Privacy Statement

NTT Global Networks (NTTGN) Privacy Statement

Version: 02_03_2021_A

This Privacy Statement was last updated on February 3rd, 2021

This is the web site of NTT Global Networks Incorporated.

Our mailing address is:

5680 Greenwood Plaza Blvd.
Greenwood Village, CO 80111

You can reach us by telephone at 720-475-4000
You can reach us by email at info@nttglobal.net

1. Introduction

NTT Global Networks Incorporated (“NTTGN”) understands the importance of ensuring that we collect, use, store, share and dispose of (collectively ‘Use’) information about you (‘Personal Data’) in a fair, ethical, transparent, secure and lawful way.

This Privacy Statement describes what Personal Data we Use about you, how we Use it, and your choices and rights in relation to your Personal Data.

This Privacy Statement applies to our Use of your Personal Data in our interactions with you through our websites and social media sites (“Sites”) that link to our Privacy Statement, or Personal Data about you that we may collect offline or receive from other parties.

In certain locations around the world, we have additional requirements that apply to how we Use your Personal Data. Please see the applicable privacy notices and statements for these locations.

This Privacy Statement is incorporated into, and part of, our Terms of Use that govern the use of our Sites.

If you have any questions about how we Use your Personal Data or would like to lodge a complaint, please contact us at dpo@nttglobal.net.

2. Information we collect about you

Personal Data is any information that identifies you or relates to you.

We collect Personal Data about you from different sources including: Personal Data that we collect directly from you; Personal Data that we collect automatically about you as you use our Sites; and Personal Data that we collect from other sources, as described in this Privacy Statement.

The type of Personal Data that we collect about you varies based on our interactions with you.

• Personal Data that we collect directly from you.

  We collect Personal Data directly from you in the following circumstances:

  • Onboard you as a client: we collect your name, business contact information, job title, and employer name when we onboard you as a client or as a representative of one of our clients
  • Purchase our products, services or solutions: to place an order for our products, services or solutions you must first create an account or establish a relationship (see above for information collected); in addition to the information collected through the account creation or client relationship process, we also will collect your payment information
  • Contact us, request information, or provide feedback: if you contact us, request information from us, we may collect your name, contact information, job title, industry, location, and inquiry information. We may also obtain your feedback about our products, services or solutions when you respond to our surveys
  • Subscribe to our mailing lists or newsletters: if you request newsletters or join our mailing lists, we collect your contact information including your name email address
  • Download white papers, reports, or other collateral: we may collect your name, contact information, job title, industry and location
  • Register and attend our events, workshops, or seminars: we collect your name, contact information, meal preferences, contact preferences, payment information (if applicable) and additional information as may be noted in our event forms
  • Use our Sites: when you use our Sites, we will collect information about your use of the Site and any information that you submit through those Sites
  • Interactions on our social media pages: if you post to our social media pages, we may collect information about you from your post. We typically Use this information to respond to your inquiry and we do not usually associate this information with your account
• Personal Data that we automatically collect
  
  We automatically collect the following information about your use of our Sites and use of our services or solutions through cookies, web beacons, and other technologies including: your domain name; your browser type and operating system; web pages you view; links you click; language preferences; demographic information such as your marketing preferences; your IP address; the length of time you visit or use our Sites; and the referring URL, or the webpage that led you to our Sites. We may also collect your approximate location through collection of your IP address. Typically, we do not combine this information with other information that we have collected about you, including, other Personal Data. For more information, see the “Cookies and Similar Technologies” section below.

3. Personal Data we collect from other sources
   
   We also collect Personal Data from other sources, as follows:

• Our affiliates: subject to applicable law, and, where required with your consent, our affiliates may provide your contact information to us if they believe that a product, service or solution may be of interest to you or through your use of their Sites or products, services or solutions
• Our business partners: we collect information about you from our business partners with whom we offer co-branded services or engage in joint marketing or service provision activities
• Public databases or list enhancement services: we obtain information about you from public databases and list enhancement programs, solutions or services. For example, we may use a service provider to verify mailing addresses. In some instances, our external service provider may perform mailing activities and we do not obtain the updated address information

We do not collect sensitive or special category Personal Data about you, e.g. information relating to your health, biometric or genetic information, religion, political beliefs, union membership, race or sexual orientation and ask that you do not send or provide this information to us.

You can choose not to provide Personal Data to us in certain circumstances. However, if your Personal Data is necessary to provide you with our products, services or solutions, access to our Sites, or to perform administrative functions, we may be unable to do these things without your Personal Data.

4. How we Use your Personal Data

We Use your Personal Data for the following purposes depending on the purpose for which your Personal Data was collected and our relationship with you:

• Performance of, or entry into a contract with you or your employer: to provide our products, services or solutions to you or your employer, and to take action on your or their requests
• Our legitimate business interests: to protect our legitimate business interests or those of a third party with whom we receive or share your Personal on legitimate interests for the purpose of managing, operating or promoting our business, including direct marketing, and intra-NTT (i.e. companies affiliated with us) transfers of Personal Data for business and administrative purposes. Whenever we rely on this basis to Use your Personal Data, we assess our business interests to ensure that they do not override your fundamental rights and freedoms. Additionally, you may have the right to object to our Use of your Personal Data in certain circumstances. See the ’Your Rights’ section of this Privacy Statement
• Compliance with a mandatory legal obligation: to ensure that we comply with applicable laws and regulations that govern and regulate how we do business
• Consent you provide: where you have provided consent to us to Use your Personal Data. You may withdraw your consent at any time. When you give your consent, you will be given details on how we will Use your Personal Data and where you can go to withdraw your consent if you change your mind

5. How we Use information about you

We may Use your Personal Data to:

• enable you to effectively use and to improve our products, services and solutions. For example, to:
  • perform administrative and business functions and internal reporting
  • send administrative information to you and manage our business relationship with you
  • obtain feedback from you about our products, services and solutions including through client satisfaction surveys, in which event, we will only Use your Personal Data for the sole purpose of sending you a survey (through our third-party Customer Experience Management platform)
  • assess the performance of our Sites, products, services and solutions and to improve their operation
  • process your orders and provide you with our products, services and solutions
  • provide you with current information about our products, services and solutions
  • respond to your inquiries and fulfil requests made by you
  • update our records and keep your contact details up to date
• Provide you with marketing materials and to personalize your experience. For example, to:
  • send marketing communications to you
  • provide you with a more personalized experience when you interact with us
  • enable you to subscribe to our newsletters and mailing lists
  • enable you to manage your marketing and cookie preferences
  • enable you to register for events, workshops and seminars hosted by us
• Achieve our business purposes and analyze information. For example, to:
  • establish, manage, and maintain our business relationship with you
  • compile usage statistics for our Sites
  • process and respond to privacy requests, questions, concerns and complaints
  • fulfil our contractual obligations
• For research and analytical purposes. For example, to:
  • better understand how you use our Sites, products, services and solutions
  • improve our Sites, products, services and solutions
  • evaluate Site, product, service and solution demand
  • administer surveys and questionnaires, such as for market research or client satisfaction requirements
• To comply with our legal obligations. For example, to:
  • investigate, prevent, or take action regarding illegal activities, suspected fraud
  • investigate violations of our Terms of Use or this Privacy Statement.

6. How we share information about you

We may share your Personal Data with the following parties for the purposes set out in this Privacy Statement (as applicable):

• Our affiliates: for the purposes set out in this Privacy Statement. NTTGN is the party responsible for the management of jointly Used Personal Data
• Business partners: to offer co-branded services or engage in joint marketing activities, as permitted by applicable law
• Service providers: to provide operational services or facilitate transactions on our behalf, including but not limited to processing of orders, assisting with sales-related activities or post-sales support, client support, email delivery, data analytics, survey distribution and insights, and auditing
• Authorities: to respond to a request for information by a competent authority in accordance with, or required by any applicable law, regulation or legal process; or where necessary to comply with judicial proceedings, court orders or government orders

We also may share Personal Data in the following circumstances:

• When you consent to the sharing of your Personal Data
• In connection with, any joint venture, merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company and to our advisors and the advisors of the other company in such transactions
• To protect the rights, property or safety of NTTGN, its affiliates and business partners, you, or others, or as otherwise required by applicable law
• For other legal reasons

When we share Personal Data with our affiliates and service providers or other parties, we have taken reasonable efforts to ensure that they implement appropriate physical, administrative and technical safeguards to protect Personal Data and are not permitted to use Personal Data for any purpose other than the purpose for which they are provided with or given access to Personal Data.

7. How we protect information about you

We are committed to protecting your Personal Data from accidental or unlawful destruction, loss, alteration, unauthorized access or disclosure by using a combination of physical, administrative and technical safeguards and contractually requiring our affiliates and service providers to whom we disclose your Personal Data to do the same.

When our Sites require you to establish an account or create and maintain usernames and passwords to access and use our Sites, we cannot guarantee the security of your Personal Data if you do not take steps to do the same on your end.  You are required to take reasonable steps to protect your Personal Data (e.g. by not sharing your passwords, choosing strong passwords and other measures).

8. How long we keep information about you

We keep information about you for as long as is necessary to fulfil the purpose for which it was collected, unless we are required to keep it for longer to comply with our legal obligations, resolve disputes, protect our assets, or enforce our rights. The criteria we use to determine how long we keep Personal Data includes:

• we are under a legal, contractual or other obligation to keep your Personal Data, or as part of an investigation for litigation purposes
• your Personal Data is needed to maintain accurate business and financial records
• there are automated means to enable you to access and delete your Personal Data at any time
• you have consented to us keeping your Personal Data for a longer time period and we keep your Personal Data in line with your consent

In some instances, we may anonymize your information in accordance with our policies and may keep those anonymized records for longer periods.

9. Cross-border transfers

As a company providing services around the world, we may transfer your Personal Data to countries where we do business or to affiliates of ours and international organizations in connection with the purposes identified above and in accordance with this Privacy Statement.

When we transfer your Personal Data outside of the country from where it was originally collected to a third country, affiliate, or international organization, we ensure that appropriate safeguards are in place, in line with applicable law, to ensure that your Personal Data is protected. You may obtain a copy of these safeguards by contacting us in accordance with the ‘How to contact us’ section below.

10. Your rights

You have rights under various data protection laws in various countries in relation to your Personal Data, but we offer them irrespective of your location.

We are committed to upholding your rights, including:

• Right to be informed: you have a right to know what Personal Data we have about you, what we do with it, where we get it from, who we share it with, how long we keep it and why we need it
• Right of access: you have the right to access your Personal Data and obtain a copy of your Personal Data from us
• Right to rectification: you have the right to update inaccurate and/or incomplete Personal Data about you
• Right to be forgotten: you have the right to have your Personal Data erased, deleted or destroyed
• Right to data portability: you have the right to move, copy or transfer your Personal Data in a safe and secure way and reuse it for your own purposes
• Right to withdraw consent: you have the right to withdraw consent at any time regarding the Use of your Personal Data or in relation to direct marketing activities
• Right to restrict Use: you have the right to limit the way we Use your Personal Data
• Right to object: you have the right to stop or prevent us from Using your Personal Data. In particular, you can object to our Use of your Personal Data for direct marketing or the sale of your Personal Data.
• Right to challenge automated decisions: you have the right to query and review decisions made about you using purely automated means (i.e. without human involvement or intervention)
• Right to complain: you have the right to make a complaint or raise a concern about how we Use your Personal Data. Complaints may be made directly to us or a relevant Data Protection Authority

Where you contact us, we may request specific information from you to verify your identify to enable us to assist you. Where permitted under applicable law we may charge you a reasonable fee to access your Personal Data, however we will advise you of any fee in advance.

In some cases, we may not be able to meet a request due to other legal or regulatory factors, or we may not be required to enforce these rights under applicable law. We may also have a legitimate business interest to decline a request.

You may contact us with requests, complaints or questions regarding these rights as set forth in the ‘How to contact us’ section, below.

11. Cookies and similar technologies

When you access our Sites, we and our service providers use cookies (small text files containing a unique identification number which are placed on your PC or device) and similar technologies including scripts, embedded web links, web beacons, Local Shared Objects (flash cookies) and Local Storage (HTML 5). We and our service providers use cookies to assist us with activities such as:

• enabling you to sign-in to our Sites
• authenticating you
• keeping track of information, you have provided to us
• improving your browsing experience
• customizing our interactions with you
• storing and managing your preferences and settings
• compiling statistical data
• analyzing the performance and usability of our Sites
• measuring traffic patterns for our Sites
• determining which areas of our Sites have been visited

These technologies collect information that your browser sends to our Sites including using data, such as your browser type, information about your IP address (a unique identifier assigned to your computer or device which allows your PC or device to communicate over the Internet), together with the date, time and duration of your visit, the pages you view and the links you click.

Our Sites may also contain web beacons or similar technologies from analytics providers, through which they collect information about your activities across our Sites to help us compile aggregated statistics.

Currently, our Sites do not recognize web browser “do-not-track” requests, but several of our service providers who utilize these cookies or web beacons on our Sites enable you to opt out of targeted advertising practices. You may, however, disable certain tracking as discussed in this section (e.g. by disabling cookies); you may also opt-out of targeted advertising.

12. Links to third party websites and applications

Our Sites may provide links to the websites of other parties. Some of the content, advertising, and functionality of our Sites may be provided via other parties that are not affiliated with us.

We are not responsible for and make no representations or warranties in relation to the security, privacy practices and content of these websites. Please ensure that you read the applicable privacy and cookies policies of these third-party sites before sharing Personal Data on these third-party sites. Your use of such third-party sites is at your own risk.

You may also interact with us through social media plug-ins by ‘liking’ or sharing information provided on our Sites. Social media plug-ins are operated by the social network themselves (such as Facebook, LinkedIn, Twitter, Google+, etc.) and are subject to the terms of use, privacy and cookies policies of the respective social network. Please ensure that you are familiar with these.

13. Direct marketing communications

We may send you direct marketing communications about our products, services and solutions.

You can choose whether you wish to receive marketing communications from us.

You may opt-out of receiving marketing materials from us at any time and manage your communication preferences by:

• selecting the option to ‘Unsubscribe’ included in our communications with you
• updating your preferences in our online Preference Center if you are registered with our Sites
• sending an email to dpo@nttglobal.net.

Once we have received and verified an opt-out request received from you, we will comply with your request as soon as is reasonably practicable.

If you opt-out of receiving marketing related communications from us, we may still send you administrative messages as part of your ongoing use of our products, services and solutions, which you are unable to opt-out of.

We do not provide your Personal Data to unaffiliated parties for their own direct marketing purposes or sell, rent, distribute or otherwise make Personal Data commercially available to any third party.

14. Children’s Privacy

• We encourage parents and guardians to take an active role in their children’s online activities. We do not aim our Sites at children. If you believe that we may have collected Personal Data about someone who is under the applicable age of consent in your country or local jurisdiction without proper consent of the child’s parent or guardian, please contact us by sending an email to dpo@nttglobal.net.

15. Updates to our Privacy Statement

We may update our Privacy Statement at any time. If we do, we will update the ’Last update’ information at the top of our Privacy Statement.

We encourage you to regularly review our Privacy Statement to stay informed about how we Use your Personal Data and privacy practices.

16. How to contact us

If you have any questions about how we Use your Personal Data, have a privacy concern, or wish to make a request or complaint relating to your Personal Data, please contact us at dpo@nttglobal.net.