Privacy Policy

Last updated 22nd November 2018

NTT COM MANAGED SERVICES, S.A.U. (“NTT CMS”, “we”, or “us”) is a company with registered office at Av. Diagonal nº 575 5ª planta 08029 Barcelona, Spain, holder of tax/VAT registration number A62396908 and registered in the commercial registry of Barcelona, section 8, sheet 227240.

NTT CMS wants you to be familiar with how we collect, use and disclose information relating to you as an individual (“Personal Information”). This policy (“Privacy Policy”) describes our practices in connection with Personal Information that we collect through or in connection with:

Collectively, we refer to these activities as the “Services”.

You may contact our Data Protection Officer at the following e-mail address: privacy@nttcom.ms

Personal Information

Personal Information we collect or obtain includes:

Collection of Personal Information

We -directly or by means of our service providers- collect Personal Information in a variety of ways, including:

We need to collect Personal Information in order to provide the requested Services to you.  If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so under applicable laws and to permit us to use the Personal Information in accordance with this Privacy Policy.

Use of Personal Information

We -directly or by means of our service providers- use Personal Information for the following business purposes:

We will engage in these activities to manage our contractual relationship with you.

We will engage in these activities with your consent or when applicable, under a legitimate interest.

We engage in these activities with your consent or when applicable, under a legitimate interest.

We engage in these activities to comply with a legal obligation or because we have a legitimate interest.

Data retention policy

We will only keep your Personal Data as long as we maintain our contractual relationship, and once ended, for a maximum period of six (6) years unless legally or contractually required for more time.

Regarding, the commercial communications we will keep your data as long as you do not withdraw your consent and withdrawn unless legally or contractually required for more time.

Disclosure of Personal Information

We disclose Personal Information:

In such cases in which the affiliates are located out of the European Economic Area, we have covered such international data transfer by signing the corresponding model clauses approved by the European Commission. You may obtain a copy of these measures by following this link.

This disclose is necessary since the affiliates would be the entities providing the Services and/or engaging into business. Therefore, this disclosure will be based on the legitimate interest they have to be able to provide you an offer and, if you accept it, provide you with the Services engaged.

These can include providers of services such as data hosting, data analysis, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.

In such cases, we will cover such international data transfer by any of the means foreseen in data protection applicable laws, depending on the particular country to which such Personal Data might be transferred (e.g. Privacy Shield, model clauses of the European Commission, etc.)

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

COOKIES & SIMILAR TECHNOLOGY

Cookies are pieces of information stored directly on the computer that you are using. NTT CMS uses cookies and similar technology in accordance with our Cookies Policy.

SECURITY

NTT CMS seeks to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

NTT CMS gives you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-in from:

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.

Access, correction, restriction, deletion, objection and portability

If you would like to request to review, correct, restrict or delete Personal Information that you have previously provided to us, object to the processing of Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us at privacy@nttcom.ms. We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Information your request relates to. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request according with the regulation. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete transactions initiated prior to the request. Also, please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.

Moreover, you have the right to present a claim directly before the competent supervisory authority, in Spain the Spanish Data Protection Agency (Agencia Española de Protección de Datos – AEPD).

THIRD PARTY SERVICES

We will only share your Personal Information with third parties as set out in this Privacy Policy. Note, however, that this Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as LinkedIn, Twitter, or any other platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our Social Media Pages.

Use of Services by MINORS

The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.

Jurisdiction and CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

Some of the non-European Economic Area (“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 here. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by following this link.

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.  Your use of the Services following these changes means that you accept the revised Privacy Policy.

CONTACTING US

NTT CMS Com Managed Services, S.A., located at Av. Diagonal, 575, Planta 5, 08029 Barcelona, Spain, is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at privacy@nttcom.ms or:

NTT Com Managed Services, S.A.U.

Av. Diagonal, 575,

Planta 5,

08029 Barcelona, Spain

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

You may also lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.