Data Privacy Statement

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Introduction

This statement contains:

Why and with whom we share your personal data

In which cases your personal data may be transferred abroad

How we protect the security and confidentiality of your personal data

The choices and rights available to you regarding the use of your personal data

How you can contact us about our privacy practices and to exercise your rights

*The Privacy Policy was last reviewed and updated on 22/10/2021 and is effective as of that date.

Key points you need to know about how we collect and use your data

We collect and use your personal data to administer our relationship with you, including to respond to your enquiries or complaints, to provide our products and Services to you, to manage our Contracts with you, to inform you about our products and services, partners, promotions and events, to administer and improve our Websites and Services, to respond to requests from authorities, to comply with our contractual and legal obligations, and for other legitimate business purposes. Colt does not share, sell, rent or trade personal data with third parties for promotional purposes.

When you express an interest in obtaining additional information about the Services, or registering to use the Web sites or other Services, or registering for an event, you provide the Company with personal contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”) to contact you. In addition, when you purchase the Services or get registered for an event, Colt may also require you to provide the Company with means for financial qualification and billing information, such as billing name and address, and the number of employees within the organization that will be using the Services (“Billing Information”) which is not considered personal data.

We may ask you for information to enable us to provide a Service to you and we collect this information by telephone, written/digital correspondence or via the website.

Subject to your consent where required by law, we use cookies and other technologies to track the use of our websites and services. To learn about our use of cookies and your rights in that respect see below.

Subject to your consent where required by law, we may use your personal data to conduct marketing, promotional and informational activities and to perform business analytics, satisfaction surveys or market research and conduct direct marketing.

We may share your personal data with other entities of the Colt group of companies, with third party providers that we engage to process data on our behalf, when such sharing is required by law or other situations as permitted by law. In accordance with applicable law, you have the right to access personal data we hold about you, to rectify, delete or erase inaccurate data, to object, at any time and free of charge, to the processing of your personal data for direct marketing purposes, as well other rights under applicable law.

Your use of our Services and Websites, and the entering into our Contracts, constitute your consent to the processing and transfer of your personal data to India and to other Colt's entities which are located in other jurisdictions outside of the European Economic Area which may not provide the same level of data protection as your home country.

This privacy policy only applies to how to Colt deals with your personal data. It does not apply to any to any other company or to any other company´s websites even if you have accessed them through Colt. If you disclose your personal data to other companies your information will be dealt with according to their privacy practices.

Frequently asked questions

What personal data will Colt collect?

For the purposes of this Privacy Policy, "personal data" means any information that identifies you, that could be used to identify you or that relates to you, and that you submit about you when interacting with us and/or is otherwise collected by us when you visit the Websites, by phone through our customer service, by writing through order forms or in another manner. During our relationship with you we may collect and process your personal data, such as your name, address, telephone, email and other contact details, and any other information relating to you which you may provide, in the following cases:

Visit our Websites and look at our Products and Services
Create an account on our Websites
Enquire about our products and Services or contact our customer service
Enter into a Contract with us and purchase our products and Services
Participate in a promotion, event, survey or other marketing campaign we organise
Sign up for our newsletters and other promotional materials.

Personal Data that you provide us

The types of personal data we may obtain in connection with the previous cases are as follows:

Your name, address, and contact details (such as telephone, mobile and fax numbers, email address)
Details of contact persons (such as name, address, function/title, telephone and fax numbers, e-mail address)
Services provided, including online Services
Names, email addresses and telephone numbers of third parties you provide to us
Online account details including username, password and other credentials used to access Colt’s products and Services
Financial and payment data such as banking details, invoices and payment terms as well as any personal data for fulfilling and legitimate processing billing information
Complaints and enquiries
Business profile
Tax identification number where you request products or services that require such information
Responses provided in response to surveys

Personal Data collected by automated means

When you visit our Websites or use our Services, subject to your prior consent where applicable by law, we may collect personal data without you actively submitting such information, by automated means, using technologies such as cookies, web server logs, web beacons, and similar technologies as described below.

The types of personal data that we may collect through your visits to the Websites or use of the Services include, to the extent permitted under applicable law and, where required, subject to your express consent, are:

the date and time of visit, referring address (location from which a visitor comes to the Websites);
type of Internet browser, OS and device details;
visitor's IP address (a unique number that is assigned to any computer that connects to the Internet for identification purposes);
traffic data for calls or Internet session when you use our phone or Internet services, including called numbers, identification of the phone, duration of the call, date, duration and data volume of the Internet session;
as the case may arise location data generated during calls or Internet sessions;
history of the contact you have had with our customer service.

Personal Data collected by third parties

Colt may also receive information about Customers from other sources, including third parties from whom we have purchased data, and combine this information with Data we already have about you. This helps us to update, expand and analyse our records, identify new customers, and create more tailored advertising to provide products and services that may be of interest to you. We will ensure that any marketing campaigns are aligned to GDPR requirements.

How do we use your personal data?

Colt shall only process your personal data for the purposes described in this Privacy Policy or as otherwise permitted under applicable law. The processing of your personal data by Colt for the purposes described hereunder is based on your explicit consent or on the necessity to process your personal data for the purposes of our legitimate interests, as provided by Article 9, 2., (a) and (f) of the General Data Protection Regulation (EU) 2016/679 of 27 April 2016 (“GDPR”).

Your personal information may be processed, both by Colt and its affiliates, for purposes including:

administer our relationship with you, including to respond to your inquiries or complaints;
to provide any goods, Services or information you have requested and information about our products and Services;
to administer, operate, maintain, and improve the Websites and our Services;
for efficient customer management relationship;
to simplify access to some interactive features on our Websites or Services;
to manage your accounts, orders, invoices and payments;
to manage and provide after-sale services;
to administer accounting and taxes;
to respond to requests from administrative or judicial authorities; and
to comply with applicable laws and regulations.

Providing personal data for these purposes is necessary and refusal would make it impossible for Colt to manage the Contract with you or to comply with its contractual and legal obligations. Subject to your consent where required by law, we may also use your personal data in order:

to keep improving the way our website works.
to count how many persons visit our websites, where they come from, when they visit, how long they stay and what pages they look at.
to associate your activity on our website in order to give us insights into products and services you might like and measure how our advertising performs
to note browser, OS and device details used to make sure you get a good online experience when you access our websites.
to provide you access to valuable Colt internet-based information and Services;
to audit usage of the Websites;
to market and improve the Services that we offer; and
to conduct promotions campaigns, survey and other marketing initiatives pursuant to the "How do we use your personal data for marketing purposes?" section to follow.
Let you know about other offers and discounts
Understand how you use products & services to develop newer & better versions
Carry out research and statistical analysis including to monitor how all customers use our network, products and services on an anonymous or business by business basis
Prevent and detect fraud or other crimes, recover debts or trace those who owe us money

Providing personal data for marketing purposes is optional and refusal will have no consequence on the performance of any Contract by Colt.

In order to provide you with a better experience and to improve the quality of our Services, to the fullest extent permitted by applicable law, we may combine the information you submit to us with other information that we may receive from you, from third parties, or with other public demographic information.

In addition, we collect information from visitors to our websites to help us to make improvements to the websites and to the Services we make available. We know, for instance, how many visitors there are to each website page, when they visited, for how long and to which areas of the website. We may share this information with our advertisers and to other companies that offer their goods or services on our websites. It helps us to show these organisations how effective our website is as a sales channel for products. You or any other individual cannot be identified from the information we share as the data is aggregated and anonymised.

Why and with whom do we share your personal data?

Our policy is to not give, sell or otherwise distribute personal data we collect to third parties outside of Colt, except where required with your express consent or where this is necessary and in accordance with applicable law. In line with this, we share personal data with the recipients listed below.

Colt subsidiaries and affiliated entities (‘Colt Affiliates’). We may share your personal data with other companies of the Colt Group (a list of Colt Affiliates is available at https://www.colt.net/legal/ and then selecting the option Colt Group of Companies. For the purposes specified under the "How do we use this information?" section previous and as described under the "Will Personal Data be transferred abroad?" section in this document.

Third party service providers. Your personal data may be disclosed to third party service providers, acting on our behalf, in connection with managing services, data analytics, finance, accounting or other administrative services and information technology support. These third party service providers will have access to – and process – personal data only on our behalf and under our instructions and will be held to appropriate security obligations.

Colt’s business partners. A list of such partners could be provided to Customers upon request provided there is a legitimate reason.

Other data recipients. For the above purposes or where otherwise required by law, we may also need to make personal data available to third parties such as advisors, banks and financial institutions, professionals, independent consultants, potential or existing investors and/or acquirers (in connection with a merger, acquisition, or sale involving Colt or its affiliates or as part of a corporate reorganization, stock or asset sale, or other change in corporate control), regulatory and/or administrative authorities, courts, police authorities

Colt may provide information, in response to properly made requests, for the purposes of the prevention and detection of crime, and the apprehension or prosecution of offenders, when required to do so by law, for example under a court order, or in response to properly made court or administrative demands. Colt may also provide information for the purpose of safeguarding national security. In either case, Colt will act in accordance with applicable Data Protection Law.

Other telecommunications operators. Colt receives information from other telecommunications operators about their customers to enable Colt to enter their details (together with our own customer´s information) in telephone directories. We also make telephone numbers available on directory enquiry services unless customers (BT or other licensed telecommunications operators) have chosen to be ex-directory.

We may also disclose personal data about you when you explicitly consent (via contract or other legal instrument) to such transfer or when we believe disclosure is necessary or appropriate for our legitimate interests (or those of the third party to whom we disclose your data), provided that they are not overridden by the data subject's interests or fundamental rights and freedoms, in accordance with applicable laws.

We may share with third parties certain pieces of aggregated, non-personal information, such as how our customers use of our Services or Websites. Such information would not identify you individually.

Please note that when you order goods and services from Colt, the Company may make enquiries about you for credit reference purposes. These enquires include searching your records held by a credit reference agency. At all times where your information is disclosed to us we will protect it in accordance with this policy and keep it secure.

Will personal data be transferred abroad?

In the performance of our Contract with you or in providing our Services or Websites to you, we may need to transfer your personal data to Colt Affiliates, business Partners or other recipients identified in the "Why and with whom do we share your personal data?" section previous that are located inside and outside the European Economic Area (“EEA”), including in countries that do not provide the same level of protection for personal data as in the EEA. In any case, we will only transfer personal data to recipients that provide an adequate level of data protection or as permitted by applicable data protection laws by implementing appropriate safeguards, including, but not limited to, relevant data transfer agreements. Colt has implemented an IGTA (International Group Transfer Agreement) based on Model Clauses contract, which makes Colt compliant with GDPR International Transfer Data Protection Rules, Brexit and Privacy Shield null declaration. The IGTA standardizes the governance around the transfer of personal data between Colt entities and includes standard contractual clauses approved by the European Commission (“Model Clauses”).

Colt BCRs controller and processor have been approved by the European Data Protection Board (EDPB) August 02, 2021. The approval was published in the official Gazette of the EDPB on August 05, 2021 and ratified by the Spanish Data Protection Authority, as Colt ́s BCR leading Authority August 16, 2021. The EDPB approved the Privacy and GDPR compliance programme implemented by Colt across the whole group. The approved privacy programme is legally binding on every company of the group.

Colt BCR Controller and Processor decisions are published at the European Data Protection Board(EDPB) website https://edpb.europa.eu/our-work-tools/accountability-tools/bcr_en and in the Spanish Data Protection Authority (“AEPD”) website: https://www.aepd.es/es/documento/ti-00003-2021-resolucion-aprobacion-bcr-responsable-colt.pdf

The Binding Corporate Rules ("BCRs") are the golden privacy certification approved by three European Data Protection Authorities as well as the European Data Protection Board which allows:

• Colt to have the highest recognition in privacy that a group of companies can have.
• Transfer of personal data easily between all Colt´s entities.
• Keeping the same levels and standards of privacy compliance all over Colt worldwide.

Please be aware that the personal data (e.g. your name and email address) you may provide through the chat bot available at the portal https://online.colt.net/ will be stored at Google LLC Cloud servers in US. You are informed before you interact with the chat bot and should you not wish to continue, you can close the chat bot. Adequate international data transfer safeguards and security measures have been implemented to keep your personal data safe and secure. For further information on how Google secures your data please visit https://cloud.google.com/security/gdpr/resource-center.

Colt Vendor Risk Management Procedure

As part of Colt´s Privacy Governance Policy, Colt ensures vendors privacy compliance through a Vendor Risk Assessment Tool to implement a Vendor Data Privacy Due Diligence including appropriate security, technical and organisational measures and legal checking. Once the Privacy Due Diligence is positively completed, prior to sharing any personal data with vendors, a Data Processing Agreement containing all the requirement stipulated in Article 28 of the GDPR is executed between the parties. In addition, if any personal data needs to be transferred to a third country outside the European Union, as per Article 46 of the GDPR, Model Clauses are executed between the parties involved to assure that personal data is processed with the same level of protection that in the European Union. Furthermore, Colt reviews vendor status on Data Protection at contract renewal and carries out audits to check vendors privacy compliance.

How is your personal data protected?

Colt has appropriate policies and technical and organizational measures in place to safeguard and protect your personal data against unlawful or unauthorised access, accidental loss or destruction, damage, unlawful or unauthorised use and disclosure. We will also take all reasonable precautions to ensure that our staff and employees who have access to personal data about you have received adequate training.

How long do we keep your personal data for?

We have a retention policy for personal data that we adhere to, in line with legal and statutory requirements. For further details regarding this please contact the DPO (Data Protection Office) at Colt using the email address [email protected]. We also may retain your information for the period of time needed for Colt to pursue legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

What happens when you provide us with personal data about third parties?

How can you update or delete your personal data?

In accordance with applicable data protection laws, you have the right to access personal data we hold about you and request the rectification or erasure of any inaccurate data. You may exercise such rights by contacting us as described under the " What are your data protection rights?" section below.

When you register online for a Colt account, you can also view and update your personal data by logging onto the Website and following the relevant instructions. To ensure any details we hold about you remain accurate, please update your personal data if it changes or send a request to us as described under the "What are your data protection rights?" section below. If you close your account we may, for limited periods and in accordance with applicable law, retain some personal data in order to comply with legal obligations or for other proper purposes, such as legal retention obligations, collecting outstanding debts or resolving legal disputes.

When you request to be removed from certain marketing offers, you will, in accordance with applicable data protection laws, be added to the relevant internal suppression list(s) to ensure your request is complied with

How do we use your personal data for marketing purposes?

We may use your personal data to conduct marketing, promotional and informational activities and to perform business analytics, satisfaction surveys or market research and direct marketing purposes in general, including sending notifications about updates to the Websites, information on our services we think may be of interest to you, initiatives or events by mail, e-mail, phone, fax, SMS, MMS or other electronic means. However, we will only do so in accordance with GDPR requirements prior to being contacted in this way and/or subject to relevant legal requirements. If you no longer wish to receive marketing information, please inform us by email or using the UNSUBSCRIBE option available on the communication.

How do we use your personal data for monitoring and recording of calls?

Your telephone calls to us may be recorded for the purposes of staff training and service quality, as well as evidence of a commercial transaction, subject to applicable law. You will be informed about this in a recorded message before your call is put through to a member of staff. Calls that are recorded for these purposes will be kept secure, will not be disclosed outside our group of companies, other than for operational purposes, and will be deleted in accordance with our policies and relevant legal requirements.

How do we treat children’s personal data?

What are your data protection rights?

In accordance with applicable data protection law, you have a right to:

obtain confirmation of the existence of, and to request a written copy of the personal information Colt holds about you.
have any inaccurate information about you corrected;
have personal data we hold about you deleted, blocked or removed;
withdraw your consent where relevant, without affecting the lawfulness of processing based on your consent before its withdrawal;
restrict the processing we make in relation with your personal data;
receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format in order to transmit them to another data controller;
object to the use of your details for marketing activities and other promotional activities, as described under the "How do we use your personal data for marketing purposes?" section previous; and
lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data relating infringes applicable data protection law.

In case you wish to exercise any such rights, please send a written and signed request to Colt as described under the "How can you contact us?" section below.

What happens if you visit a linked website?

How can we update this policy? / How can you contact us?

We reserve the right to review this Privacy Policy at any time. Where appropriate or required by law, we will notify you about the new privacy Policy by posting appropriate notice on our Services or Website or by e-mail (to the extent that we have your e-mail address). We encourage you to periodically review this Privacy Policy to stay informed about our information practices. We will indicate above the date on which this Privacy Policy was last modified. Your continued use of our Services or Website and participation in Colt events constitutes your agreement to the revised Privacy Policy. If you do not agree to the new Privacy Policy, you must discontinue.

If you have any questions about this Privacy Policy, or if you wish to exercise your rights under applicable data protection laws, please feel free to contact us through our Website or write to us at:

The Group Data Protection Officer
Colt Technology Services Group Limited
Colt House | 20 Great Eastern Street | London | EC2A 3EH | UK
We can be reached via email at [email protected].

Downloadable items

Candidate Privacy Notice

Employee Privacy Notice

Vendor Privacy Notice

Personal Data Breach Incident Response Plan

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Data Privacy Statement

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Binding Corporate Rules and International Data Transfer Privacy Tools

Colt's BCR Controller and Processor decisions are published at the European Data Protection Board (EDPB) website and in the Spanish Data Protection Authority (“AEPD”) website.

You will be able to find the BCR approval document available on the EDPB website.

The Binding Corporate Rules ("BCRs") are the golden privacy certification approved by three European Data Protection Authorities as well as the European Data Protection Board which allows:

Colt to have the highest recognition in privacy that a group of companies can have
Transfer of personal data easily between all Colt´s entities
Keeping the same levels and standards of privacy compliance all over Colt worldwide

Download our BCRs infographic

Colt BCR Controller Approved

Colt BCR Processor Approved

What are the Binding Corporate Rules?

The Binding Corporate Rules (“BCRs”) are a certification granted by the European Data Protection Board (“EDPB”), the collective body of all EU Data Protection Authorities. Through the BCRs, the EDPB certifythat the privacy programme implemented by a company is compliant with the General Data Protection Regulations (“GDPR”)and the same level of data protection compliance valid in Europe is applied all over the entities of the same group. In addition, the BCRs are a tool for safely transfer personal data outside the EU within a group of companies.

Are the BCRs a privacy compliance tool?

When was Colt awarded the BCRs?

What does the BCRs imply for Colt?

Colt's BCRs allow Colt to transfer EU personal data within the Group, even outside the EEA, recognizing a Global Privacy programme that meets highest possible industry standards.

For approving our BCRS, the EDPB audited, validated and approved Colt privacy compliance framework applicable in all Colt ́s entities. With them, Colt can offer the best data protection assurance in the world.

Are the BCRs applicable over all Colt entities?

Are there any other Telco companies which have obtained the BCRS post-GDPR?

Please could you explain a little the procedure of obtaining the BCRs?

Colt BCRs were negotiated and discussed with the 3 toughest European Data Protection Authorities and approved by the European Data Protection Boardwhich includes all the EU Data Protection Authorities. The Italian Data Protection Authority was the “guardian” of such procedure. This approval proves that Colt has implemented the most stringent privacy rules on the European scene and worldwide.

Where can you find the official approval of Colt BCR?

Individual rights

Colt shall inform all individuals about how to exercise their rights and ensure that individuals are able to exercise their rights freely. Colt will respond as appropriate to requests to exercise any of the following individual rights:

(a) Right of access: Individuals have the right to access a copy of the personal data that has been collected about them (whether held by Colt itself or at its providers), and be provided with information about the processing.

(b) Right of rectification: Individuals have the right to rectify any inaccurate or incomplete personal data concerning them (whether held by Colt itself or at its providers), in order to guarantee their accuracy and the appropriate processing thereof.

(c) Right of erasure (right to be forgotten): Individuals have the right to the deletion of personal data concerning them.

(d) Right to object: Individuals have the right to object to the processing of personal data at any time.

(e) Right of restriction: Individuals have the right to restrict the processing of personal data concerning him or her. This means that the processing will be "paused" and the personal data will only be stored.

(f) Right of data portability: Individuals have the right to receive personal data concerning them and to have that data transmitted to another controller in a structured, commonly used, machine-readable format.

(g) Right to non-automated data processing: Individuals have the right not to be subject to a decision affecting them, where this decision is based on automated data processing of information, including profiles. This includes cases in which Colt uses cookies as a technical tool to evaluate customers and predict their behaviour, performance or preferences, comparing their profile with that of other users or similar customers.

7.10.2 Colt responds to these requests in accordance with the procedure provided by the Individual Rights Policy

Data Protection Compliance Statement

Privacy By Design Certification

Data Privacy Statement

This section contains:

Why and with whom we share your personal data

In which cases your personal data may be transferred abroad

How we protect the security and confidentiality of your personal data

The choices and rights available to you regarding the use of your personal data

How you can contact us about our privacy practices and to exercise your rights

*The Privacy Policy was last reviewed and updated on 22/10/2021 and is effective as of that date.

Key points you need to know about how we collect and use your data

We may ask you for information to enable us to provide a Service to you and we collect this information by telephone, written/digital correspondence or via the website.

Candidate Privacy Notice

Cookies Policy

This Cookie Policy applies to all websites offered by Colt Technology Services Group Limited and, where applicable, any of its EU-based affiliates (hereinafter "Colt", "we" or "us"), which refer to this Cookie Policy. As this Cookie Policy applies to all of our websites (unless otherwise expressly provided), they are collectively referred to as “Websites” throughout this Cookie Policy.

When you visit our Websites we may use cookies or similar technologies as described below. By clicking on "continue" or "I accept" on the cookie banner which is presented to you, you are agreeing to our use of cookies in accordance with this Cookie Policy and you acknowledge that we will use the underlying personal data processing as we have set out here

If you do not agree to our use of cookies in this way, you should click "decline". You are also able to change your cookie choices by clicking on the relevant button. Please note, however, that disabling cookies might affect your online experience and/or prevent you from taking full advantage of our Websites.

What are cookies?

Cookies are files or pieces of information that may be stored on your hard drive or browser (or other internet enabled devices, such as a smartphone or tablet) when you visit the Website. A cookie will usually contain the name of the website from which the cookie has come from, the "lifetime" of the cookie (i.e. how long the cookie will remain on your device), and a value, which is usually a randomly generated unique number.

They enable our Websites to identify your computer, as you navigate different pages on a website, and recognise that you have visited before. Cookies themselves do not contain any directly identifiable personal information. However, we may link the information we store in cookies to any personally identifiable information you submit while on our Websites.

From time to time we may also use other technologies to log and collect data in order to analyse traffic to our Websites. These technologies will regularly only allow for a non-directly identifiable notice of your visit to be generated. However, in some instances they may allow us to obtain details about your IP address and to track visits to our Websites. In conjunction with cookies, this will enable us to identify what portions of our Websites are of interest to our visitors and to help us provide you with tailored information from our Websites.

For what purposes do our website use cookies?

Many cookies on our Websites perform essential functions or services you have requested or for security purposes, as further described in the table below.

Cookies also help us understand which sections of our Websites are the most popular, as they help show which pages are being visited and how long for. This helps us adapt our Websites to provide more relevant and accessible information and to better tailor our Websites and our products and services to your interests and needs. For example, cookies allow us to ensure that the information displayed on your next visit to our Websites will match up with your user preferences.

Cookies may also be used to help speed up your future activities and experience on our Websites.

We also use cookies to show adverts that are more relevant to your interests for example, with your consent, we use tracking technologies to remember content that has interested you and then use this to help us serve more relevant ads to you, including when you are on another site. Tracking technologies also help limit the number of times that you see an ad, measure the effectiveness of advertising campaigns and help us and others track whether ads have been properly displayed so we can pay for this.

We also use cookies to compile non-directly identifiable, aggregated statistics that allow us to understand how users use our Websites and to help us improve the structure and content of the Websites (for example, by monitoring which features of the Websites are being used, which pages are visited, how often, and what information is downloaded).

In sum, advantages of cookies are:

Remembering the details as provided by the user.
Remembering user preferences.
Helping improve the website.
Cookies can be deleted by the visitor.
Cookies cannot carry any threat to the visitor’s device.

What type of Cookies Colt may place on your device

Strictly necessary cookies: These cookies are essential in order for the operation of a website, such as cookies authenticating access to secure areas of the website. Without these cookies, services you have asked for cannot be provided.
Session Cookies (Non-Persistent Cookies): Session Cookies are the cookies which exist only while the user is on a particular website. These cookies are deleted once the user exits the web page, at the end of the browsing session.
Persistent Cookies: Persistent Cookies are the cookies which remain on your device for a longer period of time, for the duration of each specific cookie, and will remain valid until its set expiry date (unless deleted by the user before the expiry date). They are used to recognize a return visitor as a unique user. If the visitor restricts persistent cookies, these cookies fail to gather any information about that visitor.
Third Party Cookies: Certain third party cookies placed on your device are used for analytical and advertising purposes. These cookies can be persistent or non-persistent and are placed from different domain names. If you would like more information about these cookies, as well as information about how to consent or withdraw your consent for receiving such cookies, please see the table below and the links to these third parties’ privacy policies.

When you visit the Websites, you may receive cookies from third party websites or domains. You should check the relevant third party's website for more information about these cookies. The relevant third party is responsible for providing you with information regarding the cookies they place and obtaining your consent before placing cookies on your device.

Personalization Cookies: These cookies enable our website to remember choices you made on the site, e.g. keeping a user logged in.
Analytics Cookies: Analytics Cookies provide an aggregated view into site usage.
Targeting or advertising cookies: These Cookies provide targeted advertising on the site or other sites.
Social Media Cookies: These Cookies collect information when using social networking features on the site such as share or like.

How can you control, delete or withdraw your consent to the use of cookies?

You may withdraw your consent to our use of cookies on the Websites or delete or restrict the placing of cookies on your device by using our Cookie consent management platform by clicking the button below.

If you disable the cookies that the Websites use, this may impact your experience while on the Websites, for example you may not be able to visit certain areas of the Websites or you may not receive personalised information when you visit the Websites.

You can also delete cookies already stored on your computer.

Again, doing this may have a negative impact on the usability of many websites.

More Information

For more information on cookies and their use visit:

https://www.allaboutcookies.org

https://en.wikipedia.org/wiki/HTTP_cookie

For more information on Data Protection, please refer to Colt's "Privacy Statement".

How can you access, modify or delete your personal information?

As individuals, you have the right to access and to apply for the rectification of any personal data we hold about you. You also have other rights under applicable law. If you wish to be provided with more information and want to exercise these rights, please send a written and signed request to Colt via email at [email protected] or use the "Data Privacy Information" page. Alternatively you can use the relevant address below:

Alessandro Galtieri
The Group Data Protection Officer
Colt Technology Services Group Limited,
20 Great Eastern Street,
London, UK,
EC2A 3EH,

A list of all cookies active on colt.net

Cookie Provider

Google Analytics

Cookie Purpose

Google Analytics registers a unique ID that is used to generate statistical data on how the visitor uses the website. This is used additionally by Google Analytics to throttle request rate. Google collects anonymous statistics on a user's visits to the site, such as number of visits, average time spent on website and what pages have been viewed. Please note: IP Anonymysation is enabled on our Google Analytics platform, meaning that IP information automatically collected by Google is neither available, visible or actionable for anyone at Colt.

ID	Expiry	What is this used for?	Category
_ga	2 years	Used to distinguish users	Measurement
_gaid	2 years	Used to distinguish users
_gat	1 minute	Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_.
_utma	2 years from set/update	Used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics.
_utmx	18 months	Used to determine a user's inclusion in an experiment.	Measurement & Page Optimisation
_utmxx	18 months	Used to determine the expiry of experiments a user has been included in.
_gaexp	Depends on the length of the experiment, but typically 90 days.	Used to determine a user's inclusion in an experiment and the expiry of experiments a user has been included in.
_opt_utmc	24 hours	NG_TRANLSATE_LANG_KEY

Cookie Provider

New Relic

Cookie Purpose

New Relic Cookies are used for performance monitoring only, for example to track page load times. No personally identifyable information is collected in this process. For more information, visit https://docs.newrelic.com/docs/browser/new-relic-browser/getting-started/introduction-new-relic-browser

ID	Expiry	What is this used for?	Category
nr-data.net	24 hours	Monitoring website technical performance	Performance

Cookie Provider

Cookie Purpose

LinkedIn cookies are used to track visitors to colt.net that are also members of LinkedIn, and that have come to our site via referral from LinkedIn. This allows us to understand those that are interested in our products and services amd make additional offers and promotions to those users.

ID	Expiry	What is this used for?	Category
BizoID, bcookie, bscookie, UserMatch, History, lang, lidc	Your browsing session	Collecting source data on users that visit colt.net via LinkedIn. This data is collected and stored by LinkedIn	Demographic Information & Advertising

Cookie Provider

Facebook

Cookie Purpose

Facebook cookies are used to track visitors to colt.net that are also members of Facebook, and that have come to our site via referral from Facebook. This allows us to understand those that are interested in our products and services amd make additional offers and promotions to those users.

ID	Expiry	What is this used for?	Category
fr	Your browsing session	Collecting source data on users that visit colt.net via Facebook. This data is collected and stored by Facebook.	Demographic Information & Advertising

Cookie Provider

HubSpot

Cookie Purpose

Cookies collected by HubSpot are collected when browsing colt.net. When information is collected via a form submission, these details are built into an individual profile. HubSpot cookies are then used to know who has visited specific pages and downloaded specific content. Based off of your interactions on the site, and after you have entered your information into our site, some behaviour related information may be used to send you related email based content. You have the ability to be unsubscribed from these at any point should you wish to be. No personally identifyable information is collected about you by HubSpot, barring the information you give to us through our forms. Your cookie information will additionally be stored so that you do not have to fill out the same information again through forms.

ID	Expiry	What is this used for?	Category
hubspotutk	13 months	This cookie is used to keep track of a visitor's identity. This cookie is passed to HubSpot on form submission and used when deduplicating contacts.	Database Purposes
, _htsc	13 months	The main cookie for tracking visitors. It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).	Measurement
, _hssc,	30 minutes of inactivity	This cookie keeps track of sessions. This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp.
_hsscr,	End of your browsing session	Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser. If this cookie does not exist when HubSpot manages cookies, it is considered a new session.
messagesUtk	13 months	This cookie is used to recognize visitors who chat with you via the messages tool. If the visitor leaves your site before they're added as a contact, they will have this cookie associated with their browser. If you chat with a visitor who later returns to your site in the same cookied browser, the messages tool will load their conversation history.
__hs_opt_out	13 months	This cookie is used by the opt-in privacy policy to remember not to ask the visitor to accept cookies again. This cookie is set when you give visitors the choice to opt out of cookies.	GDPR
__hs_do_not_track	13 months	This cookie can be set to prevent the tracking code from sending any information to HubSpot. Setting this cookie is different from opting out of cookies, as it still allows anonymized information to be sent to HubSpot.	GDPR
hs_ab_test	End of session	This cookie is used to consistently serve visitors the same version of an A/B test page they’ve seen before.	Performance
id>_key	Does not expire	When visiting a password-protected page, this cookie is set so future visits to the page from the same browser do not require login again. The cookie name is unique for each password-protected page.
hs-messages-is-open	30 minutes	This cookie is used to determine and save whether the chat widget is open for future visits. It resets to re-close the widget after 30 minutes of inactivity.
hs-messages-hide-welcome-message	1 day	This cookie is used to prevent the welcome message from appearing again for one day after it is dismissed.

Cookie Provider

App Dynamics

Cookie Purpose

This cookie is used for technical monitoring and is not used for any analytical or marketing purposes.

ID	Expiry	What is this used for?	Category
adrum	Your browsing session	Performance measurement	Technical performance

Cookie Provider

Colt On Demand

Cookie Purpose

This cookie is used to display the Colt On Demand portal in the correct user language

ID	Expiry	What is this used for?	Category
NG_TRANLSATE_LANG_KEY	Your browsing session	Language measurement	Essential

Individual Rights

For employees, former employees + candidates

A) Data Subject Rights
Should you wish to exercise your privacy rights, please select and download the relevant form below and once completed, send it to [email protected] together with a document that can identify you.

You can find more information about your Data Subject Rights here.

B) Data processing complaints
Should you wish to raise a complaint about your personal data, please download the form below and once completed, send it to [email protected] together with a document that can identify you.

Complaint form

For customers

Should you wish to exercise your privacy rights relating to ticketing and invoicing, please select the relevant form below and raise a ticket in Colt Online. You can track updates using your ticket reference in Colt Online.

Complaint form

If you have any data privacy questions or queries on other topics, please contact [email protected].

Our Privacy Goals & Global Privacy Policy

The purpose of data privacy and protection is to safeguard and protect, in the context of personal data processing, the public freedoms and fundamental rights of natural persons, especially their reputation and personal privacy. Its objective is to regulate personal data processing, irrespective of the format in which the data is processed, the rights of data subjects and the obligations of data processors and controllers.

1. Purpose and Scope

1.1 This policy defines the privacy control requirements of Colt that will enable its employees and those processing Colt personal data to effectively protect personal data and manage privacy risks to Colt’s business services, functions, information systems, assets and people.

1.2 It is the responsibility of every Colt employee to understand these principles when fulfilling their daily activities.

1.3 The requirements defined in this document are mandatory and apply to all Colt employees.

2. Definitions

2.1 Personal data: means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; In addition, there are “sensitive data” types, which refer not only to health but to ideology, religion, ethnic background, sex life and history of criminal or administrative convictions or offences. Due to sensitive data use restrictions and specificities, Colt has implemented a separate privacy policy to govern the processing of sensitive data, the Colt Sensitive Information Policy.

2.2 Employees: means Colt employees, Colt authorised contractors, supplier sub- contractors, partners, temporary workers and any individual employed directly by supplier or who the supplier has tasked and involved in the provision of services to Colt.

2.3 Supplier: means an organisation or individual that enters into an agreement with Colt for the supply of a product or service. This includes all suppliers in the supply chain.

2.4 Colt Personal Data: means personal data relating to employees, customers and suppliers.

2.5 “Data Protection Legislation” means Regulation (EU) 2016/679 ("GDPR"), and any and all applicable data protection laws and regulations, as amended, revised or replaced from time to time.

3. Compliance

3.1 Compliance with this policy is mandatory for all Colt employees involved in processing Colt personal data.

3.2 The Data Protection Officer will monitor and report on the level of compliance that Colt employees achieve in respect of this policy and the requirements set out within this document.

3.3 Non-compliance with this policy will require explicit authorisation from the Colt Data Privacy Officer.

3.4 Prior approval should be obtained from the Data Privacy Officer before this document is provided to any third parties.

4. Roles and Responsibilities

4.1 The Data Protection Officer is responsible for maintaining this document and ensuring it remains effective in reducing the level of privacy risk to the Colt.

4.2 Colt employees are responsible for the day-to-day application of the policy and controls contained within this document. The Data Privacy Officer may require evidence to be provided from Colt employees in respect of how the requirements of this document have been applied.

5. Training and Awareness

5.1 All Colt employees must complete mandatory general privacy and information security training as well as specific training modules tailored to their role in their first 30 days of employment and annually throughout their employment. Employees who handle personal data must receive training before receiving access to Colt systems containing personal data. Supervisors are encouraged to request privacy training for themselves or for employees reporting to them if they feel it is appropriate.

5.2 In addition, the Data Protection team provides ongoing guidance and awareness materials, including newsletters, guidance documents, webinars and client-facing collaterals as appropriate.

5.3 The Data Protection team works with the Human Resources and Marketing departments to ensure that training and awareness materials are up to date, relevant and assigned or distributed appropriately. Failure to satisfactorily complete mandatory Privacy training may result in disciplinary action or loss of access to Colt IT infrastructure.

6. Data Privacy Roles and Responsibilities

6.1 Colt must define, document, and assign privacy risk management and governance roles.

6.2 Colt must educate and train Colt employees and those performing specific privacy risk management activities, so they can fulfil their duties effectively.

6.3 Colt has designated a single global DPO, engaged internally and located within the European Union. In addition, Colt has local Data Protection Officers as required by national privacy legislation and local representatives in each country who will report directly to the global DPO. The DPO´s team can be reached via email at [email protected] or [email protected].

The details of the Group Data Protection Officer are as follows:

Alessandro Galtieri

Group Data Protection Officer

Colt Technology Services Group Limited

Colt House | 20 Great Eastern Street | London | EC2A 3EH | UK

6.4 In addition, the local DPOs are as follows:

6.4.1 Italy DPO: Alessandro Galtieri
6.4.2 Germany DPO: Sebastian Kraska
6.4.3 Spain DPO: Cristina Sirera
6.4.4 India Grievance Officer: Alessandro Galtieri

Fundamental Principles

Colt must safeguard the security and integrity of personal data for which it is responsible. This includes personal data which it processes directly (Colt as a data controller), through the provision of services by third parties (as data processors to Colt) or as a provider of services (Colt as a data processor) to a third party.

In all cases, whether Colt acts as a data controller or processor, the personal data must be processed in compliance with the required legal and contractual obligations and guarantees.

The applicable data protection regulation directly affects the operations of Colt, as personal data is processed in its day-to-day activity. When processing this data, certain principles and measures must be fulfilled. These principles are as follows:

Lawfulness, fairness and transparency

Purpose limitation

Data minimisation

Storage limitation

Accuracy

Security

Colt must ensure that the personal data that is collected and processed is protected by implementing appropriate technical and organisational measures to prevent unauthorised or unlawful data processing, accidental loss, destruction or damage.

In particular, Colt must ensure that its employees who, in the performance of their duties, have access to personal data, undertake to treat such data as confidential and refrain from disclosing it to other parties, unless it is lawful to do so.

Where there is a suspected (or confirmed) breach of security which involves accidental, unauthorised or unlawful access to, or disclosure, alteration, loss or deletion of any personal data by any Colt employee or any third party, please contact CSIRT in line with the Personal Data Incident Response Process.

Data protection by design and by default

Colt must apply measures to safeguard and demonstrate compliance with data protection legal requirements by designing and implementing data protection by design and by default:

(a) Privacy by design: When designing a product or service, from the outset the Colt must take into account issues such as information requirements or obtainment of appropriate consent to process customer personal data.

(b) Privacy by default: By default, only the personal data necessary to achieve the legal objective pursued must be processed, whilst ensuring confidentiality of personal data.

7.8.2 The Privacy Impact Assessment (PIA) is a useful tool for ensuring that privacy is built in to all new processing activities and so Colt has developed guidelines and templates for:

(a) When to conduct a PIA (see PIA Justification for details);

(b) How to complete a PIA (see PIA Completing Guide and FAQs); and

7.8.3 Colt has established that a PIA must be undertaken in the following circumstances:

(a) Systematic and thorough evaluation of personal aspects relating to individuals, based on automated data processing, including profiling, and on which decisions about those natural persons are based.

(b) Large-scale data processing of sensitive data or data related to criminal convictions and offences. In Colt, large scale data processing is defined as 100 or more data subjects.

(d) Processing of sensitive personal data.

(e) Personal data transferred, external to Colt, outside of the EEA (i.e. the EU, Iceland, Norway and Liechtenstein) or adequate country .

(f) Impact to a person’s privacy is significant or maximum. Please refer to the PIA guidance document for further examples of impact.

7.8.4 The Colt PIA methodology must be followed to assess and determine the privacy controls required for any business activity involving a privacy risk e.g. projects, procurement of goods and services.

7.8.5 Employees should refer to the above documentation when conducting a PIA or assessing if one is needed and should contact the Colt Data Protection team if required (on [email protected]).

Accountability

Colt as a data controller is responsible for how it processes personal data and complying with this policy.

All Employees are required to act in accordance with this policy and, where appropriate, ensure that it is enforced.

The Data Protection team is responsible for this policy and providing training on it, however many Employees will be required to fulfil parts of this policy, most notably the Individual Rights principle. Where this is the case Employees must follow the procedures laid out in the principle and Individual Rights Policy.

Colt must maintain records of the processing activities it undertakes; the information contained in this record will differ depending on whether Colt is processing the personal data as a data controller or a data processor.

Individual rights

(c) Right of erasure (right to be forgotten): Individuals have the right to the deletion of personal data concerning them.

(d) Right to object: Individuals have the right to object to the processing of personal data at any time.

7.10.2 Colt responds to these requests in accordance with the procedure provided by the Individual Rights Policy

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