DigiAssist
PRIVACY POLICY
Introduction
Welcome to the DigiAssist Privacy Notice.
DigiAssist (hereinafter “DigiAssist” or “web app”) is a web-based application that serves as an aid for simple trouble-shooting internet issues, such as slow speeds, for Digicel (Trinidad & Tobago) Limited’s customers.
At Digicel, we respect your privacy and we are committed to protecting your personal data and earning your trust. This privacy notice is to give you clarity and transparency on the ways in which we may use your personal data.
Our goal is for you to understand i) how we look after your personal data when you visit or interact with the web app and ii) your privacy rights and how the law protects you.
1. Scope of This Notice and Who We Are
Purpose of this Privacy Notice
This Privacy Notice aims to give you information on how Digicel collects and processes your personal data through your use of DigiAssist, which includes but is not limited to any data you may provide when you utilise the features within the web app; also, when you get in contact with us through the web app.
Personal data is collected for all users of the web app. We do not knowingly collect data from or about individuals under the legal minimum age without the permission of their parent or guardian. When we do collect that data, we might do it directly, like when contact is initiated with us. We might also collect it automatically if your child uses the products or services offered within the web app.
Different products and services collect different kinds of data. It is important that you read this Privacy Notice together with any other privacy, customer or regulatory notices we may provide for specific products and services, and on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. Where applicable, this Privacy Notice supplements other notices and Digicel privacy notices and is not intended to override them.
Controller
Digicel (Trinidad & Tobago) Limited is the Data Controller (collectively referred to as “Digicel”, "we", "us" or "our" in this privacy notice) of data collected solely via DigiAssist Digicel (Trinidad & Tobago) Limited is a company registered under the laws of Trinidad and Tobago with registered office at Ansa Centre, 11C Maraval Road, St. Clair, Port of Spain, Trinidad. We are a subsidiary of the Digicel Group of Companies.
Contact Details
We have a privacy team that is responsible for handling all enquiries in relation to this Privacy Notice. The Group Privacy Team is available to answer any questions you may have about this privacy notice, including any requests to exercise your legal rights.
Depending on the market or territory within which you reside, you may also have the right to make a complaint to your regulator of privacy rights or data protection issues. However, we would appreciate the chance to deal with your concerns before you approach your regulator, so please contact us in the first instance.
For all queries regarding this Privacy Notice or our privacy practices, please email the Digicel Privacy Team at privacy@digicelgroup.com
Changes to the privacy notice and your duty to inform us of changes
We endeavour to keep our privacy notice under annual review. This version was last updated on 1st May, 2023.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-Party Links
DigiAssist may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins or applications and are not responsible for their privacy statements. Where necessary, we will provide a notice and link to the third party’s privacy notice. When you leave DigiAssist, we encourage you to read the privacy notice of every other application and website you visit.
Please see further information on Third Parties in the Glossary below.
2. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. In Jamaica only, this definition extends to personally identifiable information for individuals who have been deceased for less than thirty years.
Personal data shall not be extended to or include any data where identifiable information has been removed (anonymous data) or an individual’s identity is not ascertainable from the data set, whether on its own or combined with other known information.
You understand that as a current Digicel customer, your personal data may have previously been collected and processed pursuant to other relevant Privacy Notices, Terms and Conditions. Further, you understand that your consent provided upon signing up to be a Digicel customer warrants our access and relevant processing of your personal data relating to your account, including but not limited to, full name, national identification number (identity data); Digicel ID, account number, password, security credentials (profile data); address, email address, telephone number (contact data); financial data; transactional and other details about your account and related products and/or services; for fulfilment of the services under the web app.
Additionally, and specific to your use of DigiAssist, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Technical Data includes internet protocol (IP) address, your login data, unique device ID, browser type and version, location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this web app.
- Profile Data includes your Digicel ID, Digicel account number, and password.
- Usage Data includes information about how you use our web app, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Other Data deemed necessary for any of the purposes noted under Section 4, which may be collected from our Internal and External Third Parties, as defined in the Glossary, with or upon your consent.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific web app feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not intentionally seek to collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, you may not be able to access the services offered via the web app, or we may have to cancel a product or service you have with us; but we will notify you if this is the case at the time.
3. How is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
- Direct Interactions. You may give us your Profile Data and other personal data when you:
- interact with our web app, including making customer enquiries, registering for information or other services;
- enter a competition, promotion or survey, provide feedback, or respond to communications from us (such as SMS, emails, questionnaires); or
- contact us and provide your information via online customer support, customer call centres or our physical locations.
- Automated Technologies or Interactions. As you interact with our web app, we will automatically collect Technical Data about your equipment, browsing actions, in-app activity and patterns. We collect this personal data by using web app permissions where applicable, cookies and other similar technologies. Some of these technologies may also receive Technical Data about you if you visit other websites. Please see our Cookie Notice for further details.
- Third Parties or Publicly Available Sources. To assist us in providing you with the best experience, we may receive and/or share any personal data about you deemed necessary for any of the purposes noted under Section 4. Generally, we receive or share your personal data from and/or with various public sources, and our Internal, External and Specific Third Parties, as defined in the Glossary, with or upon your explicit consent.
4. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data, where more than one ground has been set out in the table below.
Table 1: Purposes for use of your personal data
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To process and deliver to you the services offered within the web app | (a) Profile |
(a) Performance of a contract with you (b) Consent |
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice (b) Asking you to leave a review or take a survey |
(a) Profile (b) Usage (c) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) (d) Consent |
| To administer and protect our business and our web app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Profile (b) Technical (c) Usage |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation (c) Consent |
| To deliver relevant application content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Profile (b) Usage (c) Technical (d) Marketing and Communications (e) Technical |
(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) (b) Consent |
| To use data analytics to improve our web app, products/services, marketing, customer relationships and experiences |
(a) Technical (b) Usage |
(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our web app updated and relevant, to develop our business and to inform our marketing strategy) (b) Consent |
| To make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Profile (b) Technical (c) Usage (d) Marketing and Communications |
(a) Necessary for our legitimate interests (to develop our products/services and grow our business) (b) Consent |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use a combination of your previously collected data and your Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving direct marketing communications.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Cookies
Cookies are small text files placed on a computer, tablet, or smartphone by websites you visit, generally used to make websites function properly.
You can set your browser to refuse all or some browser cookies, or to alert you when websites or web apps set or access cookies. If you disable or refuse cookies, please note that some parts of this web app may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Notice.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us .
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in Table 1: Purposes for use of personal data above.
- Internal Third Parties as set out in the .
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We share your personal data within entities throughout the Digicel Group of Companies.
Whenever we transfer your personal data out of the country of origin, however, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts that ensure an adequate level of protection through the use of technical and organizational measures.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data internationally.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data Retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Where you have decided to withdraw the consent you have given, we will use best efforts to delete your personal data within thirty (30) days, unless we are required to keep it for the reasons explained herein. We may need to keep a piece of your contact information linked to your Digicel account, e.g. email address, in our records, so we know that you have withdrawn your consent and therefore ensure we honour your choice.
Details of retention periods for different aspects of your personal data are available in our retention schedule which you can request from us by contacting us at privacy@digicelgroup.com .
9. Your Legal Rights
In some countries and under certain circumstances, you have rights in relation to your personal data. You may have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasureof your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. In order to exercise any such legal claim, we may require a court or administrative order, subpoena or other such legal or regulatory proclamation.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to explore or exercise any of the rights set out above, please contact the Group Privacy Team at privacy@digicelgroup.com .
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within sixty (60) days. Occasionally, it could take us longer than sixty (60) days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Glossary
i. LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
ii. THIRD PARTIES
Internal Third Parties
Other companies in the Digicel Group may act as joint controllers or processors, provide IT and system administration services and/or process personal data through leadership reporting. The list includes:
| Data Controllers / Digicel Affiliates | Territory |
|---|---|
| Wireless Ventures (Anguilla) Ltd. | Anguilla |
| Caribbean Cable Communications (Anguilla) Ltd. | Anguilla |
| Antigua Wireless Ventures Limited | Antigua & Barbuda |
| New Millennium Telecom Services N.V T/A Digicel Aruba | Aruba, Netherland Antilles |
| Digicel (Barbados) Limited | Barbados |
| Digicel Caribbean Limited | Barbados |
| The Bermuda Telephone Company Ltd. | Bermuda |
| Telecommunications (Bermuda and West Indies) Ltd. | Bermuda |
| Digicel Suriname N.V. | Suriname |
| Antilliano Por N.V. T/A Digicel Bonaire | Bonaire |
| Digicel (BVI) Limited | British Virgin Islands |
| Digicel SVG Limited | St. Vincent & The Grenadines |
| Digicel Panama S.A | Panama |
| Digicel (Cayman) Limited | Cayman Islands |
| Digicel (Trinidad & Tobago) Limited | Trinidad & Tobago |
| Curacao Telecom N.V. T/A Digicel Curaçao | Curaçao |
| Digicel Bonaire Antilliano Por N.V. | Curaçao |
| Santa Barbara Utilities N.V. T/A Tres Networks | Curaçao |
| Wireless Ventures (Dominica) Limited | Dominica |
| Digicel S.A. de C.V. | El Salvador |
| Digicel (Grenada) Limited | Grenada |
| U-Mobile Cellular Inc | Guyana |
| Unigestion Holding S.A | Haïti |
| Digicel (Jamaica) Limited | Jamaica |
| Caribbean Cable Communications (Montserrat) Limited | Montserrat |
| Digicel (St Lucia) Limited | St. Lucia |
| Prism Services Holdings Limited | St. Lucia |
| Digicel Antilles Françaises Guyane | Martinique |
| Idom Technologies SAS (c/o Digicel Antilles Françaises Guyane) | Martinique |
| Digicel French Caribbean | Martinique |
| Southern Caribbean Fiber | Guadeloupe |
| Digicel Investments France | Guadeloupe |
| Digicel St. Kitts Wireless Ventures (St. Kitts & Nevis ) Limited T/A Digicel St. Kitts & Nevis | St. Kitts & Nevis |
| Digicel Turks and Caicos Ltd | Turks and Caicos Islands |
| Caicos Television Holdings Ltd | Turks and Caicos Islands |
External Third Parties
- Service providers acting as processors who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Relevant regulators and other authorities as required by law (that may act as processors or joint controllers), who may require reporting of processing activities in certain circumstances.