Customer Portal Privacy Policy

1. Introduction

Colt Data Centre Services UK Limited (“Colt” or “Colt group”) collect and handle the personal data contained in our Customer Portal enabled by Cherwell. Colt will be the Data Controller of this data processing and it is located at Colt House, 20 Great Eastern Street, London, England, EC2A 3EH, United Kingdom.

Colt is committed to provide its customers with the highest standards in Data Protection, so that it processes your personal data in line with the relevant data protection laws, including without limitation the Regulation (EU) 2016/679 (General Data Protection Regulation – ‘GDPR’). To comply with the transparency principle, Colt will inform you through this Privacy Notice what personal data will be processed, why, for how long and with whom it will be shared. 

2. Categories of personal data and purposes 

Colt is handling the following personal data (i.e. data which can be used to identify you) to be used for the following purposes:

3. Legal basis

We must have a legal basis to process your personal data. The legal basis we rely on are the following:

(a) To comply with our contract obligations to deliver our services.
(b) To comply with our legal obligations.

4. Data Protection Rights 

If you wish to exercise your rights of access, rectification, erasure, restriction, portability or objection, please send an email to [email protected]. A document that can identify you may be asked if needed. 

We encourage you to contact us to update or correct your information if it changes or if the personal data we hold about you is inaccurate. 

Additionally, you are able to lodge a complaint to the competent data protection authority. However, we take our obligations seriously, so if you have any questions or concerns, we would encourage you to raise them with us first, by sending an email to [email protected].

5. Recipients

Colt may share your personal data with third parties, particularly with the company Ivanti, which operates the Cherwell system and is located in the United Kingdom notably.

6. International data transfers 

Your personal data will be hosted within the EEA and UK, however access to the personal data may be global. Colt may transfer personal data or makes personal data accessible to its subsidiaries (listed on https://www.coltdatacentres.net/), subcontractors or otherwise, located within or outside of the EEA or UK for the provision of the services. 

The transfers within the Colt Group are carried out by means of an Internal Data Transfers Agreement (IDTA) based on the Standard Contractual Clauses (SCCs) of the European Commission. The transfers outside of Colt Group are carried out on the basis of an adequacy decision of the European Union or, failing that, on the basis of appropriate safeguards as the Standard Contractual Clauses and, where applicable, supplementary security measures.

For Japan only: Colt DCS transfer personal information to countries outside of Japan in order to achieve the purposes described in this Policy. Those countries would be the United Kingdom, some EU countries, India (where Colt DCS entities are based) and the United States of America (where some of our partners are based).

We would only transfer the personal information to countries having a data protection regime with a level of protection equivalent to that of Japan (such as the EU and United Kingdom) or to recipients with a system of data protection which meets the standards to be prescribed by the PPC Ordinance, by either (a) providing assurance by appropriate and reasonable methodologies that it will treat the transferred personal information pursuant to the spirit of the requirements for the handling of personal information under the APPI (for example by executing a data processing agreement), or (b) having been certified under a PPC-recognised international arrangement regarding its system of handling personal information (such as the APEC Cross-Border Privacy Rules System).

Upon transferring personal information, we evaluate legal systems related to data protection in the destination countries/regions. In addition, we have appropriate security measures (contractual agreements, etc.) to assure the security of personal information in accordance with applicable laws. 

You can learn more about the personal information protection legal systems in countries outside Japan to which we may transfer personal information in the website published by the Personal Information Protection Commission (PPC):  https://www.ppc.go.jp/enforcement/infoprovision/laws/.

7. Retention period

Your personal data will be retained by Colt as long as it determines it is necessary to comply with its contractual and legal obligations.

8. Contact details 

If you have any questions about the present document, please feel free to contact Colt via email at [email protected].