This Privacy Policy was last reviewed and updated in December 2023 and is effective as of that date.
Who is the Data Controller?
Colt Data Centre Services UK Limited (“Colt”) is the controller of the data processed through the webpages accessible at https://www.coltdatacentres.net/ (the “Website”).
What personal data will Colt Data Centre Services 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 when interacting with us and/or is otherwise collected by us when you visit the Website, by phone through our customer service, by writing through forms or in another manner. During our relationship with you, we may collect and process your personal data, such as your name, phone, email and other contact details, and any other information relating to
you which you may provide, when you:
- Visit our Website and look at our products and services;
- Enquire about our products and services or contact our customer service;
- Participate in a promotion, event, survey or other marketing campaign we organise;
- Sign up to 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, company and contact details (such as phone number and email address);
- Services and products;
- Names, e-mail address and phone numbers of third parties you provide to us (with their consent);
- Complaints and enquiries;
- Business profile;
- Answers provided in response to surveys.
Personal Data collected by automated means
When you visit our Website 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 and similar technologies (collectively referred to as “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 Website 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. From time to time we may also use other technologies to log and collect data in order to analyse traffic to our Website. 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 Website. In conjunction with cookies, this will enable us to identify what portions of our Website are of interest to our visitors and to help us provide you with tailored information from our Website.
The types of personal data that we may collect through your visits to the Website 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 Website);
- 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)
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 or other local privacy law 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. 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 information about our products and services;
- to administer, operate, maintain, and improve the Website and our services;
- for efficient customer management relationship;
- to simplify access to some interactive features on our Website or services;
- if you become a customer, to manage your accounts, orders, invoices and payments, manage and provide after-sale services and 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, notably collected via Cookies, in order:
- To keep improving the way our website works;
- To count how many persons visit our website, 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 website;
- To provide you access to valuable Colt internet-based information and services;
- To audit usage of the Website;
- To market and improve the services that we offer;
- 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;
- To show relevant adverts on the website or outside of it (referred to as "retargeting");
- To ensure the security of our Website and prevent and detect fraud or other crimes.
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 only:
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.coltdatacentres.net/) 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 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 have appropriate security measures in place.
Colt’s business partners. A list of such partners could be provided upon request.
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 and 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 laws.
Will personal data be transferred abroad?
In providing our services or Website to you, we may need to transfer your personal data to Colt Affiliates, service providers or other recipients identified in the "Why and with whom to we share your personal data?" section 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 Transfers Agreement), which includes the standard contractual clauses approved by the European Commission.
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/.
How is your personal data protected?
Colt has appropriate policies and technical and organisational 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 also take all reasonable precautions to ensure that our staff and employees who have access to personal data have received adequate training.
How long do we keep your personal data for?
We 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?
If you provide us with personal data about third parties, you warrant, represent, and undertake that you have complied with applicable data protection laws including informing
and obtaining all necessary consents and approvals for the provision of such personal data to Colt and the processing by Colt of this personal data as described in this Privacy
Policy.
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 Website, information on our products and services we think may be of interest to you,
initiatives or events, by e-mail, banner advertising or other electronic means. However, we will only do so in accordance with GDPR or local privacy law 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. 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 treat children’s personal data?
We do not knowingly collect personal data from anyone under the age of 18 or knowingly allow such persons to use our products and services.
What are your data protection rights?
In accordance with applicable data protection laws, 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 laws.
In case you wish to exercise any such rights, please send a detailed request to Colt at [email protected].
When you visit our Website, we may use Cookies as described above. By clicking on "Allow all cookies" on the cookie banner which is presented to you, you are agreeing to our use of cookies in accordance with this Policy and you acknowledge that we will implement 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 "Reject cookies". If you would like to customise your cookies preferences, please adjust the radio buttons accordingly and click the “Allow selection” button. You are able to update your cookie settings at any time, by clicking on the black circular “Privacy” icon on the left of all pages on the Website. You can also delete cookies already stored on your computer by clearing your browser.
What happens if you visit a linked website?
The information obtained by third party websites accessed via our Website is not covered by this Privacy Policy and is governed by the terms applicable to your relationship with
that third party, and Colt accepts no responsibility or liability in respect of third party websites.
How can we update this policy?
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 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.
How can you contact us?
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 write to us at [email protected].
