What is the purpose of this privacy notice?

This privacy notice is designed to help you understand how the GWS companies based in the UK collect and use your information in their capacity as a controller. The GWS company covered is Global Wireless Solutions – UK Limited, a private limited company with company number 10557957 and whose registered office is at The St Botolph Building, 138 Houndsditch, London EC3A 7AR.

By ‘your information’, we mean information which relates to you or allows us to identify you. This may include obvious things like your name, address and telephone number (although please note that in the context of our OneMeasure Perks project, we will not collect this information). But your information can also include things like your IP address which identifies you when you visit our websites.

This notice may be updated from time to time. This version is dated September 2022.

Please note we have a separate privacy notice on how we process the information of our staff, which current and former members of staff should refer to.

Our responsibility to you

We provide wireless network benchmarking, analysis and testing services as well as consumer research services to our customers. In common with most businesses, we collect, use and share information, including personal information, in connection with providing our services and running our business.

We process your information in our capacity as a controller. This means we are responsible for ensuring that we comply with relevant data protection laws when processing your information. This includes where we process personal data as part of providing our services to our customers.

Does GWS hold information about me?

We only collect information about you in connection with providing our services and running our business. GWS collects information about you where:

  • you work for an organization which has (or potentially has) business dealings with us (so organizations such as customers/potential customers of GWS, suppliers to GWS, and government agencies)
  • you are an applicant for a job with us
  • you visit our websites
  • you download and use one of our mobile applications

Representatives

Where you have (or potentially have) business dealings with us through your organisation, most of the information which we hold about you will come directly from you. Either you will have provided the information in answer to questions from us, or we will have obtained the information from the business cards you present to us or from the correspondence you send to us. We may also obtain information about you via your organisation or from external sources.

Job applicants

Where you are applying for a job, we will ask you to provide specific information about yourself. We might conduct checks in order to verify your identity and the information in your application, and to assess your suitability for the role. This process may involve obtaining information about you from third party sources (such as the electoral role), and from your social media accounts.

Our websites and cookies

Our websites may invite you to provide us with your personal information. Where you provide us with information, we will only use it for the purpose for which it has been provided by you.

Our websites use a small number of non-intrusive cookies to help them work more efficiently and to provide us with information on how the websites are being used. In particular, the sites use Google Analytics, a web-based analytics tool that tracks and reports on the manner in which each website is used to help us to improve it. Google Analytics does this by placing ‘cookies’ on your device. Note that Google will also have its own control of this information, and will hold it on its servers in the United States in accordance with its own privacy policies. Further information on this topic is available at “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time).

You can control cookies through the settings or preferences of your browser, as well as through dedicated browser extensions or add-ons. For more information on cookies, see allaboutcookies.org.

Our mobile applications

Our GWS mobile phone diagnostic application, and the mobile diagnostic services that we provide using the application, collect information regarding your mobile device. When you download and use the application we will also assign a unique code to your mobile device. We do not collect your name, physical address or email address, nor do we share your mobile device identification information with other people outside of the GWS group of companies. With your consent, we will also track your mobile device’s location via the app in order to provide the full functionality of our diagnostic services.

OneMeasure Perks

OneMeasure Perks is based on a panel of paid users in the UK (all aged 18 or over). Panelists participating in our project will install an app on their phones. This section of the privacy notice applies only to the individuals participating in our OneMeasure Perks project, as do all other sections under the heading ‘OneMeasure Perks’.

If you agree to participate in OneMeasure Perks, we do not collect your name or physical address. However, we may ask you for your home area, postcode and certain demographic data including:

  • your age;
  • your gender;
  • your occupation and personal income;
  • your marital status;
  • your ethnicity;
  • information about your education;
  • whether your household includes individuals aged 18 or over and/or individuals under the age of 18; and
  • your household income.

We will also collect your email address in order to provide you with compensation via our rewards programme administrator.

Once you have agreed to participate in OneMeasure Perks and have downloaded our app, we may collect further personal data through that app. We may:

  • track your mobile device’s location and IP address, app usage and apps installed via the app; and
  • collect information about your engagement with your mobile device. For example, we may record the fact that you open a specific application such as a browser, an online game, a social media app or a sports betting app, listen to a podcast or make a telephone call.

Please note that the app will not give us access to the content that you view or the calls that you make.

We may also collect certain information about your device, such as your ISP, phone type, device ID and mobile network operator.

Whilst our app is installed on your device, you may receive requests via the app to fill in optional surveys about a range of topics. You will receive additional compensation in exchange for filling in these surveys.

To help protect your privacy, you will be assigned a unique panel ID and information about you will be linked to that unique panel ID in our systems.

What kind of information about me does GWS hold?

There are different types of personal information. The most important types for you to know about are:

  • Special categories of personal information: these categories of personal information often have additional protection under data protection laws around the world. These categories include information about your health, racial or ethnic origin, political opinions, religious or philosophical beliefs and trade union membership, your genetic data and biometric data, and information concerning your sex life or sexual orientation.
  • Criminal convictions information: this is information relating to your criminal convictions and offences. Local data protection laws may restrict the way in which we can use this information when compared to, for example, your name and address.

 We do not generally collect special categories of personal information or criminal convictions information, although we may collect limited amounts of these types of information in relation to our staff recruitment activities.

OneMeasure Perks: as part of OneMeasure Perks, we may ask participants for their ethnicity. In addition, whilst we do not look to collect data relating to health, the information we may gather may include, where applicable, any interaction with health-related apps. Please note that we will not have access to any information contained within these apps.

What does GWS do with my information, and what is the legal basis for this?

We are required by law to identify the legal bases on which we use your information.

We use the information which we collect about you mainly on the basis of ‘legitimate interests’ and, in our view, our use of your information in this manner does not have any detrimental impact on you or your rights.

In particular:

  • Representatives: we have a legitimate interest in contacting and dealing with individuals that work for an organisation which has (or potentially has) business dealings with us. This includes sending relevant marketing communications or making relevant marketing calls to such individual. When we send you marketing communications or make marketing calls, there are additional marketing-specific laws that we adhere to, in addition to data protection laws. You may opt out of receiving marketing communications from us at any time, and each communication we send provides a straightforward means of doing so
  • Job applicants: we have a legitimate interest in knowing the identity and background of the individuals we employ to ensure we have the appropriate staff to comply with our various legal and regulatory obligations and ethical duties. For special categories of personal information and criminal convictions information processed as part of job applications with us, we have the right to use that information based on the employment protection lawful basis
  • Our websites: we have a legitimate interest in providing to you the facilities on our website that you have requested and in understanding how our websites are used
  • Our mobile applications: we have a legitimate interest in providing to you the facilities and services on our mobile applications that you have requested and in understanding how our applications are used. Where we track you mobile device location, we will do so only with your consent. You have the right to withdraw your consent to our tracking of your device at any time, but please note that if you do so you will not be able to benefit from the full functionality of the services we offer via our apps. Our applications explain how you withdraw your consent.
  • OneMeasure Perks: we will rely on your consent to collect information about your ethnicity, monitor your use of your mobile device – including, where applicable, your interaction with health-related apps – and to track your device location. You have the right to withdraw your consent at any time by deleting the app. Please note that if you do so your participation in OneMeasure Perks will cease with immediate effect and you will not receive any further compensation.

In addition, we may process your personal information where necessary for compliance with a legal obligation to which we are subject.

Does GWS share my information with anyone else?

We do not sell your information nor make it generally available to others. But we do share your information in the following circumstances:

  • we have a number of affiliate companies around the world operating under the name “GWS”. Where it is necessary or appropriate for our affiliates to process your information in connection with our dealings with you, we will share your information with them
  • we use the services of various external companies to help us run our business efficiently, particularly in relation to our IT systems. Some of these services involve the service provider holding and using your personal information
  • your information may be shared with our professional service providers, such as accountants, where necessary or appropriate. These service providers will be separate controllers of your information, and will be responsible for how they manage your information
  • if you work for an organisation which has business dealings with us or if you apply for a job with us, we might provide some of your information to search companies so they can verify your identity on our behalf
  • if we sell all or part of our business, then your information will be transferred to the new owner to enable the continuation of the business

Where service providers are acting on our behalf (such as IT companies), they are required to keep your information safe and secure. They are also not permitted to use your information for their own purposes.

OneMeasure Perks: in relation to OneMeasure Perks only, please note that aggregated, anonymised information which does not identify specific individuals may be shared with third parties such as mobile network operators for market research purposes only. Our rewards programme administrator will only have access to your email address (and not to any other personal data relating to you) for the purpose of providing you with compensation.

Does GWS transfer my information outside the UK?

The global nature of our business means that your personal information may well be transferred across national boundaries, including, potentially, to countries that do not require organisations by law to look after your personal information in the way in which you have come to expect in your own country.

Where we transfer your information to organisations which are based outside the UK, we will do so on a basis which is lawful under the applicable data protection laws. Generally this means that where the organisation is located in a country which does not have adequate privacy protection, we will put in place a contract with the third party that includes the standard international data transfer contractual terms approved by the UK Information Commissioner’s Office. You can request a copy of these terms from us.

Does GWS make automated decisions about me?

We do not use profiling (where an electronic system uses personal information to try and predict something about you) or automated decision making (where an electronic system uses personal information to make a decision about you without human intervention).

How do you keep my information safe?

 We take security issues seriously. We implement appropriate steps to help maintain the security of our information systems and processes and prevent the accidental destruction, loss or unauthorised disclosure of the personal information we process.

How long does GWS retain my information?

We do not keep your information forever.

We keep your personal information in accordance with our data retention policy which categorises all of the information held by us and specifies the appropriate retention period for each category of information.  Those periods are based on the requirements of relevant data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and our business purposes.

What rights do I have in respect of my information?

You have a number of legal rights in respect of your information:

  • you can ask us to provide further details about our use of your information
  • you can ask us to give you a copy of your information
  • you can ask us to correct any inaccuracies in your information
  • you can ask us to erase your information or to restrict our use of your information
  • you can object to our use of your information due to your particular circumstances

Please note that some of these rights might be subject to limitations or exceptions.

We are obliged to keep your information accurate and up to date. Please help us to do this by advising us of any changes to your information.

What if I need to contact GWS or have a complaint?

If you have any questions, concerns or requests in relation to our use of your information, please email us at dataprotection@gwsolutions.com.

You can also complain about our use of your information to the UK Information Commissioner’s Office (https://ico.org.uk/global/contact-us/) – this applies wherever you are based. If you are based in the European Union, you also have the option of complaining to the data protection authority in your country.