This Privacy Policy explains how JOYNEWPHONE collects, uses, stores, and protects your personal data when you use our website or services. We are committed to handling your information responsibly and in full compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Please read this policy carefully.
WHO WE ARE
JOYNEWPHONE ("we", "us", "our") is a UK-based phone comparison and advisory service that helps consumers find competitive mobile phone upgrade and new contract deals across all major UK networks. We are registered in England and Wales.
For the purposes of UK data protection law, JOYNEWPHONE is the Data Controller responsible for your personal data. This means we determine the purposes and means by which your personal information is processed.
Our contact details are:
- Telephone: 02035 043106 (Mon–Fri 8am–8pm, Sat 9am–5pm)
- Email: privacy@joynewphone.online
- Website: www.joynewphone.online
- Registered in England & Wales
Our designated Data Protection Contact can be reached at the email address above for any data-related enquiries.
DATA WE COLLECT
We collect personal data in the following ways, and only collect information that is necessary, relevant, and proportionate to providing our services.
Information you provide directly to us:
- Identity Data: Your first name and last name, as provided when you complete our quote request form or contact us.
- Contact Data: Your mobile phone number and email address, used to provide your quote and communicate with you about your enquiry.
- Preference Data: Your stated preferences regarding handset brand, monthly budget, data allowance, contract type (upgrade, new contract, or SIM only), and preferred callback time.
- Communication Data: Records of any calls, emails, or messages exchanged between you and our advisors, including call recordings made for training and compliance purposes. You will be informed when a call is being recorded.
- Transaction Data: If you proceed to take a phone deal through us, we retain details of the deal arranged, including the network, handset, contract length, and monthly cost.
Information collected automatically:
- Technical Data: Your IP address, browser type and version, operating system, device type, time zone, and the pages you visit on our website, collected via cookies and similar tracking technologies.
- Usage Data: Information about how you interact with our website, including which pages you visit, how long you spend on each page, which links you click, and the source of your visit (e.g., search engine, referral link, or direct visit).
Information we do not collect:
- We do not collect Special Category Data (such as health information, biometric data, or political opinions).
- We do not collect full payment card details. Any payment processing is handled by regulated third-party providers.
- We do not knowingly collect data from individuals under the age of 18.
HOW WE USE YOUR DATA
We use the personal data we collect for specific, explicit, and legitimate purposes. We will not use your data in a way that is incompatible with the purpose for which it was collected.
| Purpose | Data Used | Legal Basis |
|---|---|---|
| Process your quote request and provide tailored phone deal recommendations | Identity, Contact, Preference | Contractual necessity / Legitimate interests |
| Arrange a callback from one of our UK-based advisors | Identity, Contact | Contractual necessity |
| Search network tariffs and communicate available deals to you | Preference, Contact | Legitimate interests |
| Send you a summary of your quote or deal by email or SMS | Contact, Transaction | Contractual necessity |
| Record and monitor telephone calls for training and compliance | Communication | Legitimate interests / Legal obligation |
| Send marketing communications about new deals or offers (only with your consent) | Identity, Contact | Consent |
| Analyse website usage and improve our service | Technical, Usage | Legitimate interests |
| Comply with our legal and regulatory obligations | All data as required | Legal obligation |
| Resolve disputes, enforce agreements, and protect our legal rights | All data as required | Legitimate interests / Legal obligation |
Marketing communications: We will only ever contact you with marketing material — such as new phone deals, special offers, or network promotions — if you have explicitly given us your consent to do so. You can withdraw this consent at any time by calling us on 02035 043106, emailing privacy@joynewphone.online, or using the unsubscribe link in any email we send you.
LEGAL BASIS
Under UK GDPR, we must have a lawful basis to process your personal data. We rely on the following legal bases:
- Contractual Necessity (Article 6(1)(b)): Processing is necessary to perform the service you have requested — i.e., providing you with a phone upgrade or new contract quote and arranging a callback from an advisor.
- Legitimate Interests (Article 6(1)(f)): We have legitimate business interests in improving our services, managing our business, preventing fraud, and communicating relevant offers to existing customers. We always balance these interests against your rights and freedoms before relying on this basis.
- Consent (Article 6(1)(a)): Where we rely on consent — specifically for direct marketing communications — we will always ask for your explicit agreement first. Consent can be withdrawn at any time without detriment to you.
- Legal Obligation (Article 6(1)(c)): We may need to process your data to comply with applicable laws and regulations, including requirements from financial regulators, HMRC, or law enforcement agencies.
SHARING YOUR DATA
We take the sharing of your personal data seriously. We only share your data with third parties where it is necessary, lawful, and subject to appropriate safeguards.
We may share your data with:
- UK Mobile Networks: When you agree to proceed with a phone deal, we share the minimum necessary data with the relevant network (such as EE, O2, Vodafone, Three, Sky Mobile, or iD Mobile) to process your application. These networks are independent data controllers and will have their own privacy policies governing how they use your information.
- Technology & IT Service Providers: Third-party providers that support our website infrastructure, CRM systems, email delivery, and analytics tools, operating under strict data processing agreements as our data processors.
- Call Recording & Telephony Providers: Regulated providers who store and manage call recordings on our behalf, bound by confidentiality and data processing obligations.
- Professional Advisors: Solicitors, accountants, insurers, and auditors who provide professional services to us, where disclosure is reasonably necessary.
- Regulators and Law Enforcement: Where we are required to do so by applicable law, a court order, or regulatory authority.
We will never sell your personal data to any third party. We do not share your information with data brokers, advertisers, or any unrelated third parties for their own marketing purposes.
International transfers: We endeavour to keep all personal data within the UK and European Economic Area (EEA). If any of our service providers process data outside the UK/EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the UK Information Commissioner's Office (ICO).
COOKIES & TRACKING
Our website uses cookies and similar technologies to enhance your browsing experience, analyse website traffic, and understand how visitors use our site. A cookie is a small text file placed on your device when you visit a website.
Types of cookies we use:
| Cookie Type | Purpose | Duration |
|---|---|---|
| Strictly Necessary | Essential for the website to function correctly — e.g., remembering your quote form progress and security cookies. These cannot be disabled. | Session |
| Analytics & Performance | Help us understand how visitors use our website, which pages are most popular, and where users drop off. Data is aggregated and anonymised where possible. | Up to 2 years |
| Functional | Remember your preferences and choices on the website, such as phone brand filters, to provide a more personalised experience on return visits. | Up to 1 year |
| Marketing (with consent) | Used to track visits from advertising campaigns and measure their effectiveness. Only set if you have given your consent via our cookie banner. | Up to 90 days |
When you first visit our website, a cookie consent banner will appear asking for your preferences. You can change your cookie settings at any time by clicking "Manage Cookies" in the footer of our website, or by adjusting your browser settings. Please note that disabling certain cookies may affect the functionality of our site.
DATA RETENTION
We do not hold your personal data for longer than is necessary for the purposes for which it was collected. Our retention periods are guided by the nature of the data, the purpose of processing, and our legal obligations.
- Quote Enquiry Data (no deal taken): If you request a quote but do not proceed to take a deal, we will retain your enquiry data for up to 12 months in case you wish to continue your search at a later date. After this period, your data is securely deleted or anonymised.
- Customer Transaction Records: If you take a phone deal through us, we retain your transaction and identity records for 6 years from the end of the contract in line with standard UK commercial and tax law requirements.
- Call Recordings: Telephone call recordings are retained for 6 months for training and quality assurance purposes, and for up to 3 years if they relate to a formal complaint or dispute.
- Marketing Consent Records: Where you have given consent for marketing, we retain a record of that consent for as long as we continue to send you marketing communications, plus an additional 12 months thereafter.
- Website Analytics Data: Anonymised and aggregated analytics data is retained for up to 26 months.
At the end of the applicable retention period, personal data is securely deleted, destroyed, or permanently anonymised in accordance with our internal data destruction policy.
YOUR RIGHTS
Under UK GDPR and the Data Protection Act 2018, you have a number of important rights in relation to your personal data. We take these rights seriously and will always respond to a valid request within one calendar month of receipt.
Right of Access
You have the right to request a copy of all personal data we hold about you, free of charge, along with information about how and why we process it.
Right to Rectification
If any personal data we hold about you is inaccurate or incomplete, you have the right to ask us to correct or update it without undue delay.
Right to Erasure
Also known as the "right to be forgotten." You can ask us to delete your personal data where there is no compelling reason for us to continue holding it.
Right to Restrict Processing
You can ask us to pause the processing of your data — for example, while you contest its accuracy or while we consider an objection you have raised.
Right to Data Portability
Where we process your data by automated means and on the basis of your consent or a contract, you can ask us to provide it in a structured, machine-readable format.
Right to Object
You have the right to object to processing based on legitimate interests, including profiling and direct marketing. We will stop unless we have compelling grounds to continue.
Automated Decision-Making
You have the right not to be subject to decisions made solely by automated processing that significantly affects you, including profiling.
Right to Withdraw Consent
Where we rely on your consent to process data (e.g. marketing), you can withdraw it at any time. Withdrawal does not affect the lawfulness of prior processing.
To exercise any of these rights, please contact us using the details in Section 13. We may need to verify your identity before processing your request. There is no charge for exercising your rights in most circumstances.
You also have the right to lodge a complaint with the UK's supervisory authority, the Information Commissioner's Office (ICO), if you believe we have not handled your data lawfully. You can contact the ICO at www.ico.org.uk or by calling 0303 123 1113. We would, however, appreciate the opportunity to address your concerns directly before you approach the ICO.
DATA SECURITY
We take the security of your personal data very seriously and have implemented appropriate technical and organisational measures to protect it against accidental loss, unauthorised access, alteration, or disclosure.
Our security measures include:
- SSL/TLS Encryption: All data transmitted between your browser and our website is encrypted using industry-standard TLS (Transport Layer Security) protocols.
- Access Controls: Access to personal data within our organisation is strictly limited to employees and contractors who need it to perform their job functions. All staff receive data protection training.
- Secure Data Storage: Personal data is stored on secure, access-controlled servers. We conduct regular security reviews and vulnerability assessments.
- Data Minimisation: We only collect and retain the minimum amount of personal data necessary for the purpose stated.
- Incident Response: We have a documented data breach response procedure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours and inform you without undue delay.
- Third-Party Due Diligence: All third-party providers who process personal data on our behalf are subject to rigorous vetting and bound by written Data Processing Agreements.
While we take all reasonable steps to protect your data, no method of electronic transmission or storage is 100% secure. We encourage you to protect yourself by using a strong password and keeping it confidential.
CHILDREN'S PRIVACY
Our services are intended exclusively for individuals who are 18 years of age or older. We do not knowingly collect, store, or process personal data from anyone under the age of 18.
Our website is not directed at children, and we do not use any techniques to attract or engage minors. If you are a parent or guardian and believe that your child has inadvertently submitted personal data to us, please contact us immediately at privacy@joynewphone.online or on 02035 043106 and we will take prompt steps to delete that data from our records.
THIRD-PARTY LINKS
Our website may contain links to third-party websites, including mobile network operators such as EE, O2, Vodafone, and Three. These links are provided for your convenience and information only.
Once you click a link to a third-party website, you leave our site and are subject to that third party's own privacy policy and terms of use. We have no control over, and accept no responsibility for, the privacy practices or content of any external websites.
We recommend that you review the privacy policy of any third-party website you visit before providing any personal information.
CHANGES TO THIS POLICY
We review this Privacy Policy regularly to ensure it remains accurate, up to date, and compliant with applicable data protection legislation. We reserve the right to amend this policy at any time.
When we make material changes to this policy, we will:
- Update the "Last Updated" date at the top of this page.
- Display a notice on our website homepage for at least 30 days following a significant change.
- Where we have your email address and the change materially affects how we use your data, we will notify you directly by email.
We encourage you to review this page periodically to stay informed about how we protect your personal information. Your continued use of our services after the effective date of any changes constitutes your acknowledgement of the revised policy.
Previous versions of this Privacy Policy are available on request by contacting us using the details below.
CONTACT US
If you have any questions, concerns, or requests relating to this Privacy Policy or how we handle your personal data, please do not hesitate to get in touch. Our team is here to help.
- Phone: 02035 043106 — Mon–Fri 8am–8pm, Sat 9am–5pm
- Email: privacy@joynewphone.online
- Data Protection Contact: dpo@joynewphone.online
- Post: Data Protection, JOYNEWPHONE, United Kingdom
We aim to respond to all data-related enquiries and Subject Access Requests within one calendar month of receipt. If your request is particularly complex or numerous, we may extend this period by a further two months, in which case we will write to you to explain the reason for the delay.
You also have the right to contact the Information Commissioner's Office (ICO) at any time:
Website: www.ico.org.uk | Helpline: 0303 123 1113 | Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF