Privacy Policy
1. Introduction
Welcome to our privacy policy. We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
2. Important Information and Who We Are
This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service, take part in a competition, etc.
If you are aged under 13, by using our website you are confirming that you have the permission of your parent or guardian to do so, and for your data to be collected.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller: The controller responsible for your personal data is SPIDEE CONSULTANTS LTD, a company registered in England and Wales with number 15952257.
Contact details: If you have any questions about this privacy policy or our privacy practices, please contact us:
- Full name of legal entity: SPIDEE CONSULTANTS LTD, registered in England and Wales with number 15952257.
- Email address: privacy@isp6.net
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, please contact us in the first instance. We would appreciate the chance to deal with your concerns before you approach the ICO.
We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
3. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you, including:
- Identity data: name, date of birth, gender
- Contact data: address, email address, telephone number
- Financial data: bank account and payment card details
- Transaction data: details about payments and products and services you have purchased from us
- Technical data: IP address, login data
- Profile data: your account name, purchases or orders made by you, preferences, survey responses
- Usage data: information about how you use our website, products and services
- Marketing and communications data: your preferences in receiving marketing and your communication preferences, and how you found us when you signed up
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
We do not collect any 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). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
4. How Is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your details by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our products or services, create an account on our website, subscribe to our service or publications, request marketing to be sent to you, enter a competition, promotion or survey, or give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
5. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We may use your identity data, contact data, technical data, usage data and profile data to form a view on what we think you may want or need, or what may be of interest to you. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
When you create an account, we record how you found us: the campaign named in the link you followed or, if it named none, the website the link was on, and the first page of ours you saw. We use this to learn which of the places we talk about isp6 bring members, which is in our legitimate interests. It is carried from page to page in the address bar, not in a cookie, and it is kept with your account and deleted with it. We do not share it with anyone.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and adjusting your marketing preferences, following the opt-out links on any marketing message sent to you, or contacting us directly. Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
6. Disclosures of Your Personal Data
We may share your personal data with:
- Internal third parties within our business.
- External third parties such as service providers who provide IT and system administration services, professional advisers including lawyers, bankers, auditors and insurers, and HM Revenue & Customs, regulators and other authorities.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all 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.
7. International Transfers
We do not transfer your personal data outside the UK and EU area.
8. Data Security
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 employees, agents, contractors and 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 duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data Retention
How long we keep something depends on what it is. The table below is the whole schedule, not a summary of it.
| What | How long we keep it | Why |
|---|---|---|
| A sign-up that never verified its email address | 24 hours, then it is deleted automatically. The 24 hours start over each time we send your code again: when you ask for it, sign up again or try to sign in. | There is no account yet, so there is nothing to keep. |
| An account that never completed sign-up and went quiet | 365 days of inactivity. We then email you, and delete the account 30 days later unless you come back. | You are not using it, and nothing on it is running or reserved for you. Any activity at all cancels the deletion. |
| An account whose membership has ended | We email you, then delete the account 30 days later | The membership term has run and nothing is reserved for you any more. |
| Orders, invoices and the tax position on them | 6 years from the end of the accounting year they fall in | Company law and HMRC require it. This is the one class we keep even after we delete your account. |
| The log of what happened on your account | 6 years | It is how we can show what we did and when, including the deletion itself. |
| Sponsorship paperwork: signed agreements, your verification reference, your justification, and what we filed with the RIPE NCC | For as long as we sponsor your resources, and 7 years after that | Seven years covers the six in which a contract claim can be brought, with a year's margin. As your sponsoring LIR we also have to be able to evidence the sponsorship to the RIPE NCC. |
| An application you withdrew before we filed anything | No fixed period, and we delete it if you ask | Nothing was filed, so there is nothing for it to be evidence of. |
| Support tickets | 6 years | Alongside the orders they usually relate to. |
| A message sent through the contact form: your name, your email address and the message | Until you click the link in the confirmation email, at most 24 hours, then it is deleted. Once sent, we keep the copy for 7 days. The message itself then lives in our support mailbox, like any email you send us. | The link is how we know the address works, so our reply can reach you. The short copy lets us send a message again when it did not reach the mailbox. |
| Records of the emails we send you: when each was sent, and whether it was delivered, bounced or reported as spam | 90 days | So we can check that an email reached you when you tell us it did not. |
| Newsletter consent | Until you unsubscribe. We keep the record that you unsubscribed. | So we can prove we stopped when you asked. |
Identity documents stay with the company that checks them. Identity and business verification is carried out by our verification provider. We keep the reference for the check, its result, and the response we received. We do not hold copies of your passport or your company documents, unless you uploaded a document to us directly as part of a sponsorship application, in which case it is kept with the rest of that paperwork.
Sponsorship paperwork is archived before it is deleted. Ninety days after a sponsorship ends, the documents move to long-term archive storage for the rest of the seven years. They still exist and you can still ask for them, but retrieving them takes us hours rather than seconds. If you want copies, the easy time to ask is inside that first 90 days.
When we delete an account we delete the account itself, your sign-in links and your verification sessions. We keep the paid orders, the account log and your customer record at our payment provider, for the reasons in the table. We will not delete an account while it still holds a live IPv6 block or a sponsored resource: those are released or transferred first.
10. Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These may include:
- The right to request access to your personal data
- The right to request correction of your personal data
- The right to request erasure of your personal data
- The right to object to processing of your personal data
- The right to withdraw consent
If you wish to exercise any of these rights, email privacy@isp6.net.
Asking us to delete your data. We answer a deletion request category by category rather than all or nothing, and we tell you which is which. We will delete your account, your sign-in links, your verification sessions and any application you withdrew before we filed it with the RIPE NCC.
There are things we will keep, and refuse to delete, for as long as the periods in section 9 run. We will say so explicitly and give you the date each one ends:
- Your orders and invoices, because company law and HMRC require us to hold them for six years.
- The log of what happened on your account, because it is our record of what we did, including deleting your data when you asked.
- Sponsorship paperwork, for as long as we sponsor your resources and seven years after that, because six years is how long a claim about the agreement between us can be brought and we keep a year's margin, and because as a sponsoring LIR we must be able to evidence the sponsorship to the RIPE NCC.
We will not delete an account while it still holds a live IPv6 block or a sponsored resource. Tell us where you want the resources to go, and the deletion follows once they have moved.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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 try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.