Three Children’s Privacy Notice
This Privacy Notice does not apply to the practices of any third-party apps, actions or websites that you or your child may use. You should review the applicable terms and policies for third party apps, actions, and sites to determine their appropriateness for your child, including their data collection and use practices.
Information We Collect
Once you grant permission for your child to have a Three account, their account will generally be treated like your own with respect to the information that we collect. For example, we collect:
- Information you and your child create or provide to us.
As part of the account creation process, we may ask for personal information like first and last name, address, email address, and birthdate. We collect the information you or your child provide, such as your online contact details, which are necessary for us to contact you to request consent.
- Information we get from your child’s use of our services.
We automatically collect and store certain information about the services your child uses and how your child uses them. This includes information such as:
- Your child’s device, calling, and traffic records.
We collect information about the network activity of your child’s use of Three services, including unique identifiers, device type and IMEI identifier, device settings, mobile network information including carrier name and phone number IMSI identifier information. We also collect information about the interaction of your child’s devices with our services, including IP addresses, calling and SMS messaging activity, and the date, time of such activity.
- Your child’s activity and billing information.
We collect information about your child’s activity in our services, which we use to do things like generate, calculate, and issue charges for services provided to your child.
- Your child’s location information
We collect information about your child’s location when they use our services. Your child’s location can be determined by using network data from cell towers. We use this information for network diagnostic purposes and for the creation of anonymised and aggregated data that we share with our partners.
How We Use Information We Collect
Information Your Child Can Share
Your child may be able to share information, including photos, videos, audio, and location, publicly and with others, when using their device. If your child shares information publicly, it may be accessible through search engines like Google Search. Three is not responsible for any information that your child may share.
Information Three Shares
Information we collect may be shared outside of Three in limited circumstances. We do not share personal information with companies, organizations, and individuals outside of Three except in the following cases:
- With consent
We will share personal information outside of Three with consent (as applicable).
- For external processing
- For legal reasons
We will share personal information with companies, organisations or individuals outside of Three if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- meet any applicable law, regulation, legal process or enforceable governmental request;
- enforce applicable Terms and Conditions of Service, including investigation of potential violations;
- detect, prevent, or otherwise address fraud, security or technical issues; or
- protect against harm to the rights, property or safety of Three, our users or the public as required or permitted by law.
“Digital Age of Consent”
GDPR provides that where an Information Society Service is offered directly to a child, the processing of the personal data of a child on a consent basis shall be lawful where the child is at least 16 years old. Below the age of 16, parental consent must be sought. This is often referred to as the “Digital Age of Consent”.
However, this provision applies only to consent, and only to Information Society Services. The only processing undertaken by Three which fits into these categories is our loyalty scheme 3Plus. Membership in this scheme is limited to adults.
Access to Your Child’s Personal Information
Children have Data Protection rights of their own, independent of their parents. However, Three is mindful that parents also have an interest and a duty in monitoring and managing their children’s usage of telecommunications services, especially at a younger age.
If your child’s phone number is set up as a line on your account, as the bill-payer you will receive bills including usage on this account. These bills may be itemised, showing the recipient of each call and sms, should you so choose. As a contact on the account, your child can also access this data, but not in relation to your usage or that of any other contact on the account.
If your child has a prepay account and is under the age of 13 you will be able to engage with the account subject to passing the standard identity confirmation questions (e.g. name, DoB, etc) that we ask of all customers.
If your child has a prepay account and is 13 or over, they may set you up as an authorised contact on the account. This will allow you to engage with the account through our customer care channels. You will be asked to set up a password. Please keep this safe as it will be used to validate you as the authorised contact on the account.
If your child has a Three Account, they or you can access, update, remove, export, and restrict the processing of your child’s information by signing into their My3 Account. Once signed in, you can use the various controls, to help manage your child’s privacy settings and information.
If at any time your child or you wish to stop further collection or use of your child's information, you can terminate your child’s Three Account by contacting Three customer service. Your child’s account and information will be permanently deleted within a reasonable period of time, subject to the Three Data Retention Policy.
The Right to Lodge a Complaint
If you are unsatisfied with any aspect of Three’s processing of your data, you have the right to lodge a complaint with a supervisory authority. The supervisory authority for Ireland is the Office of the Data Protection Commissioner.
Relevant Terms and Conditions
You should read this Privacy Notice in conjunction with the Terms for Three Services.
If you have any questions about your child’s Account, including how Three collects and uses your child’s data, please don’t hesitate to contact us.
You can contact Three in a number of ways, which are set out on the contact page of our website.
In accordance with Article 37 of the GDPR, Three has appointed a Data Protection Officer. If you wish to contact our Data Protection Officer in relation to the processing of your personal data by Three, you can do so by e-mailing: email@example.com
Changes to our Privacy Documentation
This Data Protection Notice is kept under regular review and is therefore subject to change. Amended versions of this document shall be notified through publication in the Privacy Centre on the Three website. This document was last reviewed on the 6th of October 2022.