- Who are we?
- What information do we collect?
- How do we use your information?
- Who may use your information?
- Third party links and services
- How do we protect your information?
- Where is your information processed?
- Marketing communications
- How long do we keep your information?
- Your rights
- How do you contact us?
1.5 We do not knowingly collect or process data from anyone under the age of thirteen (13) years old.
2. Who are we?
2.2 You can find details of all of our group companies by visiting https://www.interoute.com/contact-us
3. What information do we collect?
3.1 Most of the information we collect is information provided directly by you, which is set out on the web page on which we collect it - for example in our enquiry form. This may include:
- contact information – information such as name, job title, company name, department, email address, physical mailing address, device identity number (such as a device Uniform Resource Identifier or URL) and telephone number ;
- professional information – such as your employment background, job description and related information
- transaction information – your contact information, the products you are interested in, your purchasing requirements, financial or other payment information ; and
- responses to surveys – information you provide in responding to a survey on the website, via an app or email, on the telephone or otherwise..
3.2 We may also collect and process other information obtained through the Site or the device you are using, including:
- customer Login information, including end user data, user ID and login password;
- location information (including GPS signals sent by a mobile device, location information gathered from social media networks or sensor or IP address data from your device);
- information from cookies, web beacons or from the internet, including your IP address, browser type, operating system, domain name, access times, which pages you visit within our website and referring website addresses. Cookies are small pieces of information that are stored by your browser on your computer’s hard drive. You can find out more about how we deal with cookies in our Cookies Policy, available at https://www.interoute.com/cookies;
- if you ask us to connect with other sites (for example if you ask us to connect with your Facebook account) we may get information that way too;
- we may record telephone calls;
- user generated content, for example audio data, video data, instant messaging data, content generated during call recording and data processed for troubleshooting purposes.
3.3 If you use the Site to apply to work with us, we will use the information you supply to process your application and to monitor recruitment statistics. As a global business we may transfer your details outside of your home country and to other companies in our group. Where we want to disclose information to a third party, for example where we want to take up a reference we will not do so without informing you first unless the disclosure is required by law. Personal information about unsuccessful candidates will be held for up to 6 months after the recruitment exercise has been completed, it will then be destroyed or deleted. We retain de-personalized statistical information about applicants to help inform our recruitment activities, but individuals should not be identifiable from that data. Once a person has taken up employment with us, we will compile a file relating to their employment. At that stage we will give more details about how we hold employee data and we will expect the employee to sign up to additional privacy terms as part of their employment.
3.4 We may use publicly accessible information to verify information we are provided with and to manage and expand our business.
4. How do we use your information?
4.2 Our primary purpose in collecting your personal data is to provide you with the services you requested and those which we believe will optimize your use of the Site. We may use your personal data for the following purposes:
- to provide the information, services or support you request and related after-sales services;
- to identify you, and to contact you from time to time with product or service updates;
- to send other messages that help personalise our products and to make recommendations;
- to manage our relationship with you and to carry out any related administration;
- to provide personalised, targeted, or location-based content, services, and advertising from us and third parties;
- to promote our services, or the services of our suppliers, including by email and via social media platforms (subject to the relevant marketing permissions)*;
- to compare information for accuracy, and verify it with third parties*;
- to carry out research, including market research, statistical research on site traffic, sales and other commercial information to assist us in improving the services we provide to you and tailor the Site*;
- to enable the call recording feature to work for some of our services and in order to troubleshoot the services we provide.
4.3 In more legal terms, we process your personal data where we have your consent to do so, which you may withdraw at any time, or otherwise where this is necessary for:
- the performance of our contract with you or to take preliminary steps at your request;
- us to fulfil our legal obligations; or,
- the purposes of the legitimate interests pursued by us or by a third party.
4.4 A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. Our legitimate interests are those indicated with a “*” above, and we consider that we have implemented sufficient checks and protections to ensure that your rights and interests are not unreasonably intruded on.
*However, you can object to processing on any of these bases at any time and, if you do so, we will stop processing the personal data unless we can show compelling legitimate grounds which override your rights and interests, or we need the data to establish, exercise or defend legal claims – see “Your rights” below.
5. Who may use your information?
5.1 We may disclose your personal data to enforce our policies, to comply with our legal obligations or in the interests of security, public interest or law enforcement in any country where we have entities or affiliates. For example, we may respond to a request by a law enforcement agency or regulatory or governmental authority. We may also disclose data in connection with actual or proposed litigation, or to protect our property, security, people and other rights or interests.
5.2 We share your information with third parties who help deliver our products and services to you. Examples include hosting our web servers, analysing data, providing marketing assistance, and providing customer service. These companies will have access to your personal information as necessary to perform their functions, but they may not use that data for any other purpose.
5.3 We may also share your personal data:
- with companies in our group and/or our affiliates; or,
- with any third party you have asked us to share your personal data with – such as Facebook or any other social media site if you have asked us to connect with your account.
5.4 You may have accessed our website through a hyperlink from the website of one of our subsidiaries or trading partners. If so, you consent to your personal details and purchase information, including behavioural patterns, being shared with that trading partner in accordance with our contractual relationship with them.
5.7 Similarly, your personal information may be passed on to a successor in interest in the unlikely event of a liquidation, bankruptcy or administration.
5.8 Please remember that when you share information publicly on any Interoute website, for example a comment on a blog post, it may be indexable by search engines, including Google, which may mean that the information is made public.
6. Third party links and services
6.1 The Site may contain links to third parties’ websites. We are not responsible for the privacy practices or the content of those websites. Therefore, please read carefully any privacy policies on those links or websites before either agreeing to their terms or using those websites.
6.3 If you have asked us to share data with third party sites (such as social media sites), their servers may not be secure.
6.4 Note that, despite the measures taken by us and the third parties we engage, the internet is not secure. As a result others may unlawfully intercept or access private transmissions or data.
7. How do we protect your information?
7.1 We take what we consider to be appropriate technical and organisational measures designed to guard against unauthorised or unlawful processing of your personal data and against accidental loss or destruction of, or damage to, your personal data. While no system is completely secure, we believe the measures implemented by Us reduce our vulnerability to security problems to a level appropriate to the type of data involved. We have security measures in place designed to protect our user database and access to this database is restricted internally. However, it remains your responsibility:
- where you have a customer account for the Site:
- to keep your password or other access information secret. Your password and log in details are personal to you and should not be given to anyone else or used to provide shared access for example over a network. You should use a password which is unique to your use of the Site – do not use the same password as you use for another site or email account; and,
- to ensure no-one else uses the Site while your device is logged on to the Site (including by logging on to your device through a mobile, Wi-Fi or shared access connection you are using);
- to log off or exit from Site when not using it;
- to maintain good internet security. For example if your email account or Facebook account is compromised this could allow access to your account with us if you have given us those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us. You should keep all of your account details secure. If you think that any of your accounts has been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. You should also tell us as soon as you can so that we can try to help you keep your account secure and if necessary warn anyone else who could be affected.
8. Where is your information processed?
8.1 We might transfer your personal information to places outside of your home country, for example to companies in our group that are based outside the EEA such as those listed here for the purpose of providing you with the service you have requested. If you are in the European Economic Area (EEA) this means that your data may be transferred from the EEA to another country and stored there, where we (or our suppliers) might process it.
9. Specific terms relating to Interoute products
9.1 Because of the way in which some of our products work we may need to process additional data, or process in a different way. If we need to, we will link to specific privacy policies relating to those products here.
10. Marketing communications
10.1 If you have given permission, we may contact you by mail, telephone, SMS, text/picture/video message, and email about products, services, promotions and special offers that may be of interest to you. If you prefer not to receive any direct marketing communications from us, you can opt out at any time. See further 'Your rights', below.
11. How long do we keep your information?
12. Your rights
12.1 As explained above, you have the right to opt-out of receiving marketing communications from us. If you wish to exercise your right to unsubscribe from email marketing communications, you can use the link at the bottom of any communications received from us. This will automatically suppress your email address from receiving future email marketing communications from our systems unless you choose to opt back in.
12.2 If you wish to exercise your right to be removed from our telemarketing list, please let the caller know at the time of calling and they will make sure your number is suppressed unless you opt back in.
12.3 In addition, to the extent permitted by the laws of your country, you may have the right to object to the processing of your personal data for direct marketing purposes. If your objection is not to direct marketing in general, but to direct marketing by a particular channel e.g. email or telephone, it would help us if you can specify the channel you are objecting to.
12.4 Further, to the extent permitted by the laws of your country, you may also have the right to access, correct, delete, restrict, be forgotten, or object to processing of, or request data portability of the personal data collected about you subject to some conditions and exceptions. You can find out more about these rights in the EU by reading the General Data Protection Regulation here: http://www.eugdpr.org/the-regulation.html.
12.5 We will take reasonable steps to delete your personal data from our system(s) upon request, unless restricted by law. We may keep a copy for as long as is necessary in our opinion, in compliance with applicable laws and regulations. In most cases we will respond to any of your above-mentioned requests within one month but we reserve the right to verify your identity before dealing with your request.
12.6 If you wish to inquire about or rely on any of these rights please send the details of your request to Global.Data.Protection@interoute.com.
12.7 You may also have the right to lodge a complaint with a data protection regulator. Our lead regulator is the Information Commissioner’s Officer (ICO), whose contact details are as follows:
+ 44(0)303 123 1113
13. How do you contact us?