We will only use your personal data when the law allows us to, most commonly, in the following circumstances:

Where we need to perform the terms and conditions we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

We have set out below, 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 basis depending on the specific purpose for which we are using your data.

Purpose

To register you as a new customer

Type of data

(a) Identity (b) Contact

Lawful basis for processing including basis of legitimate interest

Performance of terms and conditions with you and where applicable, as required by law

Purpose

To supply products and services to you including: Managing payments collecting money owed to us

Type of data

(a) Identity (b) Contact (c) Financial (d) Billing

Lawful basis for processing including basis of legitimate interest

(a) Performance of terms and conditions with you (b) Necessary for our legitimate interests (to recover sums owed to us)

Purpose

To manage our relationship with you and administer your account which will include:

• Notifying you about changes to our terms and conditions or privacy policy

• Detecting and preventing crime and fraud

• Asking you to leave a review or take a survey

• Manage any concerns that you raise to our customer care department

• Quality assurance and monitoring purposes

Type of data

(a) Identity (b) Contact (c) Profile (d) Marketing and communications (e) Customer care (f) Usage

lawful basis for processing including basis of legitimate interest

(a) Performance of terms and conditions 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)

Purpose

To enable you to participate in a competition or complete a survey (non-promotional)

Type of data

(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and communications

Lawful basis for processing including basis of legitimate interest

(a) Performance of terms and conditions with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

Purpose

To market products and services to you To complete a survey (promotional)

Type of data

(a) Identity (b) Contact (c) Marketing and communications (d) Profile

Lawful basis for processing including basis of legitimate interest

(a) Legitimate interest to process marketing data (to grow our business) and consent for sending electronic marketing communications for new customers or reliance on existing customer relationship to send electronic marketing communications

Purpose

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data

(a) Technical (b) Usage

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose

To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data

(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile

Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to develop Lyca Mobile products/services and grow our business)

Marketing

You will receive marketing communications from us either if you have consented to receive them or you have purchased products or services from Lyca Mobile, and in each case, you have not opted out of receiving that marketing. You will also receive marketing communications from other Lyca entities if you have consented to receive such communications on their Lyca products or services.