possible and only shared where necessary
Depending on the circumstances:
—to comply with our legal and regulatory obligations
Or
—in other cases, for our legitimate interests, for example to protect, realise or grow the value in our business and assets
Who we share your information with
We may need to share your personal information with third parties that we use to help us deliver our products and/or services to you, for example payment service providers, mobile network operators or Customer Relationship Management systems. These third parties may also include website hosts or website analytics providers that we use to help us run our business. Further information on these third parties and our reasons for using them are included in the table below:
Third party
Our reasons
Business Support Systems
To manage your Ymobile app, account and billing
Operational Support Systems
To ensure connectivity can be established on your device with your purchased Ymobile plan
Customer Relationship Management systems
To manage your enquiries, complaints or our communications with you
Mobile Network Operators
To ensure Ymobile can accurately invoice you for usage related charges
eSIM provision partners
To ensure connectivity can be established on your device with your purchased Ymobile plan
We only allow the organisations referred to above to handle your information if we are satisfied they take appropriate measures to protect your information. We also impose contractual obligations on service providers to ensure they can only use your information to provide services to us and to you.
We may occasionally need to also share personal data with:
- our professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations and/or any personal information will be anonymised or statistical in nature;
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations; or
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations
6. How long your information will be kept
Different retention periods apply for different types of your information. Further details on this are included in the “Information we collect about you” section above.
Following the end of the of the relevant retention period, we will delete or anonymise your information.
7. Transferring your information out of the UK
We may transfer your personal data to third parties that carry out certain actions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law. Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it, which we will achieve by using the most appropriate data transfer mechanisms to transfer your personal data.
8. Your rights
You generally have the following rights, which you can usually exercise free of charge:
Access to a copy of your information
The right to be provided with a copy of your information
A more detailed explanation of this right is available here
Correction (also known as rectification)
The right to require us to correct any mistakes in your information
A more detailed explanation of this right is available here
Erasure (also known as the right to be forgotten)
The right to require us to delete your information—in certain situations.
If you wish Ymobile to delete your account and any associated data, you can do so by emailing us on support@ymobile.co.uk, or by using the Support section in your app. You can find further information, and the step-by-step process to follow here
A more detailed explanation of this right is available here
Restriction of use
The right to require us to restrict use of your information in certain circumstances, e.g. if you contest the accuracy of the data
A more detailed explanation of this right is available here
Data portability
The right to receive your information that you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
A more detailed explanation of this right is available here
To object to use
The right to object:
—at any time to your information being used for direct marketing (including profiling)
—in certain other situations to our continued use of your information, e.g. where we use your information for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
A more detailed explanation of this right is available here
Not to be subject to decisions without human involvement
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
We do not make any such decisions based on data collected by the app
A more detailed explanation of this right is available here
The right to withdraw consents
If you have provided us with a consent to use your information, you have a right to withdraw that consent easily at any time
You may withdraw consents by emailing, calling or writing to us using the details in the “How to contact us” section below.
Withdrawing a consent will not affect the lawfulness of our use of your information in reliance on that consent before it was withdrawn
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of these rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:
- provide enough information to identify yourself, e.g. your full name, address and customer or matter reference number, and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates.
9. Keeping your information secure
We have appropriate security measures to prevent your information from being accidentally lost, or used or accessed unlawfully. We limit access to your information to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
10. How to complain
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner.
The Information Commissioner can be contacted using the details at https://ico.org.uk/make-a-complaint/ or telephone: 0303 123 1113.
11. Changes to this privacy notice
We may change this privacy notice from time to time. When we make significant changes we will take steps to inform you, for example via the app or by other means,
such as email.
12. How to contact us
You can contact us by post, email or telephone if you have any questions about this privacy notice or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are:
By post: 1st Floor, Unit 27 Tileyard Road, London, N7 9AH
By phone: 0800 208 8487
By email: privacy@ymobile.co.uk
