We use your personal data complying to all data protection laws and regulations, most commonly, in circumstances where:

we need to perform services under the agreed terms and conditions with you.
it is necessary for our legitimate interests in course of our business.
we need to comply with a legal or regulatory obligation.

We have set out below, a description of all the ways and the lawful basis we use your personal data. In addition to your consent, legal, and regulatory purposes, we have also listed our legitimate interests including performance management, product offerings, market research where applicable, which may override your rights subject to the law. Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

PURPOSEType of dataLawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity (b) Contact

Performance of terms and conditions with you and where applicable, as required by law

To supply products and services to you including: Managing payments Collecting money owed to us

(a) Identity (b) Contact (c) Financial (d) Billing

(a) Performance of terms and conditions with you (b) Necessary for our legitimate interests (to recover sums owed to us)

To manage our relationship with you and administer your account which will include: • Notifying you about changes to our terms and conditions or privacy policy • Detecting and preventing crime and fraud • Asking you to leave a review or take a survey • Manage any concerns that you raise to our customer care department • Quality assurance and monitoring purposes

(a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Customer Care (f) Usage

(a) Performance of terms and conditions with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to participate in a competition or complete a survey (non-promotional)

(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications

(a) Performance of terms and conditions with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To market products and services to you To complete a survey (promotional)

(a) Identity (b) Contact (c) Marketing and Communications (d) Profile

(a) Legitimate interest to process marketing data (to grow our business) and consent for sending electronic marketing communications for new customers or reliance on existing customer relationship to send electronic marketing communications

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical (b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile

Necessary for our legitimate interests (to develop Lyca Mobile products/services and grow our business)

Marketing You will receive marketing communications from us either if you have consented to receive them or you have purchased products or services from Lyca Mobile, and in each case, you have not opted out of receiving that marketing. You will also receive marketing communications from other Lyca entities if you have consented to receive such communications on their Lyca products or services.