11 Июль 2019

Tell2Tell PRIVACY POLICY

Tell2Tell, including its affiliates comprising part of the Tell2Tell group companies ("Tell2Tell", "we" or "us"), is committed to honouring the privacy and security of personal data of its website users, job applicants, business contacts, and other individuals whose data we will collect (“user(s)” or “you”).

This Privacy Policy informs you how we will collect, store and use personal information, when you make use of our websites or otherwise communicate with us in the course of our business activities. It also tells you the choices you can make about how the information you provide to us is used.

Important Notes:

·      Regarding website users and other individuals who communicate with us online- The Tell2Tell entity which is responsible for your information is Tell2Tell Management Limited (Registered Address: Cannon Place, 78 Cannon Street, London, United Kingdom, EC4N 6AF) or else, as applicable, the specific entity which you originally communicated with directly.
 

·      Regarding other individuals, including, by way of example, job applicants, or individuals attending our corporate events – The Tell2Tell entity responsible for your information will be the Tell2Tell Group Company which originally collects information from and about you. This will be explained in the notices provided when you provide information to us.
 

·      This Privacy Policy only applies when we process data for our behalf (i.e. as controller), and it does not apply to any information which we may process on behalf of our customers or any third party. Such information will be subject to the customer's or that other third party’s privacy policies, as applicable.

WHAT TYPE OF INFORMATION WE COLLECT

When you make use of our websites or otherwise communicate with us, we collect the following types of information, which may also include individually identifiable information, namely information that identifies an individual or may - with reasonable effort - identify an individual (“Personal Information”):

·      when you register online or make an inquiry regarding our products and services, or provide us with comments or feedbacks. We will capture Personal Information about you so we can communicate effectively with you and address your requests regarding our products or services. We will hold information about your name, the company you work for, address, phone and fax numbers, e-mail address and line of business, etc. We will use this information to help manage your requests.
 

·      if you visit our websites, we will collect Personal Information from your device, such as IP address and other online identifiers (i.e. online data collected from user’s devices and protocols which leave traces which may be used to identify users). We use this to optimise your experience and help us to improve our websites and the ways we communicate with you.
 

·      If you attend one of our events: We collect Personal Information if you attend our Tell2Tell corporate events. This information may include your photos, identifying data (e.g. email, name, etc.) and any other information which may be collected by us in connection with our events.
 

·      if you apply for a job with us: we will collect Personal Information about you if you contact us about an employment opportunity at Tell2Tell. We will collect and use personal information to help assess your skills and your suitability to the relevant job position. We may also use such data to contact you if we believe a specific job position may interest you. Such information may include your name, email address, CV, telephone number, profile photo, job history and other relevant information.

We may anonymize or de-identify the information collected so that the information cannot, on its own, personally identify you. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and we may use it or disclose it to others without limitation and for any purpose.

HOW WE USE THE INFORMATION WE COLLECT

We use and share Personal Information as described in this Privacy Policy and for the following purposes:

·      To identify and authenticate your access;
 

·      To conduct analytics in order to improve and customize our websites and the ways we communicate with you;
 

·      To present you and your company business opportunities regarding our products and services;
 

·      To send you marketing communications, updates and newsletters and present personalized content (see below under “Marketing”);
 

·      To manage your application for a job positon at Tell2Tell (as applicable);
 

·      To support and troubleshoot our services, to respond to your queries and communicate with you;
 

·      To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request

LEGAL BASIS FOR USING YOUR PERSONAL INFORMATION

We will only collect, use and share your Personal Information where we are satisfied that we have an appropriate legal basis to do this. This may be because:

·      we need to use your Personal Information to perform a contract or take steps to enter into a contract with you. For example, when you provide your information with us in order to apply to a job position in Tell2Tell.
 

·      we need to use your Personal Information for our legitimate interest as a commercial organization. For example, we may collect your Personal Information in order to communicate with you and present you marketing materials and opportunities regarding our products and services.
 

·      we need to use your Personal Information to comply with a relevant legal or regulatory obligation that we have; or
 

·      we have your consent to use your Personal Information for a particular activity.

WITH WHOM WE SHARE THE INFORMATION WE COLLECT

We may share your Personal Information in the manner and for the purposes described below:

·      with other companies within our Group, where such disclosure is required to assist us in fulfilling the purposes described in this Privacy Policy or to manage our business; and
 

·      with third parties and service providers who help our business (e.g. for data analytics purposes, communicating promotional and informational materials, etc.). These third parties have agreed to confidentiality restrictions and use any Personal Information we share with them or which they collect on our behalf for the purpose of providing the contracted service to us.


We may also disclose Personal Information, or any information you submitted us, if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.

MARKETING

We may use Personal Information to let you know about our products and services that we believe will be of interest to your company. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.

To protect your privacy and to ensure you have control over how we manage marketing activities with you:

·      we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
 

·      you can ask us to stop direct marketing at any time you can ask us to stop sending email marketing, by following the "unsubscribe" link you will find on all the email marketing messages we send you.

You can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser as explained above.

SECURITY OF YOUR PERSONAL INFORMATION

We take security very seriously. We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature of the information concerned. Measures we take include, for example:

·      placing confidentiality requirements on our staff members and service providers;
 

·      destroying or permanently anonymising Personal Information if it is no longer needed for the purposes for which it was collected; and
 

·      applying security controls in the storage and disclosure of your Personal Information to prevent unauthorised access to it.


As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect User IDs and passwords, please take appropriate measures to protect this information. However, due to the open communication nature of the Internet, we cannot guarantee that communications between you and Tell2Tell, and Tell2Tell and you, will be free from unauthorized access by third parties.

STORING YOUR PERSONAL INFORMATION

We will store your Personal Information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this privacy policy. Where your information is no longer needed, we will ensure that it is disposed of in a secure manner. In some circumstances we may store your Personal Information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements.

In specific circumstances we may store your Personal Information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.

TRANSFERRING PERSONAL INFORMATION GLOBALLY

We operate on a global basis. Accordingly, your Personal Information may be transferred and stored in countries outside of Europe that are subject to different standards of data protection.

We will take appropriate steps to ensure that transfers of Personal Information are made in accordance with applicable law and carefully managed to protect your privacy rights and interests, and limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights.
To this end:

·      we ensure transfers within our Group will adhere to applicable privacy and data protection laws and that such transfers ensure a consistent level of protection wherever it is transferred within the Group;
 

·      where we transfer your Personal Information outside of the Tell2Tell Group to third parties who provide us services, we obtain contractual commitments from them to protect your Personal Information; or
 

·      where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.