SBPM Care Privacy Notice

1. Who we are

SBPM Partners UK Ltd is the controller responsible for personal information used to offer and provide SBPM Care. Our registered or principal office is Centenary House, Peninsula Park, Rydon Lane, Exeter, Devon, EX2 7XE, United Kingdom. Registration number: 17063003. UK VAT number: GB 517 2006 28.

Privacy contact: privacy@sbpmcare.com | Centenary House, Peninsula Park, Rydon Lane, Exeter, Devon, EX2 7XE, United Kingdom

This notice applies to the SBPM Care website, sign-up and payment journey, customer-care interactions, appointment planning, annual visits, reports, cancellations and complaints. SBPM Care is separate from Starlink’s internet service. Starlink has its own privacy practices for its services and accounts.

2. Information we collect

• Identity and contact data: name, service and billing address, email address, telephone number, country and communication preferences.
• Contract and payment data: subscription start date, plan, billing status, transaction references, refunds, payment token and limited card information supplied by our payment provider, such as card type, expiry and last four digits. We do not receive or store your full card number or security code.
• Installation and property data: installation address, installation date, relevant equipment and setup details, appointment windows, access instructions, installer notes, service history and information needed to coordinate safe access.
• Visit and report data: checklist results, basic performance observations, recommendations, technician notes and photographs of the installation, visible cable route and relevant property areas.
• Customer-care data: enquiries, emails, call notes or recordings where notified, complaints, cancellation requests and the outcome of support interactions.
• Website and device data: IP address, device and browser information, security and diagnostic logs, and information from cookies or similar technologies.
• Marketing data: your choices, consent records, opt-outs and engagement with messages where lawful.

Please do not send medical details or other sensitive information unless we ask and it is necessary. If you need a reasonable adjustment, tell us the adjustment you need rather than a diagnosis where possible.

3. Where the information comes from

• Directly from you when you view the site, join, pay, contact us, book or attend a visit, cancel or complain.
• From our payment provider when a payment succeeds, fails, is refunded or is disputed.
• From our UK field-service partner and technicians when they plan or complete work and reports.
• From Starlink or another installation coordinator where they are permitted to share installation information with us for the original installation or where sharing is necessary and lawful for the SBPM Care service you request.
• From our IT, communications, fraud-prevention and website providers through operation and security of the service.

4. Why we use information and our lawful bases

To take steps at your request and perform the contract

We use identity, contact, payment, installation, appointment, visit and support data to check eligibility, accept and administer your subscription, collect payment, coordinate the field-service partner, deliver the annual visit and report, provide customer care and process cancellation. The lawful basis is that processing is necessary to enter into or perform our contract with you.

To meet legal obligations

We use and retain information where necessary for tax and accounting records, consumer rights, complaints, fraud prevention, sanctions or other legal and regulatory duties. The lawful basis is compliance with a legal obligation.

For our legitimate interests

We may use limited information to secure and troubleshoot our systems, prevent misuse and fraud, defend legal claims, train staff, manage service quality, analyse de-identified or aggregated performance, and improve our customer and field processes. Our interests are operating a secure, reliable and accountable service. We balance those interests against your rights and use less intrusive information where possible.

With your consent

We rely on consent where required for non-essential cookies or similar technologies and for electronic marketing where another lawful route is unavailable. Consent is optional and may be withdrawn at any time without affecting earlier lawful processing.

Direct marketing

We send consumer email or text marketing only where you consented or where every requirement of the applicable PECR soft opt-in is met. Each message identifies SBPM and provides a simple unsubscribe route. We keep a suppression record if you opt out so we can respect your choice. Service messages about your subscription, payments, appointments, report, safety or legal terms are not marketing.

5. When information is required

We need your name, contact details, service location and payment information to enter into and perform the contract. If you do not provide required information, we may be unable to accept the order, arrange a visit or provide the service. Optional marketing choices and non-essential cookies are not required to buy SBPM Care.

6. Who we share information with

We share only what is reasonably necessary with:

• our UK field-service partner and assigned technicians, for eligibility, scheduling, safe access, service delivery and reporting;
• our payment provider, currently Stripe, for payment, billing, refunds, fraud checks and disputes;
• website, hosting and security providers, currently including Vercel for the web application;
• customer relationship, email, telephony, scheduling, reporting and IT-support providers used in production;
• professional advisers, auditors, insurers and potential business transferees under appropriate confidentiality controls; and
• courts, regulators, law enforcement or other authorities where disclosure is required or permitted by law.

Our service providers may act as processors under our instructions or as separate controllers for their own legal obligations. The production vendor list and contractual roles are reviewed and maintained internally.

7. International transfers

SBPM and some suppliers may process personal information outside the United Kingdom, including in the United States. Where UK data-protection law requires a transfer safeguard, we use an applicable adequacy regulation or data bridge, the UK International Data Transfer Agreement or UK Addendum, or another lawful safeguard. You may request information about the relevant safeguard by contacting privacy@sbpmcare.com.

8. Retention

We keep personal information only for as long as necessary for the purposes described above. Our proposed customer-facing retention periods are:

• contract, billing, payment and core service records: the contract term plus up to seven years, to meet tax, accounting and legal-claim requirements;
• annual-visit reports and installation photographs: the contract term plus up to seven years, unless a shorter period is appropriate;
• routine customer-care records: up to three years after the matter closes;
• unsuccessful or abandoned sign-up data that is not needed for a contract, fraud or legal record: up to 30 days;
• marketing consent and suppression records: for as long as needed to demonstrate and respect your choice; and
• website security logs: normally up to twelve months, unless a security incident or legal need requires longer.

We may keep information longer where required by law, needed for an active dispute or claim, or requested by an authority. We may anonymise data so it no longer identifies anyone and then retain the anonymous information for analysis.

9. Security

We use technical and organisational measures designed to protect personal information, including access controls, supplier due diligence, secure transmission, staff confidentiality and incident procedures. No system is completely secure, but we review controls in light of the sensitivity and risk of the information.

10. Your rights

Depending on the circumstances and lawful basis, you may have the right to access your information, correct it, ask for deletion or restriction, receive certain information in a portable form, object to processing based on legitimate interests, withdraw consent, and complain to the ICO. Some rights have legal limits, for example where records must be retained by law.

To exercise a right, contact privacy@sbpmcare.com. We may ask for proportionate information to verify identity and protect your data. There is normally no fee.

11. Cookies and similar technologies

We use technologies that are strictly necessary to provide, secure or remember essential choices for the site and checkout. Where production uses non-exempt analytics, personalisation or marketing technology, we provide clear information and the consent or objection control required by law before it is activated. You can revisit choices through the “Cookie settings” link where applicable.

12. Automated decisions

We do not currently make decisions based solely on automated processing that have legal or similarly significant effects on SBPM Care customers. If this changes, we will update this notice and provide the information and safeguards required by law.

13. Complaints about privacy

Please contact privacy@sbpmcare.comfirst so we can investigate. You may also complain to the Information Commissioner’s Office at ico.org.uk/make-a-complaint, telephone 0303 123 1113, or write to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Your right to complain is not affected by contacting us first.

14. Changes to this notice

We may update this notice to reflect service, supplier or legal changes. We will publish the new version and effective date. If a change materially affects how we use existing information, we will take additional steps required by law, which may include direct notice or obtaining consent.