Our Policies
Privacy Notice
This privacy notice tells you what to expect us to do with your personal information.
Contact Details
Telephone: +44 330 053 3399
Email: info@alwaysonmobile.io
What Information We Collect, Use, and Why
We collect or use the following information to provide services and goods, including delivery:
- Names and contact details
- Addresses
- Date of birth
- Purchase or account history
- Payment details (including card or bank information for transfers and direct debits)
- Account information
- Information relating to loyalty programs
- Website user information (including user journeys and cookie tracking)
- Records of meetings and decisions
- Information relating to compliments or complaints
- We hold other data on behalf of our subscribers acting as a data processor.
We collect or use the following information for the operation of customer accounts and guarantees:
- Names and contact details
- Addresses
- Payment details(including card or bank information for transfers and direct debits)
- Purchase history
- Account information, including registration details
- Information used for security purposes
- Marketing preferences
- Business information required by regulatory bodies in order to provide mobile telephone numbers and messaging services.
We collect or use the following information to prevent, detect, investigate or prosecute crimes:
- Names and contact information
- Customer or client accounts and records
- Mobile telephone numbers and other data relating to the verification of your business in order to comply with regulatory bodies in the telecoms sector to allow us to verify your business to third party messaging provides including mobile networks, Google LLC and Meta Inc.
We collect or use the following information for service updates or marketing purposes:
- Marketingpreferences
- Purchase or viewing history
- IP addresses
- Website and app user journey information
- Records of consent, where appropriate
- Mobile number
We collect or use the following information for research or archiving purposes:
- Names and contact details
- Purchase or viewing history
- IP addresses
- Website and app user journey information
- Personal information used for administration of research
- Personal information used for the purpose of research
- Records of consent, where appropriate
- Mobile number
We collect or use the following information to comply with legal requirements:
- Name
- Contact information
- Financial transaction information
- Details of campaigns that relate to the use of our services which are required to be submitted to mobile networks, Google LLC and Meta Inc for approval to send messages to your customers in accordance with the description of the services you provide
We collect or use the following information to Process personal information on behalf of our subscribers as a data processor:
- Names and contact details
- Date of birth
- Purchase or account history
- Payment details (including card or bank information for transfers and direct debits)
- Records of meetings and decisions
- Marketing preferences
- Customer or client accounts and records
- Financial transaction information
- Purchase or viewing history
- IP addresses
- Website and app user journey information
- Records of consent, where appropriate
- Mobile telephone numbers and other data relating to the verification of your business in order to comply with regulatory bodies in the telecoms sector to allow us to verify your business to third party messaging provides including mobile networks, Google LLC and Meta Inc
Lawful Bases and Data Protection Rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
Your right to erasure – You have the right to ask us to delete your personal information. You can read more about this right here.
Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
Your right to object to processing – You have the right to object to the processing of your personal data. You can read more about this right here.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide services and goods are:
Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
– We may collect some data about the usage of our product and service to help us improve those products and services.
– To ensure that those products and services are not being used in a manner which contravenes regulations and laws as laid down by telecoms regulators.
Our lawful bases for collecting or using personal information for the operation of customer accounts and guarantees are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except theright to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information to prevent, detect, investigate or prosecute crimes are:
Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for service updates or marketing purposes are:
Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for research or archiving purposes are:
Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Our lawful bases for collecting or using personal information for legal requirements are:
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for Process personal information on behalf of our subscribers as a data processor are:
Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, youdo have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, theright to object and the right to data portability.
Where We Get Personal Information From
– Directly from you
– Subscribers store data in our platforms where we act as a data processor.
How Long We Keep Information
If you do not fund your account within 1 month your data will be permanently deleted from our systems. If you do not tell us otherwise we may retain contact details for the purposes of marketing until you opt out. Other data may be retained longer to meet regulatory requirements.
Who We Share Information With
Data processors
Amazon WebServices IT services provider
This data processor does the following activities for us: AWS hosts our bespoke systems and databases used to run our services.
Google LLC Message Sending
This data processor does the following activities for us: Google send Rich ContentService (RCS) messages to end users.
Meta Inc. Message Sending
This data processor does the following activities for us: Meta send WhatsApp messages to end users.
Mobile Networks & Aggregators
This data processor does the following activities for us: Send SMS messages to end users. These can change and vary by country and region.
Others we share personal information with
- Professional or legal advisors
- Relevant regulatory authorities
- External auditors or inspectors
- Organisations we’re legally obliged to share personal information with
- Debt collection agencies
- Other relevant third parties
How to Complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the Information Commissioner’s Office (ICO).
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
Last Updated
25 September 2024
Hullo Cookie Policy
Hullo is owned and operated by Always on Mobile Limited (“Hullo”, “we”, “us”, and “our”).
This Cookie Statement explains how we use cookies and similar technologies in the course of our business, including through our websites that link to this Cookie Statement, such as www.hullo.me, and app.hullo.me, or any website or mobile application owned, operated or controlled by us (collectively, “Hullo Sites” or “Hullo Site”). It explains what these technologies are and why we use them, as well as your rights to control our use of them. Capitalised terms used and not otherwise defined in this Cookie Statement have the meanings given to those terms in our Privacy Policy.
In some cases we may use cookies and other tracking technologies described in this Cookie Statement to collect Personal Information, or to collect information that becomes Personal Information if we combine it with other information. For more information about how we process your Personal Information, please consult our Privacy Policy.
What are Cookies?
Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by online service providers in order to (for example) make their websites or services work, or to work more efficiently, as well as to provide reporting information.Cookies set by the website owner or service provider (in this case, Hullo) are called “first-party cookies”. Cookies set by parties other than the website owner are called “third-party cookies”. Third-party cookies enable third-party features or functionality to be provided on or through the website or service you are using (such as advertising, interactive content and analytics). The third parties that set these third-party cookies can recognise your computer both when it visits the website or service in question and also when it visits certain other websites or services.
Why do we use Cookies and other tracking technologies?
We use first-party and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our Hullo Sites and Service to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies enable us and the third parties we work with to track and target the interests of Visitors to our Hullo Sites, and we refer to these as “performance” or “functionality” cookies.
For example, we use cookies to tailor content and information that we may send or display to you and otherwise personalise your experience while interacting with our Hullo Sites and to otherwise improve the functionality of the Service we provide. We also enable our Members to employ cookies and similar tracking technologies in connection with their use of our Service in order to allow us and our Members to track their Contacts or end users. Finally, third parties serve cookies through our Hullo Sites and Service for advertising, analytics, and other purposes.
Our Policies
Modern Slavery
Modern Slavery and Human Trafficking Statement
This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 30 November 2022.
Always on Mobile Limited ('the Company', 'we', 'us' or 'our') is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.
Organisational structure
Always on Mobile Limited has business operations in the United Kingdom.
We operate in the technology sector. The nature of our supply chain is as follows:
We work with a number of key direct suppliers, who provide us with goods, such as computer equipment, connectivity to the internet and mobile network and services, such as outsourced business processes, IT software and marketing services. For more information about the Company, please visit our website: www.alwaysonmobile.io.
Policies
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include the following:
Procurement policy - We want to make sure that potential suppliers are committed to ensuring that slavery and human trafficking is not taking place within their own supply chains. Our procurement policy and supporting procedures set out controls and checks undertaken to help verify this.
We make sure our suppliers are aware of our policies and adhere to the same standards.
Due Diligence
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:
• Identify and action potential risks in our business and supply chains.
• Monitor potential risks in our business and supply chains
• Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
Risk and compliance
The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:
• Evaluating the slavery and human trafficking risks of each new supplier.
• Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping.
• We do not consider that we operate in a high-risk environment because the majority of our supply chain is based in the UK and in low-risk industries, such as internet software and services.
• We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will seek to terminate our relationship with that supplier immediately.
Effectiveness
We will carry out a regular audit of suppliers to ensure that slavery and human trafficking is not taking place in its business and supply chains.
