Lyca Mobile Privacy Policy Content

Lyca Mobile respects your privacy and is committed to protecting your personal data. This privacy policy aims to inform you about:

• how we use your personal data you may provide us, while you enquire, purchase, or use any of our products or services including accessing contents of this website, signing up to our communications or taking part in our surveys or competitions.
• the legal principles and lawful basis in which we process your data and
• your rights regarding your personal data.

This privacy policy is provided in a layered format for your convenience of choosing the specific areas you are particularly interested in. Alternatively, you can find a summary here.

We, Lyca Mobile UK Limited, operate in the UK with our registered office at 3rd Floor, Walbrook Building, 195 Marsh Wall, London E14 9SG. We provide electronic communication services including national and international calls, texts, and data to customers. We are part of the Lyca group of companies with diverse business areas. When we say, “we”, “us” or “our” in this policy, we are referring to Lyca group of companies responsible for processing your data.

Personal Data is any information about you from which you can be identified. However, it does not include data where your identity has been removed (it’s called anonymised data).
We may collect, use, store and transfer different kinds of personal data which may be categorised as below:

• Identity Data include your full name, date of birth, gender, language.
• Contact Data include your correspondence address, email address, contact number.
• Financial Data include your bank account and payment card details (which you provide to purchase products from us and make a payment directly to us, such as on our website).
• Billing Data include your details about payments about the products and services you have purchased from us.
• Technical Data include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, and platform you use to access our website.
• Profile Data include your username and password, purchases made by you, your interests, and preferences.
• Usage Data include information about how you use our website, products and services, top up records, call data records which include traffic data and location data.
• Marketing and Communications Data includes your preferences in receiving marketing from us and other Lyca entities (as chosen and consented to) and your communication preferences.
• Customer Care Data includes your feedback to us, survey responses and voice mail recordings when you contact us.

We process your personal data to derive information so that we can make personalised offers to our customers. Such information does not directly or indirectly reveal your identity. However, if we combine or connect the derived information with your personal data, it may directly or indirectly identify you. So, we also treat the derived information as personal data which will be used in accordance with this privacy policy.

We obtain your personal data, directly and indirectly, when you:

• Interact with our independent distributors, wholesalers, and retailers.
• Interact with us when you provide your personal data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise.
• Purchase and use our products or services or enquire about them;
• Create an account on our website;
• Subscribe to our services or communications;
• Request marketing to be sent to you;
• Enter a competition, promotion, or survey; or
• Review our products and give feedback.
• Download our app.
• • Access our website, using cookies. Please see our Cookie Policy for further details.

To use the Services, you must first activate your SIM Card, and to ensure that the SIM Card is working properly, you must also make a call, send an SMS and/ or use the data services in your Home Country (which is identified by the country code of your mobile number). Please ensure you have sufficient credit on your Account prior to use.

We use your personal data complying to all data protection laws and regulations, most commonly, in circumstances where:

• we need to perform services under the agreed terms and conditions with you.
• it is necessary for our legitimate interests in course of our business.
• we need to comply with a legal or regulatory obligation.

We have set out below, a description of all the ways and the lawful basis we use your personal data. In addition to your consent, legal, and regulatory purposes, we have also listed our legitimate interests including performance management, product offerings, market research where applicable, which may override your rights subject to the law. Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

PURPOSEType of dataLawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity (b) Contact

Performance of terms and conditions with you and where applicable, as required by law

To supply products and services to you including: Managing payments Collecting money owed to us

(a) Identity (b) Contact (c) Financial (d) Billing

(a) Performance of terms and conditions with you (b) Necessary for our legitimate interests (to recover sums owed to us)

To manage our relationship with you and administer your account which will include: • Notifying you about changes to our terms and conditions or privacy policy • Detecting and preventing crime and fraud • Asking you to leave a review or take a survey • Manage any concerns that you raise to our customer care department • Quality assurance and monitoring purposes

(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Customer Care (f) Usage

(a) Performance of terms and conditions with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to participate in a competition or complete a survey (non-promotional)

(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications

(a) Performance of terms and conditions with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To market products and services to you To complete a survey (promotional)

(a) Identity (b) Contact (c) Marketing and Communications (d) Profile

(a) Legitimate interest to process marketing data (to grow our business) and consent for sending electronic marketing communications for new customers or reliance on existing customer relationship to send electronic marketing communications

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical (b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile

Necessary for our legitimate interests (to develop Lyca Mobile products/services and grow our business)

Marketing You will receive marketing communications from us either if you have consented to receive them or you have purchased products or services from Lyca Mobile, and in each case, you have not opted out of receiving that marketing. You will also receive marketing communications from other Lyca entities if you have consented to receive such communications on their Lyca products or services.

You can also Contact our Customer Services Department to let us know your marketing preferences and whether you’re happy to hear from us by email, text, or telephone.

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  • Call 322 from Lyca Mobile free of charges.
  • You can also dial 0207 132 0322 from another network or +44 207 132 0322 from abroad. Call charges may vary depending upon network operators.
  • o Alternatively, you can also email to [email protected]

We may have to share your personal data with the parties set out below for the purposes set out:

• Other Lyca group companies and associated enterprises who provide ancillary services such as IT Services, Customer Service support for the fulfilment of your orders and clarification of any of your queries.
• Other Lyca Group companies where you have chosen to receive marketing communications from them on Lyca products and services other than Lyca Mobile.
• External third parties who provide IT technical support services, data centre services and call centre support.
• Regulators and judicial authorities who require reporting of processing activities in certain circumstances.

In case we choose to sell, transfer or merge parts of our business, then the new owners may use your personal data in the same way as set out in this privacy policy. Where applicable, we require all external third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We transfer personal data to some of our service providers who are based outside the European Economic Area (EEA). Specifically, Lyca Mobile uses a technical services provider based in India and Customer Service providers based in Morocco and Philippines. This constitutes processing of your personal data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure that a high degree of protection is afforded to it by following various safeguard measures so that there is no detriment to you. We take steps to ensure your privacy rights are at least as compliant with the requirements of EU law, including requiring appropriate security measures from such third parties, set out in a contract between us, to protect your personal data. We use specific clauses, prescribed by Data Regulations including EU and UK GDPR, in the contracts with our service providers which give personal data the same protection it has in Europe.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those staff members or other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a strict duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority of a breach where we are legally required to do so.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal requirements. Details of retention periods for different aspects of your personal data are available in our Data Retention Policy which you can request from us by Contacting our Customer Services Department. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case, we may use this information indefinitely without further notice to you.

It should be noted that, for customers who apply for and avail themselves of post-paid services from Lycamobile, we process additional personal data. This includes checking credit records and credit scores of prospective customers to enable us to complete our contract with you. In order to process your application, we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace, and recover debts and prevent criminal activity. We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants, or other financial associates. In this connection, we may also perform checks for certain customers as and when it is necessary to protect our interests during the term of the contract. The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at www.experian.co.uk/crain

Subject to certain conditions under data protection laws where applicable, you have the following rights in relation to your personal data:

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  • Right to obtain information about your processed data and right to have access to your personal data.
  • Right to correct your personal data – This enables you to correct any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us.
  • Right to ask us to delete your personal data.
  • Right to object to the processing of your personal data.
  • Right to ask us to suspend the processing of your personal data.
  • Right to transfer your personal data -This enables you to ask us to transfer your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.

Note, however, that this right only applies to automated information for which you initially provided consent to be used to perform a contract with you.

• Right to revoke your consent to the processing of your personal data.
• Right to inform us of your wishes regarding the storage, deletion and communication of your personal data to a third party upon your death.

To exercise any of the rights set out above, please send your request to [email protected] and we shall respond, in accordance to the regulations, within the stipulated timeframe. You may also reach out to our Data Protection Officer if you have any issues in enforcing your rights at [email protected] or writing to the following address, Data Protection Officer, Lycamobile UK Limited, 2nd Floor, Walbrook Building, 195 Marsh Wall, E14 9SG London. Despite our best efforts, if any of your concerns remain unresolved, you may report them to, Information Commissioner’s Office Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF Telephone:0303 123 1113 Fax:01625 524510 https://ico.org.uk/global/contact-us/ We would, however, appreciate the chance to deal with your concerns first before you approach the supervisory authority, so please do contact us in the first instance. Cost for Data Access You are normally not required to pay any fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if we find your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information, if required, in relation to your request to expedite our response. Time limit to respond According to GDPR, all legitimate requests are required to be completed within one month, before which we shall complete the request. However, if your request is particularly complex or you have made several requests it may exceed the said period. In this case, we shall notify you and keep you updated.

You can reach out through our Customer Services Department on 0207 132 0322 from any Lyca Mobile Account or +44 207 132 0322 from another telephone. You may also e-mail the Customer Services Department at [email protected] or by completing the online enquiry form at https://www.lycamobile.co.uk/en/contact-us. For compliance, enforcement and questions in relation to this policy, we have a appointed a data protection officer (DPO) who may be reached at [email protected]. or writing to the following address: Data Protection Officer, Lycamobile UK Limited, 2nd Floor, Walbrook Building, 195 Marsh Wall, E14 9SG London. Changes to the policy We update our privacy policy, time to time, to reflect the changes in data protection laws. Historic versions are archived here

Our website, app and services are not aimed at children. We do not target, intend to collect, or knowingly collect or otherwise process information from any Child. If you are under the age of 13, we request that you do not provide us with your information and do not use our website and app. If you are a parent or guardian of a child under 13, please contact us if you are aware that your child has used our website or app or otherwise provided their information to us without your consent. We shall delete or otherwise cease processing your child’s personal information within a reasonable time to make sure that we do not contact you in the future.