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Privacy Policy

  • Our full Terms and Conditions can be here: Terms & Conditions

    1 General
    1.1. This Acceptable Use Policy (“Policy”), forms part of your Agreement with Pozitive Telecom, as defined in clause 2 of the Terms and Conditions. The Policy covers the usage obligations for you and your Users in respect of the Pozitive Telecom Services and all equipment provided by Pozitive Telecom to you in connection with the Pozitive Telecom Services.
    1.2. The Policy also has a section covering the behaviour that Pozitive Telecom expects of you and your Users, whether interacting with Pozitive Telecom employees and agents (in person or over the phone).
    1.3. You must notify Pozitive Telecom as soon as reasonably practicable of any breach of this Policy and must cooperate with Pozitive Telecom promptly and follow its reasonable instructions in order to stop or remedy such breach.
    1.4. Capitalised terms (that aren’t proper nouns) used within this Policy shall be as defined in the Terms and Conditions.
    1.5. Pozitive Telecom shall at all times act reasonably and in good faith in connection with the application and enforcement of this Policy.
    2 Updates to the Policy
    2.1. Pozitive Telecom may update or amend this Policy at any time, and any such policy will be available on the Pozitive Telecom website Terms & Conditions. Your continued use of the Pozitive Telecom Services after any change to the Policy constitutes acknowledgement and acceptance of the updated Policy.
    3 Prohibited Activities using Pozitive Telecom Telecom’s Services
    3.1. You must, and shall procure that your Users must, only use the Pozitive Telecom Services:
    • as set out in this Policy and the Terms and Conditions;
    • for legitimate and reasonable business purposes, and such use should not exceed that reasonably expected of a reasonable person using them for these purposes. As an example, without limitation, Pozitive Telecom consider that if you/your Users regularly use multiple devices with one SIM or multiple SIMs with one device, that this is unlikely to be legitimate use as intended under the Terms and Conditions; and
    • for your and your Users’ own direct use. This means you and your Users must not resell or commercially exploit any of Pozitive Telecom Services or Pozitive Telecom’s content.
    3.2. You shall be responsible for your Users’ authorised or unauthorised use of the Services and shall be responsible for using appropriately strong passwords and keeping them secure and for any use made of those passwords.
    3.3. You and/or your Users must not directly or indirectly use Pozitive Telecom Services, the SIM or Pozitive Telecom phone number, or allow anyone else to use Pozitive Telecom Services, the SIM or Pozitive Telecom phone number for unlawful or improper uses, including without limitation:
    • for fraudulent, criminal or other unlawful activity which includes (without limitation) making nuisance calls, unlawful file-sharing or downloads, or viewing unlawful content;
    • in any way which breaches another person’s rights including copyright or other intellectual property rights;
    • generating content or otherwise using the Service that in any way may be, or may be perceived as harmful to others, or Pozitive Telecom’s Services or reputation, is offensive, threatening, abusive, indecent, defamatory, obscene or an annoyance, or is otherwise contrary to Applicable Law;
    • to copy, store, modify, publish or distribute Pozitive Telecom Services, equipment or their content, except where Pozitive Telecom gives you permission. This includes, without limitation, any attempt by you or a User to interrogate a SIM Card or reverse engineer the code on a SIM Card;
    • to download, send or upload content of an excessive size, quantity or frequency or to make an unusually high volume of calls, (judged in each case in relation to your typical use of such services), such that your use is having, for example, a material adverse impact on Pozitive Telecom’s network, systems and/or other customers. Pozitive Telecom will contact you if you or a User’s use is deemed excessive and discuss steps to remedy the issue (discussed further in section 6 below);
    • usage that is contrary to good faith commercial practice;
    • threatening the integrity or security of any device, network or system including the transmission of viruses, harmful components or malware;
    • to send or publish bulk messages (including but not limited to marketing messages, notifications or automated content), make bulk phone calls or to generate artificially inflated traffic or act in any way which breaches any security or other safeguards or in any other way which harms or interferes with the Pozitive Telecom network, the networks or systems of others or Pozitive Telecom Services; or
    • to use or provide to others any unauthorised directory or details about Pozitive Telecom customers each a “Prohibited Activity.”
    3.4. You and/or your Users must:
    • When using the Services, not show or send content from any age-restricted services to anyone under 18; and
    • ensure that access to any age-restricted services is deactivated if anyone under 18 uses the equipment through which Services are accessed.
    4 Responsible Use of Services
    4.1. You must, and shall procure that your Users must, only use the Services as set out within this Policy, and clause 6 of the applicable Terms and Conditions. If you or a User is in breach of this Policy and/or clause 6 of the Terms and Conditions, Pozitive Telecom shall have the right to:
    4.2. take appropriate action, including suspension and/or termination of the Pozitive Telecom Services wholly or partially, in accordance with this Policy and/or the relevant Terms; or
    4.3. take recourse as set out in clause 6 of this Policy and/or the Terms and Conditions.
    5 Abusive or Harassing Behaviour by you or your Users
    5.1. You acknowledge and agree that Pozitive Telecom has a zero-tolerance approach towards bullying and harassment in any form. As part of this, Pozitive Telecom believes that everyone has the right to be treated with dignity and respect and Pozitive Telecom does not condone any types of unacceptable behaviour or abuse including harassment, intimidation or bullying of Pozitive Telecom’s customers or employees. If Pozitive Telecom determines in Pozitive Telecom’s sole opinion (acting reasonably) that you or your Users have acted in a manner that is inconsistent with reasonable customer behaviour and in breach of this Section, Pozitive Telecom reserves the right to respond in the following ways:
    • If you or your Users abuse or harass Pozitive Telecom’s contact centre advisors, Pozitive Telecom follow a “One Strike” policy to cease the conduct immediately or the interaction will be terminated. If the abuse or harassment continues, the advisors will end the call and make a record of the incident on your account.
    • Depending on the severity and frequency of the abuse, Pozitive Telecom may decide to suspend or disconnect your account and/or the Pozitive Telecom Service(s) wholly or partially, as well as take additional measures to prevent contact with Pozitive Telecom’s advisors in the future, for example by blocking your IP address(es) and/or number(s).
    • Any threatening conduct will be reported to the police immediately, and a record will be placed on your account.
    5.2. If your and/or your User’s conduct results in disconnection of your account and/or the Pozitive Telecom Service(s) wholly or partially, an Administration Fee as set out in our Price List [insert link] may be payable in addition to all outstanding sums payable under Agreement falling immediately due. Please see clauses 6.3, 6.4, 6.7, 13 and 14 of the Terms and Conditions for further details as to when we may suspend or terminate your account and/or the Pozitive Telecom Services as a result of your conduct.
    6 Monitoring and Breaches of the Policy
    6.1. Pozitive Telecom may, in its sole discretion (acting reasonably), run manual or automatic systems and monitoring of the volume and type of use of the Pozitive Telecom Services by you or your Users in order to ensure that such use is compliant with the relevant terms of this Policy and the Terms and Conditions at all times. Pozitive Telecom may also carry out such monitoring activity where required or permitted by Applicable Law.
    6.2. If Pozitive Telecom believes that you or your Users have breached this Policy or clause 6 of the Terms and Conditions, or you have engaged in a Prohibited Activity, the actions Pozitive Telecom may take may include but are not restricted to:
    • investigating the possible breach;
    • notifying you of the breach;
    • contacting you to gather further information, request you or your Users moderate your usage, or to discuss Pozitive Telecom’s concerns;
    • issuing a formal warning to you;
    • blocking electronic communications which Pozitive Telecom reasonably believes have breached this Policy or the Terms and Conditions;
    • restriction of your or your User’s access to all or any part of the Pozitive Telecom Services with immediate effect;
    • introduce traffic management measures;
    • whole or partial suspension of your account and access to the Pozitive Telecom Services with immediate effect; and/or
    • whole or partial termination of your account(s) and access to the Pozitive Telecom Services with or without notice;
    6.3. Additional action may apply if Pozitive Telecom believes that you or your Users have engaged in conduct that could be viewed as abusive or harassing towards Pozitive Telecom’s employees, contractors or agents. These are detailed above in clause 5.
    6.4. Pozitive Telecom reserves the right to charge you any costs and expenses (properly and reasonably incurred), whether direct or indirect, associated with preventing or responding to your breach of this Policy and/or sresponding to associated third party complaints.
    6.5. Nothing in this Section limits Pozitive Telecom’s rights and remedies (available at law or in equity) in any way with respect to a breach of this Policy, a Prohibited Activity or the Terms and Conditions.
    7 Data Protection
    7.1. Pozitive Telecom reserves the right to use your account information and Users’ Personal Data (as defined in the Terms and Conditions) in connection with any investigation carried out by Pozitive Telecom in accordance with this Policy, the Terms and Conditions Terms & Conditions and Pozitive Telecom’s Privacy Policy, available at Terms & Conditions. For example, Pozitive Telecom may disclose relevant data and account information to any third-parties that Pozitive Telecom considers have a legitimate interest in any such investigation or its outcome, including without limitation, the police.
  • Bad Debt and Disconnection Policy

    Having Difficulty Paying, billing and bad debt

    This Bad Debt Policy (“Policy”), forms part of your Agreement with Pozitive Telecom, as defined in Section 2 of the Terms and Conditions [insert link]. The Policy covers your obligations in respect of the Pozitive Services.

    Invoicing

    You will receive your monthly invoice on the 3rd of each month. This will include charges in advance for your mobile, voice and broadband services, where applicable, and any call charges for the previous month. All invoices will be sent via email, accessible on the portal and payable by Direct Debit.

    Paper invoices are available upon request; however, there may be a charge for this service.

    If required, there are a number of formats which we can provide your bill in, please get in touch if a different format is required or see [our vulnerable policies link] for further information.

    Difficulty paying

    We understand circumstances can change; please let us know as soon as possible if you are having payment difficulties at any time.

    If you are having payment difficulties, contact our Customer Services in any of the following ways and they will work through your options:

    • Phone: 0333 370 6900
    • Email at: telecomhelp@pozitive.energy
    • Post: Pozitive Telecom, Floor 10, One Canada Square, London, E14 5AB

    There are a range of options our Customer Services can discuss which may help you. This may include downgrading your package or suspending outgoing calls for an agreed period. Other options may include:

    • Setting up a payment plan
    • Reviewing your contract options

    What happens if I don’t pay my bill: Missed or Late Payments

    We know it can be hard to talk about money issues, but the best thing to do if you’re struggling to pay is to speak to us. We’re here to listen and do everything we can to support you through difficult times.

    If you don't pay for your services on time in accordance with the Terms and Conditions [insert link], we will attempt to contact you to advise there is a problem or send a reminder primarily by email or text. If you require us to contact you by another method, please let us know. It is important that you know that if we don’t hear from you your service may be affected.

    If payment on your account is not brought up to date, we may take action to restrict or suspend your services, including disconnection of these services. We will take action to disconnect your service(s) as a last resort and you will be provided with an email warning prior to us placing any restrictions on your account. We will notify you if action is to be taken following attempted collection of the Direct Debts. You can bring your account up to date at any time in order to stop action being taken.

    In the event we have to chase you for payment or take action on your account to restrict or suspend services, we may charge an administration fee and/or late payment charge(s). These charges can be found on our price list [price list link].

    If you do not pay us any sum due under the Agreement on the due date we shall be entitled to charge you interest on the overdue sum from the due date until payment of the overdue sum, which shall accrue interest each day at the interest rate payable pursuant to the Late Payments of Commercial Debts (Interest) Act 1998, to run from the due date of payment until receipt by us of the full amount (including any accrued interest) in cleared funds.

    We shall invoice you for the reasonable costs incurred by us of collecting any undisputed overdue amount. Additionally, we can pass information relating to you (including, where relevant, personal data) to a credit reference agency.

    Your debt could then be passed to a third-party debt collection agency to be recovered on our behalf. You will also be responsible for all reasonable debt recovery fees we incur in recovering any money that you owe us. This may also affect your credit rating which may have an impact on your credit score and your ability to obtain credit in future.

    We may terminate the Agreement(s) in respect of some or all services with immediate effect by giving written notice to you, if you fail to pay any amount due under this Agreement on the due date and remain in default not less than 7 days after being notified in writing to make such payment.

    You can find any late payment charges which may apply on our price which can be found [ price list link ]

    If we do have to take action on the account, reduce or suspend services, it may take some time for your service to be restored once payment on your account is brought up-to-date. If we do apply restrictions to your account this may affect you making calls or having the services you are used to.

    My Direct Debit has failed, what can I do?

    We understand things can go wrong, try not to worry. If the failure has occurred because your bank details have changed, you should contact us to provide us with the new details. Otherwise, if your Direct Debt fails, we will make a second attempt to collect the payment 5 days later. If this second attempt fails, we will contact you, by email or text to notify you of the non-payment and suspension of your services.

    If the second attempt to collect payment fails, a "Failed Direct Debit charge” may be applied to your account. You can find details of these charges on our prices list here [ price list link]

    If payment is not made 30 days from the date of the last invoice, we will notify you that your service(s) will be terminated.

    To avoid disruption to your service you’ll need to pay your outstanding balance or have arranged a support plan with us.

    Notification of disconnection will be provided in the format you have notified us of, for example, large print.

    Financial Advice and Help

    If you need independent and impartial advice, please see the list below of organisations you can contact:

    Citizens Advice main website - https://www.citizensadvice.org.uk/ https://www.citizensadvice.org.uk/

    Citizens Advice (England & Wales) – they can provide free information for a customer based in England or Wales who cannot afford to pay their bills.

    • Freephone 0808 223 1133
    • Online webchat from 9am-5pm.
    • For textphone dial 18001 followed by the helpline number.
    • To contact a Welsh-speaking adviser freephone 0808 223 1144. For more information visit Debt and money – Citizens Advice

    Advice Direct Scotland - can provide free, practical advice and information to the customers in Scotland:

    Business Debtline – a charity giving free and independent business debt advice.

    National Debtline - Telephone 0808 808 4000 or www.nationaldebtline.org

    StepChange Debt Charity - Telephone 0800 138 111 or www.stepchange.org

  • We are always working to complete your port on the agreed port date. Some disruption can take place to your service on the day of the port and this is not unusual. There are occasions when you may briefly lose service as the number is transferred. You may be eligible for compensation if your transfer is delayed beyond the port date we have agreed. If there is a delay to your port and you believe you are eligible to receive compensation, please contact Customer Care Team on 0333 370 6900 or email us at telecomhelp@pozitive.energy. Any compensation will appear as a credit on your next bill.

    If any of the information we gave you when you joined us relating to your switch from another provider was incorrect, you may be eligible for compensation. If you need to contact us in relation to compensation you believe you’re entitled to, please contact Customer Care Team on 0333 370 6900 or email us at telecomhelp@pozitive.energy.

    Any compensation will be made in the form of credits and applied to your next bill.

  • We are committed to offering the very best in customer service. However, we know that things do sometimes go wrong and we are committed to resolving any complaints in a timely manner.

    Pozitive Telecom will endeavour to resolve any complaint to your satisfaction. Where this is not possible you have the option of referring your complaint to an alternative dispute resolution service. We are members of the Ombudsman Service. In the event you wish to take your complaint further the details of this service can be found at the end of this document.

    Step 1

    If your complaint is related to a service you received from Pozitive Telecom, please call our Customer Care Team on 0333 370 6900 or

    • send an email to telecomhelp@pozitive.energy, please include all the information specified above.
    • write to us at the following address: Floor 10, One Canada Square, London, E14 5AB

    When sending an email or writing to us please include the following information as this will enable us to handle your complaint more efficiently:

    • Your name and any relevant account details;
    • The date the problem occurred and details of the problem;
    • Your telephone number;

    Our team will discuss with you your complaint and try to resolve your complaint with you as quickly as possible. This will normally be carried out over the phone; however, if a call is not suitable, please advise how we best get in touch with you.

    If it is not possible to resolve your complaint in the immediate term, we will advise of the steps which will be taken and the timescales. Where a complaint needs further information and cannot be resolved immediately, we aim to update you in 10 days; however, this may not always be possible depending on the nature of the complaint.

    Step 2

    If you are not satisfied with the way your complaint is being handled or the response we have provided, you can ask for your complaint to be escalated by being passed to our Complaints Team who will undertake an independent internal review.

    Please be aware that our Complaints Team can only assist with matters that our Customer Care Team have dealt with first. You can contact our Complaints Team by emailing complaints@pozitive.energy.

    Once we have proposed a resolution for the complaint, we require you to confirm you are happy with the outcome within 28 days. After this time the complaint will be deemed closed.

    If you are unhappy with our conclusion of your complaint after it has been through the process under step 2, you may refer the issue to the Ombudsman Service for free, details can be found below.

    Your right to have the matter referred to ADR

    If you have not received a satisfactory response from us and we have reached ‘deadlock’ or eight weeks have passed since you first registered your complaint, it can be referred to Ombudsman Services (https://www.ombudsman-services.org/sectors/communications) for their impartial review. This service is free of charge to you. Any decision they make will be binding on us, but not on you, so you can seek further advice if you wish to.

    To take your complaint to the Ombudsman Service, we will send you an Alternative Dispute Resolution (ADR) letter, which you will need to share with them. We are required to send an ADR letter to you:

    • where your complaint has been through every stage of our internal complaints process and we have informed you of the outcome of that investigation, you have confirmed that you do not consider the proposed outcome to be satisfactory and we have confirmed that we do not intend to take any further action with regard to the dispute; or
    • automatically, if after 8 (eight) weeks of lodging your complaint and us confirming receipt, it remains unresolved.

    Contact details for the Ombudsman Service are as follows:

    Post: Ombudsman Services: Communications, P.O. Box 730, Warrington, WA4 6WU

    Phone: 0330 440 1614

    Email: enquiry@ombudsman-services.org

    Independent support

    Independent advice is available to domestic and microbusiness customers at any stage from Citizens Advice. You may wish to contact Citizens Advice if you need help in relation to your rights concerning a communications service – for example, if you’re struggling to pay for the communications services you use.

    Go to https://www.citizensadvice.org.uk/consumer/ scroll down to the Phone, TV or internet section.

    You can contact an adviser through the national phone service:

    Adviceline free (England): 0800 144 8848

    Advicelink free (Wales): 0800 702 2020

    Advice Helpline free (Scotland): 0800 028 1456

    Relay UK – this service maybe easier if you trouble using the phone or can't hear or speak easily, you can type what you want to say:

    18001 then the Adviceline or Advicelink number. You can use Relay UK with an app or a textphone. There’s no extra charge to use it. Find out how to use Relay UK on the Relay UK website.

    Adviceline is available 9am to 5pm, Monday to Friday. It’s usually busiest at the beginning and end of the day. It's not available on public holidays.

  • Introduction

    Telephone numbers in the UK are set out in two sections: geographic (01 and 02) and non-geographic (03, 084, 087, 09, 118). As you would expect, geographic numbers are generally linked to a location. Non-geographic numbers, unlike geographic telephone numbers and the cost of calling non-geographic numbers, is not linked to a specific UK location i.e. a town.

    The costs of calling any non-geographic number can vary and you should always check the rates associated with these calls [insert price list link].

    What are Non-geographic numbers

    Non-geographic numbers include numbers beginning with '03', '084', '087', '09' or 118 .

    Sometimes, these numbers are called 'Service' or 'Premium Rate Service' numbers and have a two-part charge for calling them.

    Calls to 03 numbers

    03 numbers are increasingly used by businesses as their main customer contact numbers and for business to business communication. Calls to 03 numbers have to cost the same as calls to 01 and 02 geographic numbers. So, we’ve included calls to these numbers as part of your package.

    What are Premium Rate Services (PRS)?

    Premium Rate Services (PRS) are regulated by the Phone-Paid Services Authority and are sometimes known as Phone-Paid Services. These non-geographic numbers (those beginning 087, 09 & 118) can be used to make purchases and the charge is made to your phone bill.
    Numbers which support Premium Rate Services are often used to call services such as: recorded information, competitions, voting, directory enquiry information, advice or chat lines.
    Those companies providing these services, as mentioned above, are called Service Providers.
    It is important to note that calls to these services vary considerably and it is important to check the cost of calling to avoid large bills. Please see our price list [ insert link]. The Service Provider should make it clear in their adverts the cost of making calls to their service.
    Sometimes, non-geographic Premium Rate Services are called Number Translation Services and the terms NTS and PRS are used interchangeably.

    Other non-geographic numbers begin:

    • 0800 and 0808 numbers or 'Freephone' numbers are free to the caller from landlines and mobiles. These calls will not be shown on your bill.
    • Texts or Short code numbers which can be 4, 5 or 6 digits in length are called SMS (Short Message Service) short codes. These are often used by businesses to allow customers to opt-in to SMS campaigns, alert services, or to enter SMS competitions. Like Premium Rate numbers, these may cost more to call/text than standard numbers. See our price list [insert link].
    • 070 referred to as 'Personal Numbers’. These are often used as a 'follow me' service where calls are diverted from one number to another. Therefore, the person being called keeps their number private. 070 numbers differ from mobile numbers which usually begin with 071 to 075 or 077 to 079. See our price list [insert link].

    Cost of calling non-geographic and Premium Rate Service (PRS) Numbers

    Calls to non-geographic numbers (calls beginning 084, 087, 09 and 118) are charged in two parts – the Access Charge and the Service Charge.
    The Access Charge is charged by us for originating and passing the call over our network. This charge is made at a pence per minute rate. See our price list [insert link].
    The Service Charge is set and charged by the network operator who terminates the call and enables you to access the service (Service Provider) once your call is connected. This charge should be made clear and advertised by the Service Provider alongside their number. This charge is not set by Pozitive Telecom.
    Your cost for making a call to a non-geographic number is the cost of the Access Charge and the Service Charge together. Your invoice will show the charge for both elements. We will pass on the Service Charge to the Service Provider.
    You will be able to find all the relevant charges in our price list [insert link].

    Further detail regarding the cost of calling non-geographic numbers

    084* – these calls will be charged at no more than 7 pence per minute (inc. VAT) or 7 pence per call (inc. VAT) where the Service Charge is set exclusively at a pence per call rate, plus our Access Charge.

    087*- these calls will be charged at no more than 13 pence per minute (inc. VAT) or 13 pence per call (inc. VAT) where the Service Charge is set exclusively at a pence per call rate, plus our Access Charge

    09* – these calls will be charged at no more than £3.60 pence per minute (inc. VAT) or £6.00 per call (inc. VAT) where the Service Charge is set exclusively at a pence per call rate, plus our Access Charge.

    118* - Directory Enquiry numbers these should not be charged at more than £3.65 (inc. VAT) per 90 seconds or £3.65 (inc. VAT) where the Service Charge is set exclusively at a pence per call rate, plus our Access Charge.

    Text Messages & SMS short codes. Usually beginning with 2, 6, 7 or 8 and can be 4, 5, or 6 digits long. Sending texts to certain short codes from your landline can be considerable expensive. Call to the following should always be checked:

    • 087 business information lines;
    • Mobile games;
    • Competitions and quizzes;
    • Charity donations;
    • Adult entertainment; and
    • Chat services.

    Please check with the Service Provider the cost of these texts before you send any messages. Alternatively, you can block making calls to these expensive numbers.

    *Calls to these numbers may be set at a pence per minute, a pence per call rate, or a rate which combines a pence per minute rate and a pence per call rate. The Access Charge will also be added to any of these variations. You can check the cost of calling Premium Rate Services on the PSA website, found here https://psauthority.org.uk/

    Blocking Numbers calls to these numbers

    As the cost of calling these numbers can be extremely expensive you may decide to block the ability to dial them. If anyone then tries to dial these numbers the call will not succeed and the cost will therefore be avoided. It does mean you will be unable to access the types of services highlighted above. To activate contact blocking please call Customer Services by:

    • Phone: 0333 370 6900
    • Email: telecomhelp@pozitive.energy
    • Post: Pozitive Telecom, Floor 10, One Canada Square, London, E14 5AB

    Phone-paid Services Authority (PSA)

    The PSA is the industry regulator for all Premium Rate charged services and it publishes a Code of Practice for Service Providers and network operators using these PRS numbers. The Code also covers how these numbers should be advertised and how providers are responsible for complying with the Code.
    The PSA investigates complaints about the promotion and operation of services that involve the use of a telephone-based connection to access a Premium Rate number. These include connections from landline telephone, Voice-over-IP telephones, fax, Internet, mobile phone (voice and SMS) and interactive TV.
    The PSA's service is free to consumers and is fully independent.

    How to complain to the PSA

    The first step with respect to any complaint is to contact our Customer Service team, see the ways to contact the team above, to see if they are able to help. Alternatively, you can get in touch with the Service Provide and they should be able to discuss the charges with you.

    If you don’t recognise the number there is a service checker available from the PSA which can be found https://psauthority.org.uk/

    Alternatively, you can submit a complaint to them:

    • Web: Using the online form found at https://psauthority.org.uk/for-consumers/report-an-issue
    • Phone : 0300 30 300 20
    • Post: Phone-paid Services Authority
      c/o Ofcom
      Riverside House
      2a Southwark Bridge Road
      London
      SE1 9HA

    When making a complaint it is useful to provide an information you may have with respect to the service. For example, the promotion or advertisement.

  • At Pozitive Telecom, we appreciate that everyone is different and circumstances change, be it long term or temporarily. We want the end-users of our services to receive the best possible service and we believe everyone should have quality access to connectivity in this digital age. To achieve this, we provide a number of services to support our customers and their employees or authorised users with diverse needs. This includes the needs of persons with disabilities, or those who, as a result of their circumstances, may be vulnerable in some other way. In this policy document, we refer to these persons as “Vulnerable Customers” or “you”.
    This policy document states the services we offer to help make life better for everyone, including our Vulnerable Customers.

    Identifying Needs

    In order to offer a consistent service, it helps if we can record limited information on Vulnerable Customers with respect to the nature of their vulnerabilities and how we can help them better. We may need to ask permission to keep a record of this information, which will be recorded on our system for internal use.

    There is no strict definition of a Vulnerable Customer that is required to use our additional services. There may be a number of factors that could influence the cause of a vulnerability. Each one could be temporary or permanent, vary widely, and may not always be obvious. For example, a person may be vulnerable due to factors such as:

    • Age
    • Physical or learning disability
    • Physical or mental illness
    • Low literacy skills
    • Communication difficulties
    • Changes in circumstances, such as bereavement or financial difficulties. Whilst not everyone with a disability is vulnerable and each person is different, we are ready to provide support services where needed. We would encourage Vulnerable Customers to inform our Customer Service team of their needs to ensure we can offer the appropriate services as soon as possible. Similarly, should a Vulnerable Customer feel the need to flag a change in circumstances, or otherwise update their records, they may contact Customers Services.
    • Customer Services can be contacted in any of the following ways:
    • Phone: 0333 370 6900
    • Email at: telecomhelp@pozitive.energy
    • Post: Pozitive Telecom, Floor 10, One Canada Square, London, E14 5AB If you are hard of hearing, for example, we can help you access different ways to communicating remotely with others and with us.

    Please see the list of services we have available to support you below.

    Our Services

    It is important to note that access to landline or broadband services may not work if there is a power-cut or other power failure. If you rely on these services, in particular for access to emergency services (for example police, fire, ambulance or coastguard services), you should ensure that you have made alternative arrangements.
    If you have services, such as medical devices, which rely on your landline or broadband service, it is important you check with the service provider or manufacturer that this service is compatible with our services.
    Pozitive Telecom offers a variety of support services. Please get in touch with Customer Services should you wish to request access to a service or discuss any of these services in more detail. Our services include:

    1. Alternative Formats: there are various ways we are able to provide documents and information on request. This includes large print, electronic copies, Braille and coloured paper. Nearly all our documents are available in these alternative formats.
    2. Directory Enquiry Information: there are various ways we are able to provide access to directory enquiry services and directory information,
      You can also apply for free directory assistance and information by calling BT Directory Assistance on 195.
    3. Relay Service: this service is available for both fixed and mobile phones and allows for a conversation to be typed into a phone keypad and then connected with the person being contacted. A relay assistant will help connect you to the person you wish to call and they will assist the conversation.
      For further information on how the services work please follow the link: https://www.relayuk.bt.com/
      Or https://www.ofcom.org.uk/phones-telecoms-and-internet/advice-for-consumers/accessibility/text-relay-guide
    4. Priority Fault Repair: if you are relying on your fixed telephone service or your broadband service, you can register for Priority Fault Repair. This service is available to those who depend on these services due to a vulnerability and the loss of this service would pose an imminent risk to your health and safety. Repairs are carried out as soon as feasibly practicable given the nature of the fault, which is often outside of our control and which may prevent an immediate response. Examples would be where adverse weather such as storms or floods prevent repairs from being undertaken.
    5. Registering your mobile to send Emergency SMS messages: you can contact the Emergency Services (Police / Fire / Ambulance / Coastguard) by SMS (i.e., “text message”) rather than dialing 999 or 112 – but you need to be registered first. To register, please follow the below process:
      • Send the word 'register' in an SMS message to 999.
      • You will then receive SMS messages about the service.
      • When you have read these SMS messages reply by sending 'yes' in an SMS message to 999.
        For more information please go to: https://www.emergencysms.net/registering_your_mobile_phone.php
    6. Contact the Emergency Services using British Sign Language (BSL): if you are deaf, hard of hearing or have a speech impediment, you may wish to access video relay services for contacting emergency services.
      999 BSL, is available either via the app or the website and connects you to British Sign Language (BSL) interpreters remotely. The interpreter will relay the conversation with the call handler and emergency authorities.
      You don’t have to register for the service. You can download the app or use a web browser for free. You can make a 999 call via this web address https://999bsl.co.uk/
      You can download the app from https://999bsl.co.uk/download/
      For more detail, please click on this link for a short video about the service https://999bsl.co.uk/wp-content/uploads/2022/04/What-is-999-BSL_-.mp4
    7. Third party bill management: this service enables you to nominate a third party or Power of Attorney to help manage your account. This person will be able to make changes to your account, discuss your account with Customer Services and make payments. This should be a trusted person as you will still be responsible for any actions taken on your account. They will not be liable as they are acting on your behalf and you will still be responsible for the bill.

    We continually monitor the service we provide and value your feedback.

  • Last Updated: 27 November 2023

    1.Introduction

    Pozitive Telecom Ltd (we, our, us) is a company registered in England & Wales (registration number 07764492) with our registered office at The Octagon, 27 Middleborough, Colchester, CO1 1TG.

    We are the data controller for your personal data. We are responsible for deciding how we process personal information about you and this Privacy Notice sets out we process this information. We are registered with the Information Commissioner’s Office (“ICO”), registration number ZB537181.

    We, together with our associated companies, provide services including energy, telecommunication, water, payment and Electric Vehicle charging (and any others that may be added from time to time and updated here) to our customers. The personal data we process is used to manage your relationship with us or an associated company (whether as a consumer or commercial relationship), comply with legal obligations and pursue our legitimate business interests.

    Any changes we may make to this Privacy Notice will be updated on our websites and, where appropriate, notified to you in writing. Should you have any queries relating to this notice please contact our Data Protection Manager using the address at the start of this privacy policy, so that they can do their very best to sort out the problem or email us at: datacontroller@pozitive.energy.

    2.Data we collect

    We will only ask for information that we need. We collect personal data to be able to provide our products and services to you. Where necessary, we may also collect personal data from others associated with you, for example if they are a beneficiary of the service e.g. including but not limited to your employees, contractors, agent or relatives. By giving us information about someone else for the purpose of arranging the service, you confirm that you have their permission to do so and that you have shared this Privacy Notice with them.

    We collect, use, store and transfer different kinds of personal data about you, depending on the service(s) we provide to you. We have grouped the data together as follows:

    • Identity Data includes first name, last name, title, gender, date of birth, identification numbers including copies of your passport, visa, driving licence, home address, personal telephone number, personal e-mail address, device identifiers.
    • Health Data includes type of vulnerability or impairment that may affect how services are accessed.
    • Contact Data includes billing address, business e-mail address and business telephone numbers.
    • Financial Data includes bank account, payment card details.
    • Transaction Data includes details about payments to and from you, other details of services you have purchased from us and usage data including who you make contact with and who contacts you.
    • Technical Data includes Internet Protocol (IP) address, your login data, browser type and version. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy [ADD LINK – Cookie Policy] for further details. The technical data we collect also includes your mobile device time zone setting and location, location history, mobile device telemetry data, mobile device data.
    • Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
    • Usage Data includes information about how you use our website, products and services, for example communications you made and received, websites you visited, performance metrics for example duration, time and cost of the communications, frequency of website access, service quality data.
    • Marketing and Communications Data includes your preferences in receiving marketing from us.
    • Other Personal Data includes personal data you otherwise voluntarily provide, for example when corresponding in writing (including via email or other electronic means), in meetings or during phone conversations or entered into any of our websites.

    The personal data collected will depend on whether you are a sole trader or corporate entity.

    The majority of the personal data provided by you is mandatory in order for us to administer the client relationship and perform our obligations under our contract(s) with you and/or comply with statutory requirements relating to the services we provide to you. Failure to provide mandatory personal data may affect our ability to perform the service and potentially affect your ongoing client relationship with us.

    We take the security of personal data very seriously. We have administrative, physical and technical safeguards in place to protect personal data against unlawful or unauthorised processing, or accidental loss or damage. We will ensure, where personal data are processed that:

    • The processing is recorded, and the record sets out, where possible, a suitable time period for the safe and permanent erasure of the different categories of data in accordance with our Data Retention Policy.
    • Where we no longer require Personal Data for the purpose for which it was collected, we will delete it or render it permanently anonymous as soon as possible.
    • Where records are destroyed, we will ensure that they are safely and permanently disposed of. The list set out above is not exhaustive, and there may be other personal data which we may collect, store and use in the context of the client relationship.

    3.How we use your data and the lawful basis

    Your data will be anonymised when we use it to test, develop and improve our services. By law we are required to explain what information we collect from you and how and why we use your personal information (the "processing activity"). We are also required to have a "lawful basis" on which to process your personal information. This is summarised in the table below.

    Where we use your data to test, develop and improve our services the data will be anonymised.

    Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest Where is the information collected from? How long do we keep the information for?
    To register you as a new customer or renew your contract (a) Identity
    (b) Contact
    (c) Financial
    Performance of a contract with you From you when you contact us directly by phone or email, or when you use our website, including our customer portal. 3 years with exception of call recordings.

    3 months for call recordings.
    To process and deliver your order including: (a) Manage payments, fees and charges
    (b) Collect and recover money owed to us
    (a) Identity
    (b) Contact
    (c) Financial
    (d) Transaction
    (e) Marketing and Communications
    (a) Performance of a contract with you
    (b) Necessary for our legitimate interests (to recover debts due to us)
    From you when you contact us directly by phone or email, or when you use our website, including our customer portal. 3 years with exception of call recordings.

    3 months for call recordings.
    To manage our relationship with you which will include:
    (a) Notifying you about changes to our terms or privacy policy
    (b) Asking you to leave a review or take a survey
    (c) Monitor service levels
    (e) Run coverage checker
    (a) Identity
    (b) Contact
    (c) Profile
    (d) Technical
    (e) Marketing and Communications
    (f) Health
    (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, give you access to services for Vulnerable Customers, and to study how customers use our services)
    (e) Necessary for our legitimate interest to ensure we provide you with accurate results of our network
    From you when you contact us directly by phone or email, or when you use our website, including our customer portal. 3 years with exception of call recordings and cookies.

    3 months for call recordings.

    Please refer to the cookie policy cookie policy for the retention periods.
    To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
    (b) Contact
    (c) Technical
    (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 restructuring exercise)
    (b) Necessary to comply with a legal obligation
    From third parties – including third parties who provide services to you and us, credit reference, fraud prevention or government agencies and financial institutions (where permitted by law). 3 years with exception of call recordings and cookies.

    3 months for call recordings.

    Please refer to the cookie policy cookie policy for the retention periods.
    To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
    (b) Contact
    (c) Profile
    (d) Usage
    (e) Marketing and Communications
    (f) Technical
    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) From the technology which you use to access our services (for example an IP address or telephone number) and how you use it; 3 years.
    To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
    (b) Usage
    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) From the techology which you use to access our services (for example an IP address or telephone number) and how you use it; 3 years with exception of cookies.

    Please refer to the cookie policy cookie policy for the retention periods.
    To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
    (b) Contact
    (c) Technical
    (d) Usage
    (e) Profile
    (f) Marketing and Communications
    Necessary for our legitimate interests (to develop our products/services and grow our business) From you when you contact us directly by phone or email, or when you use our website, including our customer portal 3 years with exception of call recordings and cookies.

    3 months for call recordings.

    Please refer to the cookie policy cookie policy for the retention periods.
    To market our products and services (including promotional offers) and those of our associated companies (a) Identity
    (b) Contact
    (c) Technical
    (d) Usage
    (e) Profile
    (f) Marketing and Communications
    (a) Consent
    (b) Necessary for our legitimate interests (to develop our products/services and grow our business)
    From you when you contact us directly by phone or email, or when you use our website, including our customer portal 3 years with exception of call recordings and cookies.

    3 months for call recordings.

    Please refer to the cookie policy cookie policy for the retention periods.
    To undertake checks for the purposes of preventing fraud and money laundering and to verify your identity (a) Identity
    (b) Contact
    (c) Financial
    (d) Employment
    (e) Technical
    Necessary for our legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws and meet the regulatory requirements that apply to us. From you and third parties e.g. credit reference agencies. 3 years with exception of cookies.

    Please refer to the cookie policy cookie policy for the retention periods.

    3.1 Credit reference and fraud prevention considerations

    Before we provide services to you, we undertake checks for the purposes of preventing fraud and money laundering and to verify your identity. These checks require us to process personal data about you.

    We also continue to exchange information about you with Credit Reference Agencies (CRAs) on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at http://www.experian.co.uk/crain/index.html.

    3.2 Automated Decisions

    As part of the processing of your personal data, decisions may be made by automated means. This means we may use automated processing methods to assess if you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision-making, so if you want to know more please contact us on the details below [ADD LINK TO PARA 10].

    3.3 Consequences of Processing

    If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services you have requested or we may stop providing existing services to you.

    A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details below [ADD LINK TO PARA 10].

    4.Who we share your personal data with

    Your personal data may be shared with third parties to fulfil part of the contract between us and them to enable us or them to provide the services to you and to comply with legal obligations:

    • Associated companies including Pozitive Payments Ltd, Pozitive Energy Ltd, First Business Water Limited to market their products or services that may be of interest to you. (Your consent may be required for us to do this.)
    • Organisations who provide us with IT and system administration services.
    • CRAs, law enforcement agencies, fraud prevention agencies, judicial bodies or tax authorities;
    • Government entities, authorities, regulatory and industry bodies.
    • Organisations who provide us with administration and processing services in order to provide a service to you, manage your account, maintain our relationships with you and for ongoing customer service, spam detectors.
    • Other communications companies where you switch providers.
    • Financial institutions if you enter into a handset and airtime agreement and organisations providing payment services which manage payments and direct debit instructions on our behalf in order to collect payments from you.
    • Accountants, lawyers, notaries and other professional advisers when considering, structuring, documenting, concluding, terminating, varying, amending or renewing a particular transaction already in place with you.
    • Companies that provide you with benefits or services associated with your good or service.
    • Revenue protection and debt collection services in order to enable debt recovery.
    • Organisations that help you with complaints management in order to respond to a complaint you made about us.
    • 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 policy.

    5.Data security

    We have policies, rules and technical and organisational measures in place to protect your personal data from unauthorised or unlawful processing and against accidental loss, destruction or damage.

    We also have procedures in place to deal with any data security breach. We will notify you and any applicable regulator of a data security breach where we are legally required to do so.

    Communications between you and us may route through a number of countries before being delivered, may be intercepted by third parties and may not always reach the intended recipient – this is the nature of the World Wide Web/Internet. We cannot accept responsibility for any such unauthorised access or loss of personal information that is beyond our control.

    You are responsible for protecting your username and password and must not share it with, or disclose it, to anyone.

    6.International transfers of Personal Data

    Your personal data may be shared with organisations based outside of the UK. These countries may not have the same data protection laws as the country in which you initially provided the information and may not provide the same level of protection.

    If we transfer personal data outside of the UK, we may rely on a decision from the Secretary of State determining that the recipient country provides an adequate level of protection. Alternatively, we may rely on appropriate safeguards in respect of transfers of personal data to a country outside of the UK, for example, by agreeing standard contractual clauses adopted by the ICO.

    7.Your rights

    Data protection laws provide you, as an individual, rights to:

    • access – you can request access to your personal information (a data subject access request), so you can check what data we hold about you and are using it in accordance with the law.
    • rectification – you can ask us to correct personal information that we hold about you.
    • erasure – you can ask us to delete your personal data where there is no good reason for us to hold this data. You can also ask us to delete or remove your personal information where you have exercised your right to object to processing.
    • restriction of processing – you can ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
    • data portability – you can ask for a copy of the data we hold about you, in an accessible format and the right to transfer it, or to require us to transfer it directly, to another controller.
    • object to processing – you can object to the processing of your personal information and there is something about your particular situation which makes you want to object to processing on this ground.
    • not to be subject to automated decisions - You have the right to object to any automated decision making, including profiling, where the decision has a legal or significant impact on you.
    • withdraw consent - you have the right to withdraw your consent where we are relying on it to use your personal data; and
    • objection to marketing. – you have the right to withdraw your consent to receive digital marketing material.

    No fee is required to claim any of these rights. However, we may charge a reasonable fee or refuse to comply if your request for access is considered to be unfounded or excessive. If you wish to exercise any of your rights, please contact us using the details set out below.

    8.Complaints, requests exercise your rights and our contact details

    If you have any queries or concerns regarding our processing of your personal data, would like to exercise any of your rights or would otherwise like to make a complaint, please contact our Data Protection Manager in the first instance at datacontoller@pozitive.energy.
    You have the right to make a complaint at any time to the Information Commissioner’s Office. Their contact details are:
    Telephone: 0303 123 1113
    Email: casework@ico.org.uk
    Post: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
    Website: www.ico.org.uk
    However, please contact us in the first instance if you have any issue that you wish to discuss.