Data Privacy Statement
Last updated: May 2018
Colt provides world-class network and communications services for enterprises and wholesale customers in Europe, Asia and North America’s largest business hubs. Colt enables the digital transformation of businesses through its intelligent, purpose-built, cloud-integrated network, known as the Colt IQ Network.
At Colt, your privacy is as important to us as it is to you. We have developed this policy because we want you to feel confident about the privacy and security of your personal data. Colt Technology Services (“Colt”, “us,” or and the “Company”) is committed to protecting the privacy of individuals that enter into contracts with Colt, individuals who visit the Company’s Web sites and ask for information, individuals who register to use Colt´s Services as defined below, and individuals who register to attend the Company’s corporate events.
• The key points you need to know about how we collect and use your personal data
• What personal data we collect about you
• How we use any personal data we might collect about you
• For which purposes we use your personal data
• 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 our use of your personal data
• How you can contact us about our privacy practices and to exercise your rights
2. Key points you need to know about how we collect and use your personal 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 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.
3. What personal data will Colt collect?
• 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 organize; or
• 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; and
• 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.
4. How do we use your personal data?
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.
5. 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.
6. 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 based on Colt Intragroup Transfer Agreement, based in the EU Commission Standard Contractual Clauses and the EU Commission Standard Contractual Clauses for the transfer of data to third countries, when needed. In addition, Colt is planning to apply for the Binding Corporate Rules during 2018. You may obtain a copy of such appropriate safeguards by sending a written and signed request to Colt as described under the "How can you contact us?" section.
By submitting your personal data to Colt when entering into a Contract with you, when you use the Websites or our Services, you consent to any the transfer of such personal data to those countries.
7. 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.
8. 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@example.com. 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.
9. What happens when you provide us with personal data about third parties?
10. 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.
11. 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.
12. 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.
13. 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 register on our Websites or Services.
14. 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.
15. What happens if you visit a linked website?
17. How to contact us?
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 firstname.lastname@example.org
Last update : May 2018
2. 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 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 an anonymous 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.
Many cookies on our Websites perform essential functions or services your have requested or for security purposes, as further described in the table below.
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 can be blocked by changing browser setting.
- Cookies cannot carry any threat to the visitor’s device.
4. What types of cookies Colt may be placing on your device?
- 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 opt-out of 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. We do not control the placing of these cookies and 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.
Examples of cookies being used by Colt include:
|Cookie name||Cookie details|
|nr-data.net||New Relic cookie is used for performance monitoring only, more details at https://docs.newrelic.com/docs/browser/new-relic-browser/getting-started/introduction-new-relic-browser.|
|hubspotutk, __cfduid, __hstc,|
|These cookies are used by a tool called HubSpot that we use to build pages for specific content offers, and send emails to specific segments of customers for content that may be of interest to them. HubSpot cookies help us to know who has visited specific pages and downloaded specific content. The __cfduid cookie is used by the content network Cloudflare to identify trusted web traffic.|
|BizoID, bcookie, bscookie, UserMatch, History, lang, lidc||LinkedIn cookies are used to track visitors to the colt.net website that are also members of LinkedIn. This allows us to make additional offers and promotions to LinkedIn users that we already know are interested in our products and services.|
|driftt_aid, driftt_sid||Drift is a conversational marketing platform that enables companise to better engage with their customers.|
|personalization_id||Similar to LinkedIn, Facebook and other social platforms, the Twitter cookie allows us to message or advertise to people on Twitter that we know have previously engaged with Colt and hence are likely interested in our products and services.|
|_gid, _ga, _gali,|
|Registers a unique ID that is used to generate statistical data on how the visitor uses the website. Used by Google Analytics to throttle request rate. Description: Registers a unique ID that is used to generate statistical data on how the visitor uses the website. Collects anonymous statistics on the user's visits to the website, such as the number of visits, average time spent on the website and what pages have been read.|
|fr||Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.|
|__atuvc, __atuvs, _at.cww, at-rand,|
|AddThis is used to provide the social sharing buttons on colt.net. Updates the counter of a website's social sharing features. Ensures that the updated counter is displayed to the user if a page is shared with the social sharing|
|__aza_perm, _pk_id#, _pk_ses#||We use Azalead to enable our website personalisation functionality.|
For Internet Explorer:
- Click on ‘Tools’ at the top of your browser window and select ‘Internet Options’
- In the options window navigate to the ‘Privacy’ tab
- To enable cookies: Set the slider to ‘Medium’ or below
- To disable cookies: Move the slider to the top to block all cookies
- Click on ‘Tools’ at the browser menu and select ‘Options’
- Select the Privacy panel
- To enable cookies: Check ‘Accept cookies for sites’
- To disable cookies: Uncheck ‘Accept cookies for sites’
- Click the wrench icon on the browser toolbar
- Select Settings
- Click ‘Show advanced settings’
- In the “Privacy” section, click the ‘Content settings’ button
- To enable cookies in the “Cookies” section, pick ‘Allow local data to be set’, this will enable both first-party and third-party cookies. To allow only first-party cookies pick ‘Block all third-party cookies without exception’
- To disable cookies, in the “Cookies” section, pick ‘Block sites from setting any data’
- Open Safari if it is not already open.
- Choose Safari> Preferences, and then click Privacy.
- In the “Block Cookies” section, specify whether Safari should accept cookies from websites, and when.
- To see an explanation of the options, click on your computer, click Details.
- If you want to see which websites store cookies on your computer, click Details
For all other Browsers and Mobile Devices:
To restrict cookies on any other browser or on a mobile device, please visit the official webpage of the browser or device manufacturer or the documentation provided by them and follow their instructions.
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.
For more information on cookies and their use visit:
For more information on Data Protection, please refer to Colt's "Privacy Statement".
6. 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 the right to object, at anytime and for free, to the use of your personal data for direct marketing purposes, as well as to exercise other rights under applicable law. If you want to exercise these rights, please send a written and signed request to Colt via email at email@example.com or use the "Contact us" page. Alternatively you can use the relevant address below:
The Group Data Protection Officer
Colt Technology Services Group Limited,
20 Great Eastern Street,