Imagine we recognise the importance of your privacy and are committed to protecting it and minimising the information we collect about you, limiting what we use it for and keeping it for no longer than required. With this in mind, we’ve developed this policy so you can clearly understand what information we collect about you and how we use it, share it and your rights to that data. We take the protection of your data seriously and apply  appropriate security measures to keep your data safe and secure and that we handle and process it in accordance with the current data protection legislation and European general data protection regulations, including the Irish Data Protection Acts 1988 to 2018 and the General Data Protection Regulation (Regulation (EU) 2016/679).

Ways we collect your data:

We collect information in a few different ways. When you give it to us, give us permission to obtain it or have given permission to other companies to share it with us.

When you enquire about our service through our website, call-centre or speaking to us directly you give us certain information voluntarily. This includes your name, email address, phone number, Eircode and any other information you give us. When you enquire about our service through other companies and have given them permission to share your data with us. This includes your name, email address, phone number, address, Eircode and any other information you provide. When you sign up for our service, we collect customer information such as name, address, Eircode, email address, phone number(s), usernames and passwords, birthdates, payment information, details of the product and service you bought, your contract type and your marketing contact preference.

If you choose to provide your health data for accessibility purposes, we may use this to provide you with assistance and support on your account, where you have provided such consent.

 

We also get technical information when you use our service:

When we provide you with your service and connect you to our network we associate technical information to your account such as the IP address, Mac address and IMEI/SIM Number and location data of the equipment we provided you which uniquely identifies you. Whenever you use our service, certain information gets created and automatically logged such as location data, traffic data, call traffic data and other diagnostic and usage data. We use this data to let you access our network and use the service, calculate billing, traffic management, performance management, fraud investigation, network troubleshooting and to meet legal or regulatory obligations.

 

Here are some of the types of information we collect:

• Location data which records your IP address, MAC address and IMEI/SIM number and unique identifiers to establish a connection between our network and your device to enable you to make or receive calls and access the internet.

• Call traffic data which records the calls you make including the date, time, duration of your phone calls and the number to or from which the calls were made.

• Diagnostic & Usage Data which records technical statistics about your connection, signal strength, coverage, upload and download speed and the amount of data you use.

• IP Traffic data which is limited to your IP address, the date and time of your internet access and the duration of your session. We don’t have a history of  your web-browsing or emails you send as this is limited for a short real-time period to enable your connection to be made. We don’t keep records of the websites you visit, what content you look at online or the content of emails you send.

• Device data is limited to the type of device you’re using and its IP address.

Devices, applications, and websites you use have their own privacy policies and settings for you to manage how information is collected. Due to the nature of the internet, any communications over it can pose a security risk. You should take appropriate measures to ensure the devices you use and any communications you send, have the proper level of security and encryption. Your device and communication security and encryption are your responsibility.

 

Information we collect on our websites:

When using our websites or applications, we may collect certain information about your device, including where available your IP address, operating system, and browser type, to gather statistical information on how you browse our websites, analyse trends, administer the site, and gather broad demographic information for aggregate use. The information does not usually directly identify you, but it can give you a more personalised web experience.

We use Analytics tools like Google Analytics to analyse use of our websites, applications and emails we send to you.

To do this Imagine and Google Analytics use Cookies and Web Beacons.

Because we respect your right to privacy, you can choose not to allow some types of cookies. However, blocking some types of cookies may impact your experience of the website and the services we are able to offer.

 

What are Cookies and Web Beacons and how do they work?

Cookies are small text files, containing a unique identification number, that are stored on your device when you visit any website. They allow us and Google Analytics to remember you and how you’ve used the site. Cookies are used in order to make websites work more efficiently and provide information. They can give you a more personalised web experience by identifying you when you return to a website and show if you have visited a site previously and what pages you visited. Our cookies and any third party cookies do not extract any information off your device. They do not hold or track your personal information or provide us with any way to contact you with the exception of the LiveChat cookie which is only enabled when you choose to interact with us through our LiveChat service on imagine.ie.

Web beacons are small image files that may be placed on web pages and within web-based emails that we send. They accurately count the number of unique users who have visited a specific page on the site and the number of times those pages are displayed. We may also use web beacons to let us know how many people opened a web-based email. They are also used to facilitate the transfer of data from our website to the Google Analytics website.

Information is generally collected in aggregate form and we will not associate any
information gathered from cookies on our websites or applications with any
personally identifying information from any other source.

 

Can I enable or disable cookies?

When you access our sites or applications for the first time or after a cookie has expired, you will be asked to set your preferences for the use of cookies, except strictly necessary cookies, on those sites and applications. After that you can change your cookie preferences at any time by clicking on the ‘Cookie Settings’ button in the footer. You can then adjust the available sliders to ‘Active’ or ‘Inactive’, and then click ‘Confirm My Choices’. You may need to refresh your page for your settings to take effect.

Alternatively, most web browsers allow some control of most cookies through the browser settings. Generally, your browser will offer you the choice to accept, refuse or delete cookies at all times. If you choose to refuse cookies, you may still use our sites or applications, but you may be limited from accessing certain areas or services. Some of our business partners may also use cookies on our sites or applications. You can find out more about cookies at www.allaboutcookies.org which shows you how to see what cookies have been set on your browser and how you can manage them.

For more details on what information we collect when you use our websites or applications and how to choose your cookie preferences see our Cookie Policy.

We record information when you interact with us about your service such as:

• When you communicate with us through letters, emails, chat services, calls, social media and our website or applications.

• When you set-up your My Imagine account with your contact and email information and create your unique password.

• When you provide information to us through competitions, surveys, or market research.

We also obtain information from third parties where you have given them permission to share it with us, such as:

• Address verification services

• Publicly available sources where you have given them permission to share it with us.

• Profile information (including lifestyle and demographic composition)

You are not required to provide any of the personal information described above to us, however, if you do not do so, you may not be able to set up an account with us, or the functionality of our products or services may be reduced.

 

What we do with the information we collect:

The main purpose we collect and use your information is to provide you with our product and services in accordance with our contract with you and manage your relationship with us. We also use it for legitimate business reasons or to comply with a legal or regulatory obligation.

We use the information we collect:

• To provide the products and services you request.

• To manage our relationship with you and administer your account for service delivery, provisioning, customer services enquires, technical support, billing, payment processing and to manage collections.

• To record instructions you give us and keep you updated on any changes to your service.

• To record our communications with you including but not limited to emails and phone conversations, to administer your account and for verification, training, and quality assurance.

• To route and manage traffic and usage across our network.

• To ensure our network is secure and detect and prevent fraud or carry out network troubleshooting.

• To meet our legal or regulatory obligations.

• To investigate, prevent or take action regarding illegal or inappropriate activities (whether alleged or proven) and violations of our Terms and Conditions and/or applicable law.

• To protect or enforce our rights or those of a third party.

• To protect someone’s vital interests.

• To include your name, address, and phone number in the National Directory Database if you so requested or if you ask us to remove it as you have opted out.

• To verify the personal data we hold about you is accurate.

• To improve our product and services and offer new features.

• To build a profile about you and your time as an Imagine customer, which we use to target and tailor the direct marketing we send you, determine what offers about our products and services you are eligible for and how to provide those offers to you.

• To ensure we give you access to relevant content.

• To conduct analyses of the performance of our services, network, or customer services through anonymised or aggregated information which doesn’t identify you.

• We may anonymise and aggregate any of the personal data we hold (so that it does not identify you). We may use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our site, apps and developing new products and services.

 

In addition to the specific circumstances above, we’ll only use your information
with your consent:

• To send you information about our products, services and promotions that might interest you. Each time we send you marketing information we give you the option to unsubscribe.

• When you accept the use of cookies on our websites or applications. For more information, please see our Cookie Policy.

 

How and when we share information:

We share your information with trusted third parties for a number of reasons, including:

• With other companies within the Imagine Group.

• For the performance and delivery of our products and services with companies who work on our behalf and based on our instructions. For example, communications, customer satisfaction or experience surveys, engineering services, billing, payment processing, cloud services, equipment vendors. In which case we will require those parties to ensure that information is kept confidentially, securely and the use is limited to the purpose for which it was provided.

• With advertising or marketing partners so that we can run advertising campaigns and conduct market research and analysis. This may include social media sites such as Facebook, Instagram, Twitter and Google Ads. Any information provided to these third parties will be pseudonymised by hashing so that your information cannot be directly identified.

• To detect, prevent or otherwise address fraud, security, or technical issues. To carry out credit checks or debt collection processes where legally applicable.

• If you fail to meet your contractual obligations with us.

• To protect or enforce our rights or those of a third party.

• To deal with complaints, queries and protect our legal rights.

• If required to comply with a law, regulation, or legal request.

• To protect someone’s vital interests.

• If there was a potential merger or change of ownership of Imagine, we will provide your information to that organisation and its advisors and service providers to the extent that this is relevant to the proposed transaction.

• If there was a merger or change of ownership of Imagine in which case the new owner of the business would assume the rights and obligations regarding your information.

• If a third party who is processing your data on our behalf is required to disclose it by law.

• If we need to transfer your data outside the EEA when we require a third party to work on our behalf for the performance and delivery of a product or service, we require any such service providers to process your information in a secure manner and in accordance with Irish and EU law on data protection. We will always ensure that there is a proper legal agreement that covers the data transfer. In addition, if the country is not considered to have laws that are equivalent to EU data protection standards, then we will enter into a legal agreement with the third party that reflects those standards and ensure there are appropriate security measures and controls in place to protect your personal data. Further information about the legal agreement we use can be found here.

 

How long we keep your information:

We keep your information only so long as we need it to provide services to you and for the purposes described in this policy. When we no longer need to use your information and there is no need for us to keep it to comply with our legal or regulatory obligations we’ll either remove it from our systems or anonymise it so that we can’t identify you.

 

How we secure your information:

At Imagine securing your data is important to us, which is why we take appropriate security measures, protocols, and processes to secure and protect the confidentiality, integrity, and availability of your information. We always aim to protect your personal information against unauthorised access, use or disclosure, using security technologies, procedures, and limited access control.

 

Rights you have about your information:

You have rights in relation to the personal information that we hold about you:

• The right to know what’s been collected and how it’s being processed.

• The right to access the information we hold about you, known as a Subject Access Request.

• The right to have inaccurate or incomplete information corrected.

• The right to restrict the processing for example if you want us to establish its accuracy or the reason for processing it.

• The right to object to processing your information.

• The right to withdraw your consent for direct marketing purposes.

• The right to have information erased when we no longer have a legitimate reason to keep it.

• The right to have your information transferred to you or another organisation of your choice in electronic form.

• The right to object to decisions being made solely by automated means.

• The right to make a complaint to the Data Protection Commissioner about your information.

As we use your information to provide you with your services and for the performance of our contract with you, if you object to processing information or make requests for restriction/erasure these may affect our ability to provide you with the service requested.

You can exercise any of your rights by contacting our Data Protection Officer at the details below. 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 in our reasonable opinion, 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 may also contact you to ask you for further information in relation to your request to speed up our response.

 

Your Contact Preferences:

You can manage your contact preferences and decide how you would like us to keep you updated about our products, services and exclusive promotions via post, telephone, text, or email at any time via your My Imagine online customer portal.

Provided you agree to receive marketing information from us by the method you have chosen, we will continue to send you information about our products, services, and exclusive promotions until you contact us to opt out of receiving the marketing or change the method in which you receive the information.

We don’t share your information with third parties for marketing purposes, unless you have given us consent to do so. We’ll only send you information that’s relevant to our services. If at any time you no longer want to hear from us simply update your contact preferences on your My Imagine customer portal or just click unsubscribe at the bottom of any email or text message we send you.

To provide you with your service and manage your account with us we will always send you communications about your account, billing, usage, or important service updates, using your contact information or through a service notification.

 

How we make changes to this policy:

We may update this policy from time to time. When we do, we will post the current version on our website and, where appropriate, notify you using your contact email. We encourage you to periodically review this policy so that you will be aware of how we use your information.

 

How can you contact us about this policy?

If you have any questions about this Privacy Policy or you wish to request access to your information that we hold then you can contact our Data Protection Officer at dataprotection@imagine.ie or write to us at Imagine Networks Services Limited, Data Protection, Sandyford Business Centre, Blackthorn Road, Dublin 18.

This Privacy Policy was last updated October 25th 2022.

Version.R5-October-2022