Mobile Genie | Privacy Policy

Introduction
1.1 This Privacy Policy explains how Bramden Limited (“we”, “us”, “our”) collects and uses personal data when you visit our paid-advertising landing page, submit your details for a callback or quotation, or otherwise interact with us about business mobile, data and related services.
1.2 We process personal data in accordance with the UK GDPR and the Data Protection Act 2018 and, if applicable, the Isle of Man Data Protection Act 2018 (Applied GDPR).
1.3 By submitting your details, you acknowledge that you have read this Privacy Policy. Where we rely on consent for direct marketing, you may give or refuse consent using the tick-box at the point of collection and you can withdraw consent at any time.
Data controller and contact details
2.1 The data controller is Bramden Limited, company number 03331V with registered address at No. 5, Victoria Street, Douglas, Isle of Man, IM1 2LR.
2.2 You can contact us at googleppc@bramden.com about this Privacy Policy or your data protection rights.
What we collect
3.1 Identification and contact data: name, job title, business name, business email, business phone number, and any information you include in free-text fields.
3.2 Marketing and communications data: your preferences for receiving marketing from us and your communication preferences.
3.3 Technical and usage data: IP address, device identifiers, approximate location, pages viewed, referral source (including the paid advert you clicked), session duration and similar analytics.
3.4 Tracking data: cookies, pixels and similar technologies used for analytics, performance measurement and ad-campaign attribution.
3.5 Call recordings: if you speak with us by phone and we record calls for training and quality purposes, we will tell you at the start of the call.
How we obtain data
4.1 Direct interactions when you complete our web form, request a callback or communicate with us.
4.2 Automated technologies through cookies, pixels and similar technologies when you view or interact with our landing page.
4.3 Third-party sources such as advertising platforms and analytics providers that report campaign performance and attribution.
Roles, purposes and lawful bases
5.1 We act as data controller for all personal data collected via the landing page and related channels.
5.2 We engage Plan Communications Limited (“Plan”) as our processor to contact you on our behalf about the advertised product and associated services and to assist us in handling and tracking your enquiry. Plan processes your personal data only on our documented instructions and for no other purpose.
5.3 Handling your enquiry and pre-contract steps: to contact you (including via Plan on our behalf), to provide quotes and proposals, and to discuss our services. The lawful basis is legitimate interests (to respond to your request) and, where applicable, steps prior to entering into a contract at your request.
5.4 Direct marketing: to send information about our services by email, phone or SMS, including where communications are sent by Plan on our behalf strictly in accordance with our instructions. The lawful basis is consent where required by law, or legitimate interests for business-to-business marketing to corporate subscribers where permitted. You can opt out at any time.
5.5 Analytics and campaign attribution: to measure and improve the performance of our landing page and paid advertising. The lawful basis is consent where required for non-essential cookies, otherwise legitimate interests.
5.6 Compliance and security: to comply with legal obligations, maintain records, prevent fraud and secure our systems. The lawful bases are legal obligation and legitimate interests.
Cookies and tracking technologies
6.1 We use essential cookies that are necessary for the site to function and non-essential cookies and pixels for analytics and advertising attribution.
6.2 Where required, we will request your consent for non-essential cookies via a consent banner. You can change your preferences at any time using here: Manage Cookies. Further information is set out in our Cookie Policy.
Disclosures of personal data
7.1 We share personal data with Plan Communications Limited as our processor to contact you on our behalf about the advertised product and to support enquiry handling, CRM and attribution activities under our instructions and subject to a written data processing agreement.
7.2 We share personal data with other service providers acting as processors who provide hosting, CRM, marketing, analytics, call and email services, and site security, each under a written data processing agreement.
7.3 We may share limited data with advertising platforms for attribution and performance reporting, subject to your consent where required.
7.4 We may disclose data to professional advisers and to authorities where required by law or to protect legal rights.
7.5 We do not sell your personal data.
International transfers
8.1 Where processors or platforms (including Plan’s sub-processors engaged on our instructions) are located outside the UK or Isle of Man, we ensure appropriate safeguards such as the UK International Data Transfer Agreement or Standard Contractual Clauses and, where relevant, transfer risk assessments. Details are available on request.
Data processing arrangements
9.1 We have entered into written data processing terms with Plan that meet the requirements of UK GDPR Article 28, including obligations on confidentiality, security, sub-processing, assistance with data subject rights, and deletion or return of personal data at the end of the services.
9.2 Plan will not determine its own purposes or means of processing your personal data and will not use your personal data for its own marketing. Plan may contact you only to the extent necessary to fulfil our instructions in connection with your enquiry and any consent you provide to us.
Data retention
10.1 Enquiry and lead records are retained for 12 months from the last meaningful interaction unless you ask us to delete them sooner, subject to legal and regulatory record-keeping requirements.
10.2 Marketing preference records are retained until you withdraw consent or object, after which we retain a minimal suppression record to honour your request.
10.3 Technical logs may be retained for 12 months for security and diagnostics.
Your rights
11.1 You have the right to request access, rectification, erasure, restriction, data portability and to object to processing, and the right to withdraw consent at any time where processing is based on consent.
11.2 To exercise these rights, contact googleppc@bramden.com. We may need to verify your identity.
11.3 You also have the right to lodge a complaint with the Information Commissioner’s Office (UK) or, if applicable, the Isle of Man Information Commissioner.
Security
12.1 We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure or destruction, taking into account the nature of the data and the risks of processing. We require our processors, including Plan, to do the same.
Automated decision-making
13.1 We do not carry out automated decision-making that produces legal or similarly significant effects on you.
Third-party links
14.1 Our landing page may include links to third-party sites. Those sites have their own privacy policies and we are not responsible for them.
Changes to this Privacy Policy
15.1 We may update this Privacy Policy from time to time. The version date will appear at the top of the page. Material changes will be highlighted appropriately.
Contact
16.1 Questions about this Privacy Policy or our processing of personal data should be sent to googleppc@bramden.com.