Privacy Policy
Cubic Telecom Limited (hereinafter referred to as "Cubic", "us", "we" or "our") is committed to respecting your privacy and to complying with all applicable data protection and privacy laws.
Increasing innovation and development in mobile telecommunications means that our relationship with our customers is growing closer. We acknowledge that our customers like to be briefed on what we do with their personal data. Therefore, the objective of this policy is to inform you how we handle your personal data.
Cubic Telecom offers a wide range of product and services based on modern technologies including mobile telecommunications and internet (related) services. This policy applies to all personal data ("Data") in our possession and specifically includes the following: call traffic details, service usage data (e.g. E-Mail/Internet use) and customer information (including name, address, fixed line number, mobile number, email address and all other contact details).
Acquisition
1. All Data will be obtained fairly. We will make you aware of all purposes that we intend to use your Data for at the time of collection or will be advised to you prior to use.
2. Data will be accurate and complete and, where necessary, kept up to date.
3. Data will be adequate, relevant and not excessive in relation to the purposes for which it was obtained.
4. All acquisition methods (e.g. customer application forms, competition entries) will have a clear information piece explaining any intended purposes, including secondary uses that may not be obvious to you (e.g. if competition entries are intended to be used for marketing purposes, this will be clearly advised to you and an appropriate opt out box will be provided).
Use and Disclosure of Information
5. Data will be kept only for clear and legal purposes.
6. All Data will be processed fairly and in keeping with the purposes for which it was obtained.
7. Data will not be used, disclosed or processed in any manner incompatible with the purposes for which it was obtained.
8. Disclosure of Data will only be made to third parties who are our agents or servants acting on our directions. Save as required by law (e.g. criminal investigations), no disclosure of Data will be made to third parties for those third parties' own purposes or use.
9. Under no circumstances will lists of customer data/information (i.e. mailing lists or database information) be disclosed to a third party for that third party's exploitation or use without your express permission. Data may be legitimately given to Cubic Telecom's servants or agents for legitimate purposes as described above. This may include the transfer of data to other jurisdictions for processing. In these circumstances, we will ensure that adequate contractual and technical safeguards are in place to protect your Data. All such processing will take place in full compliance with all applicable laws.
10. If Data has been obtained for a purpose without advising you of other compatible secondary purposes for which it is subsequently to be used, the Data will not be so used without advising you.
Retention
11. Data will be kept for no longer than is necessary for the primary purpose for which it was obtained.
12. Data will be retained for any period required by law.
13. Some Data that is not otherwise subject to retention for normal reasons may need to be retained because of circumstances such as litigation or government investigation.
14. Subject to paragraphs 13 and 14, the following specific retention periods will be followed:
| Type of Record or Information |
Retention Period |
|---|---|
| Call Traffic Details (actual record of call, i.e. time of call, caller, number called, duration of call, etc) | 6 months plus current month (max.) for our purposes (as described above and in our general terms and conditions e.g. market research, product development). |
| Interconnect call records (i.e. the records of calls made to or received from other networks) are retained for 12 months for inter-operator billing purposes. | |
| For legal purposes, call traffic records will be retained for a period of 3 years to comply with State requirements. This retention will take place in a restricted access secure system and will not be used for Cubic Telecom's commercial purposes. | |
| Data Service Usage Details (WAP site visits, web site visits, live! Use, text alert subscriptions) | 6 months plus current month (max.) for our purposes (as described above and in our general terms and conditions). This data does not include content. |
| For legal purposes usage records will be retained for a period of 3 years to comply with State requirements. This retention will take place in a restricted access secure system and will not be used for Cubic Telecom's commercial purposes. | |
| Cookies | Cookies are stored on a per session basis only to aid your navigation of our websites. Persistent cookies may be set to store display related preferences. Depending on your browser, you may also be able to control cookie use by altering your browser settings. |
| Invoices & Statements | 6 years plus current year for invoices and statements. |
| The call detail element of your standard bill will be severed and deleted after 6 months, as described above. | |
| Location Based Information for value added services (excluding network traffic data) | Deleted immediately on completion/ termination of the value added service. |
Cookies
15. We will make limited use of cookies for certain online services where your account details are accessible. For security purposes, cookies are used to maintain current session details (e.g. user name, site preferences). These cookies reside in the temporary Internet file of your PC and are set to expire 30 minutes after your last action or when you elect to log off. Cookies with longer expiry dates may occasionally be used to store your display preferences. These cookies do not contain any user-specific details (such as user names or passwords).
16. Depending on the type of browser you are using, you may be able to configure your browser so that: (i) you are prompted to accept or reject cookies on an individual basis or (ii) to prevent your browser from accepting any cookies at all. You should refer to the supplier or manufacturer of the web browser for specific details about cookie security.
Access to your Information
17. You are entitled to copies of your Data kept by us. Requests should be in writing* and should be addressed to: Office of Customer and Channel Management, Cubic Telecom, Unit 6 Oak Court Road, Western Business Park, Dublin 12. Please quote your name, address and your mobile and/or account number. We will take all reasonable steps to confirm your identity before issuing any copy Data.
Information Security
18. Cubic Telecom is constantly reviewing and enhancing its technical, physical and managerial procedures and rules to protect your personal data from unauthorised access, accidental loss and/or destruction. We use industry standard secure sockets layer (SSL) technology, for example, to encrypt sensitive information such as your credit card and other financial information.
19. Please be aware that communications over the Internet, such as emails/webmails, 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. Cubic Telecom cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
20. It may be necessary to transfer your personal information to other group companies or service providers located in countries outside of the European Economic Area (EEA)**. This may happen where our servers or suppliers and service providers are based outside of the EEA or where you use our services and products while visiting countries outside of the EEA. The data protection and other laws of these countries may not be as comprehensive as those in Ireland or the EU - in these instances, we will take steps to ensure that your privacy rights are respected.
General
21. If you have any query about Cubic Telecom's data protection policy or practices, please write to: Data Protection Officer, Cubic Telecom, Unit 6 Oak Court Road, Western Business Park, Dublin 12 or send an email to dataprotection@cubictelecom.com
22. This policy should be read in conjunction with the general terms and conditions of this website and the general terms and conditions that apply to your use of Cubic Telecom's mobile telephony services, where more details of the use we make of your data is outlined.
23. We reserve the right to amend or modify this Data Protection Policy at any time, in response to changes in applicable data protection and privacy legislation.
* We may charge a small fee to cover the administration costs. This fee is set by the Data Protection Commissioner from time to time.
** The European Economic Area (EEA) currently comprises the Member states of the European Union plus Norway, Iceland and Liechtenstein.
