Privacy Policy
This Privacy Policy explains what personal information Fortress Freedom Phone Ltd ("Fortress", "we", "us") collects when you contact us, place an order, or use one of our services, and what we do with it. We deliberately collect as little as possible, and we keep it for as little time as possible.
1. Who we are
Fortress Freedom Phone Ltd is a private limited company registered in England & Wales (Companies House No. 17168647). For data-protection purposes we are the data controller of any personal information we collect from you. You can reach us at admin@fortressfreedomphone.co.uk.
2. Information we collect
We only collect information when you give it to us, and only what we need to do the job:
- Contact details — your name (or alias), email address, phone number, and any messaging-app handle you use to reach us.
- Order details — the products and services you have ordered, the address or collection arrangement for delivery, and any preferences you have specified (e.g. duress PIN configuration).
- Payment information — confirmation of payment via the method you chose (cash receipt, bank transfer reference, card receipt, or cryptocurrency transaction reference). We do not store full card numbers; card payments are handled by our payment processor.
- Communications — the messages, calls, and emails you send to our customer-facing channels, kept for the period necessary to support you and to evidence the transaction.
We do not use any web analytics, advertising trackers, or third-party cookies on this website. The site uses no cookies of any kind. Visiting fortressfreedomphone.co.uk does not, by itself, place any data we hold about you.
3. Why we collect it & legal basis
Under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 we rely on the following lawful bases:
- Performance of a contract — to take and fulfil your order, deliver the device, set up your managed line, provide ongoing support, and process payment.
- Legitimate interests — to communicate with you about your account, to investigate suspected breaches of our Acceptable Use Policy, to maintain and improve the service, and to prevent fraud.
- Legal obligation — to respond to lawful requests by UK authorities, to comply with our regulatory duties as a UK communications operator, and to keep records required by tax and company law.
- Consent — only where we ask you for it explicitly, for example to keep you on a non-essential mailing list. You can withdraw consent at any time.
4. How long we keep it
We hold personal information only for as long as we need it for the purpose we collected it for, plus any minimum period required by law. As a guide:
- Active customer records — for the duration of your service plus six years from the end of the financial year of your last transaction, in line with HMRC record-keeping requirements.
- Order & payment records — six years, as required by tax and company law.
- Pre-sale enquiries that do not result in an order — up to twelve months, then deleted.
- Customer-facing message threads — for the life of the account, then deleted within twelve months of account closure.
Where the law allows, we delete or fully anonymise records earlier than the periods above.
5. Who we share it with
We share personal information only with parties who need it to deliver the service to you, and only the minimum required. These include:
- Shipping carriers — to deliver your device. They receive your delivery address and a parcel reference, nothing more.
- Payment providers — for card payments, to process the transaction. They receive payment details directly; we do not pass them anything beyond what is necessary to settle the payment.
- Our wholesale telecoms partners — for managed-line customers, the technical identifiers required to route calls to your line. They do not receive your name or contact details from us.
- Our infrastructure providers — limited operational data necessary to host the service and protect it from abuse.
- Lawful authorities — when we are served a valid legal order. We respond only to what the order requires, and only with information we hold.
We do not sell, rent, or share personal information for marketing purposes. We never share your communications content with any third party for any commercial purpose.
6. Where information is stored
Customer records are held within the United Kingdom and the European Economic Area. Operational telecoms infrastructure is hosted in Iceland, which is recognised by the UK as providing adequate protection for personal data. Where any third party we use is located outside the UK or EEA, we ensure that the transfer is covered by an appropriate safeguard recognised under UK data-protection law.
7. Your rights
Under UK data-protection law you have the right to:
- Be informed about how your data is used (this policy).
- Access a copy of the personal data we hold about you.
- Rectify inaccurate or incomplete data we hold about you.
- Erase ("right to be forgotten") your data, where we are not required to keep it for a legal reason.
- Restrict our processing of your data in certain circumstances.
- Object to processing based on legitimate interests, where applicable.
- Data portability — to receive a copy of your data in a structured, machine-readable format.
- Withdraw consent at any time, where processing was based on consent.
To exercise any of these rights, email admin@fortressfreedomphone.co.uk. We respond to all valid requests within one calendar month.
8. Security
We treat personal information with the same posture we apply to our own product. Records are encrypted at rest, access is restricted to staff who need it to do their job, and we use strong authentication on every system that holds customer data. We will notify you and the Information Commissioner's Office without undue delay if we discover a personal-data breach that meets the legal threshold for notification.
9. Children
Our products and services are intended for adults. We do not knowingly collect personal information from anyone under the age of 18. If you believe a child has supplied us with personal information, please contact us and we will delete it.
10. Changes to this policy
We may update this Privacy Policy from time to time. The current version is identified at the top of this page. Material changes will be brought to the attention of active customers by email at the address held on file.
11. Complaints
If you are unhappy with how we have handled your personal information, please contact us first and give us the opportunity to put it right. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO):
- Online: ico.org.uk/make-a-complaint
- Phone: 0303 123 1113
- Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF