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your rights in relation to your personal data and how to contact us or make a complaint.
We regularly review and, where necessary, update our privacy information and post changes on our websites. If
we plan to use personal data for a new purpose, we will update our privacy information and communicate the
changes to the individuals concerned before starting any new processing.
HiHi Ltd (company number 07590894) and all other group companies from time to time together (HiHi, we us,
our) are committed to protecting and respecting your privacy.
This Policy applies to you if you use our services (our Services), and if you contact us or we contact you about
our Services. It also applies to visitors to your website (our Website): https://www.hihi.co.uk/
We are committed to protecting your privacy. We will only use the information that we collect about you lawfully
and in accordance with the current Data Protection Act 2018.
1 SCOPE OF POLICY
1.1 This policy applies to your use of:
1.1.1 your HiHi telephone device; and
1.1.2 any of the services and products accessible through HiHi phone (Services) including network
services, internet services, software applications (Apps), unless the Terms states that a separate
1.2 This policy sets out the basis on which any personal data HiHi collects from you, or that you provide to
us, will be processed by us. Please read the following carefully to understand our views and practices
regarding your personal data and how HiHi will treat it.
1.3 By ticking the ‘Agree/Disagree’ prompt when setting up your user profile and preferences, you consent to
HiHi collecting and using your data in accordance with the terms of the policy. If you no longer consent
to the processing of your data as described in this policy, you should contact HiHi Ltd.
1.4 We may also rely on our legitimate interest, as well as the legitimate interest of third-parties to which your
information is disclosed, to process your information, including for conducting data analytics.
1.5 For the purpose of the Data Protection Act 2018, or any replacing legislation, the data controller is HiHi Ltd
(company number 07590894) and all other group companies from time to time as appropriate, whose
registered office is at One Lansdowne Plaza, 24 Christchurch Road, Bournemouth, BH1 3NE.
2 INFORMATION WE MAY COLLECT FROM YOU
HiHi may collect and process the following data about you (Information):
2.1 Information you give us. You may give us information about you by:
2.1.1 filling in forms on the Apps;
2.1.2 by corresponding with us (for example, by email or chat);
2.1.3 registering with us for a business account;
2.1.4 configuring and registering individual profiles and configuring settings and preferences;
2.1.5 downloading, registering or subscribing for an App;
2.1.6 subscribing to any of our Services;
2.1.7 searching for an App or Service;
2.1.8 making an in-App purchase;
2.1.9 sharing data via an App’s social media functions;
2.1.10 syncing the HiHi phone with a user’s social media account, including but not limited to,
Facebook, Twitter and LinkedIn;
2.1.11 syncing content with a user’s email, address book, mobile device contacts or calendars;
2.1.12 uploading video content to the HiHi phone;
2.1.13 when you report a problem with an App or Service;
2.1.14 using the terminal equipment;
2.1.15 using the search engine for internet searching/browsing;
2.1.16 inputting your data into the search engine;
2.1.17 using the network to make voice and video calls;
2.2 The Information you give us may include your name, address, email address and phone number and those
of your contacts, your company name, job title, location, your mobile phone number, age, date of birth,
username, password and other registration information, financial and credit card information,
information about your internet searches and browsing/purchasing preferences.
Information we collect about you and your device. Each time you use your HiHi phone or one of our
Apps and Services we may automatically collect the following adventure,
2.2.1 technical information, including the type of mobile device you use, a unique device identifier
(for example, your HiHi phone’s unique number, the address of the HiHi phone’s wireless
network interface), mobile network information, mail server type, your mobile operating
system, the type of mobile browser you use. time-zone setting;
2.2.2 information stored on your HiHi phone, including contact information, friends lists, login
information, photos, videos or other digital content, check-in; and
2.2.3 details of your usage of the HiHi phone, including telephone numbers dialled, time of day,
duration of call, type of business called, working hours, identity of callers (both incoming and
outgoing), number of calls, call recording, web surfing behaviour including internet visited and
search/browser preferences, and use of any of the Apps and Services, (including, but not
limited to, traffic data, location data, weblogs and other communication data) whether this is
required for our billing purposes or otherwise and the resources that you access.
2.3 Location information. We may also use the information we collected above to determine your current
location. Some of our location-enabled Services and Apps require your personal data for the features to
work. If you wish to use this particular feature, you will be asked to consent to your data being used for
for the purpose. You can withdraw your consent at any time by contacting us in accordance with our
contact details set out in paragraph 12.
2.4 Information we receive from other sources. We are working closely with third-parties (including, for
example, business partners, sub-contractors in technical, payment and delivery services, advertising
networks, analytics provider, search information providers. App developers and credit reference agencies)
and may receive information about you from them.
2.5 If you contact us, HiHi may keep a record of that correspondence.
2.6 Unique application numbers: when you install or uninstall a Service or App containing a unique
application number or when such a Service or App searches for automatic updates, that number and
information about your installation, for example, the type of operating system, may be sent to us.
experience when you use the Apps or browse the internet and also allows us to improve the Apps and Services.
Among the Cookies we utilise are the following:
An analytics platform that is used to measure response to TV advertising.
Cookie Name Type Date Stored Purpose
__adal_ca Persistent Traffic source / campaign
Store which advertising
campaign drove a user to
__adal_cw Persistent Visit timestamp Tie back conversion
events to earlier visits
__adal_id Persistent Device ID (generated) Uniquely identify a device
4 USES MADE OF THE INFORMATION
4.1 We use Information held about you in the following ways:
4.2 Generally in respect of:
4.2.1 to register you on the HiHi phone for an App or Service;
4.2.2 to provide a Service, App or feature you request;
4.2.3 to provide maintenance services;
4.2.4 to identify numbers dialled or calls received;
4.2.5 to provide itemised billing and other billing information to the subscriber;
4.2.6 for the prevention and detection of fraud or crime;
4.2.7 for business monitoring and internal record keeping;
4.2.8 to carry out our function as a telecommunication service provider in particular in order to carry
out the transmission of communications;
4.2.9 to comply with legal obligations.
4.3 Based on your past use of the HiHi phone, your personal profiles, preferences calling habits and user
behaviour including internet user behaviour:
4.3.1 to provide general and tailored content (such as weather, news, traffic and events) and make
4.3.2 for advertising, such as providing customised advertisements and consent (including through
our advertisers) and sending your promotional communications and push information alerts
and notifications to the HiHi phone or your email and mobile device;
4.3.3 to send you service messages and ‘how-to’ information on a personalised basis;
4.3.4 for assessment and analysis of our market, customers, product and services ;
4.3.5 for research and development to better understand the way people use the HiHi phone so we
can improve it and develop new Apps and Services;
4.3.6 to aggregate your information with other information held by us from other users of the HiHi
phone (whether employed by your employer or third-party);
4.3.7 to provide computerised telephony integration services; and/or
4.3.8 otherwise with your consent.
4.4 We may associate any category of information with any other category of information and will treat the
combined information as personal data in accordance with this policy for as long as it is combined.
4.5 We do not disclose information about identifiable individuals to our advertisers, but HiHi may provide
them with anonymous aggregate information about our users (for example, HiHi may inform them that
500 men aged under 30 have clicked on their advertisements on any given day). HiHi may also use such
aggregate information to help advertisers reach the kind of audience they want to target (for example
women in SW1). HiHi may make use of the personal data we have collected from you to enable us to
comply with our advertisers’ wishes by displaying their advertisement to that target audience.
4.6 [The HiHi phone also has capacity to be used as CCTV and facial recognition].
5 DISCLOSURE OF YOUR INFORMATION
5.1 We may disclose your personal information to any member of our HiHi group, which means our
subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the
Companies House 2006.
5.2 We may disclose your personal information to third-parties:
5.2.1 in the event that HiHi sell or buy any business or assets or are negotiating any such sale or
purchase, in which case we may disclose your personal data to the prospective seller or buyer
of such business or assets;
5.2.2 if HiHi or substantially all of its assets are acquired by a third-party, in which case personal data
held by it about its customers will be one of the transferred assets;
5.2.3 if HiHi are under a duty to disclose or share your personal data in order to comply with any
legal or regulatory obligation or request;
5.2.4 in order to:
a) protect the rights, property of safety of HiHi, our customers or others. This includes
exchanging information with other companies and organisations for the purposes of
fraud protection and credit risk reduction; or
5.2.5 we may disclose your personal information to any company within the HiHi group of
companies or to any third-party service provider acting on our behalf (such as cloud service
6 WHERE WE STORE YOUR PERSONAL DATA
6.1 The data that we collect from you may be transferred to, and stored at, a destination outside the
European Economic Area (EEA). It may be processed by staff operating outside the EEA who work for us
or for one of our suppliers. These staff may be engaged in the fulfilment of your request or order, the
processing of your payment details and the provision of support services. By submitting your personal
data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to
6.2 All information you provide to us is stored on our secure servers. Any payment transactions carried out
by us or our chosen third-party provider of payment processing services will be encrypted. Where HiHi
have given you (or where you have chosen) a password that enables you to access certain Services, you
are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Where you have been assigned credentials (or have credentials yourself) to enable you to access services
or data, you are responsible for keeping these confidential. Never share your credentials with other
6.3 Unfortunately, the transmission of information via the internet is not completely secure. Although HiHi
will do our best to protect your personal data, we cannot guarantee the security of your data transmitted;
any transmission is at your own risk. Once HiHi have received the information, we will use strict
procedures and security features to try to prevent unauthorised access.
6.4 We may collect and store personal data on your HiHi phone.
6.5 When using certain Services including social networking, chat room or forum features, ensure that when
using these features that you do not submit any personal data that you do not want to be seen, collected,
or used by other users.
7 DIRECT MARKETING
7.1 HiHi may use information about you which we hold in order to provide you with information about
products or services, promotions, special offers and other information which relates to our products or
services or which we believe may be of interest to you.
7.2 When you provide us with information about yourself, you will be given the option to let us known that
you do not want that information to be used for direct marketing purposes whether by ourselves or by
any third-party (including our commercial partners). We will only use that information for the purpose
of direct marketing in accordance with your preferences (or where HiHi are otherwise permitted to do so
7.3 HiHi may use information about you which we hold in order to provide you with information about
products or services, promotions, special offers and other information which relates to our products or
services or which we believe may be of interest to you.
7.3.2 telephone (including automated calls which means a call which delivers a pre-recorded
message with marketing content to your telephone);
7.3.3 SMS text message and/or any other form of electronic messages (including MMS; picture
messages, video messages, instant messages, and next generation messages);
7.3.6 via an App;
7.3.7 social networking websites;
7.3.8 any mobile telephone media content not referred to elsewhere in this list;
7.3.9 or any other method which becomes relevant from time to time.
8 PRIVACY AND ELECTRONIC COMMUNICATIONS (EC DIRECTIVE) REGULATIONS 2003
8.1 These Regulations specify that we must obtain your consent where we carry out the following actions:
8.1.1 storing or gaining access to information stored in terminal equipment of a user;
8.1.2 processing and storing of traffic data relating to a user; and
8.1.3 processing of location data relating to a user.
8.2 We have set out above the information and data we will be storing and why. Consequently, by agreeing
to the terms of this policy you acknowledge you are giving your informed consent for the purposes of
8.3 You can withdraw your consent to the process of traffic and location data as set out at paragraphs 8.1.2
and 8.1.3 above.
9 YOUR RIGHTS
9.1 You have the right to ask us not to process your personal data for marketing purposes. HiHi will usually
inform you (before collecting data) if we intend to use your data for such purposes or if we intend to
disclose your information to any third-party for such purposes. You can also exercise the right to prevent
such processing at any time by contacting us at email@example.com
9.2 The Apps and Services may, from time to time, contain links to and from the websites of our partner
networks, advertisers and affiliates (including, but not limited to, websites on which the App or the
Services are advertised). If you follow a link to any of these websites, please note that these websites and
any services that may be accessible through them have their own privacy policies and that we do not
accept any responsibility or liability for these policies or for any personal data that may be collected
through these websites or services, such as contact and location data. Please check these policies before
you submit any personal data to these websites or use these services.
10 ACCESS TO INFORMATION
The Data Protection Act 2018 gives you certain rights to access personal information held about you. Your
right of access can be exercised in accordance with that act. Any access request may be subject to a fee of
£10 to meet our costs in providing you with details of the information we hold about you.
appropriate, notified to you by email or when you next log onto the HiHi phone or via website updates
at www.hihi.co.uk. The new terms may be displayed on-screen and you may be required to read and
accept them to continue your use of the HiHi phone App or the Services.