Privacy policy

This website is operated by OG Exclusives London Ltd, with a registered address at Crossways School Road, Charing, Ashford, Kent, TN27 0JN. You know us by our trading name, GRADE MOBILE.

Our Privacy Policy outlines how we collect, store, and process your personal data. Grade Mobile is committed to protecting your privacy and will ensure your personal information is handled securely and in accordance with the Data Protection Act 2018 and the General Data Protection Regulation (GDPR). Under these laws, OG Exclusives London Ltd is the "controller" of your personal data.

We ask that you carefully read this policy to understand how we manage your personal data, both when you interact with us directly and when you visit our website. We will request your consent for certain data collection activities, such as cookie usage, when you visit our site.


1. Information We Collect

We collect personal data from you in the following ways:

1.1. Information You Provide Directly

When you engage with our website, for example, by submitting forms or making purchases, you provide us with information such as:

  • Your name
  • Address
  • Email address
  • Phone number
  • Date of birth

1.2. Information Collected Automatically

When you visit our website, we may automatically collect certain information, including:

  • A truncated and anonymized version of your IP address
  • Browser type and version
  • Operating system and platform
  • Information on how you arrived at and navigate through our site (such as page response times, pages visited, clicks, and download errors)

We use third-party tracking services like Google Analytics, Microsoft Clarity, and Facebook Pixel to better understand your experience on our website and improve the services we offer. 

1.3. Cookies

We use cookies to distinguish you from other users. Cookies help us provide you with a better user experience and improve our website functionality. You can manage your cookie preferences or withdraw consent via your browser settings or through our cookie banner. For more details, see our Cookie Policy.


2. How We Use Your Information

Under UK GDPR and the Data Protection Act 2018, we will only process your personal data when we have a lawful basis to do so. We will ensure that any data processing meets one of the following conditions:


2.1. Legal Bases for Processing

We will process your personal data only when:

  • It is necessary to perform a contract with you (e.g., to provide products or services you have requested).
  • It is in our legitimate business interests to do so (e.g., to improve our services or prevent fraud). Where we rely on legitimate interests, we ensure these interests do not override your fundamental rights and freedoms.
  • You have provided consent, particularly for marketing communications (you can withdraw consent at any time).
  • It is necessary for legal compliance, such as when conducting due diligence for fraud prevention.
  • We are required to do so for a task in the public interest, such as preventing financial crime or assisting vulnerable customers.

3. Marketing and Communication

We may contact you via phone, email, or text for the following purposes:

  • To complete pre-sale Know Your Customer (KYC) and Customer Due Diligence (CDD) checks.
  • To discuss any missed payments or arrears and explore whether support measures can be provided.
  • To remind you of contract renewals or offer upgrades.
  • To request feedback or send marketing content (with your prior consent).
  • For any other communication required by law or regulation.

You have the right to opt-out of receiving marketing communications at any time by contacting us directly at contact@grademobile.co.uk.


4. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including legal, accounting, or reporting requirements.

For example, we are legally required to keep certain basic customer information (e.g., contact, identity, financial and transaction data) for six years after you stop being a customer, for tax purposes.

When we no longer need your personal data, we will either delete or anonymize it. If deletion is not possible (e.g., because the data is stored in backup archives), we will securely store and isolate the data from further processing until deletion is possible.


5. Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed unlawfully. These measures include:

  • Encryption of personal data, both in transit and at rest.
  • Access controls to limit access to your data to only those employees, agents, contractors, and third parties who have a business need to know.
  • Regular security reviews and procedures for handling data breaches.

Despite these precautions, please note that transmission of data over the internet is not entirely secure, and any transmission of personal data to our website is done at your own risk.


6. Sharing Your Information

We only share your personal data with trusted third parties to help deliver our services or to meet legal obligations. These include:

  • Companies within the OG Exclusives Limited group.
  • Third-party service providers, such as payment processors, delivery services, and marketing agencies.
  • Credit reference agencies, for identity checks or when offering credit broking services.
  • Debt collection agencies, when necessary to recover missed payments.
  • Customer due diligence providers, for identity verification and fraud prevention.
  • Professional advisers, such as lawyers, auditors, and insurers.

We will ensure that any third parties we engage are subject to strict data protection and confidentiality agreements, and we will only share the minimum amount of personal data necessary.


7. International Data Transfers

In some cases, your personal data may be transferred to, and processed in, countries outside the UK and the European Economic Area (EEA), including the US. When we transfer data outside of the UK, we ensure that appropriate safeguards, such as Standard Contractual Clauses (SCCs), are in place to protect your data in accordance with applicable laws.


8. Your Rights

Under the UK GDPR, you have several important rights in relation to the personal data we hold about you. These rights are explained below:


8.1. Right of Access (DSARs)

You have the right to access the personal data we hold about you, commonly referred to as a Data Subject Access Request (DSAR). This allows you to receive a copy of your personal data and check that we are lawfully processing it.

To make a DSAR, please follow these steps:

  • Submit Your Request: You can submit your request by email to contact@grademobile.co.uk or by post to PO Box 807, Folkestone, CT20 9NG. Please include the subject line: "Data Subject Access Request."
  • Proof of Identity: To protect your privacy, we will need to verify your identity before disclosing any personal information. Please provide a copy of your ID (e.g., passport or driver’s license) and proof of address (e.g., recent utility bill or bank statement).
  • What We Need to Know: In your request, please specify the personal data you wish to access and any particular processing activities or time periods you are interested in. This will help us respond to your request more efficiently.

We will respond to your request within one month of receipt, in accordance with the UK GDPR. In some cases, we may need additional time to process complex requests, in which case we will notify you of the extension within the one-month period.


8.2. Right to Rectification

You can ask us to correct any inaccurate or incomplete information we hold about you. If you believe any of your personal data is incorrect, please contact us with the necessary details, and we will update our records accordingly.


8.3. Right to Erasure (Right to be Forgotten)

You may request that we delete your personal data in certain circumstances, such as:

  • When the data is no longer needed for the purposes for which it was collected.
  • When you withdraw your consent (if processing was based on consent).
  • When the data has been unlawfully processed.

Please note, however, that we may retain some information where required by law or where we have legitimate grounds to do so (e.g., for compliance with legal obligations or the establishment, exercise, or defence of legal claims).


8.4. Right to Restrict Processing

You have the right to ask us to suspend processing your personal data if:

  • You contest the accuracy of the data (while we verify this).
  • The processing is unlawful, but you do not want us to erase the data.
  • We no longer need the data, but you want us to keep it for legal claims.
  • You have objected to us processing your data, but we are verifying whether we have overriding legitimate grounds to continue processing it.


8.5. Right to Data Portability

You have the right to request that we transfer the personal data you provided to us to another organisation, or directly to you, in a structured, commonly used, and machine-readable format (such as a CSV file). This right only applies where:

  • The processing is based on your consent or a contract.
  • The processing is carried out by automated means.


8.6. Right to Object

You can object to us processing your personal data in certain circumstances. For example, you can object to:

  • Processing based on legitimate interests, where you feel it impacts your rights and freedoms.
  • Direct marketing, including profiling for marketing purposes. You can easily opt-out of receiving marketing communications by following the unsubscribe instructions in our emails or by contacting us directly.

8.7. Right Not to Be Subject to Automated Decision-Making

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significant effects concerning you. This includes decisions such as credit checks that are performed automatically. You may request human intervention and contest the decision if you believe it has been made incorrectly.


8.8. Right to Withdraw Consent

If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. Once consent is withdrawn, we will cease processing your data for that specific purpose unless we have another lawful basis to continue.


How to Exercise Your Rights

To exercise any of these rights, please:

  • Email us at contact@grademobile.co.uk or write to us at GRADE MOBILE, PO Box 807, Folkestone, CT20 9NG.
  • Provide sufficient information to verify your identity (e.g., full name, address, customer or matter reference number, and a copy of your ID).
  • Specify which right you wish to exercise and, if applicable, the specific information to which your request relates.

We will respond to your request within one month. If your request is complex or we require additional information.


9. Automated Decision-Making

We may use automated decision-making processes, such as credit checks and identity verification, to assess your eligibility for certain services. These processes are necessary to enter into or perform a contract with you. If you have concerns about the results of an automated decision, you can request human intervention, express your point of view, or challenge the decision.


10. Changes to Our Privacy Policy

We may update this policy from time to time to reflect changes in the law or our business practices. Any significant changes will be posted on our website, and we may notify you by email if necessary.


11. How to Contact Us

If you have any questions about this Privacy Policy or your personal data, please contact us at:

GRADE MOBILE
PO Box 807
Folkestone
CT20 9NG
Email: contact@grademobile.co.uk


12. Complaints

If you are not satisfied with our response to any concerns you raise, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO). You can contact the ICO via their website at www.ico.org.uk or by telephone: 0303 123 1113.