PRIVACY NOTICE
Your privacy is very important to us. We are committed to ensuring that when you choose us to use our services, you know what personal data we collect about you and how we use personal data that you provide to us.
We are committed to protecting and respecting your privacy. This Privacy Notice describes how we will use your personal data. We operate in a business to business environment enabling us to keep the collection of personal data to a minimum. If personal data is collected, it is done so in the context of a data subject proactively signing up to a TMT service or in the context of a direct relationship the data subject has with us.
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Please take the time to read and understand our Privacy Notice. WHO WE ARE
TMT Analysis Limited (trading as TMT ID) is a limited company with company number 10354347. Phronesis Technologies Limited is a limited company with company number 10726796. Our registered office is at Mansion House, 33 Queen Street, London, United Kingdom, EC4R 1BR ( together – “TMT”, “we” or “our” or “us”).
We are a provider of number portability data, intelligence and analytics services (“services”). Our platform operates through our website https://www.tmtid.com/ (“Website”). “customer”, “you” or “your” means an individual who is the subject of personal data we process as a data controller.
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SCOPE OF THIS PRIVACY NOTICE
This Privacy Notice (together with any other documents referred to in it) sets out the basis on which any personal data (i) we collect from you; (ii) you provide to us; or (iii) we collect from third parties will be processed by us.
This Privacy Notice also sets out how you can instruct us if you prefer to limit the use of that personal data and the procedures that we have in place to safeguard your privacy.
For the purpose of this Privacy Notice, Data Protection Legislation means the General Data Protection Regulation 2016/679 (the “GDPR”) applicable in the European Union. For the purpose of the Data Protection Legislation, the data controller is TMT Analysis Limited. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using our Website, registering with us or submitting information to us you signify you have read and understood our collection, use and disclosure of your personal information in accordance with this Privacy Notice. If you do not agree with this Privacy Notice, you must not use our Website, access our services or submit information to us.
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PERSONAL DATA WE MAY COLLECT (OR RECEIVE) ABOUT YOU
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We may collect (or receive) and process your personal data when:
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you contact us, whether through our Website or otherwise (for example, via our online form, by e-mail, post, fax or phone), as we may keep a record of that correspondence. For example, if you submit a complaint, report a problem with our services or our Website or otherwise liaise with our customer service, technical support or any other department in our company;
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you fill in and submit information on our Website via your PC, a mobile device or otherwise. This includes information provided by you when you update a customer account such as your name, e-mail, country, password, etc;
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you use and interact with our Website, including your device’s manufacturer and model, IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system, web browser, platform, mobile carrier, and your ISP. We may collect details of your visits to our Website (including, but not limited to, traffic data, location data, weblogs and other communication data). We do this via email and website cookies, and similar tracking technology built into our Website. We make cookie policies available on our Website to give you more detailed information on how we use them;
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you use your customer account to log in or you use our platform technology and other features and functionalities, including our solutions and applications;
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we receive, use and/or provide personal data as part of the number portability data, intelligence and analytics services you buy from us and any relevant information about them. Under no circumstances is personal data disclosed to any third parties other than those who need to know this information in the context of the services we provide;
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we use cookies and other technologies as described below;
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the personal data you give us may include:
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name and address;
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e-mail address;
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username, password;
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IP address;
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phone numbers;
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credit card details;
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occupation;
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We may check some of the personal data that you provide to us against third party databases to confirm that it is accurate.
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We may have access to your financial information, such as your billing address, bank account details and payment history in order to allow us to take payments from you in connection with the number portability data, intelligence and analytics services you purchase, send you refunds or enable our customer service to deal with your enquiries. Under no circumstances are these details disclosed to any third parties other than those who need to know this information for the performance of the services requested.
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We may have access to your social media content where this is in the public domain, and any messages you send direct to us via social media. This personal information can include posts and comments, pictures and video footage on websites such as YouTube, Facebook and Twitter.
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When you digitally interact with companies that are also our business clients (which include, but are not limited to, global entities engaged in payment transaction processing, other related payment services, and multinational Fintech and AdTech companies), we may be asked to verify your identity and help prevent fraud using your personal information, such as your full name, residential address, mobile telephone number or date of birth. Our business clients are responsible for obtaining your consent for and/or giving you legal notice about this processing of your personal information. TMT uses real-time, secure Application Programming Interface (API) calls to process and protect the personal information transmitted to us from third parties (e.g., our business clients) as part of our user authentication and identity verification processes. For most of our products and services, we do not retain the personal information transmitted to us in real-time by our business clients.
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HOW WE COLLECT YOUR PERSONAL DATA
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We collect your personal data through:
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our Website, including when you complete the online form;
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emails you send to us, or that we send to you;
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our conversations with you;
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your use of social media, including “like” buttons and similar functions made available by social media platforms;
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information collected from our business clients;
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public sources; and
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mobile phone operators
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HOW WE MAY USE YOUR PERSONAL DATA
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We may process your personal data for one or more lawful bases of processing (“Lawful Basis”) depending on the specific purpose for which we are using your data (see below).
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We may process your personal data for the purpose of:
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dealing with your inquiries and requests, including contacting you where necessary. Lawful Basis: your consent or performance of our contract with you;
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notifying you about important changes or developments to our Website or to our services (e.g. changes of features or enhancements). Lawful Basis: performance of our contract with you or necessary for our legitimate interests;
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carrying out our obligations arising from any contracts connected to you. Lawful Basis: performance of our contract with you or necessary for our legitimate interests;
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providing and personalising our services. Lawful Basis: performance of our contract with you or necessary for our legitimate interests;
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providing you access to all parts or features of our Website or our services. Lawful Basis: performance of our contract with you or necessary for our legitimate interests;
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where applicable, processing your payments. Lawful Basis: performance of our contract with you or necessary for our legitimate interests;
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administering your registration and/or membership and other customer accounts records. Lawful Basis: performance of our contract with you or necessary for our legitimate interests;
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for market research, analysis and creating statistics. Lawful Basis: your consent, performance of our contract with you or necessary for our legitimate interests;
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to send you marketing communications, for instance, to contact you from time to time regarding things you have told us you want to hear about; new products, for example, or special offers, competitions and sponsored events. Lawful Basis: your consent or necessary for our legitimate interests;
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prevent, detect and investigate potentially prohibited, fraudulent, or illegal activities. Lawful Basis: to comply with our legal obligations or necessary for our legitimate interests;
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improving and developing our Website or our services. Lawful Basis: performance of our contract with you or necessary for our legitimate interests;
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ensuring that content from our Website is presented in the most effective manner for you and for your computer or mobile device. Lawful Basis: performance of our contract with you or necessary for our legitimate interests;
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ensuring we have adequate security measures and services so you can safely access our Website. Lawful Basis: performance of our contract with you, to comply with our legal obligations or necessary for our legitimate interests;
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comply with all the applicable laws and regulations. Lawful Basis: to comply with our legal obligations;
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debt recovery or debt tracing, crime, fraud and money laundering compliance. Lawful Basis: to comply with our legal obligations or necessary for our legitimate interests;
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for recruitment purposes if you have applied for a position with us including to contact you to discuss a role with us and to assess your suitability. Lawful Basis: your consent, performance of our contract with you or necessary for our legitimate interests;
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to monitor how people use our Website to see if they are being abused or threatened, for example, by internet trolls posting inappropriate comments in review areas or by would-be hackers looking to undermine our security. Lawful Basis: your consent, performance of our contract with you or necessary for our legitimate interests;
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to allow us to understand our customer base across all our businesses. Lawful Basis: processing is necessary for our legitimate interests;
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to help us conduct focused market research based on trends and common factors, so we can further improve our Website we offer to all our customers. Lawful Basis: processing is necessary for our legitimate interests;
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to test new systems and processes as we roll them out (but generally only in anonymous form) to make sure they work correctly and meet the standards we set for ourselves. Lawful Basis: processing is necessary for our legitimate interests;
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to assist us in the development of new products over a period of time. Lawful Basis: processing is necessary for our legitimate interests; and
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identification verification services on behalf of our business clients (by checking such personal data against third party databases). Lawful Basis: processing is necessary for our legitimate interests. The processing of such data assists our business clients in preventing fraud and assists the data subject in accessing a service or product and it is in their interests to avoid theft of their identity / or have fraud committed in their name.
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If you are an existing customer, we may contact you with information, products or services that you request from us or ones which are similar to the services we are providing to you (independently or jointly with others), unless you opted out to be contacted for such purposes. We may contact you for this purpose by post, telephone, as well as by email. If you change your mind about being contacted in the future, please let us know.
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We do not sell, rent, or otherwise provide your personal data to third parties unless you consent to this or it is necessary to provide you with our services or as described in this Privacy Notice. We may share information with any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries (the “Affiliates”).
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If you choose to post messages on any online forum or other message platforms that we may make available for this purpose on our Website, we may collect that information you provide to us. We may process this information as necessary to respond to any social media posts or other public comments you might make, whether they are directed to us or about us, our Website or other activities, to resolve disputes, provide customer support and troubleshoot problems, as permitted by law. Lawful Basis: to comply with our legal obligations, performance of our contract with you and necessary for our legitimate interests.
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You may ask us to provide you with information about our services or about services offered jointly with or on behalf of other organisations by sending us an e-mail to info@tmtid.com or writing to us to the following address: Mansion House, 33 Queen Street, London, United Kingdom, EC4R 1BR.
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If you stop using our Website or our services or your permission to use our Website or our services is terminated, we may continue to use and disclose your personal data in accordance with this Privacy Notice (as amended from time to time) and as permitted by law. However, if you wish us to stop e-mailing you with information in connection with our Website or our services, please unsubscribe or send your request to the contact details set out above.
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Where applicable, you can change your contact details at any time by updating your profile in your customer account and update your contact preferences by changing your settings related to your notification choices.
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We may use personal data you provide to us, or to third parties offering combined services with us, to customise the services we provide to you.
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The Internet is not a secure medium. However, we have put in place a range of security procedures, as set out in this Privacy Notice.
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Where you have been allocated an account, this area is protected by your user name and password, which you should never divulge to anyone else.
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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.
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We cannot accept responsibility for any unauthorised access or loss of personal data that is beyond our control.
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We will use reasonable endeavours to implement appropriate policies, rules and technical measures to protect the personal data that we have under our control (having regard to the type and amount of that data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.
For instance, our security measures include, but are not limited to:
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educating our employees as to their obligations with regard to your personal data;
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requiring our employees to use passwords and/or smartcards when accessing our systems;
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encrypting data sent from your computer to our systems during internet transactions and client access codes transmitted across networks;
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employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses entering our systems;
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using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing;
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practising a clean desk policy in all premises occupied by us and our related bodies corporate and providing secure storage for physical records; and
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employing physical and electronic means such as alarms, cameras and guards (as required) to protect against unauthorised access to buildings.
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We will ensure that your personal data will not be disclosed to government institutions or authorities except if required by law (e.g. when requested by regulatory bodies or law enforcement organisations in accordance with applicable legislation).
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Certain services may include social networking, chat room or forum features. When using these features please ensure that you do not submit any personal data that you do not want to be seen, collected or used by other users.
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TO WHOM WILL YOUR PERSONAL DATA BE DISCLOSED OR TRANSFERRED TO?
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Your personal data may, for the purposes set out in this Privacy Notice, be disclosed for processing:
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to our employees, our Affiliates and their employees;
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to our third-party consultants, (sub-)contractors, suppliers or other service providers who may access your personal data when providing services (including but not limited to IT support services) to us (e.g. we may share your personal data with email marketing companies who help us to email or mail our newsletter to you and other people who help us provide our Website and related services to you. This includes information technology experts who design and host our Website and general service companies). For instance, we disclose personal data when we outsource certain functions, including bulk mailing, card and cheque book production, market research, direct marketing, statement production, debt recovery and information technology support. We also seek expert help from time to time to help us improve our systems, products and services;
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to analytics and search engine providers that assist us in the improvement and optimisation of our Website;
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to our successors in title, our prospective sellers or buyers of our business or to our Affiliates when we have a merger or re-organisation;
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to government bodies and law enforcement agencies and in response to other legal and regulatory requests;
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to any third-party where such disclosure is required in order to enforce or apply our End Users Terms of Use or other relevant agreements;
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to protect the rights, property, integrity or security of our company, our customers, or others (including, without limitation, you). This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
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where you have consented to this, to selected third parties that may contact you about products and services which may be of interest to you in any jurisdiction where we operate;
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to third parties of TMT may use your personal information to facilitate our business activities in accordance with the principles of data protection. It may be necessary, for instance, for these third parties to use your personal data for purposes such as fraud prevention and identity verification
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Any social media posts or comments you send to us (on our Facebook page, for instance) will be shared under the terms of the relevant social media platform (e.g. Facebook or Twitter) on which they are written and could be made public. Other people, not us, control these platforms. We are not responsible for this kind of sharing. So before you make any such remarks or observations, you should review the terms and conditions and privacy policies of the social media platforms you use. That way, you will understand how they will use your personal data, what personal data relating to you they will place in the public domain, and how you can stop them from doing so if you are unhappy about it.
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In all circumstances where personal data may become known to our contractors, agents and outsourced service providers, there are confidentiality arrangements in place. Contractors, agents and outsourced service providers are not able to use or disclose personal data for any purposes other than our own.
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In order to facilitate our services, TMT may send your personal data to selected third parties such as financial institutions. The legal basis for the processing of such data is Legitimate Interest.
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Categories of data sources: TMT collects personal data from various categories of data sources in the delivery of its services. It is important to note that we only collect information necessary for specific lawful purposes. Please refer to Section 6 of this Privacy Notice on HOW WE MAY USE YOUR PERSONAL DATA. Below are the data sources that we commonly work with: (i) mobile network operators, (ii) data service providers; and (iii) government bodies.
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YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
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You can write to us at any time to obtain a copy of your personal data and to have any inaccuracies corrected.
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You have the following rights, though, please note that they do not apply in all circumstances:
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request access to your personal data (commonly known as a “data subject access request”);
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request correction of the personal data that we hold about you;
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request erasure of your personal data. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
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object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
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request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
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request the transfer of 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 that this right only applies to automated information (i.e. not to hard copies) which you initially provided consent for us to use or where we used the information to perform a contract with you; and
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withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
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Please write to:
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TMT Analysis Limited, Mansion house, 33 Queen Street, London, United Kingdom, EC4R 1BR; or
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Please quote your name and address. We should be grateful if you would also provide brief details of the personal data of which you would like a copy or which you would like to be corrected (this helps us to more readily locate your data).
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We will require proof of your identity before providing you with details of any personal data we may hold about 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 in relation to your request to speed up our response
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We try to respond to all legitimate requests within 1 (one) month. Occasionally, it may take us longer than 1 (one) month if your request is particularly complex or you have made a number of requests. In this case, we will notify you within 1 (one) month of the receipt of your request and keep you updated.
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We may charge you a reasonable fee to you when a request is manifestly unfounded, excessive or repetitive, or we receive a request to provide further copies of the same personal data. Alternatively, we may refuse to comply with your request in these circumstances.
We use cookies to store and collect information about your use of our Website. Cookies are small text files stored by the browser on your equipment’s hard drive. They send information stored on them back to our web server when you access our Website. These cookies enable us to put in place personal settings and load your personal preferences to improve your experience.
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WHERE WE STORE AND PROCESS YOUR PERSONAL DATA
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA“). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or Affiliate companies. Such staff may be engaged in, among other things, the fulfilment of your request, the processing of your payment details and the provision of support services. Where this occurs, in most cases we use approved ‘Standard Contractual Clauses’ approved by the European Commission and a risk assessment, which together, act as an appropriate safeguard to ensure that such data is adequately secured and protected. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.
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YOUR CONSENT AND CHANGES TO THIS PRIVACY NOTICE
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We reserve the right to amend or modify this Privacy Notice and if we do so we will post the changes on our Website. It is your responsibility to check the Privacy Notice every time you submit personal data to us.
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In the event that the purposes for processing personal data change, we will contact you as soon as practicable and seek your consent where such notification relates to a new additional purpose for processing.
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USE OF YOUR PERSONAL DATA SUBMITTED TO OTHER WEBSITES
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Except as otherwise expressly included in this Privacy Notice, this document addresses only the use and disclosure of personal data we receive about you or collect from you.
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If you disclose your personal data to others (e.g. websites we link to), different rules may apply to their use or disclosure of the personal data you disclose to them. We are not responsible for the privacy policies and practices of other websites even if you accessed the third party website using links from our website.
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We recommend that you check the policy of each website you visit and contact the owner or operator of such website if you have concerns or questions.
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We will only retain your personal data for as long as you have consented to it or when is necessary to us to provide you with our services or fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, reporting or regulatory requirements. For instance, by law we have to keep basic information about our customers (including contact, identity, financial and transaction data) typically for six (6) years after they cease being customers for tax purposes.
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To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of your personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
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In some circumstances you can ask us to delete your personal data.
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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.
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If you would like to let us know about something we have done, or failed to do, whether positive or negative, please let us know. Your comments enable us as an organisation to learn and continuously improve our services.
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If you think there is a problem with the way we are handling your personal data, you have the right to complain to the Information Commissioners Office at:
Questions, comments and requests regarding this Privacy Notice should be addressed to info@tmtid.com
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YOUR DUTY TO INFORM US OF CHANGES
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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.
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If your personal details change, please help us to keep your information up to date by notifying us at info@tmtid.com
Last Update: 07 May 2024. Reviewed annually or earlier subject to changes in applicable law or following technical or business changes
