We can be contacted at the email address UKDataProtection @nttdata.com
What kind of personal data do we collect?
We collects (1) registration data, (2) data that you have voluntarily shared, (3) data collected when you access and interact with the Website or the Company Service (“Activity Data), and (4) information from other sources. More specifically:
- Registration data: the information you submit to register for a Company Service. Registration data may include your name, surname, email address, gender, country, postcode and birthday etc.
- Data that you have voluntarily shared: the responses you submit to requests for information when using the Company Services or interacting with the Website. For example, when you sign up to our newsletters or online services, or interact with us through our contact section.
- Information from Other Sources: we may supplement the information we collect with information from other sources, such as publicly available information from social media services and commercially available sources.
When the information collected from or about you does not directly or indirectly identify you as a specific person, we may use that information for any purpose or share it with third parties to the extent permitted by applicable data protection laws and regulations.
We do not collect:
- Special categories of personal data. We ask that you do not send or disclose any information included in a special category of personal data (such as social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Website, the Company Services or otherwise.
How do we use your personal data?
We use the personal data we collect from and about you to:
- Allow you to use the Website and/or provide you with Company Services that best suit you;
- Measure and improve Company Services and features;
- Improve your Website and Company Service experience (online and offline) by delivering content you may find relevant and interesting;
- Provide you with customer support and to respond to your inquiries;
- Comply with the law or legal process or respond to requests from public and regulartory authorities;
- Complete a merger or sale of assets. If we sell all or part of our business or make a sale or transfer of our assets or are otherwise involved in a merger or transfer of a material part of our business, as part of that transaction we may transfer your information to the other party or parties involved;
- Upon your prior consent, deliver (via email, SMS, telephone, chat and social media) offers, promotions and marketing communications of the Website and the Company Services including group companies and co-branded services or features, such as contests or other promotions arranged together with a third party that may be hosted on the Website or the Company Services or on the third party's services; and
- Upon your prior consent, deliver (via email, SMS, telephone, chat and social media) marketing communications customised to your interests.
When the data collected from or about you does not identify you personally, we may use that information for additional purposes or share it with third parties.
On what ground do we use your personal data?
The legal basis of processing as as follows:
- Points 1 to 6 of Section 3 above: processing is necessary to run the Website and the provide Company Services. Processing is mandatory, as without such activities the relevant services could not be provided;
- Point 7 of Section 3 above: processing is required by applicable laws and therefore is mandatory; and
- Point 8 of Section 3 above: processing is on the basis of optional consent and, on occasion, the legitimate interest of the Company and of its counterparties. This data processing activity is not mandatory and you can object at any time as per Section 11 below.
- Point 8 or Section 3 above: processing is discretionary, but the lack of provision of consent may mean that you cannot connect or link to social media services via the Website or the Company Services;
- Point 9 or Section 3 above: processing is discretionary, but the lack of provision of consent may mean that the Company and third parties cannot provide you with generic marketing communications of the Company and third parties services/products or communications based on your interests, or provide co-branded services.
You can revoke your consent to data processing under Points 8 or 9 of Section 3 above at any time by sending a communication as set out in Section 11 below.
Who has access to your personal data?
For the purposes set out at Section 3 above, we may share your personal data to the following categories of recipients in compliance and with Section 7 below:
Third parties service providers entrusted with processing activities and duly appointed as processors when required by applicable laws, e.g. cloud service providers, other entities of the group, providers of services instrumental to or supporting the Company Services - and thus, by way of example and without limitation, companies that provide IT services, experts, consultants and lawyers - companies resulting from possible mergers, demergers, or other transformations, and
Competent national authorities/regulatory bodies in order to comply with applicable laws and regulations.
Is your personal data transferred abroad?
Your personal data may be transferred to countries within and outside the European Economic Area (EEA), in particular to the USA and India. Some non EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards. The full list of these countries is available
For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place appropriate and suitable safeguards to protect your personal data. Any transfer of your personal data is in compliance with the requirements and the obligations provided by applicable data protection laws, such as standard contractual clauses adopted by the European Commission as per Articles 45 and 46 of the EU General Data Protection Regulation 2016/679 (the “GDPR").
You have the right to request a copy of the above measure or further information on your personal data by contacting the Company at the address indicated in Section 11 below
What are your rights with regard to your personal data?
You have the right, at any given time, to:
- Confirm whether your personal data exists, be informed of its content and source, and verify its accuracy or request integration, update or amendments;
- Request the deletion, conversion to an anonymous form or restriction of any personal data processed in breach of applicable law; and
- Oppose data processing, in all cases, for legitimate reasons.
To exercise these rights, you may send a request to the contact listed in Section 11 below. Your request should include your email address, name, address, and telephone number and specify clearly what information you would like to access, change, update, suppress or delete.
After you cancel your account, or if you ask us to delete your personal data, copies of some information may remain viewable in certain circumstances. For example, where you have shared information with social media or other services. In addition, due to the nature of cache technology, your account may not be instantly inaccessible to others. We may also retain backup information related to your account on our servers for some time after cancellation or your request for deletion, to comply with applicable law.
With regards to information provided for marketing purposes, you may revoke your consent to process at any given time. If you no longer want to receive marketing-related emails from us, you may opt-out of these marketing-related emails by following the unsubscribe instructions in our communications or sending a request to the contact listed in Section 11 below
What is going to happen on 25 May 2018?
From 25 May 2018, the GDPR is effective and the following provisions apply:
A. Retention period applying to your personal data
- Data collected for the purposes set out in Points 1 to 7 of Section 3 above is retained for such time necessary to provide you access to the Website or to provide the Company Services, plus the length of any applicable statutory limitation period following the termination of Company Services; and
- Data collected for the purpose set out in Points 8 or 9 of Section 3 above is retained for a period of three years.
At the end of the retention period your personal data will be either deleted, anonymised or aggregated.
B. Additional rights
From 25 May 2018 you also have the right at any given moment to:
- Request that we limit the processing of your personal data where:
- You contest the accuracy of the personal data, until such time as we have taken sufficient steps to correct or verify its accuracy;
- The processing is unlawful but you do not want us to erase the data;
- We no longer need the personal data for the purposes of the processing, but you require the data for the establishment, exercise or defense of legal claims; or
- Where you have objected to processing justified on legitimate interests grounds until such time as we have verified compelling legitimate grounds to continue processing,
- Object to the processing of your personal data;
- Request the erasure of your personal data without undue delay;
- Data portability (e.g. to receive an electronic copy of your personal data, if you would like to port your personal data to yourself or a different provider), when we are relying upon your consent or the fact that the processing is necessary for the provision of the Company Services and the personal data is processed by automatic means; or
- Lodge a complaint with the relevant supervisory authority.