We can be contacted at the email address UKDataProtection@nttdata.com
Table of Content
The Company is the data controller of the personal data we collect from and about you through the Website and the Company Services.
What kind of personal data do we collect?
The Company might collect data from and about you.
Specifically, the Company collects (1) registration data, (2) data that you have voluntarily shared with the Company, (3) activity data and (4) information from other sources.
However, we do not collect either financial information or special categories of personal data relating to you (e.g., health or judicial data).
How do we use your personal data?
We collect your data to allow you to use the Website and/or to provide you with our Company Services, and to allow you to interact with such Company Services.
We may also use your data to send you offers promotions and marketing communications based on your personal preferences and habits. If you would prefer not to receive information of this nature, please see section 11
On what ground do we use your personal data?
Your personal data is collected to enable you to use the Website and the Company Services, and also to comply with legal obligation and/or to protect our legitimate interests.
We may not be able to offer you Company Services if you fail to provide relevant data. Similarly, we may not be able to grant you access to the Website without such data.
You will always have an option not to provide personal data for marketing purposes.
How do we process your personal data?
The security of your data is a top priority. We have implemented appropriate administrative, technical and physical measures to safeguard your personal data against loss, theft and unauthorised use, disclosure or modification.
Who can access to your personal data?
Subject to applicable laws, we may share your personal data with (i) service providers, (ii) our affiliated companies and (iii) national authorities.
Is your personal data transferred abroad?
Your personal data may be transferred to other countries within the European Economic Area (EEA) or countries recognised by the EU Commission as offering an adequate level of protection. For transfers to other countries, We will always ensure additional, appropriate and suitable safeguards are in place to protect your personal data.
What are your rights with regard to your personal data?
Among other rights, you have the right to access, integrate, update, amend and delete your personal data.
What happened on 25 May 2018?
The EU General Data Protection Regulation 2016/679 is effective as of 25 May 2018. This introduces additional data privacy obligations and additional rights for individuals.
The UK Data ProtecionProtection Act 2018 is effective as of 25 May 2018 and is the UK’s implementation of the GDPRenacts.
The Effective Date above shows the relevant date of release.
How can I contact you with regard to the processing of my personal data?
You can contact us at the following email address: UKDataProtection@nttdata.com
2. WHAT TYPE OF PERSONAL DATA DO WE COLLECT?
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.
3. 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;
Comply with the law or legal process or respond to requests from public and regulatory 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;
Provide you with (via email, SMS, telephone, chat and social media) offers, promotions and marketing communications relating to 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
Send (via email, SMS, telephone, chat and social media) marketing communications customised to your interests.
4. ON WHAT LEGAL BASIS DO WE PROCESS 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;
Point 8 of Section 3 above: processing is a 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, and
Point 9 of section 3 above: processing is a 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.
5. HOW DO WE PROCESS YOUR PERSONAL DATA?
As set out in Section 3 above, your data is processed through both electronic and manual means subject always to appropriate security measures. Please note that although we use appropriate administrative, technical, personnel and physical measures to safeguard the personal data we collect from loss, theft and unauthorised use, disclosure or modification, we cannot guarantee the full exclusion of all cyber-risks.
In order to protect the Company’s network and infrastructure we deploy Security Information and Event Management software to identify and counter attacks originating outside the organisation to prevent damage to critical company asset’s (data leakage, disruption of services etc.) to reduce / compensate their impact.
Although this data is collected on an anonymized basis, this information will be decrypted in the event of an attack, the decrypted information may include email and IP addresses.
6. 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, andCompetent national authorities/regulatory bodies in order to comply with applicable laws and regulations.
7. 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 at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en .
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 measures or further information on your personal data by contacting the Company at the address indicated in Section 11 below.
8. 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.
If you no longer want to receive marketing-related emails from us, you may opt-out by following the unsubscribe instructions in our communications or sending a request to the contact listed in Section 11 below.Section 9 outlines additional rights, effective from 25 May 2018.
9. WHAT IS GOING TO HAPPEN FROM 25 MAY 2018?
On 25 May 2018, the GDPR and the UK Data Protection Bill 2018 came into force and the following provisions apply:
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.
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 interest’s 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.
Last modified 28 February 2019.
11. CONTACT US
The Data Protection Officer is Lynda Osborne. NTT Data UK. 2 Royal Exchange. London EC3V 3DG
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