1. Personal information
2. How we use your personal information
3. Sharing and disclosing your personal information
4. How long do we keep your information
5. Your right of access to your personal information
6. Security and protection of your personal information
7. Location Services
8. Our promise
Personal information is any information that identifies you as an individual or is capable of identifying you. We collect personal information such as:
· your full name;
· your gender;
· your date of birth or age;
· your delivery and/or your billing address including postcodes;
· your telephone number;
· your email;
· your debit or credit card details;
· your banking information;
· information on add-on products and services purchased by you;
· your preferences and interests both when you tell us what they are or when we deduce them from what we know about you;
· your demographic information (which we may acquire from third parties);
· the channel you chose to purchase your device or sign up to our services;
· how you use our products and services. This may include your traffic data such as the phone numbers that you call and send messages to (and the phone numbers that you receive calls and messages from) and the date, time, duration and cost of your communications including your phone location at the time these communications are made and the types of websites that you visit, your spend, your device details, your phone usage (including voice, messaging, web/ WAP use, application use), your purchasing habits, your location, your searching and browsing history on our websites (including the date, time and duration of your internet session) and your preferences;
· your amount of data usage (MBs used);
· roaming information (the country you are in and the network used when making communications);
· your internet protocol (IP) address which we collect when you visit our website; we will allocate an IP address to your device when your connect to the internet using our phone network and/or broadband services;
· your device details;
· your communications with us;
· your account information such as your billing history, the services you use and anything else relating to your account; and
· any information to help you decide which of our products and services would suit you best.
· checking details on application for credit and credit related or other facilities;
· managing credit and credit-related accounts or facilities;
· recovering debt;
· checking details on proposals and claims for all types of insurance; and/or
· checking details of job applications and employees.
These agencies will also use the records for statistical analysis about credit, insurance and fraud. We and other organizations may access and use the information recorded by fraud prevention agencies from other countries.
We collect information in three (3) ways:
1, Directly from you when you are asked to provide personal details about yourself, including in the following circumstances:
· when you purchase products and/or services from us whether in store, online or by phone;
· when you communicate with us (e.g. when you submit an application form to become our customer or if you contact us for any enquiries including by calling all our customer services);
· when you use our products and services;
· if you enter a competition or prize draw;
· if you subscribe to our newsletters or other alerts;
· if you take part in one of our researches, surveys or consumer panels; and/or
· when you tell us about your interests and preferences (we may also infer what these are based on what we know about you).
2. Indirectly from you when you use our services including when you:
· visit and use our website including by using cookies;
· use our network, services and related products;
· access the internet; and/or
· download any of our software and/or mobile applications.
3. We collect information about you from other organizations including from:
· credit reference and fraud agencies;
· data marketing agencies; and/or
· business directories.
We use your personal information for the following purposes:
· to make credit decisions about you;
· to confirm that your orders have been received and to process them, to validate you as a registered customer when using our services and calling our customer services;
· for providing the relevant products and services to you, for administration of your account with us and customer services, and for billing purposes;
· to tell you about functionality changes to our website, changes to our services or changes to our terms and conditions, to remind you about your customer benefits, and to advise you regarding the use of our services;
· to help us develop our offers, products and services and the layout of our website to ensure that our services are as useful and enjoyable as possible;
· for our internal purposes such as management, research, analytics, corporate reporting, credit scoring and to improve business efficiencies;
· to contact you to invite you to form part of our consumer panel or research groups about our products and services or third-party products and services;
· for segmentation of our customer base, marketing of our products and services and to understand and keep you informed about what is the best package for you according to your use of our services;
· to provide you with the best customer experience we can;
· to ensure security for you and our staff, and help maintain service quality (calls to our customer services may be monitored and/or recorded for quality and training purposes);
· to check that your home or office or other location is covered by our network and to optimize your network coverage and our network;
· to prevent and detect criminal activity, fraud and misuse of or damage to our services or networks and to prosecute those responsible, to defend our rights or property or to protect the rights and interests of our customers and users;
· to comply with applicable laws, regulations, court orders, government and law enforcement agencies' requests, to operate our systems properly or to protect ourselves or our users and customers or to solve any customer disputes;
· for the management of traffic, your personal information may also be used for tracing nuisance or malicious calls and for emergency services;
· to send you newsletters. You can opt out of receiving our newsletters (below you will find more information on opting out);
· to provide aggregated statistics about our sales, customers, traffic patterns to third parties, but these statistics will not include any information that is likely to identify you;
· to carry out research and analysis and monitor customer use of our network and products and services on an anonymous or personalized basis to identify general consumer trends and to understand better our customers' behaviors and partner with other businesses to create new services and to develop interesting and relevant products and services for our customers, as well as personalize the products and services we offer you. We may use information about your location for research and analytics purposes but we will only retain this information in an anonymized form to ensure that you cannot be identified as an individual;
· to market and advertise our branded products and third party products and services that may be of interest to you including third party offers, promotions, advertisements, competitions or commercial communications by telephone (mobile and landline when available), post, fax, electronic messaging (including SMS and MMS), email or online or via any other interactive media. We may also use information about your location as a factor in deciding which mobile ads to serve to you. You can opt out for third party products and offers (below you will find more information on opting out); and/or
You can always tell us that you do not wish to receive newsletters and/or direct marketing communications. But remember, you may miss out on valuable and exciting offers. If you would prefer not to receive marketing information, simply let us know at any time by contacting us as below.
Please call Customer Services on 145 from a Digicel handset or send an email to firstname.lastname@example.org if you wish to opt out.
Please note that it may take up to 5 working days to process your opt out request.
We may share your personal information with:
· our Group Companies and their agents and sub-contractors;
· our service providers involved in providing the services to you including the provision, distribution, delivery and marketing of our products and services and advertising. These service providers have to follow our express instructions in respect of the use of your personal information and they must comply with appropriate security measures to protect your personal information. We may transfer your personal information to countries outside of Aruba, which do not always provide the same level of protection as Aruba, for the purposes of providing you with our services. If we do make such a transfer, we will ensure appropriate technical and organizational measures to secure your personal information are in place to ensure that your personal information is protected against loss and any form of unlawful processing;
· credit reference agencies;
· fraud prevention agencies;
· debt collection agencies;
· insurance providers if you have purchased an insurance policy through us;
· law enforcement agencies, regulators, courts and public authorities;
· emergency services;
· our trusted business partners for research purposes, to identify and understand general consumer trends and to understand better our customers; and/or
· prospective or actual purchasers, sellers or partners and their advisers if we decide to sell, buy, merge or otherwise re-organize our business.
The period we keep information varies according to what the information is used for. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we will retain it for no longer than is necessary for the purposes for which the data was collected or for which it is to be further processed.
If you want, you can always access your personal information. Just make a written request to NEW MILLENNIUM TELECOM SERVICES N.V. T/A DIGICEL ARUBA, with registered office at L.G. Smith Blvd 60, Oranjestad, Aruba to the attention of the Legal Department. We may charge you USD 6.75 (or the equivalent in local currency) to cover the cost of processing your request and supplying your information to you. We will ask you to provide identification to ensure we do not disclose your information to the wrong people. If you tell us that we hold any inaccurate information about you we will correct it at no charge to you.
We do our best to protect your personal details and other information about your account because we want you to feel completely confident about using our services. We will review our processes and procedures to protect your personal information from unauthorized access and use, accidental loss and/or destruction. Sometimes we use other organizations to process your personal information on our behalf. We don't allow them to use this information for their own commercial purposes and they have to follow our strict instructions and comply with appropriate security measures. We store all your account details and other such information on secure servers, adhering to all applicable legislation.
We need to know approximately where you are so that we can deliver services to you. Location information (such as your Cell ID) is relayed to us and some of our partners when your phone is turned on or when you use the services. This information may also be shared with the emergency services so that when you make an emergency call, the emergency services are able to respond more quickly to the call. Cell ID location information cannot usually be used to pinpoint exactly where you are. For example, it cannot usually be used to determine which particular house or shop you are in at a given time. Instead it offers an approximate location based on your position relative to the nearest mobile phone masts. The accuracy of this information depends on how close you are to a mobile phone mast and is likely to be more accurate in urban areas compared to rural areas. This location information may also be used to provide you with services that are linked to your location such as traffic reports and entertainment listings.
You may receive certain passive location services in circumstances where you have adjusted settings or activated certain features on your phone. For example, if your phone has 'Bluetooth' enabled, you may receive messages from third parties located nearby. If you do not wish to receive these services, we suggest you de-activate the relevant feature(s) on your phone or contact the third parties directly.
· Value the personal information entrusted to us and make sure we respect that trust;
· Be open with individuals about how we use their information and who we give it to;
· Make it easy for individuals to access and correct their personal information;
· Keep personal information to the minimum necessary and delete it when we no longer need it;
· Have adequate safeguards in place to prevent the loss and/or unlawful processing of your personal information; and
· Check that we are living up to our promises and report on how we are doing.