Who we are: Titus Telecom (“Titus”, “we”, “us”, “our”). We provide hosted telephony/connectivity services and IoT cellular connectivity. We are the controller of personal data described in this notice, unless stated otherwise. In some situations, we also act as a processor — see “When we act as a processor”.
Contact us:
Email: support@titustelecom.co.uk | Phone: +44 (0)1934 818440
Postal: Postal (for written enquiries): our current registered office address (as listed at Companies House). For the up-to-date address, see our website Contact page
1) What this notice covers
This notice explains what personal data we collect, how and why we use it, our lawful bases, who we share it with, how long we keep it, international transfers, your rights, and how to contact us or the ICO. It is designed to meet the transparency and “right to be informed” requirements of the UK GDPR (Articles 12–14).
2) The data we collect
We collect different types of information depending on how you interact with us and which services you use:
a) You and your organisation
• Identity & contact details (e.g., name, job title, business email, phone, employer). • Account and billing information, orders, direct‑debit details (via secure payment partners). • Communications with us (tickets, calls, emails). • Marketing preferences. • Website interactions (see “Cookies & analytics”).
b) Hosted Telephony/Connectivity (when you use our services)
• Service configuration data (numbers/CLI assignments, extensions, SIP credentials), call detail records/traffic metadata, quality metrics, logs, voicemail/recordings if enabled. We process these for service provision, billing, security/fraud prevention and legal compliance.
c) IoT Cellular (data‑only SIMs for IoT/M2M)
• SIM identifiers (IMSI/MSISDN/ICCID), IoT line/account data, usage and traffic metadata, APN, IP/log data for diagnostics and security. V1.1
Special category data: We do not intentionally process special category data through our services. If you choose to route such data, you are responsible for any additional safeguards and lawful bases needed.
3) Why we use your data and our lawful bases
|
We only use personal data where we have a lawful basis under UK GDPR. The table below links our purposes to the lawful basis relied on: Purpose |
Examples (non‑exhaustive) |
Lawful basis |
|
Provide and support our services |
Provisioning hosted voice/IoT SIMs, routing calls/data, diagnostics, ticketing, number management, service changes. |
Contract (to deliver the services you order). |
|
Billing & account management |
Invoicing, payments, debt recovery, credit control. |
Contract; Legitimate interests (recover sums due). |
|
Security, fraud & abuse prevention |
Protect network integrity, detect Artificially Inflated Traffic (AIT)/SMS pumping, abuse or attacks; ensure lawful‑intercept compliance. |
Legitimate interests; Legal obligation. |
|
Regulatory & legal compliance |
Record‑keeping, responding to lawful requests, compliance with telecoms/PECR obligations. |
Legal obligation. |
|
Customer communications |
Service notifications, changes to terms, incident updates. |
Contract; Legitimate interests (service communications). |
|
Direct marketing (B2B) |
Emails to business contacts about relevant services; event invites. |
Legitimate interests (with clear opt‑out) and subject to PECR. |
|
Website analytics & cookies |
Measure and improve our site; remember preferences. |
Consent for non‑essential cookies under PECR. |
Where we rely on legitimate interests, we balance our interests with your rights and freedoms and you can object at any time (see “Your rights”).
4) Cookies, analytics and similar technologies
We use cookies and similar technologies on our website. We will tell you what we use and why, and will obtain your consent for any non‑essential cookies (e.g., analytics/advertising). Only strictly necessary cookies operate without consent (e.g., those essential for a service you request). You can change or withdraw consent at any time via our cookie controls. These principles follow PECR and the ICO’s guidance. V1.1
5) When we act as a processor (on your instructions)
For certain features (e.g., call recordings/voicemail content, address books you upload), we process Customer Personal Data on your documented instructions under our Annex A – Data Processing Schedule (DPA). That DPA sets out roles, security, sub‑processors, transfer mechanisms and deletion/return.
6) Who we share data with
• Network providers and carriers (to deliver connectivity and routing). • Platform and infrastructure providers (voice platforms, SIM/IoT management, hosting, ticketing, billing). • Professional advisers (legal, audit), and authorities when legally required.
We require recipients to protect data appropriately and only use it for the intended purposes.
7) International transfers
Where we transfer personal data outside the UK, we use appropriate safeguards under UK GDPR, typically the International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, together with any required Transfer Risk Assessment. We only proceed where protection is not materially lower post‑transfer.
8) How long we keep data
We apply retention aligned to purpose and legal/regulatory requirements (e.g., tax, complaints handling, telecoms rules). We delete or anonymise when no longer needed. (See also Annex A DPA for processor‑data deletion and limited statutory exceptions).
9) Your rights
Under UK GDPR you have rights including: to be informed, access, rectification, erasure, restriction, objection, data portability, and rights related to automated decision‑making/profiling. These rights are free of charge and we aim to respond within one month (we may extend by up to two months for complex/voluminous requests and will tell you why).
You can object to direct marketing at any time, and we will honour that promptly. V1.1
10) How to exercise your rights
Email support@titustelecom.co.uk with the subject “Data rights request”, or write to our current postal address found on company house. We may need to verify your identity to protect your data. We’ll keep a simple log of requests to demonstrate compliance.
11) Direct marketing (B2B)
For business‑to‑business marketing, we follow UK GDPR and PECR. Some channels require consent; others may be sent on legitimate interests where permitted. In every case, we will identify ourselves, explain how to opt out, and honour opt‑outs.
12) Security
We implement technical and organisational measures appropriate to risk (access controls, encryption in transit where applicable, role‑based permissions, logging, resilience and backup, staff confidentiality). No provider can guarantee absolute security, but we continually improve our controls.
13) Children
Our services are business‑focused and not directed at children. If you believe a child has provided us personal data, please contact us and we will take appropriate steps.
14) Complaints
If you have concerns about our use of your personal data, please contact us first. You also have the right to complain to the Information Commissioner’s Office (ICO). See the ICO’s website for guidance on rights and how to contact them.
15) Changes to this notice
We may update this notice to reflect changes in law or our services. We’ll post the latest version at https://www.titustelecom.co.uk/legal/privacy and, where appropriate, notify you via email or your account. Please check back periodically.
16) Quick reference: lawful bases we most often rely on
• Contract (to deliver the services you ask us to provide). • Legitimate interests (e.g., network security, preventing fraud/AIT, B2B marketing, improving services) — always balanced with your rights and with opt‑out for marketing. • Legal obligation (e.g., to comply with applicable law/regulatory requirements). • Consent (e.g., non‑essential cookies/analytics; any optional services that require consent).
