Last updated: [Month 2026 — fill]
This policy explains how FlinxLayer LLC (trading as FlinxLayer) collects, uses, shares and protects your personal data when you enquire about, order or use our broadband and mobile services. We take privacy seriously and handle your data in line with the General Data Protection Regulation (GDPR) and applicable local law in [jurisdiction — fill].
1. Who is the data controller
The data controller is FlinxLayer LLC, registered Colorado SOS ID 20261603660, registered office 110 16th Street, Suite 1460, Denver, CO 80202, USA. For any privacy question or to exercise your rights, contact our privacy team at support@flinxlayer.com or write to us at the registered office, marked for the attention of the Data Protection Officer [DPO contact — fill].
2. What data we collect
- Account and identity data — your name, date of birth, account number and the identity or credit-check results we obtain when you sign up.
- Contact data — email address, phone number and the installation/billing address.
- Address and postcode — used to run availability and coverage checks and to schedule installation.
- Network, usage and traffic data — information generated as you use the service, such as connection records, data volumes, IP address assignment, and the technical metadata our network needs to route and operate your service.
- Payment data — billing details, processed through regulated payment processors; we do not store full card numbers ourselves.
- Support communications — the records of your contact with us, including call notes, chat and email, used to resolve issues and improve service.
3. Lawful bases for processing
We rely on one or more of the following lawful bases under the GDPR:
- Performance of a contract — to set up, provide, bill and support your service.
- Legitimate interests — to run, secure and improve our network, prevent fraud and abuse, and manage our business, where this is not overridden by your rights.
- Legal obligation — to meet regulatory, tax, accounting and lawful-data-retention requirements.
- Consent — for optional marketing and any non-essential cookies; you can withdraw consent at any time.
4. How we use your data
We use your data to check availability and complete installation, create and manage your account, provide and route your broadband and mobile service, take payment and issue bills, provide support, protect the network and other users from abuse and fraud, comply with our legal duties, and — only where permitted — keep you informed about relevant products.
5. Network, traffic data and lawful interception
As a network operator we generate and hold technical traffic data needed to deliver and secure your service. We may be required to retain certain communications data, and to assist with lawful interception or disclosure, under [applicable communications / data-retention law — fill]. We only do so where we have a valid legal obligation or a properly authorised request, and we keep such handling to the minimum the law requires.
6. Who we share data with
- Payment processors — to take and reconcile payments securely.
- Installers and field engineers — to carry out installation and fault work at your address.
- Upstream providers and internet registries — limited operational data where required to route traffic or maintain accurate registry/abuse records for our address space.
- Law enforcement and regulators — only on a lawful, properly authorised request, or where we are legally required.
- Professional advisers and service providers — acting as processors under contract and bound to protect your data.
We do not sell your personal data.
7. International transfers
Where data is transferred outside [jurisdiction / the EEA — fill], we put appropriate safeguards in place — such as an adequacy decision or Standard Contractual Clauses — so your data keeps an equivalent level of protection.
8. How long we keep it
We keep personal data only as long as needed for the purpose we collected it, then delete or anonymise it. Account and billing records are typically kept for the life of your contract plus the period required by tax and accounting law; traffic and communications data for the minimum period set by applicable retention law; support records for a reasonable period after closure. Specific retention periods are available on request.
9. Your rights
Subject to law, you have the right to:
- Access the personal data we hold about you.
- Rectify inaccurate or incomplete data.
- Erase data where there is no overriding reason to keep it.
- Restrict or object to certain processing, including direct marketing.
- Portability — receive your data in a portable format.
- Complain to your data-protection supervisory authority [authority name — fill] if you are unhappy with how we handle your data.
To exercise any right, email support@flinxlayer.com. We will respond within the period the law allows.
10. Cookies
Our website uses essential cookies to function and, with your consent, analytics cookies to understand how the site is used. You can manage non-essential cookies through your browser or our cookie controls. We will publish a fuller cookie notice [cookie notice link — fill].
11. Security
We use appropriate technical and organisational measures — including access controls, encryption in transit, network monitoring and staff confidentiality obligations — to protect your data against unauthorised access, loss or misuse. No system is perfectly secure, but we work continuously to keep your data safe and will notify you and the relevant authority of a qualifying breach as the law requires.
12. Contact
For any privacy matter, contact us at support@flinxlayer.com or by post to 110 16th Street, Suite 1460, Denver, CO 80202, USA for the attention of the Data Protection Officer [DPO contact — fill].