Connected & Protected Ltd t\/a Resolve Telecoms customer privacy notice 

This privacy notice tells you what to expect us to do with your personal information. 

• Contact details 

• What information we collect, use, and why 

• Lawful bases and data protection rights 

• Where we get personal information from 

• How long we keep information 

• Who we share information with 

• How to complain 

Contact details 

Post 

5 Collinson Court, , Church Street, FRODSHAM, Cheshire, WA6 6PN, GB 

Telephone 

01244 555115 

Email 

[email protected] 

What information we collect, use, and why 

We collect or use the following information to provide and improve products and services for clients: 

• Names and contact details 

• Addresses 

• Payment details (including card or bank information for transfers and direct debits) 

• Usage data (including information about how you interact with and use our website, products and services) 

• Credit history and credit reference information 

• Information relating to compliments or complaints 

• Audio recordings (eg calls) 

• Records of meetings and decisions 

• Account access information 

• Website user information 

We collect or use the following personal information for the operation of client or customer accounts: 

• Names and contact details 

• Addresses 

• Purchase or service history 

• Account information, including registration details 

• Information used for security purposes 

• Marketing preferences 

• Technical data, including information about browser and operating systems 

We collect or use the following personal information for information updates or marketing purposes: 

• Names and contact details 

• Addresses 

• Profile information 

• Marketing preferences 

• Purchase or account history 

• Website and app user journey information 

• IP addresses 

We collect or use the following personal information for research or archiving purposes: 

• Names and contact details 

• Addresses 

• Purchase or client account history 

• Website and app user journey information 

• IP addresses 

We collect or use the following personal information to comply with legal requirements: 

• Name 

• Contact information 

• Identification documents 

• Client account information 

• Health and safety information 

• Any other personal information required to comply with legal obligations 

• Safeguarding information 

We collect or use the following personal information to protect client welfare: 

• Names and contact information 

• Client account information 

• Emergency contact details 

We collect or use the following personal information for dealing with queries, complaints or claims: 

• Names and contact details 

• Addresses 

• Payment details 

• Account information 

• Purchase or service history 

• Call recordings 

• Photographs 

• Customer or client accounts and records 

• Financial transaction information 

• Correspondence 

• Location data 

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 set out in brief 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. Read more about the right of access. 

• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification. 

• Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure. 

• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing. 

• Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing. 

• 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. Read more about the right to data portability. 

• Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent. 

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 and improve products and services for clients 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 rely on legitimate interests where processing personal information is necessary to operate, maintain and enhance our telecoms services in ways that benefit our clients while safeguarding individuals’ rights and privacy. This includes processing information to ensure network reliability, prevent fraud or misuse, improve service quality and develop features that enhance the client experience. This processing is legitimate because clients reasonably expect a telecoms provider to monitor performance, protect the integrity of the network and ensure their service operates securely and efficiently. These activities directly support the delivery of a high-quality and dependable service, which is in the interests of both our organisation and our clients. It is necessary because, without using certain information such as account identifiers, service usage data, technical performance information or security-related events, we would be unable to detect issues, prevent service interruptions, investigate faults, protect systems from threats, or make informed improvements to our infrastructure. The benefits to clients include improved reliability, stronger security, faster problem resolution, reduced service downtime, and the development of products that better meet their needs. These benefits outweigh the limited risks, which we minimise by only processing the information we need, applying strict access controls, using secure systems, and ensuring individuals can exercise their data protection rights at any time. We do not use this information in ways that would override individuals’ interests or expectations. Our assessments show that the processing is proportionate, supports essential service functions and improvements, and does not create undue impact on the people whose information is involved. 

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above. 

Our lawful bases for collecting or using personal information for the operation of client or customer accounts 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. 

• 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 rely on legitimate interests where processing personal information is necessary to operate client accounts efficiently and provide a smooth and reliable service experience. This includes using information to manage account details, monitor service status, respond to enquiries, maintain accurate records, and ensure clients receive timely and effective support. This processing is legitimate because clients reasonably expect a telecoms provider to use their information to keep their account functioning properly. It enables us to provide a consistent and high-quality service, support ongoing communication, prevent errors, and ensure that any issues affecting an account are identified and resolved quickly. It is necessary because we must use certain personal information—such as contact details, service identifiers, and account history—to manage day-to-day account operations. Without this information we would be unable to maintain accurate account information, support clients, deliver updates, or communicate about service issues that may affect them. The benefits to clients include smoother account management, faster support, fewer service disruptions, improved accuracy of account records, and clearer communication. These benefits outweigh the limited risks, which we mitigate by strictly limiting access to account information, applying strong security measures, and ensuring that individuals are able to exercise their data protection rights easily. We do not use account information in ways that would override individuals’ interests or cause undue impact. Our legitimate interest assessments show that the processing is proportionate, supports the efficient operation of customer accounts, and aligns with what clients reasonably expect from a business telecoms provider. 

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above. 

Our lawful bases for collecting or using personal information for information 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. 

• 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 rely on legitimate interests for certain types of information updates and non-intrusive marketing communications that are relevant to our existing clients. This includes sharing service updates, product improvements, important changes that may affect their telecoms services, and information that helps clients make informed decisions about the solutions they use. This processing is legitimate because clients reasonably expect to receive updates about the services they already have with us, as well as information that may improve their telecoms performance, reliability or cost-efficiency. These communications help ensure that clients are aware of developments that could benefit their business operations. It is necessary because we need to use basic contact information, such as names and email addresses, to keep clients updated about relevant service matters or new options that may enhance their existing setup. Without processing this information, we could not provide timely updates, notify clients about important service-related issues, or share improvements that may support their business needs. The benefits to clients include staying informed about service changes, improved performance and security, access to new features, and the ability to make better decisions about their telecoms services. These benefits are balanced carefully against any potential impact on individuals. We minimise risks by keeping communications relevant, proportionate and infrequent, giving clients clear opt-out options, and ensuring we do not use their information in unexpected ways. We do not place our interests above those of individuals. Our approach ensures that the communications we send are genuinely useful, aligned with client expectations and supported by safeguards that protect privacy and uphold individuals’ rights. 

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above. 

Our lawful bases for collecting or using personal information for research or archiving purposes: 

• 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 rely on legitimate interests when we use personal information for internal research and archiving purposes that help us improve the quality, reliability and efficiency of our telecoms services. This may include analysing historical service data, reviewing account records, identifying usage patterns, and assessing how our products perform over time. This processing is legitimate because clients reasonably expect a telecoms provider to review past information to improve service performance, strengthen security, and develop better products. These activities support a more reliable network, faster issue resolution, and overall improvements that directly benefit clients. It is necessary because without retaining and reviewing certain information, we would be unable to understand how our services are used, diagnose recurring issues, identify long-term trends, or make informed decisions about upgrades and improvements. Archiving relevant information also enables us to maintain accurate records, support consistency in service delivery, and meet certain regulatory expectations. The benefits to clients include more resilient telecoms services, better-informed support, improved infrastructure planning, and the development of solutions that reflect real-world needs. These benefits outweigh the minimal risks, which we reduce through strong access controls, limited retention periods, secure storage, and ensuring that archived information is used responsibly and proportionately. We do not use archived or research information in ways that would override individuals’ rights or expectations. Our assessments show that this processing is proportionate, aligned with industry norms, and carried out with measures that protect privacy at all stages. 

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above. 

Our lawful bases for collecting or using personal information to comply with legal requirements: 

• 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 protect client welfare are: 

• 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 rely on legitimate interests when we use personal information to protect the welfare of our clients in the context of their telecoms services. This includes processing information to prevent fraud, protect accounts from unauthorised access, safeguard clients from service misuse, identify security risks, and notify them of issues that may affect their ability to use their telecoms services safely and effectively. This processing is legitimate because clients reasonably expect their telecoms provider to take proactive steps to protect their accounts, maintain the security of their communications, and alert them to risks that may impact their business operations. Protecting clients from harm, disruption or misuse is an important part of delivering a trustworthy telecoms service. It is necessary because we must use certain personal information—such as account identifiers, usage patterns or security alerts—to identify unusual activity, respond to risks quickly, prevent service-related fraud, and ensure clients remain in control of their accounts. Without processing this information, we would be unable to detect or respond effectively to situations where a client’s welfare or service security could be compromised. The benefits to clients include stronger protection from fraud or misuse, fewer disruptions, enhanced account security, increased reliability of services and early detection of potential issues. These benefits outweigh the limited risks, which we minimise through strict access controls, secure processing, data minimisation and clear options for clients to contact us or raise concerns. We do not process information in ways that override individuals’ rights or expectations. Our measures ensure that the processing is proportionate, aligned with normal industry practices and genuinely focused on safeguarding clients and supporting their welfare in relation to their telecoms services. 

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above. 

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims 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. 

• 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 rely on legitimate interests when we process personal information to respond to queries, resolve complaints and handle claims from clients. This processing is necessary for us to investigate issues properly, provide accurate and timely responses, improve our services and ensure that clients receive the support they reasonably expect from a telecoms provider. This processing is legitimate because both our organisation and our clients benefit from clear communication, efficient problem resolution and effective complaint handling. Clients expect us to use relevant information to understand their situation, look into their concerns, and resolve matters fairly. It also helps us identify trends or recurring issues so we can make improvements that benefit all clients. It is necessary because we need to access certain personal information—such as contact details, account history, service records and communication logs—to understand what has happened and to put things right. Without processing this information, we would be unable to investigate concerns, provide meaningful support, or defend ourselves against claims if needed. The benefits to clients include faster resolution of issues, more accurate responses, improved service reliability and a fair and transparent process for addressing concerns. These benefits outweigh the limited risks, which we manage through secure handling of information, strict access controls, and ensuring we only use the data that is relevant for dealing with the query, complaint or claim. We do not process information in ways that override individuals’ rights or place our interests above theirs. Our approach ensures that the processing is proportionate, respectful of privacy and aligned with what clients reasonably expect when raising a question or concern about their telecoms services. 

For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above. 

Where we get personal information from 

• Directly from you 

• Publicly available sources 

• Suppliers and service providers 

• Third parties: 

• We may receive personal information from trusted third parties who are involved in delivering, supporting or managing telecoms services on behalf of our clients. These third parties typically include: Authorised resellers or partners We may receive contact details, service requirements, or account setup information from authorised partners who have been engaged by the client to arrange or manage telecoms services. Technology and platform providers Some personal information may be shared with us by hosted telephony platforms, network operators, connectivity carriers or billing system providers where this is needed to activate services, resolve service issues or support client accounts. Client representatives or intermediaries Information may come from individuals or organisations acting on behalf of a client, such as IT support companies, administrators or nominated account managers who are authorised to liaise with us. These third parties only provide information that is necessary for service delivery, support or account management, and we ensure that any personal data shared with us is handled securely and in line with our data protection responsibilities. 

How long we keep information 

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For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above. 

Who we share information with 

Joint data controllers 

We have a joint controller relationship with Data Shepherd. We process your personal information with that joint controller for the following reason: Why do you work with the joint controller? We work with the joint controller because our services require shared responsibility for determining how certain personal information is collected, used, and managed. Both parties contribute to the design and delivery of the service, and this means we must jointly decide the purpose of processing, the categories of data involved, and the lawful basis relied upon. Working together ensures that individuals receive a consistent experience, that data is handled in a transparent and coordinated way, and that all relevant legal obligations, particularly those relating to data protection, are met. What processing do you carry out with the joint controller? The processing we undertake jointly reflects the purposes identified in “Why do you collect or use personal information?” and includes activities where both parties actively determine how and why personal data is used. Collecting and assessing personal information Both parties determine which personal information is necessary and gather it through agreed channels such as contact forms, customer onboarding, enquiries, or service-delivery processes. Sharing relevant personal data to deliver services We exchange the specific information required to provide the contracted service effectively. This may include contact details, service-related information, and enquiry or case information. This sharing is deliberate and controlled, and both parties jointly decide what is necessary and proportionate. Coordinating responses and actions based on that data We jointly use the information to assess customer or client needs, provide accurate information or support, manage ongoing relationships or communications, and ensure a smooth and consistent user experience. Both controllers take an active role in determining how the information informs decisions. Maintaining compliance and accountability Together, we determine how long data should be retained, what security measures apply, how individual rights requests are handled, and how to demonstrate compliance to regulators. These decisions are made collaboratively and form part of our shared responsibilities under the joint controller arrangement.. 

Data processors 

Hosted telephony platform providers 

This data processor does the following activities for us: Operate and support our hosted phone systems. 

Network and connectivity providers 

This data processor does the following activities for us: Supply and maintain broadband, SIP and telecoms network services. 

Others we share personal information with 

• Regulatory authorities 

• Organisations we’re legally obliged to share personal information with 

• Publicly on our website, social media or other marketing and information media 

• Suppliers and service providers 

• Professional consultants 

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 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 26/11/2025