Privacy Policy


**Last Updated: October 7, 2024**


1. Introduction


Green Mobile Limited ("we", "our", or "us") is committed to protecting your privacy and ensuring that your personal data is handled in a safe and responsible manner. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our services, visit our website, or interact with us.


2. Data Controller


Green Mobile Limited

Green Mobile House

London, United Kingdom

Email: privacy@greenmobile.co.uk

Phone: 0800 GREEN-MOB (0800 473 366)


3. Information We Collect


3.1 Personal Information

  • **Identity Data**: Full name, date of birth, gender
  • **Contact Data**: Email address, telephone numbers, postal address
  • **Financial Data**: Payment card details, billing address, bank account information
  • **Service Data**: Mobile phone usage, data consumption, call records, text messages
  • **Technical Data**: IP address, device information, browser type, location data
  • **Marketing Data**: Your preferences for receiving marketing communications

    • 3.2 Special Categories of Data

    We may process special categories of personal data only with your explicit consent or where permitted by law.


    4. How We Use Your Information


    We process your personal data for the following purposes:


    4.1 Service Provision

  • Providing mobile network services and E-SIM products
  • Managing your account and billing
  • Customer service and technical support
  • Network maintenance and optimization

    • 4.2 Environmental Impact Tracking

  • Calculating and displaying your environmental impact through VeriTree partnership
  • Tracking tree planting and carbon offset contributions
  • Generating impact reports and certificates

    • 4.3 Legal Obligations

  • Compliance with telecommunications regulations
  • Anti-fraud and security measures
  • Law enforcement requests where legally required

    • 4.4 Marketing (with consent)

  • Sending promotional materials about our services
  • Personalizing offers and recommendations
  • Market research and surveys

    • 5. Legal Basis for Processing


    We process your personal data under the following legal bases:


  • **Contract**: To provide our services and fulfill our contractual obligations
  • **Legal Obligation**: To comply with telecommunications and other applicable laws
  • **Legitimate Interests**: For fraud prevention, network security, and business operations
  • **Consent**: For marketing communications and optional services

    • 6. Data Sharing


    We may share your personal data with:


    6.1 Service Partners

  • **VeriTree**: For environmental impact tracking and verification
  • **Transatel**: For global network connectivity
  • **Payment Processors**: For secure payment processing
  • **Fairphone**: For device support and warranty services

    • 6.2 Third Parties

  • Regulatory authorities when legally required
  • Law enforcement agencies where permitted or required by law
  • Professional advisers (lawyers, accountants, auditors)

    • We do not sell your personal data to third parties for marketing purposes.


    7. International Transfers


    Some of our service partners may be located outside the UK/EU. When we transfer your data internationally, we ensure appropriate safeguards are in place:


  • Adequacy decisions by the UK Information Commissioner's Office
  • Standard Contractual Clauses approved by the European Commission
  • Binding Corporate Rules where applicable

    • 8. Data Retention


    We retain your personal data only for as long as necessary:


  • **Active Customers**: For the duration of your service plus 7 years for regulatory compliance
  • **Former Customers**: 7 years from account closure for legal and regulatory requirements
  • **Marketing Data**: Until you withdraw consent or 3 years of inactivity
  • **Call Records**: 12 months as required by telecommunications regulations

    • 9. Your Rights


    Under UK GDPR, you have the following rights:


    9.1 Right of Access

    Request a copy of the personal data we hold about you


    9.2 Right to Rectification

    Correct inaccurate or incomplete personal data


    9.3 Right to Erasure

    Request deletion of your personal data in certain circumstances


    9.4 Right to Restrict Processing

    Limit how we use your personal data


    9.5 Right to Data Portability

    Receive your personal data in a structured, machine-readable format


    9.6 Right to Object

    Object to processing based on legitimate interests or for marketing purposes


    9.7 Rights Related to Automated Decision Making

    Not be subject to purely automated decision-making


    To exercise your rights, contact us at privacy@greenmobile.co.uk or call 0800 GREEN-MOB.


    10. Cookies and Tracking


    Our website uses cookies and similar technologies:


  • **Essential Cookies**: Required for website functionality
  • **Analytics Cookies**: To understand how you use our website
  • **Marketing Cookies**: To personalize advertisements (with consent)

    • You can manage your cookie preferences through our cookie consent banner or browser settings.


    11. Data Security


    We implement appropriate technical and organizational measures to protect your personal data:


  • Encryption of data in transit and at rest
  • Regular security assessments and penetration testing
  • Staff training on data protection
  • Access controls and authentication systems
  • Incident response procedures

    • 12. Children's Privacy


    Our services are not intended for children under 16. We do not knowingly collect personal data from children under 16 without parental consent.


    13. Changes to This Policy


    We may update this Privacy Policy from time to time. We will notify you of significant changes by email or through our website. The "Last Updated" date indicates when this policy was last modified.


    14. Contact Us


    For any questions about this Privacy Policy or our data processing practices:


    **Email**: privacy@greenmobile.co.uk

    **Phone**: 0800 GREEN-MOB (0800 473 366)

    **Post**: Data Protection Officer, Green Mobile Limited, Green Mobile House, London, UK


    15. Complaints


    If you are not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):


    **Website**: ico.org.uk

    **Phone**: 0303 123 1113

    **Post**: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF


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