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1 Who are we?

Fulnett Ltd T/A Strencom of Heron House, Blackpool Retail Park, Blackpool, Cork, T23
R50R and its subsidiaries, are committed to protecting and respecting your privacy.
For the purpose of applicable data protection legislation, the data controller of your
personal information is Fulnett Ltd.

2 What does this Privacy Policy do?

2.1 Fulnett Ltd T/A Strencom (hereafter referred to as Strencom) has developed this
privacy policy because we want you to feel confident about the privacy and security of
your personal information. Strencom takes all reasonable care to prevent any
unauthorised access to your personal information.
2.2 When we refer to “personal information” in this privacy policy, we mean information
that relates to you in circumstances where we can identify you directly or indirectly.
We may hold and use personal information about you in your capacity as a business
customer or as an individual when you visit our websites.
2.3 This privacy policy only applies to how Strencom deals with your personal
information. It does not apply to your use of services, products or websites made
available to you by third parties, even if you access them through Strencom.

3 Nature and Purpose of Processing
Strencom Processes the Personal Data to:

3.1 make informed decisions about End Users and the Services;
3.2 perform day to day management of accounts and the Services;
3.3 record consent, e.g. in relation to marketing preferences or disability or medical
conditions, to make its Services more accessible, to provide information in alternative
formats and to ensure marketing materials are issued in line with preferences;
3.4 provide, maintain and bill the Services;
3.5 provide access to online platforms;
3.6 meet its legal and regulatory obligations and to comply with orders of the court or
other bodies having lawful jurisdiction;
3.7 authenticate End Users on the network;
3.8 identify, manage and resolve defects and incidents;
3.9 assess and report on the credit-worthiness of clients or potential clients;
3.10 take any other action to the extent necessary to discharge an obligation pursuant to
this Agreement; and
3.11 receive, manage and resolve requests, queries, complaints and claims.

4 The Personal Data Processed concern the following categories of
Personal Data only:

4.1 account data e.g. caller line identification/telephone numbers, account number,
device ID, IP address, service history and usage data;
4.2 personal data e.g. name, title, address and circuit ID;
4.3 financial data e.g. credit or debit card details and bank details;
4.4 interaction history and connection data e.g. authentication logs, online alias and
service performance data;
4.5 company data where this identifies a Data Subject e.g. company name and company
registered number;
4.6 contact information e.g. email address;
4.7 social media details e.g. profile IDs and handles;
4.8 identification related data e.g. passport and driving licence;
4.9 professional life data e.g. job title and employer;
4.10 product information e.g. speed logs; and

5 Categories of Data Subject
The Personal Data Processed shall concern the following categories of Data Subjects
only:

5.1 officers and staff of Client, including employees, consultants, volunteers, agents,
temporary workers, casual workers and other individuals authorised to act on behalf
of Client; and
5.2 End Users or their authorised representatives.

6 What personal information do we collect from you and how do we use
it?

We may collect and process the following personal information about you:
(a) Personal information that you provide by filing in forms from Strencom provided
portals and our website www.strencom.net / (“our site”). We use this information
to provide the services that you have requested and that we have agreed to provide
to you. Our lawful ground for processing your personal information for these
purposes is that it is in our legitimate business interests to do so.
(b) We may ask you from time to time about what use you make of the services we
provide, what other services you would like us to provide in the future. Our lawful
ground for processing your personal information for these purposes is that it is in
our legitimate business interests to do so.
(c) We may collect personal information about your use of our site and services to help
us to make improvements to our sites and to the services we make available to our
customers. Our lawful ground for processing your personal information for these
purposes is that it is in our legitimate business interests to do so.
(d) We may also monitor and record our communications with you, including e-mails
and phone conversations which may then be used for training purposes, quality
assurance, to record details about the products and services you order from us, and
in order to meet our legal and regulatory obligations generally. Our lawful ground
for processing your personal information for training purposes and quality
assurance purposes is that it is in our legitimate business interests to do so.
(e) We receive information about you from other telecommunications operators
where you are also our customer. Our lawful ground for processing for the
remaining purposes described in this section is that it is in our legitimate business
interests to do so.

7 How else do we use your personal information?

7.1 Marketing and Advertising
We may need your personal data in order to send you marketing materials which we
think you may be interested in. In these instances our lawful ground for processing
your personal data for marketing purposes in that it is in our legitimate business
interests to do so.

8 Do we share your personal information with anyone else?

8.1 We sometimes use other companies to help us to provide the service that we have
agreed to supply to you. To enable them to do this, we may need to share your
personal information with them. When we do so, these companies are required to
act in accordance with the instructions we give them and they must meet the
requirements of applicable data protections legislation when processing your personal
information.
Our lawful ground for processing your personal information for the purposes
described in this section is because it is in our legitimate business interests to do so.
8.2 We may provide your personal information, in response to lawful requests, for the
purposes of the prevention and detection of crime, and the apprehension or
prosecution of offenders. We may also provide information for the purposes of
safeguarding national security. In either case we do so in accordance with applicable
data protection legislation. We also provide your personal information to third
parties when required to do so by law, for example under a court order, or in
response to lawful demands, under powers contained in legislation.
Our lawful ground for processing your personal information is because such
processing is necessary for us to comply with legal obligations we are subject to.

9 For how long does Strencom keep your personal information?

Strencom shall Process Personal Data for no longer than is necessary for the purposes
for which it is Processed.

10 How do we protect your personal information?

10.1 We are serious about guarding the security of your personal information. We take
appropriate organisational and technical security measures to protect your personal
information against unauthorized disclosure or processing.
10.2 Where we have given you (or where you have chosen) a password which enables you
to access certain parts of our site, you are responsible for keeping this password
confidential. We ask you not to share a password with anyone.
10.3 We use various security measures to protect the information we collect, as
appropriate to the type of information, including encryption, firewalls and access
controls. Our company databases are accessible only by persons who have entered
into and are bound by a confidentiality and nondisclosure agreement with Strencom.
10.4 Unfortunately, the transmission of information via the internet is not completely
secure. Although we will do our best to protect your personal data, we cannot
guarantee the security of your information transmitted to our site; any transmission is
at your own risk. Once we have received your information, we will use strict
procedures and security features to try to prevent unauthorised access.

11 Changes to our Privacy Policy

Any changes we make to our privacy policy in the future will be posted on this page
and, where appropriate, notified to you by email.

12 Contact

Questions, comments and requests regarding this privacy policy are welcomed and
should be addressed to Fulnett Ltd. T/A Strencom, Heron House, Blackpool Retail
Park, Blackpool, Cork, Ireland. T23 R50R or by email at support@strencom.net.

We wanted a provider that could lead us in the right direction and give us the help we needed to get on with our fundraising efforts. Strencom immediately understood the way we work and how the internet s upports our outreach. We really value the service they offer.

Joanne Di Rosa

Technology Manager, Microsoft