For the purpose of the General Data Protection Regulation and the UK Data Protection Bill 2018, the data controller is NTT Europe Limited, company number 02307625, whose registered office address is 1 King William Street, London, EC4N 7AR, England (collectively referred to in the Policy as “NTT”, “we” or “us”).
This Policy applies to the websites operated by NTT, accessible via www.eu.ntt.com and any mobile applications or other online and/or mobile applications or Websites operated by us that are related to us (collectively, the “Websites”).
When you provide us with information whilst visiting Websites operated by or under instruction of NTT, as a customer of ours, or direct to us by other means, it may contain personal data. We will protect your personal data in accordance with this Policy. Personal data means any information from which a person can be identified directly or indirectly by reference to an identifier such as your name, identity number, e-mail address or IP address.
1. Information we may collect from you
1.1. We may collect and process the following data about you:
1.1.1. Information that you provide by filling in forms on our Websites. This includes information provided at the time of registering to use our Websites, subscribing to our service, requesting research papers, posting material or requesting further services including, for example, name, business address, job title, job function, email address, telephone number, demographic information and/or other information that may identify you as an individual. We may also ask you for information when you enter a competition or promotion sponsored by us, sign-up for email newsletters and when you report a problem with our Websites. You can choose not to provide us with some of this information, but doing so may affect your ability to use our Websites and our services.
1.1.2. If you contact us, we may keep a record of that correspondence.
1.1.3. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
1.1.4. Subject to your expressed marketing preferences, to send you marketing information about goods and services which may be of interest to you by post, telephone, email or other means. You have the right to "opt in” and "opt out” of certain uses of your personal data for these purposes.
1.1.5. Details of your visits to our Websites including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own purposes or otherwise and the resources that you access.
1.1.6. Information we may receive about you if you use any of the other Websites we operate or the other services we provide. This may include information sent to us from other parties operating those services on our behalf, including, for example, sub-contractors in technical, payment and delivery services, advertising networks and analytics providers. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
1.1.7. Your contact details: postal address, telephone numbers (including mobile number) and email address, so that we can communicate with you via telephone, email, letter, text message, social media, or in person.
2. IP addresses and cookies
2.1. We may collect information about your computer, mobile phone, personal electronic device, and all other similar electronic or mobile devices, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not show personal details that identify you.
2.2. For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies are small pieces of information (e.g. cookies, web beacons, pixels, gifs tags or other similar technologies) sent by a web server to a web browser which allow the web server to recognize the web browser. This operates as a piece of data stored on your browser or device, or may identify, compile, aggregate and/or collect information through other means. They help us to improve our Websites and to deliver a better and more personalized service. They enable us:
2.2.1. To estimate our audience size and usage pattern.
2.2.2. To store information about your preferences, and so allow us to customize our Websites according to your individual interests.
2.2.3. To speed up your searches.
2.2.4. To recognize you when you return to our Websites.
2.2.5. You can control how your browser handles cookies received from our website. You can choose to refuse all cookies, or to be prompted before a cookie is saved to your hard drive, or to only accept cookies from certain websites that you designate. Information on deleting or controlling cookies is available at www.AboutCookies.org. By refusing to accept cookies from us, you may not be able to use some of the features and functionality available on our Websites.
For specific information about the cookies we use click here.
3. Uses Made Of The Information
3.1. We use information provided by you and/or held about you (including your personal data) in the following ways:
3.1.1. To ensure that content from our Websites is presented in the most effective manner for you and for your computer.
3.1.2. To carry out our obligations arising from any contracts or transactions entered or contemplated to be entered into between you and us or to provide you with the Websites and any services requested by you.
3.1.3. For any specific purpose for which it was provided or volunteered.
3.1.4. To develop, market, sell or provide products and services.
3.1.5. To keep you apprised of information and developments that you may find of interest.
3.1.6. To inform you of our or our business partner's products or services.
3.1.7. To perform analysis and research in relation to transactions, including without limitation, analysing and conducting research on our user's demographics and interests, information about your browsing and viewing preferences.
3.1.8. To allow you to participate in interactive features of our Websites including services provided by our affiliated companies including companies that, directly or indirectly: control us; or are controlled by us; or are under common control with us, when you choose to do so. Please see Section 6 for further information.
3.1.9. To notify you about changes to our services.
3.1.10. If you review or download information, we track the visit to give us information about which part of the Websites is frequented.
3.1.11. To send you notices (for example, in the form of e-mails, SMS, mailings, and the like), and otherwise correspond with you, about products, services, companies and events, sponsored by us and others, that we think might interest you, where you have consented to be contacted for such purposes.
3.1.12. When you submit information and/or your CV for a job application on our careers site or directly this will be used for background checks and where applicable for obtaining references. This will contain personal data, and may contain sensitive information submitted by you. We will use information held about you to provide you with updates on the status of your application and provide you with information about job opportunities.
3.2. We use information on the basis that its use is necessary:
3.2.1. to fulfil a contract that we have in place with you,
3.2.2. for the purposes of our or a third party’s legitimate interests (including our legitimate commercial and related interests, such as understanding our customers and potential customers and providing you with information on our products and services); or
3.2.3. for compliance with a legal obligation to which we are subject, or where you have given us your consent.
4. Where we store your personal data
4.1. The information that we collect from you may be transferred to, and stored at, or processed from a destination outside the European Economic Area where the laws applicable to your personal data may offer the same level of protection. Those processing your personal data may be engaged in, among other things, provision ofmarketing or support services. We will adopt appropriate safeguards necessary to ensure that your data is treated securely and in accordance with this policy and applicable laws. If your personal data is to be transferred to or processed by another organisation in a country that is not listed as 'adequate' by the European Commission, we will only do so if we have contracts or other appropriate safeguards (protection) in place in accordance with the GDPR.
5.1. While we have implemented reasonable technical and organisational precautions to protect the security and integrity of personal data provided to our Websites, due to the inherent nature of the internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. We maintain physical, electronic and procedural safeguards to protect your personal data. We strive to protect information transmitted on or through the Websites or services, however, we cannot and do not guarantee the security of any information you transmit on or through the Websites, and you do so at your own risk. We cannot and do not guarantee the security of your data and information.
6. Third parties
7. Disclosure of your information
7.1. We may disclose your personal data to any member of the NTT Group, which means our subsidiaries, our ultimate holding company and its subsidiaries (both direct and indirect).
7.2. We may also use your personal data to maintain our internal record keeping and/or share it with our affiliates for internal marketing or other purposes.
7.3. We also use other service providers to process personal data on our behalf. We use them to provide marketing and sales lead generation, and [any other reasons for using 3rd party providers?]. Where we use such third party organisations, we still control your personal data and we will ensure that we have strict controls in place to make sure it is properly protected.
In addition, we may also disclose your personal data to third parties in the following circumstances:
7.3.1. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
7.3.2. If NTT or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
7.3.3. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and other agreements; or to protect the rights, property, or safety of NTT, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
7.3.4. We may disclose user information to government authorities, and to other third parties when compelled to do so by government authorities or otherwise as required or permitted by law, including but not limited to in response to court orders and subpoenas. We also may disclose user information when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of our Websites, or anyone else that could be harmed by such activities. Additionally, we cooperate with law enforcement inquiries and other third parties to enforce laws, intellectual property rights and other rights.
8.1. Your personal data will be retained for as long is reasonably necessary for the purposes listed above or as required by applicable local law. Please contact us for further details of applicable retention periods.
8.2. We may keep an anonymized form of your personal data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
9. Your rights
9.1. You have the right to:
9.1.1 request information on and access to all the personal data we hold about you;
9.1.2 request that any inaccurate personal data we hold be corrected;
9.1.3 object to certain types of processing of your personal data we carry out (including the right to opt-out of any direct marketing);
9.1.4 request that we delete the personal data we hold about you; and
9.1.5 request a copy of your personal data in a machine reasonable, commonly used format (or to request we transfer your personal data in such a format to a third party service provider).
9.7. In order to exercise these rights, you will need to contact us via email at firstname.lastname@example.org or in writing to NTT at its registered office address marked for the attention of the Data Protection Officer. We will consider such responses and respond to you within 30 days. We may charge you a small fee and may require verification of your identity for providing a copy of your information as permitted by law.
11.1. Questions, comments and requests regarding this Policy are welcomed and should be sent via email to email@example.com. You also have a right to lodge a complaint with your local data protection authority however we recommend you contact us before doing so as we may be able to resolve any issues with you directly in a more efficient manner.
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