Policy last updated: 25/03/2019.
Giacom World Networks Limited (Giacom) understands your concerns over the privacy of Personal Data you may submit through the use of this website or through any other form of contact with our organisation.
The information we collect
Personal Data is anything which identifies you as an individual, either on its own or by reference to other information. We may collect the following Personal Data from you when you use our website or contact us:
- information such as name, address, email address, contact number and payment details which are collected to support the transactions carried out between you and us on or in relation to this website;
- information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation); and
- any other information that you choose to provide to us.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser, and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
We use "session" cookies on the website. Session cookies will be deleted from your computer when you close your browser.
We will use the session cookies to: keep track of you whilst you navigate the website; prevent fraud and increase website security.
Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. For example, in Internet Explorer you can refuse all cookies by clicking "Tools", "Internet Options", "Privacy", and selecting "Block all cookies" using the sliding selector. Blocking all cookies will, however, have a negative impact upon the usability of many websites.
Legal Basis for using Personal Data
Giacom will only process Personal Data where we have a legal basis to do so. The legal basis will depend upon the reason we collected and the needs to use the Personal Data. Under UK and EU data protection legislation in almost all cases the legal basis will be because:
- processing of the Personal Data is necessary to perform the contract to fulfil your request for services;
- processing of the Personal Data is necessary to support your consumption of services;
- processing of the Personal Data is necessary to support the creation of a contract with you as a new Customer;
- it is in Giacom’s legitimate interests as a provider of cloud services to process the Personal Data to operate and improve the Giacom Cloud Market and associated services;
- Giacom processes the Personal Data to comply with a legal obligation;
- you have consented to Giacom using the Personal Data for a particular purpose
If processing of your Personal Data is subject to any other laws then the basis of processing your data may be different to that set out above and may in those circumstances be based on your consent in all cases.
How we use the Personal Data we collect
Giacom will use Personal Data to fulfil our contractual obligations under the Reseller Agreement or Customer Agreement and associated Service Specific Terms (SSTs). For example, we will process Personal Data such as, name, address, email address, payment details for the purpose of:
- answering any enquiry you raise;
- enabling you to register to use the services available on the website;
- billing you for the services you consume;
- delivering and supporting the services to which you subscribe, including notification of service status updates;
- administering your customer account, and to support other general business activities;
- validating our licence returns to 3rd party vendors;
As a provider of cloud services, via the Giacom Cloud Market, we have a legitimate interest to process Personal Data to improve the services we offer and carry out our business. For example, we will process Personal Data such as, name, address, email address, IP address, browsing history, page visits, length of visit for the purpose of:
- answering any enquiry you raise;
- sending you marketing communications;
- administering and enhancing our website;
- improving your browsing experience by personalising the website;
There are instances Giacom is subject to a legal obligation and processes Personal Data to comply with those obligations. For example, we will process Personal Data such as, name, address, for the purpose of:
- satisfying legal or regulatory requirements, e.g. periodic returns to HMRC;
Alternatively, Giacom may collect and use Personal Data that you have consented to be processed for a specific purpose. For example, we will process Personal Data such as, name, address, for the purpose of:
- registering you as a potential candidate for employment with Giacom;
- providing your personal testimony regarding your experiences of dealing with Giacom
- answering questions to support the proposed or actual sale, merger or transfer of all or a portion of our business, and/or acquisition of another business;
If you opted to receive any communications from us, but subsequently change your mind, you may opt-out at any time via cloudmarket.com/opt-out or by writing to the Head of Compliance, Giacom World Networks Limited, Bridge Haven One, Saxon Way, Hessle, HU13 9PG or by using the email address HeadofCompliance@giacom.com.
While we will restrict the processing of your Personal Data in line with your request, we may add your Personal Data (name and address) to a ‘suppression list’ to ensure we do not send any communications in the future.
How long will we keep Personal Data
Giacom will keep your Personal Data only for a long as we need it for the purpose it is being processed for. For example, if you subscribe for services through the Giacom Cloud Market we will keep your Personal Data as long as you are an active subscriber to that service, and after that for a period which enables us to handle or respond to any complaints, queries or concerns relating to the service. We will also keep Personal Data as required to comply with any legal obligation.
We will actively review the Personal Data we hold and delete it securely, or in some cases anonymise it, when there is no legal, business or customer need to retain it.
We may disclose information about you to other organisations who provide specific business services to us.
Such organisations (listed below) are required to handle your Personal Data in accordance with applicable laws related to privacy and data protection. The processing of any Personal Data by the organisations will be explicitly defined within contractual terms.
Giacom Cloud Market Service providers – organisations who require your Personal Data in order to deliver the services to which you subscribe though the Giacom Cloud Market.
Direct Marketing companies - contracted to produce and distribute direct marketing material for which you have ‘opted-in’.
Financial Services organisations - used to support the financial processes that we perform. For example, these include credit checks against prospective customers, to ensure we are not exposed to unnecessary financial risk, and BACS to facilitate those customers paying via Direct Debit.
Payment Gateways – used to facilitate the payment for services. The organisation will only have access to the Personal Data you provide directly to them when you make a credit card payment. We will not collect or store credit card details.
Business Bureaus – used to check the accuracy of the Personal Data (name, address and contact details) for potential customers who have consented to us holding their Personal Data.
Recruitment Websites - used to facilitate the recruitment of new employees. The organisation will only have access to the Personal Data you provide directly to them when you complete their on-line forms. The organisation is a data controller for this Personal Data.
General Service providers – who provide specific, ad-hoc services to us. For example, Courier services, Hospitality services to help promote Giacom events.
Cloud Service Providers - who host bespoke business applications that allow us to improve the efficiency and effectiveness of our general business activities.
Auditors – used to validate our compliance with the Vendor’s contractual Terms and Conditions. For example, Personal Data (email address) may be used to confirm our licence management procedures are correct.
Transaction Manager / Prospective Purchasers – Personal Data may be used to validate the business performance, customer volumes declared by us as part of a sale, purchase or merger.
Other persons or organisations permitted or required by applicable law or regulation.
We also utilise Co-locators – who host components of our physical infrastructure within their own datacentre, but who do not have any access to the Personal Data held by Giacom.
International data transfer
Information which you provide may be transferred to countries which do not have data protection laws equivalent to those in force in the European Economic Area.
We will only transfer Personal Data when satisfactory safeguards are in place.
You have the right to:
- request confirmation whether we hold your Personal Data and, if so, to access that Personal Data.
We will inform you of: the purposes for which the Personal Data is processed; the categories of the Personal Data processed; whether your Personal Data has been disclosed and the categories of recipient of the disclosure; whether your Personal Data has been transferred to another country or international organisation; the expected period for which the Personal Data will be stored. If we did not obtain the Personal Data directly from you, we will also inform you of the source.
We may withhold such Personal Data to the extent permitted by law.
- request correction of the Personal Data we hold.
- request erasure of your Personal Data, subject to any legal obligation to which we are subject or where the processing of the Personal Data is for the establishment, exercise or defence of legal claims. We will accept your request for erasure where we have a legal obligation so to do, acceptance of such a request is otherwise at our discretion. Please be aware that the erasure of your Personal Data may affect our ability to provide the website and the services associated with it to you and in some cases our acceptance of an erasure request may require your account to be closed.
- restrict processing of your Personal Data where you contest the accuracy of the Personal Data we hold, consider our processing to be unlawful, consider that we no longer need the Personal Data but it is required by you in relation to a legal claim or where you have objected to our processing in accordance with your legal rights, provided in each case that we shall only be required to apply such restriction where we have a legal obligation to do so and until the issue giving rise to the restriction is resolved.
- withdraw any consent that you have previously given to our processing of your Personal Data.
- receive the Personal Data you have provided to us in a structured, commonly used and readable format, where the processing is carried out by automated means.
We may withhold such Personal Data if it adversely affects the rights and freedoms of others.
- object to the processing of your Personal Data, for example the use of your Personal Data for direct marketing purposes.
We will never knowingly collect Personal Information from minors (children under 16 years of age, or any other age defined under applicable law). If we become aware that a minor is attempting to or has submitted Personal Information via this Site, we will notify the user that we will not accept his or her Personal Information. We will then remove any such Personal Information from our records.
Please let us know if the Personal Data which we hold about you needs to be corrected or updated. Failure to inform us of a change to your Personal Data may result in the suspension, or withdrawal, of your subscribed services.
Third party websites
In the unlikely event that you have a complaint about our treatment of your Personal Data, it will be dealt with in accordance with our complaints handling procedure. You should contact the Head of Compliance, who will respond to you within 28 days.
If you are dissatisfied with this response you may request that your complaint be escalated, in which case it will be escalated to a member of the Giacom Executive Team who will review your complaint and the initial response and provide a further response within 28 days of your request to escalate the matter.
You may also raise a complaint to the Information Commissioner’s Office. Please see https://ico.org.uk/for-the-public/raising-concerns for more information.
The data controller responsible in respect of the information collected on this website is Giacom World Networks Ltd, Bridge Haven One, Saxon Way, Priory Park, Hessle, HU13 9PG