A little background

Telcom Group Ltd (trading as “Elevate”) is committed to protecting our customer privacy and takes its responsibility regarding the security of customer information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information.

In here we will outline the following things:

What personal data we collect and use about you in connection with your relationship with us as a customer, and through your use of our website and online services;
Where we obtain data about you from;
What we do with that data;
How we store the data;
Who we transfer/disclose that data to;
What your data protection rights are and how to exercise them;
And how we comply with the data protection rules.

The ‘Data Controller’ (us)

Elevate is the ‘Data Controller’ of the personal data we use about you to deliver that service or task to you. There may be situations where we use third parties to help us with these services, and we have outlined some of them below.

As the entity responsible for the care of your data, you can reach us via any of our contact details or you can contact our Data Protection Officer (DPO) via dpo@elevate.uk. Our registered offices are at NorthStar, 135-141 Oldham Street, Manchester, M4 1LN.

What personal data we collect

Personal data means any information relating to you which allows us to identify you, such as your name, contact details, reference number, payment details and information about your access to our website.

We will collect personal data from you when you contact us or make a purchase for one of our services with us (either directly or indirectly through our trusted third-party partners) or when you contact us.

Specifically, we will collect the following categories of information depending on what service or interaction you are having with us:

Name, job title, billing address, work address, e-mail address, telephone number, credit/debit card or other payment details;
Information about service requirements you may have from us in order to quote for, deliver and operate those services
Information about services you have with us and the property in which those services are provided (including any contact information provided)
Information about your company, its size and relevant product or technology requirements
Information about your support queries;
Information about your use of our website and customer portal;
The communications you exchange with us or direct to us via letters, emails, chat service, calls, and social media.
Contractual history – this includes details about service you have purchased from us

We do not collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

How we collect your data

We use different methods to collect data from and about you including through:

Direct interactions
We collect your personal data when you fill in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

Purchase services from us
Subscribe to our mailing list
Request marketing to be sent to you
Contact us when you have any enquiries about our services
Providing feedback

Indirect interactions
We may get your data from third parties like Google, Cognism etc that we use for marketing purposes. This helps us target marketing better and will be from trusted, verified sources only.

How, why & for how long we use your data

Outlined below is how, why, and for how long we use your data. This can range from it being necessary to deliver the contracted services we have with you, or even necessary to meet a legal obligation, right the way through to using data with your consent for things like survey feedback. We only keep your data while it is necessary to perform that task or meet our obligations. Once it is no longer necessary, it is securely deleted.

Our purpose	The ‘lawful basis’ for doing so	How long we keep it
Setting up and providing your account. Providing products and services you request and to process your order and manage your account	Necessary for the provision of our contracted services with you.	Duration of your account + 7 years
Service communications. If we send you communications about the services, you have asked for, and any changes to such services. These communications are not made for marketing purposes	Necessary for the provision of our contracted services with you.	Duration of your account + 1 year
Credit or other payment card verification/screening. We use your payment information for accounting, billing and audit purposes and to detect or prevent fraudulent activities	Necessary for the provision of our contracted services with you & in our legitimate interests to help prevent and protect you from fraud.	Duration of your account + 7 years
Customer Services communications. We use your data to manage our relationship with you and resolve any issues.	Depending on the nature of the issue, this will either be necessary to manage the contracted services we have with you, legally required when we are dealing with a statutory right or complaint, or in our own legitimate interests to resolve the matter for you.	Duration of your account + 1 year
Call recordings. Where some customer services calls are recorded we use these recordings to improve the services and resolve any issues raised.	It is in our legitimate interests to do so in order to monitor our services and investigate any issues raised.	30 calendar days from date of recording
Service improvement. We use your data in relation to how we have supported you in order to improve that support, assist in the development of new services and train our staff. We anonymise this wherever possible.	It is in our legitimate interests to do so in order to learn from and improve upon our services for you.	Only until it is anonymised.
Feedback and surveys. We use your data to contact you to obtain feedback on our services and interactions. Responses will be anonymous unless you choose to provide contact information to resolve a specific matter.	It is in our legitimate interests to contact you to obtain feedback. We only use your data in that feedback where you provide personal data and with your consent.	Only for the duration of the survey or to respond to the requested action.
Sending you marketing. From time to time, we will contact you with information regarding promotions and ancillary products via e-communications. You will have the choice to opt in or opt out of receiving such communications by indicating your choice at this stage. You will also be given the opportunity on every e-communication that we send you to indicate that you no longer wish to receive our direct marketing material.	As a business customer it is in our legitimate interests to contact you about how we can help.	As long as you are a subscriber. Once you have unsubscribed your data will be deleted immediately, to a maximum of within 30 calendar days.
Provide tailored services. As part of our marketing campaigns, we use your data to provide information we believe is of interest to you, to personalise the services we offer to you, such as special offers we have.	Where you are a business customer, it is in our legitimate interests to use your data to ensure that the messages you get match your needs and that we don’t message you in our outreach programmes so we use your data to screen against any campaigns.	As long as you are a subscriber. Once you have unsubscribed your data will be deleted immediately, to a maximum of within 30 calendar days.
Tax & accounting purposes. We will keep minimal details for a limited time relating to tax and other payments on your account in order to meet our financial obligations.	This is to meet our legal obligations around UK tax and financial accounting.	Duration of your account + 7 years

Profiling and automated (AI based) decision making with your data

We do not perform any profiling based on personal data that has a legal or otherwise significant effect. We do not make any decisions about you, using automated means (AI) and we do not envisage this changing in the near future. If the situation does change, we will notify you in writing before doing so.

Marketing and preferences over your data

We only send marketing on a Business to Business (B2B) basis. Therefore we send marketing materials under our own legitimate interests and offer an opt out to you via various methods. You can opt-out from email messages by clicking on the ‘unsubscribe’ link that appears in all emails we send. If you don’t want to receive texts from us, you can tell us by contacting us at any time or replying to the number provided. Otherwise, you can always contact us directly at any time to update your contact preferences.

We also use some of your basic contact details to use services like Google Ads to validate paid ads, retargeting website visitors, and audience matching (profiling current customers to target new prospects). Wherever possible this data is anonymised and companies like Google, will also offer an opt-out which our activities are screened against.

If you have any questions or concerns about your use of data for this purpose, please get in touch directly and we’ll be happy to help.

Use of our website

In order to improve our website (elevate.uk) and the services available through it, we use various cookies and similar technologies to do so. You can accept or reject these cookies from any page of the website by responding to the banner in the first instance or clicking on the cookie icon in the bottom of your page.

The full list of cookies is outlined in the cookie pop-up at the bottom of your webpage (except this one, as it is separate). As a summary, we use strictly necessary, functional, analytical and marketing based cookies. Most cookies are ‘ours’ and remain on our site and systems, some are provided and hosted by third parties (like Google). Which ones are which are also outlined in the cookie banner.

In our efforts to respect our website visitors' online privacy as much as we can, we also run another type of ‘cookie’ offered by plausible. This is a privacy friendly product that anonymises all of your data at the point of collection and adds in additional features to enhance privacy throughout. Unfortunately there is no handy tool to opt-out on screen. Instead, if this is something you do not want us to use, please opt out at elevate.uk/plausible-opt-out.

Sharing your data

We do share personal data with trusted third parties where this is necessary to provide, support, secure, bill for and improve our services. These may include providers of payment processing, customer relationship management, customer support, cloud hosting, IT infrastructure, email and collaboration tools, billing and finance systems, website services, analytics, marketing, security, network delivery, installation and professional advisory services.

Where these third parties process personal data on our behalf, they are required to do so only on our instructions, to protect the data appropriately, and to comply with applicable data protection law. Some third parties may act as independent controllers, for example where they process payment, legal, regulatory or fraud-prevention information for their own legal or compliance purposes.

We may also share limited contact information with selected marketing platforms, including Google, to help us manage marketing preferences, suppress existing customers from certain campaigns, measure campaign effectiveness and present relevant marketing. You can object to this at any time by using the unsubscribe or preference options in our marketing communications, or by contacting us directly.

As an Internet Service Provider, we may occasionally receive requests or demands from law enforcement, regulators, courts or government agencies. We will only disclose personal data to these bodies where we are legally required or permitted to do so, and we will assess each request in accordance with applicable law.

Security of your data

We have implemented a range of measures to protect your data while it is with us and our suppliers. These range from contractual measures with our suppliers and those that access your data, right the way through to technical security measures to help manage our Information & Cybersecurity.

To help us protect your data, and help demonstrate our commitment to good security standards, we maintain certifications under the UK Cyber Essentials Plus programme, as well ISO standards 27001 and 9001.

For business customers, if you require more detail on our security arrangements as part of your due diligence, please feel free to get in touch.

The physical location of your data

Where possible, we aim to keep all of your data within the United Kingdom. However, there are some instances where we are unable to keep it within the UK and it is therefore either hosted in or accessed from another country.

Where your data is leaving the UK, we ensure that adequate protections are put in place to both legally and technically protect your data. This includes using UK/EU Adequacy Decisions, Standard Contractual Clauses, or other permitted mechanisms. Where there presents an unacceptable risk to the security and confidentiality of your data, we will not transfer that data to that location.

As 2 examples of transfers we use to offer services to you;

We use Stripe, Inc. to securely store and process payment card information - read more here
We use Mediahawk Ltd. to help link phone calls to website visits - read more here
We use Google Ads for marketing and promotional purposes - read more here

Your rights over your data

You have the following rights concerning your personal data:

Your right	Translation
The right of access	You have the right to know and see what information we hold on you. A written request is called a “Subject Access Request”. We have to provide information within 30 calendar days of your request.
The right to rectification	You have the right to have incorrect or incomplete information corrected within one month. This includes any information we have shared with other companies processing data on our behalf.
The right to erasure	You can request to be forgotten, however this is not an absolute right. There may be situations where we are legally required to keep your data, for example to meet our legal obligations.
The right to restrict processing	You can ask us to stop using your personal information if you are contesting the accuracy or use of the information. We have to stop processing this information until we have corrected it or established, we have a legal right to use it.
The right to data portability	You can request certain information is shared with another, similar, organisation. This only applies to information that is carried out by automation, is only about you and only where we have it with your consent or contract. Anything else is out of scope for a portability request.
The right to object	You can object to us using your information where we are using our legitimate interests. For marketing you can do this via the methods provided and for anything else please follow the details below.

Concerns over our handling of your data

If you have a concern over how you believe we have handled your data you have avenues to explore. In the first instance you have the right to complain to us as the Data Controller. Our Data Protection Officer (DPO) will investigate the matter and determine an appropriate course of action.

If you are not satisfied with that course of action, you also have a right to then lodge a complaint with the (Information Commissioner's Office (ICO) about us via www.ico.org.uk, casework@ico.org.uk or 0303 123 1113.

Getting in touch with us

For any questions, comments, or exercising of any of your rights please send them for the attention of the Data Protection Officer (DPO) at dpo@elevate.uk. You are also welcome to contact customer services or your account manager however the DPO will be the most direct method to get in touch.