Privacy Policy — Baltic Broadband Limited

Last Updated: July 2026

balticbroadband.co.uk is a website owned by Baltic Broadband Limited ("we", "us", "our"). We are committed to protecting and respecting your privacy and your personal data.

This policy (together with our Terms of Use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

We have appointed a Compliance Officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Compliance Officer using the details set out below.

1. Contact Details

Our full details are:

• Full name of legal entity: Baltic Broadband Limited (Company No. 10868537)
• Registered Office: Sandhills Studios, 51 Sandhills Lane, Liverpool, United Kingdom, L5 9XJ
• Email address: data.controller@balticbroadband.co.uk

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Your Duty to Inform Us of Changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you, categorised as follows:

• Information you give us: You may give us information about you by filling in forms on our site (balticbroadband.co.uk) or by corresponding with us by phone, email, or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, participate in a promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, email address, phone number, financial and credit card information, personal description, photograph, and customer number.
• Information we collect about you: With regard to each of your visits to our site, we may automatically collect technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform. We also collect information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through, and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
• Information we receive from other sources: We may receive information about you if you use any of the other websites we operate (if any) or the other services we provide. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment, and delivery services, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with internet connectivity or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. Cookies

Our website sometimes uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

We use the following cookies:

• Essential cookies: Required for the operation of our website, such as enabling secure logins.
• Analytical/performance cookies: Allow us to recognise and count visitors and see how they move around the site. This is statistical information and does not identify individuals.
• Functionality cookies: Used to recognise you when you return to our website, allowing us to personalise content and remember preferences.
• Targeting cookies: Record your visit to our website, the pages you have visited, and the links you have followed to make our website and advertising more relevant to your interests.

4. How We Use Your Personal Data

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

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

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for Which We Will Use Your Personal Data

Below is a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so, including our legitimate interests where appropriate:

Marketing & Opting Out

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us, purchased goods or services from us, or registered for a promotion, and you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by clicking the opt-out links on any marketing message sent to you, or by contacting us at optout@balticbroadband.co.uk.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosure and Transfer of Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the operational table above:

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
• If we receive a third-party complaint regarding unlawful or illegal service misuse (e.g., an alleged breach of copyright), we may use your IP address to notify you. Unless required by law, we will not disclose your personal information directly to the complainant.
• We may retain certain internet service usage data to comply with statutory law and will disclose this information when lawfully requested to do so.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

External Third Parties

• Service providers acting as processors based in the UK who provide IT, telecommunications network infrastructure, data centre colocation, and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in the UK who provide consultancy, banking, legal, insurance, and accounting services.
• HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Credit reference agencies and debt collection agencies for the purposes of managing your account, running credit checks, and recovering outstanding debts.

International Data Transfers

Some of our external third-party service providers (such as cloud hosting, productivity suites, and CRM platforms) may be based outside the United Kingdom (UK). Therefore, their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data under the UK data protection test (meaning their legal protections are not materially lower than those of the UK).
• Where we use certain service providers, we may use specific approved frameworks and contracts (such as the UK International Data Transfer Agreement or approved Standard Contractual Clauses) which give personal data the same statutory protection it has in the UK.

6. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

7. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it, and whether we can achieve those purposes through other means, alongside applicable statutory legal requirements.

In some circumstances, you can ask us to delete your data (see below). In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (a "data subject access request").
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data where there is no good reason for us continuing to process it.
• Object to processing of your personal data where we are relying on a legitimate interest or processing for direct marketing.
• Request restriction of processing to suspend the processing of your personal data in specific scenarios.
• Request the transfer of your personal data to you or to a third party.
• Withdraw consent at any time where we are relying on consent to process your data.

If you wish to exercise any of the rights set out above, you can contact us at any time by writing to us at Baltic Broadband Limited, Sandhills Studios, 51 Sandhills Lane, Liverpool, United Kingdom, L5 9XJ, or via email at data.controller@balticbroadband.co.uk.

Security Verification

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. How to Make a Data Protection Complaint

If you believe we have infringed on your data protection rights under the UK GDPR, you have the statutory right to lodge a formal complaint directly with us.

• How to submit: You can email your complaint directly to data.controller@balticbroadband.co.uk with the subject line "Data Protection Complaint".
• Our process: We will formally acknowledge your complaint within 30 days of receipt, investigate your concerns thoroughly, and keep you fully informed of our findings and any corrective actions taken.
• Escalation: You retain the right to escalate your complaint to the Information Commissioner's Office (ICO) if you remain unsatisfied with our internal resolution, though we appreciate the opportunity to resolve any issues with you directly in the first instance.

10. Glossary & Lawful Basis Definitions

• Legitimate Interest: Means the interest of our business in conducting and managing our operations to enable us to give you the best service/product and the most secure experience. We consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Performance of Contract: Means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a Legal or Regulatory Obligation: Means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.