Privacy policy

Draft – last updated [DATE]. Items in [square brackets] need completing before the site goes live.

Who we are

Compare Phone Market (comparephonemarket) is run by Craig Fitches, a sole trader based in the UK. Craig Fitches is the “controller” of the personal data described in this policy, which means he decides how and why it is used.

Contact: [email protected]
Postal address: [ADDRESS]
ICO registration number: [ICO NUMBER]

The short version

• You do not need an account, and we never ask for your name, email address or payment details to compare deals.
• With your permission, we use analytics cookies to understand how the site is used. You can say no and the site still works.
• When you click through to buy, you leave our site. The retailer handles your order and your personal details, under its own privacy policy.
• We never sell your personal data.

What we collect

Always, because the site needs it:

• Your cookie choices, stored in the cpm_consent cookie on your device.
• Standard web server logs: your IP address, browser type, the page you asked for and the time. Our hosting provider keeps these to run the site securely and find faults.
• When you click “Buy now”, we record which deal was clicked and when, so we can show which phones are popular. We don’t use a cookie for this or store your IP address. Instead we keep a short code made from your IP address and browser that changes every day, so we can count each visitor once a day without being able to identify you or follow you from one day to the next.

Only if you accept analytics cookies:

• A random identifier stored in a cookie (for example _ga), so we can tell new visits from returning ones.
• The pages you view, the filters you use, the searches you make (and how many results they returned), and which deals you click through to.
• How you reached us, for example the website or advert that referred you and any campaign codes in the link (such as cmp1 or utm_source).
• Device and browser details, your approximate location (country or city, worked out from your IP address) and your language settings.

Only if you accept marketing cookies: information about whether you arrived from one of our adverts, so we can measure how well they work.

If you email us: your email address and whatever you choose to tell us.

Why we use it, and our lawful basis

• Running and securing the site (server logs, remembering your cookie choices): our legitimate interests in providing a working, secure website.
• Analytics (improving the site and understanding which deals are useful): your consent.
• Marketing measurement (understanding which adverts work): your consent.
• Earning commission (recording that a sale came from our site): our legitimate interests. Awin and the retailer set their own cookies for this on their websites.
• Replying to you when you contact us: our legitimate interests in answering your question.

You can withdraw your consent at any time using Cookie settings. Withdrawing consent does not affect anything collected before you changed your mind.

Who we share it with

We use trusted service providers who process data on our behalf:

• Google (Google Analytics), if you accept analytics cookies. Google Analytics 4 does not log or store IP addresses. [CONFIRM GOOGLE SIGNALS IS OFF]
• Adobe (Adobe Analytics and Experience Platform), if you accept analytics cookies.
• [HOSTING PROVIDER], which hosts the website and keeps server logs.
• Awin, our affiliate network, which records when a visit from our site leads to a sale so we can be paid. Awin is a controller of that data; see Awin’s privacy policy.

When you click a deal, the retailer or network (for example O2, giffgaff or iD Mobile) becomes responsible for any personal data you give them.

We may also share information if the law requires it.

International transfers

Google and Adobe may process data outside the UK, including in the United States. Where they do, they rely on the UK’s adequacy regulations (including the UK–US “data bridge”) or the UK International Data Transfer Addendum to protect your data.

How long we keep it

• Analytics data: 14 months, after which Google and Adobe delete it automatically. [CONFIRM THE RETENTION SETTING IN GA4 AND ADOBE]
• Analytics cookies on your device: up to 2 years, or until you clear them or turn analytics off.
• Your cookie choice (cpm_consent): 6 months.
• Server logs: [30] days.
• Emails: up to 2 years after we last hear from you.

Your rights

Under UK data protection law you have the right to:

• ask for a copy of your personal data;
• ask us to correct or delete it;
• object to, or ask us to restrict, how we use it;
• ask us to transfer it to you or someone else; and
• withdraw your consent at any time.

Because we do not know your name, we may need the analytics identifier from your browser to find your data. The easiest way to stop analytics is to turn it off in Cookie settings. To use any of these rights, email [email protected]. We will reply within one month.

Complaints

If you are unhappy with how we have used your data, please contact us first. You can also complain to the Information Commissioner’s Office (ICO) at ico.org.uk or on 0303 123 1113.

Children

This site is for adults. Phone contracts are only available to people aged 18 or over, and we do not knowingly collect data about children.

Changes to this policy

We will update this page if we change how we use personal data, and show the date of the latest version at the top. See our cookie policy for details of each cookie.