DIGICEL (TRINIDAD & TOBAGO) LIMITED

CONFIDENTIALITY AND PRIVACY STATEMENT

Publication Date: 02 October, 2023

Digicel (Trinidad & Tobago) Limited, together with its authorised dealers and resellers, subsidiaries and affiliates (collectively referred to as “Digicel”, "we", "us" or "our" in this Statement) is committed to respecting the privacy of its customers, subscribers and end-users (collectively referred to as “you”) and to complying with applicable data protection and privacy laws. This Confidentiality and Privacy Statement (“Privacy Statement”) is intended to give you a general understanding of how Digicel may collect, use, protect, and otherwise deal with your personal information.   

You acknowledge that by providing your information to Digicel, you consent to the processing of your data in accordance with this Privacy Statement. Different Digicel branded or affiliated products and services collect different kinds of data. It is important that you read this Privacy Statement together with any other privacy, customer or regulatory notices we may provide for specific products and services, and on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. Where applicable, this Privacy Statement supplements other notices and Digicel privacy notices and is not intended to override them. We invite you to visit our webpage here for the list of our current service and product specific notices and policies.

Personal Information Collection

Digicel reserves the right to collect and use your confidential, personal or proprietary information when you: 

·      Purchase, sign-up for, subscribe to or use Digicel’s wide range of products and services that are offered or for which you may choose to opt-in;

·      Make customer enquiries via online customer support, customer call centres or our physical locations;

·      Request information or other services; 

·      Respond to communications from us (such as SMS, emails, questionnaires or surveys);  

·      Interact with Digicel’s websites including submitting an application form, completing a survey form or using any other online service;   

·      Enable, or fail to disable your browser’s internet cookies, which can facilitate Digicel’s tracking of personal preferences, including websites visited;

·      Engage with Digicel’s social media pages, including Twitter, Instagram, and Facebook; 

·      Participate in Digicel’s promotional events, incentive or loyalty programs;

·      Provide information through Digicel’s customer call centres, authorised dealers, resellers and other sales channels or any other affiliates or business dealings with Digicel by which you have consented to provide your personal information.  

Types of Information Collected

The types of information that Digicel may collect include, but are not limited to:

·      contact information (such as name, address, email address and telephone number);

·      identification information (such as passport identification number, tax registration number, driver’s license, date of birth);

·      demographic information (such as age range, marital status, gender, occupation);

·      photographs such as those that you may submit for contests or prize winning competitions;

·      product specific information (such as preference, closed user group (CUGs), friends and family who you choose to include in your service plan, credit limit);

·      financial information (such as banking details, financial status direct debit and related bill payment banking transactions);

·      service account information (such as call usage, account balances, transaction history, credit information, billing, loyalty points);

·      information that relates to the use of a telecommunications service or telecommunication network by a user, including the quantity, technical configuration, type, origination, destination, content or amount of such use;

·      your behaviour, usage or activity on any of our products and services;

·      any other data you choose to share with us or provide via any product, service, campaign or promotion.

Use

Any information, including personal information, collected by Digicel will be used in support of the intended purposes stated at the time at which it was collected, or otherwise communicated to you in writing thereafter, and may be subject to the terms, conditions or policies that may be provided at time of collection, along with any and all amendments to said terms, conditions or policies further communicated for your acceptance, or any preferences indicated by you.  We may  otherwise use your information to assist with service related issues, technical support and billing purposes, to enhance your customer experience by providing you with specific products and services tailored to meet your needs; for general marketing campaigns, network protection, legal and regulatory compliance.

Mobile Applications

Digicel may from time to time offer and request your participation in various mobile applications to enhance the user experience. If you choose to register for an application, we may obtain information about you and/or your mobile device. Digicel will use the information collected in accordance with this Privacy Statement and any product, service or application-specific privacy notices.  You may stop the collection of your personal information at any time by uninstalling the relevant applications for which you have registered or you may contact us and make a request to opt-out.  

Digicel may also offer applications developed by third parties to enrich your experience. When you download a third-party application to your mobile device, the third party application may collect information about you in connection with your download or use of that application. Digicel is not responsible for the collection or use of information by any third-party application. Digicel recommends that you carefully review the privacy statements of each third-party application prior to downloading or using them.

Linked Sites

Digicel’s websites may contain links to third-party sites that are not controlled by Digicel or covered by this Privacy Statement, including those belonging to Digicel dealers and resellers, co-branded websites offered in conjunction with a business partner, or independent product review sites. Digicel is not responsible for the collection or use of information by any third-party websites. Digicel recommends that you check the Privacy and Cookie Statements of all sites you visit before providing any information, including personal information.

Digicel Dealers and Resellers

When you purchase, sign-up or register for a product or service from a Digicel Dealer or Reseller, the Dealer or Reseller will share your information with Digicel as your service provider. While Digicel encourages its Dealers and Resellers to ensure full compliance with all applicable laws and policies, and has provided information to our Dealers and Resellers relating to non-disclosure obligations, Digicel shall not be held responsible for Dealers’ and Resellers’ compliance, or lack thereof, with applicable laws.

Sharing

Digicel does not disclose, trade, transfer or otherwise share your information, including personal information, except in the following instances:

·      as required by law, such as in conjunction with a court order, government inquiry, litigation, dispute resolution or similar legal process;

·      when we believe in good faith that disclosure is necessary to protect our rights, protect your security, investigate fraud or respond to a law enforcement request;

·      with Digicel service providers, field engineers, contractors who work on our behalf and who do not have an independent right to use the information to which they have access or that we disclose to them;

·      with our business partners for Digicel’s marketing activities, which, in such circumstances, no specific personally identifiable information is provided;

·      with third parties for research and development purposes; 

·      with our Digicel dealers, resellers, subsidiaries and affiliates for providing you products and services, and for marketing and advertising;

·      with your consent, which we may get in writing, online or orally; and

·      with third parties to facilitate identity verification or fraud prevention and in order to help prevent the misuse of our network, products and services; or

·      with third parties to facilitate or complete a business transaction for the delivery of our products and services.

In all cases, third parties must agree to a strict duty to keep all information provided confidential and to use it only for the purpose for which it was obtained.     

Data Transfer

Digicel will endeavour to ensure adequate commercial agreements are established with third-party affiliates with respect to cloud computing services and exporting of data to countries in accordance with applicable legislation. Digicel also uses well-known security technologies and practices to secure data from unauthorized access or interception.

Data Retention

Digicel will endeavour to retain your personal data only for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider: the amount, nature and sensitivity of the 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, regulatory, tax, accounting or other requirements. 

Security

Digicel is concerned about safeguarding the confidentiality of your information. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Privacy Support & Inquiries 

If you have concerns or questions regarding this Privacy Statement or Digicel’s privacy practices, or if you wish to update your personal information or stop the collection of your personal information, please contact us at privacy@digicelgroup.com or via any of the channels indicated here.

Changes to Privacy Statement

Digicel reserves the right to amend or modify this Privacy Statement at any time and in response to changes in applicable legislation. Notice of any such change along with the revised policy will be posted on our website.